Super Appli, Inc. | GDPR Privacy Policy

We, Super Appli, Inc., take protection of personal data of data subjects in the European Economic Area (“EEA”) under the terms and conditions set forth in the General Privacy Policy which comply with Act on the Protection of Personal Information in Japan and this GDPR Privacy Policy which comply with the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and other relevant laws and regulations. If there is any discrepancy or inconsistencies between the General Privacy Policy and this GDPR Privacy Policy, this GDPR Privacy Policy shall prevail.

1. Purpose of Use and Legal Grounds of Collection and Process

We collect and process your personal data under the following purposes and legal grounds:

	Purpose of Use	Legal Grounds
1	To confirm your application to our email delivery services to be provided with respect to our business, and to deliver emails to you through such email delivery services	consent
2	To confirm your registration of our membership services to be provided with respect to our business, and to provide such membership services	consent
3	To deliver a reward in compensation for your cooperation to answer our questionnaires with regards to our business	consent
4	To deliver goods, etc. of prizes applied with regard to our business	consent
5	To provide or improve our products and services, and to develop new services	Legal obligations, contract performance, legitimate interest or consent
6	To deliver information with regards to our products or services	Legal obligations, contract performance, legitimate interest or consent
7	To answer your inquiries with regards to our business	Legal obligations, contract performance, legitimate interest or consent
8	To use for development, provision and maintenance of our services	Legal obligations, contract performance, legitimate interest or consent

2. Personal Data Categories

We process your personal data to the extent necessary for the purposes stated above. Such personal data may include:

(a) Age, birth date and sex;
(b) Name user name and/or nickname;
(c) Email address;
(d) Phone number; and,
(e) Other information indicated by us in advance whereby a specific individual can be identified

3. Our Legitimate Interests

Our “legitimate interests” set forth in Article 1 of this GDPR Privacy Policy are as follows:

(a) To manage personal data so as to provide our online game service and other game services, social networking services and gamification services to you timely and effectively; and,
(b) To manage personal data so as to ensure the safety of your personal data.Note that we will not collect or process your personal data if your interests or fundamental rights and freedoms which require protection of personal data shall override our interest.

4. Recipients or Categories of Recipients

Your personal data may be received by the following third parties to the extent required for the purposes set forth in this GDPR privacy policy on the conditions that we comply with the applicable laws and regulations on personal data protection:

(a) Lawyers, tax accountants and other professions who are bound by confidentiality obligations under the relevant laws and regulations;
(b) Officers and employees of us; and,
(c) Service providers which process your personal data on behalf of us.

5. Transfer to Third Countries

Your personal data may be transferred to a controller or processor in a third country only where (a) the EU Commission has decided that such third country ensures an adequate level of protection, (b) we and such controller or processor have entered into standard contractual clauses or standard data protection clauses adopted by the EU Commission, (c) such transfer is necessary for the performance of a contract between you and us or for the implementation of precontractual measures taken at your request, (d) such transfer is necessary for the conclusion or performance of a contract concluded in your interest between another natural or legal person and us or (e) you have explicitly consented to the proposed transfer after having been informed that such transfer might cause the leakage of or any other risks to your personal data due to the absence of an adequacy decision and appropriate safeguards.

6. Data Storage Period

Your personal data will be erased when our purposes of use are fulfilled; provided, however, that if you request us to erase such personal data, we will erase your personal data within 10 days after such request even before the fulfillment of our purposes of use. Note that if you provide personal data to play our game services on Facebook, your personal data will be erased within three days after your last play.

7. Access, Rectification, Erasure, Data Portability and Withdrawal of Consent

You have the right to access, rectify or erase your personal data, restrict or object to processing your personal data, and receive your personal data in a structured, commonly used and machine-readable format. Also, you have the right to withdraw your consent to our collection and process of your personal data at any time and your withdrawal does not affect the lawfulness of our processing based on your consent before your withdrawal.If you have any inquiries to the above rights or our process of your personal data, please contact us through the following email address: Attention: Game Service Division, Super Appli, Inc.

Email Address:

contact@ml.super-elements.net

8. Complaint

If you are in the EEA, you have the right to lodge a complaint to our process of your personal data with an applicable supervisory authority having jurisdiction over your residence.

9. No Statutory or Contractual Requirement

Unless otherwise agreed between you and us, the provision of your personal data is neither statutory requirement nor contractual requirement. If the provision of your personal data is neither statutory requirement nor contractual requirement, you will not suffer any disadvantages from non-provision of your personal data.

10. Automate Processing

Your personal data will not be used through automated decision-making process including profiling.

11. Data Security

We implement various technical and organizational security measures to protect your personal data from misuse, unauthorized access, rectification or erasure or any other risks.

12. Use of Processor

We may outsource the process of your personal data to certain processors for the purposes set forth herein. In such a case, we use only processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the applicable laws and regulations and ensure the protection of your rights.

13. Personal data of Person under 16 years old

If you are under 16 years old and you intend to provide your personal data to us, please obtain your guardian’s consent before providing your personal data.

Special Provisions for Information Obtained through Facebook

While we provide our online game services on Facebook, a social network services provided by Meta Platforms, Inc. (formerly known as Facebook, Inc.), (“SuperAppli Facebook Game Services”), we hereby pledge to manage and protect personal data obtained through Facebook properly in compliance with the following special provisions as well as other provisions of our privacy policies. In the event that there is any conflict or inconsistency between provisions of our privacy policies and the following special provisions, the following special provisions will prevail.

1. Purpose of Use

We will not use your personal data obtained through Facebook for any purpose other than that of providing SuperAppli Facebook Game Services to you.

2. Type of Information Obtained through Facebook

We may obtain following information through Facebook:

(1) Your profile name in Facebook;
(2) The URL address of your profile picture; and,
(3) Locale Information

3. Prohibition of Combining Personal Data with Other Information

We will not combine your personal data obtained through Facebook with your information received from any other third party so as to identify you.

4. Prohibition of Provisions of Personal Data without Consent of Meta Platforms, Inc.

We will not provide your personal data obtained through Facebook to any third party (including subcontractors) without consent of Meta Platforms, Inc.

5. Handling of Personal Data at the End of Services through Facebook

We will delete all of your personal data obtained through Facebook by the time we cease to provide SuperAppli Facebook Game Services through Facebook.

6. Request for Deletion

You can, through setting functions of Facebook, request us to delete your information obtained by us through Facebook (please refer to Facebook help webpages for the detailed steps). Your request for deletion will be completed within one day after such request in normal cases. You can check our processing status of your request through deletion request screen.

7. Amendment to Special Provisions

If any amendment to this Special Provisions is required, we will consult with Meta Platforms Inc. and follow its instructions, if any.

Revised on 7th January, 2022