Privacy Policy for Customers in the European Economic Area
Gotcha Gotcha Games Inc. (“Company” or “we”) recognises the importance of protecting Personal Information,
and we strive to handle properly the Personal Information provided by you, our customer residing in the
European Economic Area (EEA) and protect your privacy in compliance with the General Data Protection Regulation
(GDPR)
and related laws and regulations (“Laws”.) Before using our website and receiving a service from the Company,
you need to read through this Privacy Policy.
“Personal Information” means address, name, telephone number, and any other information that can be used to
identify
a customer as a specific individual (including the information that falls under the definition of “Personal Data”
in Article 4 of GDPR.)
1. Personal Information We Collect
The Company may collect from you the Personal Information, including the following:
・Name, address, date of birth, telephone number, email address, occupation, age, and username
・Access history data such as IP address and cookies data during (at the time of) your access to our website
・Shopping data, contents of inquiries, customer account information, orders and contract information, particulars
of
goods delivered, billing information, bank account information, history of transactions and contacting, as well as
the
information about transactions and communication between you and the Company on our website
・Identification and location information of a terminal device
2. Purpose of Use of Personal Information We Collect
The Company will collect Personal Information from you mainly in the cases below.
The purposes of our use of the Personal Information we collect and the legitimate basis for the use are as
follows:
・To process your registration for a service, and to provide you with the service (Performance of a contract)
・To process your application for a prize, gift, contest or the like, to notify you if you are a winner or entitled
to receive some prize, and to deliver the prize, goods, or the like to you, or to give you the prize money
(Performance of a contract)
・To process your application for participation in an interview survey, to request your participation in the said
survey,
and to provide you with a reward or the like (Performance of a contract)
・To confirm your order for goods or fee-based service, to confirm your payment therefor, and to deliver the goods
to you
(Performance of a contract)
・In cases where you use a certain service that is jointly provided by the Company and one of our business-alliance
partners,
to provide the user information about you to the said partner only to the extent required at a minimum for the
provision of
the service to you (Performance of a contract)
・To process your application for employment, to decide to hire you or not, or to notify you of a career seminar or
the like
(Legitimate interests)
・To recommend any goods or service, or to provide you with other information about new goods, service, or the like
based
on your user history (Legitimate interests)
・To conduct market research, planning, or research and development (Legitimate interests)
・To develop new goods, service, or the like (Legitimate interests)
・To improve your experience on our website in a way such as by personalising advertisements and contents you may
be shown
on our website or any of our services (Legitimate interests)
・To provide you with a service based on your visit, shopping, browsing, and shopping behavior history, or location
information,
and to understand and analyze your usage situation (Legitimate interests)
・To aggregate the Personal Information and make statistical material that cannot identify any specific individual,
to conduct marketing,
to develop new goods or service, and to improve the quality of our services based on the material (Legitimate
interests)
3. Sharing of Personal Information with Outside Parties
The Company will share your Personal Information with its group companies. Also, the Company may share your
Personal Information
with the following business partners and/or other third parties:
・Service providers
The Company may conduct the business by using a third party such as a marketing company, and an IT service
provider.
In that case, the Company may need to share your Personal Information for the provision of a specific service.
The shared Personal Information about you will be used under the instruction of and for the purpose of the
Company.
・Legal obligations
In accordance with the Laws, the Company may disclose your Personal Information to public authorities engaging in
the enforcement
of law at the requirements under the Laws, the court order, or the request of a governmental authority or law
enforcement agency
(including those required in terms of national security or law enforcement measures, as well as those made by a
governmental authority
and the court of a country where the Company is conducting the business.)
To the extent permitted by law, where necessary, the Company may disclose your Personal Information to a third
party
(including a legal advisor) to prove, assert or defend against a legal claim; to exercise our rights; to protect
our property,
other ’s rights and property, or safety; or to support an external audit, our compliance, and corporate governance
function.
4. Transfer of Personal Information to Third Party Outside of EEA
In cases where the Company needs to conduct a cross-border transfer of the Personal Information about you, a
customer in the EEA,
to a third country outside of the EEA, we will take appropriate protective measures required for the cross-border
transfer
of the data.
