This is an English translation of the Japanese original. If the two differ, the Japanese version prevails.

Privacy Policy

Effective: November 12, 2026

KUDs ("we") sets out below how we handle information about the players ("you") of the game Pechi Pechi Penguin (the web, iOS and Android versions; the "Service"). The Service is provided for people in Japan. The English text is for people in Japan who use English.

1. Our approach

• We do not ask for your legal name, postal address or phone number in order to play. We do handle email addresses, names and the like in these cases:
  • When you buy on the web version: you enter your email address, card details and the like on Stripe's screen. Card numbers do not reach us. Your email address is included in Stripe's purchase notice and passes through our server, but we do not read or store it there. We can see the email address and what was bought in Stripe's dashboard. We pass Stripe a reference number for each purchase and the item's number (not your temporary ID)
  • When you sign in with Apple or Google: the sign-in result may include your name or email address, but we only verify it and do not store them (2.5)
  • When you contact us: we receive your email address, what you write, and any pictures you attach (2.10)
• When you communicate with the Service, your IP address reaches our server (2.11).
• If you have never used the online features and you play against the computer or as two players on one device, the contents of your matches are not sent to our server. However, if you answered "Send" to play counts (2.6), those counts are sent, including solo play. On the web version, opening the pages involves communication and web analytics (2.7, 2.11).
• Once you have used an online feature, the game communicates with our server even when you play alone, such as on the title screen (daily rewards, balances, rewards for stars, showing friends who is online; 2.8).
• We do not use the information we collect for advertising or tracking (following you across other companies' apps or websites). The ads we plan to add in a future app update will be shown by Google's AdMob; the information Google collects from your device for them is described in 2.9.

2. Information we collect

2.1 When you use the online features

From match records and temporary IDs, we work out totals such as the share of people who played again the next day or 7 days later, and use them to improve the Service. We do not look at how any one person plays. Everyone who has played an online match is included in these numbers, whatever they answered about "play counts".

2.2 Friends

We record your friend number (9 digits), your relationships with friends (friends, requests, blocks) and their dates, whether you accept invitations from friends, when you last opened the game, and the character you used in your last match. Your friends see your name, whether you are online or in a match, the day you last played, your trophies and band for the current season, and the character you used last. Whether you are online is held by the server only while the game is open, and is not stored.

2.3 Ghosts

We use the name, character, costume, level, match level and trophies of players who played recently as the look of opponents ("ghosts") for other players who could not find an opponent. The computer plays them, and they are shown as ghosts. You can opt out with "Lend my look to ghosts" in the game's Settings, and the copy is then deleted. We do not use the look of players who last played more than 14 days ago.

2.4 In-game currency, items and purchases

• Coins, gems (paid and free, kept separately), items, character levels, match level, chests, season pass progress, missions, and the history of their changes (when, what was gained and what was spent)
• When you buy something: the purchase record (item, amount, date and time, and the store's or Stripe's transaction number)
• The first time you make a purchase, or the first time you watch an ad while your age is unknown: your year and month of birth (for the monthly spending limits for minors and the handling of players under 13 in section 7; we do not ask for the day)
• Payment details such as credit card numbers are handled by Apple, Google and Stripe; we do not receive them
• When you buy on the web version: you enter your email address, card details and the like on Stripe's screen. Our server does not receive or store them. We can see the email address and what was bought in Stripe's dashboard. We pass Stripe a reference number for each purchase and the item's number (not your temporary ID)
• When you buy in the apps: we pass your temporary ID to RevenueCat, and purchase records are verified through RevenueCat

2.5 Sign-in (only if you sign in with Apple or Google)

We store the sign-in type (Apple or Google), your user number with that provider, which app or website you signed in from, and when you linked the sign-in. For Apple, we store an encrypted refresh token solely to revoke the link with Apple when you delete your account. When you sign in, we pass Apple or Google a verification string that guards against impersonation; it does not contain your temporary ID (it contains a form that cannot be turned back into it). We do not store your email address, name or photo even if the sign-in result includes them. We do not receive your password.

2.6 Play counts (only if you agree)

We ask when you first play. Only if you answer "Send" do we send counts such as the mode, stage, wins and losses, match length and whether "Play again" was pressed, including solo play, in a form that cannot tell whose they are (no ID or time is attached), and store them as daily totals. You can change your answer in Settings at any time; choosing "Don't send" also discards the counts not yet sent.

2.7 Web analytics

On the web version, Cloudflare Web Analytics counts page views, where visitors came from, country, device and browser type, and loading speed. It does not use cookies or IDs that identify devices. It is not in the apps.

2.8 Information on your device, and communication when you play alone

The play log (scores and speeds of each match) and settings (sound, language) stay only on your device and are not sent. The key of your temporary ID is stored on your device and used to confirm that it is you in online communication.

