Privacy Policy (Pococha Official Site)

Effective Date: March 24, 2021

In this Privacy Policy, "DeNA", "we", "us", or "our" means DeNA Co., Ltd. and its subsidiaries.

Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect and use your information in connection with use of our official site for Pococha ("Services"). By using our Services you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy. This Privacy Policy should be read together with our Terms of Use ("Terms of Use").

So please take a moment to learn the five W's, the How, and other important matters about the information we collect and how we use it. If you have any questions, please contact us at support@pococha.com.

Contents

  • The WhatBoth non-personal information and personal information may be collected and used by us.
  • The WhyThe primary objective for collection and use is to deliver and improve our Services.
  • The WhenWhen you provide information to us, or when you use the Services.
  • The HowBy providing information to us directly using the Services. Cookies may be used, but options are available to remove/disable certain cookies by the settings on your browser.
  • The WhoWe may share your information with persons who help us provide the Services, but only as necessary, and they must keep it confidential. Except only in special circumstances, we never transfer your personal information to advertisers or marketers without your separate consent. We do not knowingly collect personal information from children under 18.
  • The WhereIn line with this Privacy Policy, your information may be processed in Japan and other countries as necessary.
  • Changes to Privacy PolicyWe may change this Privacy Policy, so please check for any updates.
  • Other Important MattersMeasures are taken to safeguard information received from you, and we keep your personal information only as long as necessary.
  • Information Notice for California Residents & Privacy RightsCertain provisions of this Privacy Policy are for California residents; if you are a California resident, you should confirm if they apply to you.

The What

In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information is information that can be used to identify you as an individual, and might include your name, email address, IP address etc. Non-personal information is information that does not permit direct association with you. Both personal information and non-personal information may be used alone or in the aggregate with information collected from other users. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers in a way that enables you to be identified. But the same pieces of information are considered non-personal information if they are taken alone or combined only with other non-personal information provided the information cannot otherwise be linked or attributed back to you as an identifiable individual.

The Why

Our primary objective in collecting your information is to provide you with a superior and personally relevant user experience. To achieve this, your information may be used as follows or by requesting explicit consent where required by law:

  • To help us develop, deliver (in accordance with our Terms of Use), and improve our Services.
  • For market research purposes that support our efforts to deliver a more valuable service to our community of users.
  • To provide end-user support.
  • To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our Terms of Use and this Privacy Policy.
  • To audit and analyze data for technical administration, to improve our Services, and for end-user communications.

The When

Your information is collected by us when you directly interact with our Services and otherwise through use of our Services via your device you use to access or use our Services ("Device").

When you use our Services, we collect information related to your Device as described in "The How" section below.

The How

As already mentioned, we may collect information from you when you directly interact with our Services and otherwise through your access to or use of our Services.

Direct interaction includes such actions as providing an email address. You specifically agree that we shall have the right, but not the obligation, to collect and store the information referred to in this paragraph.

We may also collect your information from third parties who provide it to us, including other users of our Services.

As is standard practice, we do use "cookies" in connection with the Services. A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services, we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own "third party" cookies--see "The Who" for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.

Except for cookies strictly necessary for enabling us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the content you visit. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services. We use Google Analytics to collect and process certain analytics data. You can learn about Google's practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Some of our Services, including messaging, may use "click-through URLs" linked to other content on our Services. We track this click-through data to help us determine interest in topics, Services usability, and other measures of user engagement.

In using our Services, our servers record information sent from your Device, which may include information such as cookies and language.

BY ACCESSING OUR SERVICES, YOU ARE CONSENTING TO THE USE OF COOKIES UNDER THE TERMS OF THIS PRIVACY POLICY.

The Who

Our Responsibility for Our Collections

Persons with Whom We May Share Your Information
You agree that we may share your information as follows:

・With Third Parties for Industry Analysis

You agree that we may share technical information related to your Device (such as cookies), aggregated non-personal information, and anonymous information with analytics analysis entities ("Ad Entities") with whom we have strategic relationships, and Ad Entities may also be permitted to collect such information via cookies and other tracking technologies. This information may be used to undertake user trend analyses, demographic profiling, and analytics. Please note, though, that some Ad Entities also act as Service Providers (defined below) for us, and in those cases we may share your information as explained below.

