COVER Corporation (with an address of Sumitomo Fudosan Tokyo Mita Garden Tower 15F, 3-5-19 Mita, Minato-ku, Tokyo, 108-0073, Japan; represented by Motoaki Tanigo, its Representative Director) (“Company”) hereby establishes this holoplus Privacy Policy (“Policy”), which shall set forth how the Company collects the information of users of holoplus, a product provided by the Company, and any related services (collectively, “Services”), and the personal information of such users, as well as when and how the Company collects and handles such information for certain purposes of use.
Please read this Policy carefully. You will need to agree to this Policy before using the Services.
Please note that there is a separate holoplus Privacy Policy for US Residents that is governed by for US users.
The Company shall obtain the following information in connection with your use of the Services.
Account information, e-mail addresses, login information, information provided by other service vendors (e.g. Google and Apple), information related to viewing and using the Services, any content that is communicated with other users, cookies, information related to devices that are used, internet domain names, IP addresses, investigative information and any other information that is necessary to appropriately and smoothly operate the Services.
Notes
a. Information that the user publicizes on his/her own
In the Services, users may publicize information by using functions such as comments. In such circumstances, the Company does not have the ability to control access to such content and information. If you decide to publicize content and information, you agree that you are doing so based on your own appropriate judgment.****
b. Information obtained from third-party accounts
If you register or login to the Services using a third-party account, such as Google or Apple, it is possible that information that is held in that account (including usernames, email addresses, pictures, gender, birthdays, locations, friends, follows, posted content) may be disclosed to the Company. This Policy does not apply to such third parties and the Company shall not bear any responsibility in any manner whatsoever regarding the disclosure of information to the Company by third parties. Before using third-party accounts to use the Services, please read the privacy policies of such third parties.
Other than for the purposes set forth above, the Company may obtain anonymized information of users or information that is processed in a way so that users are not able to be identified. In such cases, the Company may use such information without the consent of a user for purposes that are permitted by laws and regulations.
Note
The Company uses Google Analytics to collect, record and analyze the records of use of users in connection with their use of the Services.
With respect to users’ use of the Services, the Company collects information related to the history of when the user visited the Services. However, the data that is gathered does not include information that can identify the individual.
Also, it is possible for you to stop the gathering of your information in this way through Google Analytics by invalidating this function in your settings with Google. For details, please take a look at the following website.
https://policies.google.com/technologies/partner-sites?hl=en
The Company will not provide or disclose the personal information of users to third parties except for the following circumstances.
(1) After obtaining the consent of the user, himself or herself
(2) When providing information to a contractor of the Company (that is required to enter into a non-disclosure agreement with the Company) for the purpose of providing the Services to users (e.g. providing delivery vendors with users’ addresses). (These vendors may not use information beyond the necessary scope of the services they provide to the Company.)
(3) When the Company receives a formal inquiry based on law by a public institution, such as a court, a bar association or the police
(4) When there is imminent danger to someone’s life, body or assets and there is a need for urgency
After the purpose of use of the personal information of users has been fulfilled (including but not limited to the termination of the Services), the Company shall promptly delete, destroy or irreversibly anonymize such information by an appropriate method.
Users have the right to request to have their own personal information that they provided to the Company, or that was provided or recorded by a third party, revealed, modified, no longer used or deleted. However, under certain circumstances, the Company shall be able to deny all or part of a user’s requests.
In order to make such requests, please contact us by the method indicated at the bottom of this Policy.
The Company shall handle the personal information of users carefully and shall implement reasonable security measures to protect such information from unauthorized access, use or disclosure, including the use of physical, technical and other procedural preventative measures. If users would like to know the details of the security management measures that the Company takes, please contact us by the method indicated at the bottom of this Policy.
If the user desires to know what the purpose of use of his or her personal information is or to have such information revealed, modified, no longer used or deleted, the Company shall promptly respond to the user’s request based on laws and regulations.
This policy is governed by Japanese law. It is targeted to users that reside in Japan but also applies to users overseas to the extent permitted by applicable laws. Please also note that we have a separate privacy policy for users who reside in the United States.
Please use the following form to send requests related to this policy and the use of information that is collected based on this policy.
COVER Corporation; Point of Contact for holoplus
[URL]https://share.hsforms.com/1rBi_Y6_ZSDqwSBiH2wHTzQbzjz3
Established August 29, 2023
COVER Corporation (“Company”; or “we”, “us”, “our”) hereby establishes this Privacy Policy for US Residents (“Policy”) which shall set forth how the Company collects the information of US users of holoplus (“user”; or “you”, “your”), a product provided by the Company and any related services (collectively, “Service”), and the personal information of such users, as well as when and how the Company collects and handles such information for certain purposes of use. Please note that there is a separate holoplus Privacy Policy that is governed by Japanese law for all other non-US users.
