Privacy Policy for EU Residents

STAR FACTORY, Inc. (hereinafter the “Company”) provides for the following privacy policy (this “Privacy Policy”) regarding the handling of User Information of users for every kind of service provided by the Company (hereinafter “Services”) and will take all possible measures to protect the information.

Article 1 Definition of User Information

1. User Information means information of users who use Services.

2. Personal Data means the User Information that concerns an identified or identifiable real person, including name, date of birth, telephone number, address, e-mail address, organization name, location, social network service account, IP address and cookie identifier.

Article 2 Consent to Privacy Policy

1. A user who manifests his/her consent to this Privacy Policy will be deemed to have consented to this Privacy Policy. The user may at any time withdraw his/her consent to this Privacy Policy. However, a user who withdraws his/her consent will be no longer able to use a service (or function) that requires the use of information that the Company has collected upon the consent of the user.

2. To use Services, a user under the age of 16 years needs to have his/her parental consent to the use of the Services or will consent to their use after having obtained the permission of his/her parent.

Article 3 Collection of User Information

The Company may collect the following User Information of users for Services. A user who does not provide the information may be unable to use all or part of the Services.

(1) Information collected directly from a user through the registration for Services, change to the registered items, or inquiry or communication of the user

- Name

- Email address

- Telephone number

- Login name

- Login password

- Information collected from inquiries to the customer support

- Feedback from the user, including reviews and complaints

(2) Information automatically collected through a user’s use of Services

- Position information

- Information on conditions of service use (e.g., information on action settings, the number of uploaded files, and screen orientation of the device at the occurrence of a crash)

- Date/time of access to Services

- Application and browser of the device used for viewing Services and pages viewed

(Including websites of third-party services that the user has used before using a Service)

- Information on the equipment used for accessing Services, the model of hardware, the equipment’s IP address, MAC address and other unique identifiers, OS (and its version), language selection, advertising identifier, serial number, information on the equipment’s action, and mobile network information

(3) Information collected through services operated by third parties

The Company may collect information of a user when the user permits the Company to collect his/her User Information through a service operated by a third party. In this case, the information collected from the user by the Company on its own may be matched with the information obtained from the third party to improve Services or provide advertising relevant to the interests of the user.

Article 4 Purposes of Using User Information

1. The Company will use collected User Information for the following purposes of utilization or to the extent necessary for the achievement of the purposes of utilization. Should it need to change a purpose of utilization, the Company will notify users or announce it.

(1) To process registration for Services, verify identity, and provide, maintain, protect and improve Services

(2) To check conditions of the use of Services (including cases of using services provided by any other business than the Company through Services)

(3) To provide information about contents of Services, updates, events/campaigns, changes to terms, etc.

(4) To provide information about a Service and respond to inquiries about it

(5) To deal with violation of the terms for Services and every kind of regulations of the Company

(6) To create statistical data about the use of Services

(7) To authenticate a user at the time of login or after login when using Services

(8) To analyze registered information and conditions of use to enhance for a user the convenience of content and advertising provided by a third party and viewed by the user using Services

(9) To grasp conditions of distribution of advertising, measure advertising effectiveness and display behavioral targeting advertising

(10) To provide part of the information (not including Personal Data) to an ad distributor with whom the Company cooperates (hereinafter simply an “Ad Distributor”)

(11) To plan and draw up plans for future Services and implement them

(12) To distribute or display advertising of the Company or a third party

(13) To send prizes and other goods to users who win them in a campaign, etc.

2. In addition to the purposes of utilization set forth in the preceding paragraph, the Company may set out a purpose of utilization peculiar to an individual Service. The Company will identify such purposes of utilization of an individual Service as much as possible, and will announce them in advance in the website or a service screen for the individual Service.

Article 5 Third Party Provision of Personal Data

1. Out of the User Information collected from a user, the Company may provide Personal Data to a third party, if:

(1) The user consents to it;

(2) The user violates terms of the Company, and there are sufficient grounds to believe that disclosure of the Personal Data is inevitable to protect rights, property or services of the Company;

(3) It is necessary for the protection of human life, body or property, and it is difficult to obtain the consent of the person concerned;

(4) It is necessary to cooperate with a national government organ, a local public body, or a person delegated thereby to perform any business provided for in laws and regulations, and by obtaining the consent of the user, the performance of the business is likely to be impeded;

(5) The business of the Company, including provision of Personal Data, is succeeded to, including due to a merger, company split and transfer of the business;

(6) Data are provided to a business alliance partner to provide services accommodating desires of the user, including payment processing, data analysis and customer service;

(7) Data are provided to a third party who provides functions and services on behalf of the Company, so that various functions and services will be provided through Services;

(8) Data are provided to an ad distributor to provide advertising relevant to the interests and concerns of the user; or

(9) It is permitted under laws and regulations.

2. The Company requires a third party to whom Personal Data are provided to comply with the EU General Data Protection Regulation (hereinafter “GDPR”) and relevant laws and regulations and handle User Information by paying attention to the privacy of users. For details of the handling of User Information at a third party to whom the information is provided, please inquire directly to the third party. Personal Data may need to be transferred to a country outside the EU. When executing the transfer, the Company will securely protect the transferred data at an adequate level.