5. Precaution Notice
Our website on the Internet operated by the Company may contain an external link. In that case, please note that
the Company
will not assume any responsibility for the handling of your Personal Information on the said external website.
Also, please note that some of third parties other than the Company may independently collect your Personal
Information
through advertisements placed on our goods, such as a magazine published by the Company. In that case, we will,
also,
not assume any responsibility for the handling of your Personal Information.
6. Rights Held by Customers in EEA
You, a customer in the EEA, have the following rights in relation to your Personal Information retained by the
Company:
(1) Right to access to your Personal Data
(2) Right to request the rectification of your inaccurate Personal Data
(3) Right to request the erasure of your Personal Data
(4) Right to request the restriction on the processing of your Personal Data
(5) Right to receive your Personal Data in a structured, commonly used and machine-readable format
(6) Right to object to the processing of your Personal Data
In cases where your Personal Data is processed on your consent, you, a customer in the EEA,
have the right to withdraw your consent in relation to your Personal Data at any time.
For your submission of a request for any of the rights held by you in relation to your Personal Information,
please see “7. Contact for Inquiries” below.
7. Contact for Inquiries
The point of contact below accepts any comment, inquiry, or complaint from yourself in relation to your Personal
Information.
When you request under “6. Rights Held by Customers in EEA,” please describe the following points and contact us
at the
specified point of contact:
(1) Contents of the Personal Information about which you want to make a request
(2) Name of a service about which you want to make a request
(3) Reason for your request
(4) How you want the Company to address your request
After receiving the request from you, the Company will ask you to provide a document required for the confirmation
of your identity
as specified by us to verify that the request is made by yourself. Upon the completion of the verification
process,
we will address your request.
In cases where a request is made by a proxy for you, not by yourself, we will ask the proxy to submit a document
certifying
his/her authority of representation to the Company.
8. Contact Information of Data Protection Officer
The Company appoints a Data Protection Officer to address matters regarding the protection of Personal Information
adequately.
Contact of the Data Protection Officer:
Attn: Personal Information Protection Supervisor
Gotcha Gotcha Games Inc.
2-13-3, Fujimi, Chiyoda-ku, Tokyo
9. Handling of Personal Data of Customers below 16 Years
Please understand that if you are below the age of 16 years, the Company will ask the consent of your parental
guardian, where necessary,
before receiving the provision of your Personal Data.
10. Retention Period
The Company will not retain your Personal Information for any purpose other than the purpose of obtaining the
information or beyond
the requirements under applicable Laws.
11. Cookies
On our website, as with a lot of other websites, the Company may use cookies or another automatic information
collection program,
where necessary, subject to your consent.
Cookies are the function to store the information about a user on the user’s browser or hard drive through our
website.
By using cookies, you can save time to re-type the information already stored on your hard drive.
Also, we may use cookies to improve your experience on our website by keeping the record of when and how you use
our website.
You can set your browser to disable the functionality of cookies; however, in a few cases, some of our website
features may
not function as a result.
For the same purpose as above, the Company may use an IP address, conduct trend analysis, manage our website,
track a user’s behavior or online activities, and collect statistical demographic information such age or gender,
etc.
The Company may use a web beacon on our website to access cookies and have them placed on your browser.
We may collect the information about a user’s page transitions on our website, too.
The information provided by the web beacon includes your computer’s IP address, the type of browser you use,
and the length of time of your browsing our website.
We may, also, collect the information about when you opened an email or a newsletter.
For details on how the Company uses cookies, please see our Cookies Policy placed here.
12. Other Matters
Please note that if you do not provide us with the updated and accurate information about you, in some cases,
you may not receive an adequate service.
You have the right to lodge an objection to the processing of the Personal Information in relation to you with the
data protection
supervisory authority having jurisdiction over the place of your residence.
13. Amendments to Privacy Policy
The Company may amend or update this Privacy Policy without limiting any of the rights held by an individual
outlined herein.
Upon the amendments to this Privacy Policy, we will state the date of such update below.
Date of Update: 25 September 2020
For the group companies of Gotcha Gotcha Games Inc., please see
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