Digital Product Privacy Policy (EU)

Version 0608.2018

NoelRecords(Yasuhiro Takano), noelrecords1@gmail.com, respects the privacy rights of its users and recognises the importance of protecting their personal data. This Digital Product Privacy Policy (the "Privacy Policy") provides information relating to the collection, processing, use and privacy of information you submit through the Digital Product.

NoelRecords(Yasuhiro Takano) is the controller within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 -"GDPR").

Words and expressions in this Privacy Policy have the same meaning as in the End User License Agreement for the Digital Product.

1 What Information We Collect and Process

1.1 Information about Your Person and Devices You use

We may collect and use your information below to provide our services and to measure and improve them over time.

・Log data
・Country data
・Age and gender data
・Device model you use
・Screen resolution of your devices

1.2 Information Related to Your Transactions

If you use the Digital Product to make any transactions, we collect and process information about these transactions, such as the registration of licences, purchase of items, use of items, payments and other related activities.

1.3 Information Related to Your Use of the Digital Product

We may collect your activity history data such as which features of the Digital Product you used, at what times you played, as well as crash reports.

1.4 Cookies and Similar Technologies

The Digital Product may use cookies and other similar technologies. Cookies are small files downloaded to your device. Cookies help us to ensure the safety and smooth functionality of our services (security cookies and session cookies).

The security and session cookies that we employ are necessary to provide you with the services you have requested. For example, we employ cookies that enable us to maintain your dictionary data.

2 How Information Is Used - Purposes of Processing

2.1 Providing the Service

We collect and further process the information in order to:

・Enable your use of the Digital Product correctly; and to
・Process requests that you make via the Digital Product.

If you use the Digital Product for making transactions, we process the information about the transactions you make to the extent necessary to process your orders, to provide you with the transaction history and to meet our financial and legal obligations.

The legal basis for the processing referred to in this Section 2.1 is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).

2.2 Fraud Prevention and Prevention of Other Illegal Activities

We may process the collected information relating to the use of the Digital Product to prevent fraud, potentially illegal or offensive activities or to enforce our rights or the rights of other users.

The legal basis for this processing is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the prevention of fraudulent and illegal activities, the protection of our systems and networks, of our services and of our users and the enforcement of our legitimate rights and rights of our users.

You have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right you may at any time contact us as provided in Section 6 of this Privacy Policy.

2.3 Usage Information

"Usage Information" as referred to in this Section 2.3 includes all information submitted through the Digital Product as well as all information collected and processed when using the Digital Product.

2.3.1 Provision of the service

We process the Usage Information for the provision of the service of the Digital Product described in Section 2.1. The legal basis for the processing referred to in this Section 2.3.1 is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).

2.3.2 Product and Service Improvement

We process the Usage Information to perform analytics and statistics of the usage of the Digital Product in order to improve and optimise the Digital Product and our products, our services and performance of our products and services.

​

Our digital product uses the following tools,

​

・Firebase Analytics, an analytics service provided by Google, Inc.

・Facebook Analytics, an analytics service provided by Facebook, Inc. 

The legal basis for this processing is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the improvement and optimization of the Digital Product and of our products and performances which is to the benefit of the users.

You have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right you may at any time opt out in the "Privacy Policy" settings of your Digital Product.

2.3.3 Customized Offers and Recommendations

We may also process the Usage Information for purposes of customised marketing, so that content, products and services can be tailored to meet your needs and to enable customised recommendations and offers displayed to you via the Digital Product or other online functionalities.

 

Our digital product uses the following tools,

​

・Admob, an advertisement distribution service provided by Google, Inc.

・nend, an advertisement distribution service provided by F@N Communications, Inc.

​

The legal basis for this processing is Art. 6 para. 1 (f) GDPR. We have a legitimate interest in processing your information for such marketing as it avoids displaying recommendations and offers that are irrelevant for the user. Customised recommendations and offers have an increased relevance of the user and thus improve the online experience for the benefit of the user.

You have the right to object at any time to the processing of your information for such customised marketing purposes. To exercise this right you may at any time opt out in the "Privacy Policy" settings of your Digital Product.

2.4 Cookies and Similar Technologies

The legal basis for using security and session cookies as explained in Section 1.4 above is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).

3 User Communications

When you send an email or other communication to us, we use those communications in order to process your inquiries and respond to your requests.

The legal basis for this processing is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).

4 Storage Time

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or - where the applicable law provides for longer storage and retention periods - for the storage and retention period required by law. After that your personal data will be deleted.

In particular:

・If you withdraw a consent on which a processing of your personal data is based, we will delete your personal data without undue delay to the extent that the collection and processing of the personal data was based on the withdrawn consent.

・If you exercise a right to object to the processing of your personal data, we will delete your personal data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.

5 Your rights under GDPR

In particular, but without limitation, you may have the following rights under applicable European data protection law:

・Right of access: You have the right to obtain confirmation from us as to whether or not we process personal data from you and you also have the right to at any time obtain access to our personal data stored by us. To exercise this right you may at any time contact us as provided in Section 6 of this Privacy Policy. You can also access the information you provided in the settings of your Digital Product.

・Right to rectification of your personal data: If we process your personal data, we shall endeavour to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which your personal data was collected. If your personal data is inaccurate or incomplete, you have the right to obtain the rectification of such data. To exercise this right you may at any time contact us as provided in Section 6 of this Privacy Policy. You can also change the information you provided in the settings of your Digital Product.

・Right to erasure of your personal data or right to restriction of processing: You may have the right to obtain the erasure of your personal data or the restriction of processing of your personal data. To exercise this right you may at any time contact us as provided in Section 6 of this Privacy Policy.

・Right to withdraw your consent: If you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal. To exercise this right you may at any time contact us as provided in Section 6 of this Privacy Policy.

・Right to data portability: You may have the right to receive the personal data concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller. To exercise this right you may at any time contact us as provided in Section 6 of this Privacy Policy.

・Right to object: You may have the right to object to the processing of your personal data as further specified in this Privacy Policy.

・Right to lodge a complaint with supervisory authority: You have the right to lodge a complaint with a data protection supervisory authority located in the European Union.

6 Contact

If you have any questions about this Privacy Policy and our data processing activities or if you want to exercise any of your rights under GDPR, please contact:

NoelRecords(Yasuhiro Takano), noelrecords1@gmail.com