Privacy Policy

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Last Updated [28 January, 2013]

As used in this Privacy Policy, “DeNA”, “we”, “us”, or “our” refer to DeNA Co., Ltd. This Privacy Policy forms a part of the Terms of Use (“Terms”) of the Services, which is available for your review. By accessing the Services, you agree to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you must not access the Services. Capitalized terms used but not defined in this Privacy Policy shall have the meanings ascribed thereto in the Terms.

We believe that you are entitled to notice, choice, access, and security when it comes to your information. This Privacy Policy describes the collection, use and sharing of the information you provide to us in connection with the Services. If you have any questions about this Privacy Policy, please contact us at [email protected].

1.Collection of Information

In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information means personal information such as a full name that either alone or in combination with other information, identifies, relates to, describes, or is capable of being associated with, a particular individual. Non-personal information is information that does not permit direct association with you or any specific individual, as well as publicly available information that is lawfully made available to the general public from government records.

2. Children Under the Age of 13 in the U.S.A.

If you are accessing the Services in the U.S.A., the Services are offered and made available only to users 13 years of age or older. In addition, certain Services may be subject to heightened age and/or other eligibility requirements. Therefore, if you are not yet 13 years old in the U.S.A. (“children”), please discontinue using the Services immediately. By using or attempting to use the Services in the U.S.A., you certify that you are at least 13 years of age. We do not knowingly collect or store Personal information from children. Upon notice or discovery of information collected from a child without our knowledge, we take all reasonable efforts to erase or destroy any such personal information.

3. Your California Privacy Rights

California law permits those of our customers who are California residents the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at [email protected].

4. Information We Collect and Use

4.1
In connection with your registration as a user of our Services and with your permission, we collect your real name, phone number (including country code), date of birth and, as described below, information regarding the contacts within your mobile device (“Device”). We may collect information when you create your personal profile or otherwise communicate requests, suggestions, or other communications. The information that you provide will be used for the purposes set forth below.
4.2
In order to connect you with the contacts in your Device’s address book, we will ask for your permission to collect your contacts’ real names, phone numbers and email addresses solely for purposes of your use of the Services. Your contacts’ information will be stored in connection with your Comm Account.
4.3
In accessing or using the Services, information sent from your Device is recorded through server log files and tracking technologies such as cookies (see the section entitled Use of Cookies and Other Tracking Technologies, below). This information includes device model type, time and date stamp, operating system and its version, and may also include information regarding mobile carrier, unique device identifier, language, network status, time zone, time spent, clickstream data, IP address, and other statistics on your use of the Services; in some cases a unique identification number may be generated and matched with your Device.
4.4
Our primary objective in collecting your information is to provide you with a superior and personally relevant user experience.

To achieve this objective your personal information may be used as follows:

(a) show which of your contacts (as it appears in your address book) use and are using the Services to recommend them as potential contact in the Service;
(b) notify you when your contacts register to use the Services;
(c) authentication purposes;
(d) create, update, and maintain lists of friends or contacts;
(e) carry over your existing Comm Account to different Device;
(f) messaging, exchange data and communicate with other Comm Users;
(g) investigate and resolve problems with the Services;
(h) respond efficiently to your inquiries;
(i) provide Services and Services-related content;
(j) recommend products and services of interests directly to you;
(k) provide advertisements, marketing and sales information;
(l) invoice fees, calculate charges and provide payment services;
(m) provide after-sales service and respond to inquiries and complaints;
(n) develop new features and functions to enhance the Services;
(o) provide system maintenance and handle system malfunctions;
(p) provide Service-related announcements, newsletters and/or other communications;
(r) to request that you participate in marketing surveys;
(s) statistical analyses;
(t) carry out contests and campaigns (which may be subject to additional terms and conditions); and
(u) provide affiliate and loyalty programs.

We may collect, use, transfer, and disclose non-personal information for any purpose.
4.6
For location-based services, we may collect, use, and share precise location data, including the real-time geographic location of your Device. Unless you explicitly opt-in to permit the use and sharing of your personal information regarding your geographic location, your location data will only be collected and used anonymously in a form that does not personally identify you.

5. Persons with Whom We May Share Your Information

5.1
We may use our authorized agents or third party service providers (“service providers”) to perform functions on our behalf for the purpose of administering and maintaining the Services, including payment functions, social networking services, content, features, functions, and other operations of the Services. Our service providers may have access to your personal information only to perform these tasks on our behalf in connection with the Services and are obligated not to disclose or use your personal information for any other purpose.
5.2
We may also offer you services that allow you to link your Comm Account to a social networking service (“SNS”) such as Facebook. In these instances, we will request your permission to allow DeNA access to and use of your SNS ID number, access token, your real name, pictures and other information you have independently provided to and made accessible through such SNS. Such access will be in accordance with the privacy settings you have set in your SNS account, if any.
5.3
We may need to make your personal information available to third parties in the following limited circumstances: (a) disclose information about you to law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process (including subpoenas), (b) to protect the property and rights of DeNA or a third party, (c) to protect the safety of the public or any person, or (d) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity, (e) If, in our sole discretion, we believe such disclosure to be necessary or appropriate in connection with the Services to investigate or resolve possible problems, or (f)In the event of a bankruptcy, merger, acquisition, transfer of control, joint venture or other business combination involving us, or our subsidiaries, or affiliates.
5.4
We may further provide anonymous and non-personal information to third parties for the purpose of customizing and targeting advertising messages, such as the number of times you visited an advertisement website through the Services, to better provide you with information regarding goods and services that may be of interest to you.