We collect information that identifies, describes or could reasonably be linked to a particular user or his/her device (“Personal Information”). In particular, we will collect the following categories of Personal Information from our users:
| Category | Examples |
|---|---|
|
A. Identifiers |
|
|
B. Personal information |
email addresses, birth date |
|
C. Commercial information |
Records of in-game goods/services purchased, and other purchasing histories |
|
D. Internet or other similar network activity |
Login history to the Services, chat messages and interactions between users, event logs |
|
E. Geolocation data |
Countries and regions from which consumers access an internet website |
|
F. Inferences drawn from other personal information |
Profile reflecting a person’s preferences, characteristics, predispositions and aptitudes |
We do not collect any other Personal Information other than what is listed above.
We obtain your Personal Information listed above when you (i) register your personal account for our Service, (ii) access or use the Service, and (iii) communicate with us for inquiries about the Service.
Notes
1.Information that the user publicizes on his/her own
In the Services, users may publicize information about themselves by using functions such as chats. In such circumstances, the Company does not have the ability to control access to such content and information. If you decide to publicize content and information, you agree that you are doing so at your own risk and based on your own appropriate judgment.
b. Information obtained from third-party accounts
If you register or login to the Services using a third-party account, such as Twitter or Google, it is possible that information that is held in that account (including names, usernames, avatar names and icons, email addresses, pictures, locations) may be disclosed to the Company. This Policy does not apply to such third parties and the Company shall not bear any responsibility in any manner whatsoever regarding the disclosure of Personal Information to the Company by third parties. Before using third-party accounts to use the Services, please read the privacy policies of such third parties.
We may use Personal Information for one or more of the following business purposes indicated below:
Other than for the purposes set forth above, the Company may obtain information that is processed in a way so that users are not able to be identified (“Deidentified Data”). In such cases, the Company may use Deidentified Data without the consent of a user for purposes that are permitted by laws and regulations.
Note
The Company uses Google Analytics. This service places cookies on your device (including a “ClientID”) to collect, record and analyze the records of use of users in connection with their use of the Services. The information collected is shared with Google.
With respect to users’ use of the Services, the Company collects information related to the history of when the user visited the Services. However, the data that is gathered does not include information that can identify the individual.
Also, it is possible for you to stop the gathering of your information in this way through Google Analytics by invalidating this function in your settings with Google. For details, please take a look at the following website.
https://policies.google.com/technologies/partner-sites?hl=en
We may disclose your Personal Information to a third party for business purposes or commercial purposes. When we disclose Personal Information to service providers for business purposes or commercial purposes, we enter into a contract that describes such purposes and requires the service providers to keep such Personal Information confidential and to not use the same for any purpose except for performing the contract.
As of the date this Policy was established, during the preceding twelve (12) months, we have not shared or disclosed the following categories of Personal Information from the above list to any third parties for business purposes or commercial purposes.
We have not sold any Personal Information in the preceding twelve (12) months.
As used in this Section, the term “child” or “children” means those under the age of 13, and the term “parent” includes legal guardians.
Our services are intended for general audiences and are not targeted at children. We do not knowingly collect, use or share any Personal Information about children. If you are a parent and believe that your child has provided us with Personal Information, please contact us by using the form we set forth below and request that your child’s information be deleted from our system. If we learn that we have inadvertently collected Personal Information from children, we will deactivate the relevant account or accounts and take reasonable measures to promptly delete such Personal Information from our records.
Depending on your jurisdiction, in accordance with applicable laws, you may have several rights in relation to our processing of your Personal Information, which may include requesting access to, correcting or deleting your Personal Information.
If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides consumers who are residents of California with specific rights regarding Personal Information. The following parts A through F of this Section describe your CCPA rights and explain how to exercise such rights. Please refer to section (e)(3) below to read about what a “verifiable consumer request” is.
A. Right to Access Specific Information
You have the right to request that we disclose certain information to you about our collection, sharing, disclosure, or use of your Personal Information over the past twelve (12) months from the time of your request. Upon receiving and confirming your verifiable consumer request, we will disclose the following information to you:
Please note that we have not sold any Personal Information in the preceding twelve (12) months, and we have no plans to do so in the future.
B. Right to Request Deletion
You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Upon receiving and confirming your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
C. Opt-Out Rights
Opt-out rights do not apply as we have not sold and will not sell any Personal Information collected from consumers.
D. Non-Discrimination
We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not:
E. Exercising Rights under the CCPA
(1) To exercise your rights under the CCPA to access or delete your Personal Information as described above, please submit a verifiable consumer request to us as detailed in subsection (3) below by contacting us in the manner set forth in Section 8 (Contact Us).
(2) Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
(3) A “verifiable consumer request” must:
F. Response Timing to Verifiable Consumer Requests
We will review and improve the contents of the above items regarding the handling of your Personal Information as appropriate. When changes are made to this Policy, an update notice will be posted on the website and will be effective as of the date posted.
If you have any questions or comments about this Policy, the ways in which we collect and use your Personal Information, or wish to exercise your rights described in Section 6 (Your Rights and Choices under Applicable Law), please do not hesitate to contact us at:
https://share.hsforms.com/1rBi_Y6_ZSDqwSBiH2wHTzQbzjz3
Established August 29, 2023
