1. Privacy Policy

Scope

This “Privacy Policy on the promotion website for Symphogear XD UNLIMITED” (this “Policy”) provides for the handling of personal data on the “Symphogear XD UNLIMITED” official website(the “Website”) provided by [Pokelabo, Inc.] (the “Company”). With regard to matters that are not provided for in this Policy, please also review the “Basic Policy regarding the Protection of Personal Information.


2. Collection of Personal Data; Purpose of Use

List of information that will be collected

The Company may collect the following information from you in connection with the provision of the Website:

  • IP address
  • Cookie

The Company may collect the following information provided by you when making an inquiry via the form of the Website.

  • User ID
  • User Name
  • Email address
  • Inquiry

Purpose of use

The Company will use the collected information for the following purposes:

  • Providing the services of the Website
  • Measuring, studying, and analyzing the usage of the Website and the results of implementing various measures
  • Conducting marketing research and surveys
  • Introducing Company’s applications and other various services, promotions, campaigns, events, etc. operated by the Company or a third party
  • Providing information to the third parties (including joint users) set forth in “4. Provision to Third Parties; Information Collection Module”
  • Handling inquiries (including identity verification)

Legal basis

The legal basis for the processing of your personal data is;

  • Legitimate interests (to improve and enhance user experience such as informing our products, and to improve and enhance user experience such as answering inquiries from you)

3. Our Policy regarding Children

The Website is not intended for children under 13 years of age, and we do not knowingly collect or solicit personal data from anyone under the age of 13 or knowingly allow such persons to browse the Website. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number or e-mail address. No one under the age of 13 may provide any personal data. In the event that we learn that we have collected personal data from a child under the age of 13, we will delete that data. If you believe that we might have received data from or about a child under the age of 13, please contact us at “Customer Information Disclosure and Inquiry Desk” set forth in “5. Personal Information Inquiry Desk” of the “Basic Policy regarding the Protection of Personal Information”.


4. Provision to Third Parties; Information Collection Module

Provision to third parties

In the cases set forth in “4. Provision to Third Parties” of the “Basic Policy regarding the Protection of Personal Information”, the Company may disclose personal data to third parties inside and outside the country.

Information collection module

The Website contains the following information collection modules provided by the following third parties for purposes such as providing the features included in the Website and analyzing usage. With regard to the purpose of use of the information that will be collected or has been collected through such information collection module, please review the privacy policy that has been provided by each company providing an information collection module:

Disclosure to third parties outside of the country

When you agree to this Policy, you acknowledge that the collected data set forth in this Policy may be transferred outside of your country or region and that there may be cases where the country or region to which the data is transferred does not have laws or regulations imposing protection obligations that are equal to or greater than the laws and regulations regarding personal data and other privacy protection in your country or region. You agree that the Company will disclose the collected data set forth in this Policy to its parent company, GREE, Inc., and its affiliates as well as its approved subcontractors, media, and/or ad agents located in Japan, or the country other than member states of EEA where the approved subcontractor, media or ad agents establish its hub for the purpose of use set forth in this Policy.


5. Method of Notices, Announcements, or Obtaining Consent; Method of User Involvement

Notices and announcements

This Policy is posted and announced on the Website. The Company may amend this Policy, and any important changes will be announced on the Website. The amended Policy will become effective when it is posted on the Website


6. Request for Disclosure, Etc.; Inquiries

Request for access, rectification, erasure, restriction of processing, object to processing, data portability, etc.

You have the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. With regard to such requests, please review the Company’s “Basic Policy regarding the Protection of Personal Information.
You have the right to lodge a complaint with a supervisory authority which governs your habitual residence with respect to processing of your personal data.

Inquiries

If you wish to make an inquiry, to discuss, or to file a complaint with regard to the handling of personal data in connection with the Website, please contact us after reviewing the Company’s “Basic Policy regarding the Protection of Personal Information.

Data Protection Officers (DPO)

Company elected the data protection officer is involved, properly and in a timely manner,
in all issues which relate to the protection of personal data.
Post: Data Protection Officer
GREE, Inc.
Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku,
Tokyo, Japan
dpo@gree.net

Controller of your personal data and its contacts

Pokelabo, Inc.
Roppongi Hills Tower, 6-10-1 Roppongi Minato-ku,
Tokyo, Japan
info.appli@pokelabo.co.jp

7. Administration Policy

Amendment of this Privacy Policy

The terms of this Privacy Policy may be revised or amended. Unless otherwise specified by the Company, the revised or amended Privacy Policy will come into effect when it is posted on this website.

Retention Policy

Except as the case being necessary for the compliance of applicable law, regulation or order by the government, court, or other applicable authority, the personal data will be deleted after five (5) years since the “Symphogear XD UNLIMITED” application ceases to distribute.

Others

Please note that if you do not provide Company with the latest and accurate information of yourself, you may not receive appropriate service.


8. Terms for Specific Countries

If you reside in any of the places listed below, the relevant terms shall apply;

  1. United States

This Privacy Notice Section 1 (“California Privacy Notice”) supplements and modifies the “Basic Policy regarding the Protection of Personal Information” and the “Privacy Policy” of [Pokelabo, Inc.] (the “Company”) and applies solely to the user who resides in United States of America ("consumers" or "you").

  1. 1. Your personal information the Company collects
    • IP address
    • Cookie
    • The Company may collect the following information provided by you when making an inquiry via the form of the Website.

    • User ID
    • User Name
    • Email address
    • Inquiry
  1. 2. How the Company collects your personal information
  2. Directly from you: For example, inquiries you make about this Website

    Automatically or indirectly from you: For example, by automatically
    collecting information or observing when you access the Website.

  1. 3. The purpose to collect and sale sell your personal information
  2. (1) The purpose to collect your personal information

    • Providing the services of the Website
    • Measuring, studying, and analyzing the usage of the Website and the results of implementing various measures
    • Conducting marketing research and surveys
    • Introducing Company’s applications and other various services, promotions, campaigns, events, etc. operated by the Company or a third party
    • Providing information to the third parties (including joint users) set forth in “4. Provision to Third Parties; Information Collection Module”

    (2) The purpose to sell your personal information

    • Measuring, studying, and analyzing the usage of the Website and the results of implementing various measures
  1. 4. Sharing or sales of your personal information
  2. (1) The third-party service provider to provide the service contemplated under the purpose to use your personal information as follows

    Not applicable

    (2) Company may sell sales your personal information subject to your right to opt-out to those sales

    • Google, LLC. (Measuring, studying, and analyzing the usage of the Website and the results of implementing various measures)
  1. 5. Your Rights and Choice
  2. (1) You have the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. With regard to such requests, please review the Company’s “Basic Policy regarding the Protection of Personal Information.

    (2) Personal Information Sales Opt Out

      DO NOT SELL MY PERSONAL INFORMATIONIF YOU WANTTHECOMPANY NOT TO SELL YOUR PERSONAL INFROMATION, PLEASE FOLLOW THE INSTRUCTION AS FOLLOWS

      • To opt out the sale of your personal information to Google, LLC.
      • Please follow the instruction as specified in the Google Analitics Opt Out Add-on page operated by Google, Inc. You can access this page from here.

      Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, Company will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include personal information, if necessary to verify your identity and the nature of your request.


Established on December 1, 2019