6. Privacy of Your Submissions.

6.1
We respect the privacy of the contents of any information related to or contained in a Submission, We do not monitor, endorse, edit or screen any Submissions, although we reserve the right only when necessary, to monitor, edit, and/or otherwise use such content in compliance with applicable law or to protect and defend our rights and interests, or the rights and interests of Comm Users, and other third parties in connection with the Services. With regards to the contents of emails, text message, chats, calls and other such non-public mediums, such right to monitor, edit or otherwise use will be limited to instances only where required by applicable law.
6.2
Information contained in your personal profile is automatically made public.
6.3
Other than as required by applicable law, we are not responsible for the accuracy, use, or misuse of any information that you publicly disclose or share with or receive from other Comm Users and third parties through the Services and you should assume that any such disclosure you make in the Services may be made publicly available by such receiving parties, even without your knowledge or authorization. Please see the Terms for additional details regarding Submissions.

7.Use of Cookies and Other Tracking Technologies

7.1
We may gather certain information through use of “cookies” and other such features, which may be downloaded to your Device (“Cookies”). These tools allow us to store data about your use of the Services, including the collection of identifiers associated with the Device you use to access the Services. We may use Cookies to store your user preferences, authenticate user sessions, and determine whether you have installed the software necessary to access certain material or applications. BY ACCESSING THE SERVICES, YOU ARE CONSENTING TO THE USE OF COOKIES ON YOUR DEVICE. 7.2
If you choose to access third party websites or services through the Services, such as advertisements, such third party may download Cookies onto your Device to measure the effectiveness of their ads or personalize advertising content. We have no control over these third party Cookies. This Privacy Policy covers our use of Cookies only, and does not cover the use of Cookies by third parties.

8. Choice as to How Your Information is Used

Except as otherwise permitted or required by applicable law, DeNA will obtain your permission before using personal information collected in a way that is inconsistent with this Privacy Policy.

9. Push Notifications; Opt outs

9.1
We may send push and local notifications to your Device concerning updates, events, and special offers for the Services. Please note that you have the option of deactivating push or local notifications by changing the settings of the Services or your Device.
9.2
If you do not wish to receive emails or postal mailings on future offers or information about products, promotions or services, you will be able to opt out by sending such request to  [email protected].
9.3
The Services allows you to the option to link, or tag, photos to a particular Comm User. Such photos will appear in the profile section of the Comm User who has been tagged to such photos. You may not tag Comm Users to photos without first obtaining their consent. If you do not wish to be tagged in a photo, you may opt out of the tag option by changing the setting in your Comm Account.
9.4
Please note that opting out of or not providing personal information may prevent access to some or all features, functions or areas of the Services.

10.Security Measures

We take your privacy very seriously and employ commercially reasonable measures to safeguard personal information stored in our servers and databases against loss, theft, and unauthorized disclosure or use. Please be aware that no security measures are perfect, and we cannot control the actions of third parties or any persons with whom you choose to share information. We are therefore not responsible for circumvention of any security measures by third parties. Any information that you choose to within the Services, or that you transmit by other available channels, may be accessible to third parties. Any such disclosures are made at your own risk and DeNA disclaims all liability related thereto.

11.Links

As discussed more fully in the Terms, the Services may contain links to other third party services or websites, including Advertisers, and other unaffiliated sites. We are not responsible for information you choose to disclose to such third parties and the use of your information is subject to the privacy policies such third party services or websites. This Privacy Policy applies only to information collected through the Services.

12.Changes to Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that on our website and/or by email to any email address we may have for you at that time. Your continued access to or use of our Services after we have changed the Privacy Policy will indicate your agreement to the updated Privacy Policy.

13. Users Outside of Japan

If you are located anywhere outside of Japan, you recognize and agree that by accessing or using the Services, any personal information, including personal information, collected may be transferred to, and in any manner processed or stored in, any country or territory, including, but not limited to, Japan and/or the United States.

14. Update Your Personal Information

14.1
Generally, you may correct factual inaccuracies about your personal information collected by us. DeNA will promptly process requests to correct such personal information and may charge you an administration fee to do so (if permitted by applicable law). For any of the foregoing, please contact us at [email protected].
14.2
Please note that certain personal information collected as required by applicable law, such as for corporate and regulatory record-keeping requirements, will not be deleted upon the user’s request, unless it is in violation of the Terms or applicable law.

15.Contacting Us

If you have any questions, inquiries, requests or complaints concerning our Privacy Policy or information practices, please contact us at [email protected].
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