The stars of stage challenges stay on your device. Once you have used an online feature, the challenge's number is sent to our server for the reward when you earn a star and when the title screen appears. The title screen also communicates for daily rewards, balances and showing friends who is online.

2.9 Ads in the apps (planned for a future update)

We plan to add rewarded ads in a future app update. The apps and the web version have no ads now. Once they are added, Google LLC's AdMob shows ads in the apps only when you choose to watch one (for rewards such as opening a chest sooner, up to 3 times a day). We will not add ads to the web version. Holders of the Season Pass Deluxe get the same rewards without watching. Players under 13 (section 7) are not shown the button to watch ads. The rest of this section describes how things will work once ads are added. We will review this policy and let you know before adding ads (section 9).

• To show ads, the AdMob SDK sends the following information from your device to Google, which uses it to show ads and measure their effectiveness, for analytics, and to prevent fraud (under Google's privacy policy).
  • Android: IP address, device and account identifiers (the Android advertising ID and app set ID), in-app interactions (such as opening an ad or watching a video), and information about how the app and the SDK perform
  • iOS: device identifiers (per-app or per-developer identifiers), advertising data such as the ads seen, approximate location inferred from the IP address, in-app interactions, app performance information, and crash logs
• On iOS we do not ask for permission to track you across other companies' apps and websites (App Tracking Transparency), so your iOS advertising identifier (IDFA) is not sent to Google. On iOS we also show only non-personalized ads, never ads chosen from your past behavior. Even so, Google may use device identifiers (per-app or per-developer identifiers) for frequency capping and aggregated ad reporting.
• On Android you can reset or delete your advertising ID in the device settings.
• To give rewards, we pass your temporary ID and the reward type to AdMob when an ad is loaded, and our server receives a notice from AdMob when you finish watching. Our server records the daily count and the transaction number of that notice.

2.10 Inquiries

When you contact us by email, we receive your email address, what you write, and any pictures you attach (such as screenshots of the game). We use them only to answer you and to check deletion requests (section 6). When we refund by bank transfer (Article 12 of the Terms; App Store purchases and the like), we receive your account details (bank, branch, account type and number, and name) and use them only for the transfer.

2.11 Information in communication (IP address and the like)

When you communicate with the Service, your IP address reaches our server through our network provider (Cloudflare). Our server uses it only in memory, for short-term rate limits, and does not store it (it disappears after about 2 minutes without use). The country determined from your connection is stored as described in 2.1. The continent is used only while looking for an opponent, and is not stored.

The server's operating logs may contain match numbers and, when processing purchases, temporary IDs. Cloudflare may keep communication records to provide its service and for security (under Cloudflare's policies).

2.12 The review prompt (apps)

In the apps, a screen asking for a review may appear, for example after you win a match (not for players we know are under 13). That screen belongs to Apple and Google. Each store receives your rating and text, and they do not come directly to us. Like anyone else, we can read reviews once they are public. How each store handles them follows Apple's and Google's policies.

3. How we use information

1. Matching online opponents, running matches, trophies and rankings
2. Replays, spectating, friends and ghosts
3. Managing in-game currency and items, verifying purchases, the monthly spending limits for minors and the handling of players under 13, and handling refunds
4. Managing paid gem balances and accounting under Japan's Payment Services Act
5. Detecting and preventing cheating
6. Answering inquiries, and refunds by bank transfer
7. Improving the Service (play counts and web analytics are used only as numbers that cannot tell whose they are; from match records and temporary IDs, we work out totals such as the share of people who played again (2.1); from purchase records, we work out totals such as sales)
8. Showing ads in the apps when you choose to watch one, and giving the rewards (once ads are added; 2.9)

4. Service providers and third parties

We do not give your information to third parties except as required by law or as needed to use the following companies' services.

• As the table shows, much of the information is entrusted to companies abroad. For information on other countries' systems for protecting personal information, see the website of Japan's Personal Information Protection Commission (in Japanese). In the register of an international framework (APEC's CBPR), we have confirmed Stripe, LLC and Cloudflare, Inc. (we have not confirmed that their certification covers this Service's information). Apple Inc. is listed, but we could not confirm its renewal. We could not confirm Google or RevenueCat in the register. We have not checked the register for Anthropic.
• If you want to know about the measures each company takes, contact us. We will tell you what we know.
• Information sent directly from your device is described in section 11.