Article 6 Joint Use of Personal Data

If in providing Services to users in the future, the Company requires another company to conduct operations (hereinafter the “Cooperating Company”), the Company may use Personal Data jointly with the Cooperating Company. In this case, prior to joint use, the Company will provide users with an announcement about the purpose of utilization, name of the Cooperating Company, types of the information, and name of the administrator.

Article 7 Entrustment of Personal Data

1. To the extent necessary for the achievement of the purposes of utilization, the Company may entrust all or part of the handling of Personal Data to an outsourcee. In this case, the Company will sufficiently examine the competence of the outsourcee as an operator of the outsourced business, and will, in making a contract, check relevant matters, including concerning confidentiality obligations and will develop a system for adequate management of the information.

2. The Company will use the following services and entrust the handling of Personal Data to the services:

List of services used

http://www.starfactory-inc.co.jp/legal/list.html#service-list

3. As the Company uses the services set forth in the preceding paragraph, Personal Data may be kept or processed in the following countries:

List of countries

http://www.starfactory-inc.co.jp/legal/list.html#service-country-list

Article 8 Deletion of User Information

1. While the Company may retain User Information during and after a period where a user and the Company have a contractual relationship, the Company will not keep it beyond necessity. When the purpose of collecting and processing User Information is attained, the Company will delete the User Information without delay.

2. The period during which the Company keeps User Information will vary depending on the type of the information and the purpose of processing.

Article 9 Records on Processing of User Information

When the Company processes User Information, the Company will handle records on the processing of information in compliance with the obligations provided for in GDPR. The Company will comply with GDPR and reflect in these records all information necessary for cooperation with the supervisory authorities under GDPR.

Article 10 Security Measures

When processing User Information, the Company will take adequate technical and systematic measures and execute the processing by ensuring adequate security.

Article 11 Notice of Invasion of User Information to Competent Supervisory Authorities

In preparation for the occurrence of security invasion that may lead to accidental/illegal destruction, loss, alteration, unauthorized disclosure/access of/to User Information that would be transferred, kept or otherwise processed, the Company has a system and measures in place to promptly detect and assess details of the invasion. Based on results of the assessment, the Company will give necessary notice to the supervisory authorities and contact the users who are affected.

Article 12 Rights to User Information

Under GDPR, users in the EU will have the following rights regarding the Company’s handling of User Information. For exercise of these rights, please contact the point of contact for inquiries set forth in Article 15.

(1) Explanations and copies

A user is entitled to request explanations about User Information retained by the Company and about the manner of use of the information at the Company. If the Company collects User Information upon the consent of a user or because it is necessary for the provision of a service requested by a user, the user is entitled to receive the delivery of copies of the information on the user collected by the Company.

(2) Correction

If a user is convinced that his/her information retained by the Company is inaccurate, the user may request correction of the information.

(3) Deletion

A user is entitled to demand deletion of his/her User Information.

(4) Limitation in processing

A user is entitled to prohibit or limit processing of his/her User Information by the Company.

(5) Right of portability

A user is entitled, to the extent that it is technically possible for the Company, to have his/her User Information transferred directly to a third party.

(6) Objections and complaints

If a user believes that the Company fails to comply with obligations of this Privacy Policy and GDPR, the user may file complaints with EU Data Protection Authorities.

Article 13 Link

While a company other than the Company may collect User Information in its website to which the website of the Company is linked, this Privacy Policy, however, does not apply to it, and the Company will not undertake any obligations or responsibilities whatsoever regarding collection of User Information by any company other than the Company.

Article 14 Cookies and Behavioral Targeting Advertising

1. The Company and an ad distributor may send, through Services, cookies to the browser of a user and use the technology.

2. A user may opt out of cookies or refuse them by changing browser settings on his/her part. When the user opts out of cookies or refuses them, part of the Services may not work properly.

3. When a user’s settings allow receipt of cookies, an Ad Distributor may acquire cookie information such as the browsing history of the user using Services, and may display advertising of the Company in the ad space of the Ad Distributor.

4. An Ad Distributor may distribute advertising relevant to the interests and tastes of a user by using cookies, access data, identifier of the Company and attribute information of the user.

5. Cookie information of a user collected by an Ad Distributor will be handled in accordance with the privacy policy of the Ad Distributor.

6. A user may be able to terminate an Ad Distributor’s use of cookies and access data by accessing the opt-out page of the Ad Distributor and opting out of it. In this case, advertising relevant to the interests and tastes of the user may be no longer distributed, or the same advertising may be distributed repeatedly. A user who wishes to opt out will access the following opt-out page and make settings in accordance with the procedure of the site of each Ad Distributor:

List of privacy policies and opt-out of Ad Distributors

http://www.starfactory-inc.co.jp/legal/list.html#ad-privacy-list

Article 15 Point of Contact for Inquiries

For any questions about this Privacy Policy, inquiries about the handling of User Information, and requests under Article 12, please contact the inquiry address (info@starfactory-inc.co.jp). The Company will provide answers to inquiries, as a rule, by e-mail only. Unless otherwise provided for in laws on the protection of User Information or other relevant laws and regulations, the Company will not be obliged to answer any inquiries.

Article 16 Revision

Whenever needed, the Company may revise this Privacy Policy. When revising this Privacy Policy, the Company will promptly announce the date and contents of the revision in our website.

Established on June 1, 2019