“Kakegurui xx Collaboration Special Original Merch Giveaway” Privacy Policy
1. Privacy Policy
i. Subject
"Kakegurui xx Collaboration Special Original Merch Giveaway" Privacy Policy ("the Policy") sets forth the handling of personal data for the Kakegurui xx Collaboration Special Original Merch Giveaway ("the Giveaway") being implemented by Pokelabo ("the Company"). For information not included in the Policy, please refer to the Company's PrivacyPolicy.
2. Purpose of acquisition and use of personal information
i. List of information to be acquired
The following information will be obtained for the implementation of the Giveaway.
● Personal data to be acquired from all participants:
- Social media account name、ID (Twitter, Facebook)
● Personal data to be acquired from winning individuals only:
- Full name
- Phone number
- Address
ii. Purpose of Use
The Company will use the information it has acquired for the following purposes:
● Management of the Giveaway
● Inquiries regarding the Giveaway
● Shipping prizes to winners
● Correction of violations of the Terms and Conditions
● Responding to inquiries
● 4. Provision to third parties listed in "Provision to third parties"
iii. Legal Basis for Handling
The legal basis for the handling of personal information is as follows:
● Your Consent
● Legitimate interests (improvement of the user experience through the Giveaway and shipping prizes to winners).
3. Children's Policy
The Giveaway is not intended for children under the age of 16 and does not knowingly collect or request personal data from children under the age of 16 or allow them to participate in the Giveaway. If you are under the age of 16, do not submit any information about yourself, such as your name, address, phone number, or email address. If you are under the age of 16, you are not allowed to provide personal information. If it is discovered that the personal information of a child under the age of 16 has been collected, all of their data will be deleted. If you believe that the Company may have received data from a child under the age of 16, please contact 6. Disclosure Requests, Inquiries v. Handling of Personal Information Contact Information.
4. Provision to third parties
i. Provision to third parties
Personal information may be disclosed to third parties in Japan and overseas as described in 5. Provision to Third Parties under the Company’s Privacy Policy.
ii. Disclosure to overseas third parties
In agreeing to this Policy, you acknowledge that the acquired information described in this Policy may be transferred outside of your country or region of residence and that there may be no laws or regulations that impose the same or greater obligation of protection than the personal information protection laws of your country or region of residence in the country or region of residence, and you agree that the Company will disclose the acquired information described in this Policy to its parent company, GREE, Inc. and its group companies, contractors, media, and advertising agencies in countries other than Japan and EEA member countries for the purposes of use described in this Policy.
5.Notification and Publication
ⅰ.Notification and Publication
The Policy is posted and published on the official SINoALICE homepage's notices section. The Company may make changes to the Policy. Any significant changes made will be notified and posted on the official SINoALICE homepage's notices section. The revised policy shall be effective from the time it is posted on the official SINoALICE homepage's notices section.
6. Disclosure Requests, Inquiries
i. Disclosure, correction, deletion, restriction on handling, objection to handling, data portability, etc.
In the event that a customer or his or her representative requests the disclosure, correction, deletion, suspension of use, access, restriction of processing, data portability, right to object, etc. of the customer's personal information, we will respond without delay to the extent possible under the law. For such requests, please contact 6. Disclosure Requests, Inquiries v. Handling of Personal Information Contact Information
In addition, you have the right to file a complaint with the supervisory authority having jurisdiction over your place of residence regarding the handling of your personal data.
ii. Inquiries
For inquiries, consultations, and complaints regarding the handling of personal information of the Giveaway please contact 6. Disclosure Requests, Inquiries v. Handling of Personal Information Contact Information.
iii. Data Protection Officers (DPO)
The Company has appointed data protection officers to be involved in all matters relating to the protection of personal data, as appropriate and in a timely manner.
Position: Data Protection Officer
GREE, Inc.
Roppongi Hills Gate Tower, 6-11-1Roppongi, Minato-ku,
Tokyo, Japan
dpo@gree.net
iv. EU Representative
The Company has appointed the following EU representative.
Post: Pokelabo, Inc. EU Representative
PLANET // LEGAL
Neuer Wall 54, 20354 Hamburg, Germany
eu_representative@planit.legal
v. Handling of Personal Information Contact Information
Pokelabo, Inc.
Roppongi Hills Gate Tower, 6-11-1Roppongi Minato-ku,
Tokyo, Japan
info.appli@pokelabo.co.jp
7. Operating Policy
i. Changes to the Policy
The contents of this policy are subject to revision and change. Unless otherwise specified by the Company, the revised or amended Policy shall take effect from the time it is posted on the official SINoALICE homepage's notices section.
ii. Data Retention Period
Except as necessary to comply with applicable laws, regulations, or orders from governments, courts, or other regulatory bodies, personal information will be deleted when it is no longer necessary to achieve the "Purpose of Use" above.
iii. Other
If you do not provide us with current and accurate information, you may not be able to receive proper service.
8.Terms for Specific Countries
If you reside in any of the places listed below, the relevant terms shall apply;
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 [PK, Inc.] (the “Company”) and applies solely to the user who resides in United States of America ("consumers" or "you").
i. Your personal information the Company collects
● Personal data to be acquired from all participants:
- Social media account name、ID (Twitter, Facebook)
● Personal data to be acquired from winning individuals only:
- Full name
- Phone number
- Address
ii. How the Company collects your personal information
Directly from you: For example, application for this Giveaway and communication with applicants.
iii. The purpose to collect and sell your personal information
(1) The purpose to collect your personal information
● Management of the Giveaway
● Inquiries regarding the Giveaway
● Shipping prizes to winners
● Correction of violations of the Terms and Conditions
● Responding to inquiries
● 4. Provision to third parties listed in "Provision to third parties"
(2) The purpose to sell your personal information
Not applicable
iv. Sharing or sales of your personal information
(1) The Company may disclose your personal information for a business purpose as follows. We may share your personal information with third parties.
● Management of the Giveaway
● Shipping prizes to winners
The third-party service provider to provide the service contemplated under the purpose to use your personal information as follows
● Tokyo Otaku Mode Inc. （Management of the Giveaway 、Shipping prizes to winners）
(2) Company may sell sales your personal information subject to your right to opt-out to those sales
Not applicable
v. Your Rights and Choice
(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, 6. Disclosure Requests, Inquiries v. Handling of Personal Information Contact Information.
(2) Personal Information Sales Opt Out
Not applicable
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.
Date of Enactment: April 26, 2022
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