5. How long we keep information

• Inputs of ranked and ghost matches: 30 days. Shared replays: 90 days. Top matches that were re-checked, and ghost matches you won: 180 days
• Match results and changes in trophies: kept with no set end (if you delete your account, they are kept with the link to your temporary ID removed)
• Transfer codes: stop working after 24 hours, and are deleted by the daily processing after that
• Inquiry emails: deleted one year after we finish handling them. What you send for a deletion request is deleted after we reply. Account details for a refund by bank transfer are deleted after the transfer, except as needed by law and for accounting
• The server's restore copies: up to 30 days
• Purchase records: 7 years (section 6 describes what happens after you delete your account)
• Records held by outside companies: under each company's policies
• Other information: until you delete your account

6. Deletion, disclosure and other requests

• You can delete your data at any time in the game under Settings → Account → "Delete account" ("Delete my records" if you are not signed in). We ask you to confirm twice before deleting.
• Deletion removes your sign-in, trophies, in-game currency and items and the history of their changes, character levels, chests, season pass and mission progress, year and month of birth, gacha history, friendships and friend number, transfer codes, cheat-check records, the copy of your look for ghosts, and recent ghost records in the matchmaking system (if those cannot be removed, they disappear within 30 days). We also revoke the link with Apple (if that fails we try again, but it may not succeed).
• The following remain after deletion:
  • Purchase records (item, amount, date and time, season, store, refund date and time, transaction number). The link to your temporary ID is removed, but the transaction number stays, so comparing it with the records held by Stripe, Apple or Google shows which purchase it was (Stripe is not given your temporary ID)
  • Results of matches with other players (place, team, changes in trophies, date and time), with your temporary ID removed
  • Match inputs and shared replays (until the end of the periods in section 5). Replays keep your name (the combination of words) and trophies
  • Your temporary ID and a mark that it was deleted (when it was created, last seen and deleted, and the version of its key), used to keep the records from coming back
  • Records of deletion requests (the number showing which records they were is emptied after deleting)
• We ask RevenueCat to delete its records of you when you delete (they are removed on RevenueCat's side in due course; if that fails we try again, but it may not succeed).
• Payment and purchase records held by Stripe, Apple and Google are not removed by deleting in the Service. If you want Stripe's records deleted, contact us and we will explain the procedure.
• Our server cannot revoke the link with Google sign-in. You can remove it yourself in your Google Account settings.
• For requests for disclosure, correction, suspension of use and the like, contact us at the address below. A temporary ID alone makes it hard to confirm who you are, so we check your friend number and things only you can know (examples are on the Deleting your account and records page). We do not ask for ID documents.
• If you cannot open the game, see Deleting your account and records for how to ask us to delete your data.

7. Children

The Service is intended for people aged 13 and over (the store age rating is 13+). We do not ask for your legal name or email address in order to play, and there is no chat. Names are only combinations of words provided by the Service. Minors have monthly spending limits.

If the year and month of birth we ask for at your first purchase (or the first time you watch an ad) show that you are under 13, we handle it as follows.

• You cannot make purchases (you can from the month after the month you turn 13; your year and month of birth are stored, as for other players)
• You are not shown the button to watch ads (no ads are shown)
• You are not shown the review prompt
• Play counts (2.6) are not sent (the counts not yet sent are discarded). Players who have played an online match are still included in totals such as the share of people who played again (2.1)
• Online matches and friends work as usual (there is no feature for entering or showing free text)
• Parents can ask us to delete the records by contacting us (they can also be deleted in the game under Settings → Account)

8. Security

Communications are encrypted. Sign-in refresh tokens are stored encrypted. Only hashes of transfer codes are stored. On our side, only the operator, and the AI tool the operator uses to investigate faults and cheating (Anthropic in section 4), can access the information. The AI tool reads only what is needed, and counts or states alone when they are enough.

We use the services of companies abroad. The countries are as follows. For those countries' systems for protecting personal information, see the materials on the website of Japan's Personal Information Protection Commission (in Japanese).

• Countries of the companies: USA (Cloudflare, Apple, Google, RevenueCat, Stripe, Anthropic), Ireland (Stripe, Google's group companies), Singapore (Google's group companies)
• Countries of the servers: RevenueCat is in the USA. Stripe's policy names the USA and India. The countries of Cloudflare's servers (this Service's servers and database) cannot be identified, because the service runs at locations around the world and cannot be restricted to Japan. We specify the Asia-Pacific region for the database. The candidates are countries in Asia-Pacific, and the USA and the countries of the European Economic Area, which Cloudflare's policy names as the main places of storage. Apple and Google may handle information around the world under their policies, so the countries cannot be identified; the candidates include the USA. We could not confirm Anthropic's countries from its official guidance; the candidates include the USA.

9. Changes to this policy

We will announce changes in the Service or on our website.

10. Contact

• Operator: KUDs (run by an individual; the name and address will be disclosed without delay on request)
• Email: contact@kuds.jp

11. Information sent outside

Under the external transmission rules of Japan's Telecommunications Business Act, we publish below the information sent from your device to companies other than us. It is sent directly from your device, not through our server.

The apps and the web version have no ads now. Once a future update adds ads, the information in 2.9 is sent to AdMob (Google LLC). We will update this table and let you know before then.