1. Collected personal data and means of collection
For the purposes of the Policy, “personal data” refers to information collected by the Company in accordance with the Policy, and consists of information relevant to user recognition, activity records regarding telecommunication services, and other information created or stored on users’ devices, such as smartphones, related to users or users’ devices. Personal data collected by the Company through the Services include the following, listed by means of collection.
① Information provided by users
The following information is provided by users imputing the information.
● Email addresses
● Other information entered by users on data forms
② Information collected automatically by the Company
The company may collect information regarding user access of the Services. Such information includes the following.
● Advertising ID (※1)
● IP addresses
● Information regarding conversions, views, and clicks
● Information regarding user agents (※2)
● Referrer information (※3)
(※1) Consists of a string of characters generated by a smart device’s OS, including the IDFA (Identification for Advertisers) for Apple iOS or the Advertising ID issued by Google’s Android OS, and will be used for targeted advertisements which match user interests and preferences.
(※2) Refers to the OS, browser, etc. used by a smart device. Version and other information will be collected.
(※3) Refers to the website URL viewed immediately prior to viewing the target website.
2. Purpose of use of personal data
① Purpose of use of information provided by users
・ Responding to inquiries and concerns regarding the Services
② Purpose of use of information automatically collected by the Company
(1) Creation of statistical data related to the Company’s services that have been anonymized to prevent identification of individual users
(2) Distribution and display of the Company’s or third parties’ advertisements, including targeted advertisements (appropriate advertisements selected and distributed based on user interests or affiliations).
(3) Measurement and analysis of effectiveness of distributed advertisements
(4) Other uses for marketing purposes
3. Means of notification, publication, and gaining consent; means of requesting cessation of use
Users may request cessation of use for the entirety or a part of their personal data via the Services’ specified settings, in which case the Company will swiftly cease such use in accordance with the Company’s regulations. However, because the collection and use of some personal data is a prerequisite for the Services, depending on the kind of personal data in question, the Company may only cease collection of such data in the event that the user unsubscribes from the Services by the means established by the Company.
4. Sharing of personal data with third parties
The Company does not share personal data provided by users with third parties except in the following cases, or in cases where such sharing is permitted by laws and regulations governing personal data.
(1) In the case that user consent was obtained for sharing data with third parties
(2) In the case of outsourcing under the supervision of the company after an appropriate contract (a non-disclosure agreement with the company) has been signed with the subcontracting entity, in order to fulfill a purpose of use.
(3) In the case that personal data is shared due to company mergers, splits, business transfers, etc.
(4) In the case that it is required for the protection of a person’s (including corporations) life, physical wellbeing or property
(5) In the case that it is especially required for the promotion of public health or the healthy development of children
(6) In the case that revealing information is necessary due to laws, regulations, and legal procedures, or due to a request by a government agency or public institution
5. Information collection module (※4)
(1) adjust Inc. (adjust SDK)
① Types of collected information: advertiser_id (iOS: IDFA, Android: Advertising ID),
app_version, uuid, IP addresses, and user agents
② Purpose of use: to distribute advertisements and verify the efficacy of distributed advertisements, and to manage usage of the Services
③ Sharing with third parties: yes (party has signed a non-disclosure agreement)
(※4) The information collection module is a program produced by a third party not affiliated with the primary application and which analyzes usage of the application to assist improvement of the services’ features and the distribution of appropriate advertisements.
6. Means of stopping the information collection module
In the event that the user wishes to stop the information collection module, the user can stop the automatic collection of personal data and disable the targeted advertisement services by changing the settings on the user’s own device.
(1) Advertising ID
Please follow the instructions provided by Apple Inc. and Google LLC to change the relevant settings.
●IDFA (Apple Inc.)
In the event that you do not wish to receive advertisements based on your interests and preferences in the App Store or Apple News:
●Google Advertising ID (Google LLC):
Opt-out method （https://www.applovin.com/optout）
Opt-out method （https://vungle.com/gdpr-faq/）
Opt-out method （https://unity3d.com/jp/legal/privacy-policy）
・ironSource Mobile Ltd.
Opt-out method （https://developers.ironsrc.com/ironsource-mobile/air/publisher-terms-conditions/）
7. Shared use
The Company does not conduct shared use of user personal data.
8. Disclosure of personal data
The Company shall prompty disclose personal data to the user based on laws and ordinances regarding personal data upon receiving a request for disclosure from the user after it has confirmed that the request has been submitted by the user. The Company shall notify the user if the pertinent personal data does not exist. However, this may not be applicable if the Company bears no legal duty to disclosure based on laws and ordinances regarding personal data and other laws and ordinances.
9. Revision and suspension of use for personal data
① After confirming the identity of the user, the Company shall prompty conduct necessary investigations in the case that a user requests revisions to personal data based on laws and ordinances regarding personal data for the reason that the personal data is inaccurate, or in the case that a user requests the Company to suspend its use of personal data based on laws and ordinances regarding personal data for the reason that the data was handled in a manner which exceeded the boundaries of the publically stated purpose of use, or that the data was collected in an improper manner, including using fabrications. Based on the results of this investigation, the Company shall revise or suspend the use of the user’s personal data and notify the user of this action. The Company shall also notify a user if it determines not to revise or suspend use of data for logical reasons.
② In the case that a user requests that the Company delete the user’s personal data, the Company shall delete the personal data and notify the user of this action after confirming the identity of the user and determining the necessity of responding to this request.
③ The provisions in ② above are not appicable if the Company does not bear a legal duty to revise or suspend the use of personal data based on laws and ordinances regarding personal data.
10. Deletion of personal data
The Company shall delete pertinent personal data three years after the last day a user accesses the Services.
11. Regarding data of users 13 years of age or younger
In principle, the services of the Company do not target users 13 years of age or younger. The Company does not intentionally collect data which can identify specific individuals from these users. If by some circumstances the Company does acquire data which does identify a specific individual 13 years of age or younger without permission from a guardian, the Company will take appropriate measures to promptly delete such data from its records.
Upon receiving personal data from users, the Company ensures the security of such data by using encryption through SSL (security socket layer) encryption technology or similar security technology in order to prevent improper access by third parties during the data transmission process. In order to secure the personal data of users, the Company shall set up firewalls, utilize anti-virus programs, and take other reasonable security measures in order to prevent the leaking, misappropriation, and falsification of personal data by improper access from third parties.
Please send all opinions, questions, complaints, and inquires regarding the handling of personal data to the e-mail address below.
The Company reviewing the operational status of handling personal data as appropriate and may change the Policy as necessary as it continues to strive for improvement. Upon changing the Policy, the Company shall notify users by displaying the information on sites which provide the applications which provide the Services, or in the application of the Services. However, the Company shall request user approval according to laws and ordinances in the case that changes to the Policy require user approval based on laws and ordinances.
Enactment date: May 25, 2018
The Company shall delete pertinent personal data ten years after the day it acquires user personal data.