Privacy Policy (For EU residents)

1. Users to Whom the Privacy Policy Applies

This Privacy Policy applies to the handling of personal data (Article 4(1) of the General Data Protection Regulation 2016/679 (the "GDPR")) of the users who use the services of the Company (defined as below) from EU, Iceland, Liechtenstein, and Norway (hereinafter collectively referred to as "EU").

2. User Personal Data to be Collected

The Company may collect from the user(s) (the "User(s)") the following personal data (the "User Personal Data"):

• Name (including nicknames and pen names)
• E-mail address
• Address
• Photos and videos
• Information regarding means of payment of the Users, such as credit card, bank accounts or electronic money
• ID used by the Users for external services or any other information which the Users authorize the service providers of such external services to disclose by privacy settings of such external services
• Identification information generated by using cookies
• Information regarding the OS and the terminal used by the User, such as ID generated by the OS, the type of the terminal, and the terminal identifier
• History of the Users’ activities on the Company’s website, such as time spent on the Company’s website, input history, and purchase history
• Usage history of the Company’s applications such as startup time, input history, and purchase history of the Company’s applications
• Location information of the Users

3. Purpose of Use of the User Personal Data

The Company uses the User Personal Data collected from the User for the following purposes, on the legal bases including legitimate interests (Article 6(1)(d) of the GDPR), performance of contractual obligations (Article 6(1)(b) of the GDPR), the User’s consent (Article 6(1)(a) of the GDPR) or compliance with legal obligations in EU and its member states (Article 6(1)(c) of the GDPR):

When processing is required for the pursuit of legitimate interests (Article 6(1)(d) of the GDPR)

• to register or verify the User’s identity and authenticate with the Company’s services (the “Services”)
• to manage the User’s usage history of the Services
• to analyze the User’s activity history in the Services to maintain and improve the Services
• for market analysis and marketing
• to inform the User of the Services
• to correspond to actions that violate the Company's terms and conditions, laws and regulations
• to inform the changes etc. to the Company’s terms and conditions
• in addition, to provide, maintain, protect and improve the Services

When processing is required for the performance of contractual obligations to provide the Services to the User(Article 6(1)(b) of the GDPR)

• to settle usage fees
• to inform the User of changes to, discontinuance of, termination of, or cancellation of the Services
• to respond to the User’s inquiries

When the User’s express consent is obtained in advance (Article 6(1)(a) of the GDPR)

To deal with any act which violates the laws and regulations of EU and its member states which applies to the Company(Article 6(1)(c) of the GDPR)

• To deal with any act which violates the laws and regulations of EU and its member states

4. Transfer of the User Personal Data to Japan

The Company will transfer the User Personal Data to Japan for the purposes of fulfilling any contractual obligations with the User or any pre-contractual procedures requested by the User. Japan has been accredited by the European Commission for the protection of personal data.

5. Retention Period

The Company will retain the User Personal Data for as long as necessary to fulfill the purposes for obtaining and processing the User Personal Data as set out in this Privacy Policy. Specific retention periods are decided by taking into account the purposes for obtaining and processing the User Personal Data, the nature of the User Personal Data and the necessity of retaining the personal data for legal or business reasons.

6. User’s Rights

The User has the right under the GDPR to obtain information regarding processing of the User Personal Data, to access the User Personal Data, to request corrections to or deletion of the User Personal Data, to restrict the processing of the User Personal data, to data portability, to be free from automated decision-making (including profiling) and to object to the processing of the User Personal Data.

In addition, if the User is dissatisfied with the processing of the User Personal Data, the User may lodge a complaint with the Data Protection Supervisory Authority of the User’s country of residence, place of workplace or place of the alleged infringement.

7. Withdrawal of Consent

The User may withdraw its consent to the Company’s use of the User Personal Data at any time by the means otherwise specified by the Company at the time the Company obtaining the User’s consent. However, the legality of any action taken based on the User’s consent prior to the withdrawal is not affected by the User’s withdrawal of consent.

8. Automated Decision-making

The Company does not make decisions solely based on automated data processing that produces any legal or similar material effect on the User.

9. Amendment to Privacy Policy

The Company will amend this Privacy Policy as necessary. In such case, the Company will announce or notify, in an appropriate manner, the timing when the amended Privacy Policy will be enforced and the contents thereof.

10. Contact Information

If you have any question regarding this Privacy Policy, please contact the data administrator at:

Stack Forward LLC

Niveau 9, bâtiment Ariake Frontier Tower B, 3-7-26 Ariake Koto-ku, Tokyo, 135-0063, Japon

[email protected]