DENDAMA privacy policy

The Company shall process and handle the information of its customers (hereinafter referred to as "Users") in the application service "DENDAMA" (hereinafter referred to as "this Application") provided by the Company as follows.

1. (General Provisions)

This privacy policy will apply in connection with the use of this Application and related services and equipment (hereinafter referred to as "the Service").It also describes the User's data protection rights, including a right to object to some of the processing which the Company carries out. More information about User rights, and how to exercise them, is set out in the "Data protection rights of Users" section.

2. (Information collected by the Company)

① Information directly obtained from Users
When the User completes the registration procedure of the Service, in order to provide services including identity verification, prevention of unlawful use, creation and publication of a profile page, or communication function with other Users, the Company will ask Users to register basic information such as User's username, name, e-mail address or other personally identifiable information.
② Terminal information
In order to maintain and improve this Application or to prevent fraudulent activity, the Company will collect the User's terminal-specific information such as browser type, device ID, device type and operating system used.
③ Location information
Where the User has consented, the Company will collect location information transmitted from the User's smartphone, tablet or other information terminal to the extent necessary for providing the Service to the User. The User can stop sending location information by changing the setting on the information terminal, however, all or a part of this Application may not be available thereafter.
④ Payment information
When the User purchases the virtual currency in the Service directly from the Company, the Company will obtain the payment information necessary for the settlement processing, such as the User's address and email address. If a third-party payment service company (including, but not limited to, Apple Inc. and Google LLC) processes the purchase of the User, the billing information / payment information provided to the payment service company by the user will be obtained by the Company. ⑤ Information related to customer support
When using the Company's customer support, the Company will collect and store contact information (name, email address, account information) and the content of the User's inquiry.
⑥ Information on User actions
When the User uses the Service, the Company will collect information relating to the User's use of the Service, such as duration of play and scoring.
⑦ Information on communication function
The Company will store information (including text, user profiles, messages, photos, images, sounds, videos and other information contents) which is provided or sent by the Users to communicate with the Company or other Users while using the Service.
⑧ Acquisition of information using cookies, etc.
The Company may acquire and store Cookies and other identifiers.
⑨ Cooperation with external service
The Service allows Users to share information about their use of the Service to external services such as Facebook, Twitter, Instagram, etc. These social media platforms are not within the Company's control and Users should refer to the platforms' privacy policies for more information on how their personal information will be used.
⑩ Information on DENDAMA device
The Company will collect and store information such as triaxial acceleration sensor, triaxial gyro sensor, coil sensor and firmware version on the DENDAMA device linked with this Application.

3. Purpose of use and legal basis for the use

The Company will use the information of the User for the following purposes:
To fulfill a contract, or take steps linked to a contract. This is relevant where the User makes a purchase from the Company or enters a competition that the Company is running. This includes the following purposes:
① To provide products and services and to provide relevant information
② For sweepstakes campaign implementation
③ Personal identification and authentication
④ Billing and billing calculation
⑤ To respond to inquiries / complaints
⑥ For notification of necessary matters in service operation

As required by the Company to pursue its legitimate interests, in particular:
⑦ To prevent unlawful acts or actions that may be illegal and enforce the terms of use
⑧ System maintenance and troubleshooting
⑨ Preparing statistical information to the extent that Users cannot be identified
⑩ Development and provision of this Application, website, service, content and advertisement

Where the User has given their consent:
⑪ For questionnaires
⑫ Advertisement or promotion of products etc. of the Company and third parties
⑬ To share the User's personal information with third parties
For purposes which are required by law (including where we need parental consent to provide online services to children under 13):
⑭ For the exercise of rights and obligation under contract or applicable law

4. Sharing of personal information

The Company may share User information with third parties in the following cases:
① If the Company needs to disclose the User's personal information in accordance with laws, regulations, legal procedures or requests from the public or government agencies in and outside the User's residence;
② In case of organization restructuring, merger, assignment, or other business succession due to other reasons; and
③ Where the Company needs to provide Users' personal information to service providers, such as IT hosting and maintenance providers, customer service providers and advertisers. These companies are authorized to use Users' personal information only as necessary to provide these services.

5. International transfer of information

Personal information will be transferred to the Company's affiliates and contractors, including to countries outside the European Economic Area, such as Japan and the United States.
Where information is transferred outside the EEA, and where this is to an affiliate or a contractor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification, Users' consent, or a contractor's Processor Binding Corporate Rules. Users can request a copy of the relevant mechanism by making a request at the contact details set out below.

6. Safety management measures

The Company takes reasonable administrative, technical and physical measures to prevent loss, theft, abuse, unauthorized access, disclosure, tampering, and destruction of User's personal information.
In order to preserve the safety of User's personal information, the Company provides privacy and safety guidelines to its employees and thoroughly implements measures to protect privacy within the Company.

7. Data protection rights of Users

Users in the EU have the right to ask the Company for a copy of their personal information; to correct, delete or stop any processing of their personal information, to obtain a copy of their personal information in a structured, machine readable format and to port this information to another data controller.

These rights may be limited, for example if fulfilling the User's request would reveal personal information about another person, or if the User ask the Company to delete information which it is required by law to keep or has compelling legitimate interests in keeping.

To exercise any of these rights, the User can get in touch with the Company using the details set out below. If Users have unresolved concerns, they have the right to complain to an EU data protection authority where they live, work or where they believe a breach may have occurred.

8. Inquiries about privacy policy

For questions or inquiries regarding the privacy policy, please contact info@dendama.co.jp. However, if an inquiry method is specified in the Application or the website, User can use such inquiry method.

9. Cookie Policy

In order to better serve you, the Company collects information automatically through the use of "cookies". A cookie is a text file containing small amounts of information that this Application can send to User's browser, which may then be stored on User's computer as a tag that distinguishes the computer but does not identify the User.

10. Child's personal information

The Company will never intentionally acquire personally identifiable information from children under 13 years of age. If for some reason the Company has acquired information that may identify children under 13 without the consent of their parents or guardians, the Company will take measures to quickly delete such information from its records.

11. Destruction of acquired information

Registration data, will be kept as long as the User are an active user of the Services and for 3 years after this.
Where the Company processes personal information for providing the Services, marketing and Service improvement purposes or with the User's consent, the information is processed until the User ask the Company to stop and for a short period after this (to allow the Company to implement the User's requests). The Company also keeps a record of the fact that the User has asked not to receive direct marketing so that the Company can respect their request in future.

Where the Company processes personal data in connection with performing a contract or for a competition, the data is kept for 3 years from the User's last interaction with the Company.
The acquired personal information will be deleted after a reasonable retention period in light of relevant laws and regulations and usual business practices of the Company or when it is no longer necessary to use it.

12. Revision of privacy policy

The Company may update its privacy policy from time to time. Amendments to the privacy policy will be posted on the Company's website along with the latest privacy policy. If the Company changes this policy, it will take effect from the time it is posted on the website.

13. Date of enactment / revision

09 01, 2018.