・With our Service Providers

Sharing of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a "Service Provider") (e.g., improvement of our Services' features, marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are obligated not to disclose or use your personal information for any other purpose.

・With Certain Third Parties in Special Circumstances

At times, we may disclose information about you to law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.

Under another special set of circumstances, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets, and in this connection we may transfer all of your information, including personal information, to any successor entity.

Policy Not to Collect Personal Information from Children

We do not knowingly collect personal information from, or store personal information of, children. We will upon notice or discovery take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge.

The Where

You understand and agree that we may transfer your information to and process it in Japan and other countries outside of your country of residence. Such transfer could subject the user's personal information to foreign laws, which may provide different levels of protection than those in your home country.

Changes to Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice on our Services by, including but not limited to, posting the most recent version indicated by the updated “Effective Date”. You can view the latest Privacy Policy any time by clicking the “Privacy Policy” link at the bottom of the applicable webpage. We encourage you to check for updates regularly. Your use of our Services after we have changed the Privacy Policy will apply the Privacy Policy in effect at the time your personal information is collected.

Other Important Matters

Protecting Your Information

We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, your username, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device). We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or "personal information" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Corrections and Certain Opt-Out Options

If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us at support@pococha.com. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.

Other Websites and Services

Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or "click on" an advertisement or another third party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.

The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third party websites or services, and this Privacy Policy does not apply to information collected by them, including Ad Entities. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.

Information Notice for California Residents & Privacy Rights

As described below, California residents may have additional rights and choices related to identifying information and other types of personal information.

This section covers how we collect and use your information in connection with the use of our official site for the Services and applies solely to California residents.

Summary of Information Practices

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your "personal information" as defined in the California Consumer Privacy Act ("CCPA").

Categories of personal information we collect and disclose.

Throughout our Privacy Policy, including in "The What" and "The When" sections, we discuss in detail the specific pieces of personal information we collect from and about users.

Under the CCPA, we are also required to provide you with the "categories" of personal information we collect. The categories we may collect are:

  • Contact information (for end-user support), such as names, email addresses and other information you provide us;
  • Internet or other network or device activity, such as browsing history or Services usage;
  • General geolocation information, such as latitude-longitude coordinates based on IP address; and
  • Other information that identifies or can be reasonably associated with you; and
  • Inference data drawn from the information above;

We share all of above categories of personal information with:

  • Our affiliates and subsidiaries;
  • Our service providers, such as marketing service and providers of technical services (e.g., data storage, security, and customer relationship management databases); and
  • Other parties where required by law or to protect our rights.

In some cases, the link between the data and the use or disclosure was more direct than others. The specific uses and disclosures in which service providers are involved varies from provider to provider.

How we use these categories of personal information.

We and our service providers may use the categories of personal information we collect from and about you for the following business purposes and commercial purposes (as those terms are defined in applicable law):

  • Our or our service provider's operational purposes;
  • Auditing consumer interactions on our site (e.g., measuring ad impressions);
  • Providing the Services;
  • Improving our existing Services;
  • Other uses that advance our commercial or economic interests;
  • Other uses about which we notify you.

Examples of these types of uses are discussed in "The How" section of this Privacy Policy. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect ("aggregate") or remove pieces of information ("de-identify") to limit or prevent identification of any particular user or device.

Sale of Personal Information

We do not sell information that directly identifies you such as your name and email address. We share certain information as set forth in "The Who" section and allow third parties to collect certain information about your activity, for example through cookies, as explained in "The How" section. You can control these cookies through browser settings and other controls. We do not believe these activities are a "sale of personal information" as such terms are described under the CCPA.

Please note that we also do not knowingly sell the personal information of minors under 18 years of age without legally-required affirmative authorization.

California Privacy Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

  • Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
  • Provide access to and/or a copy of certain information we hold about you.
  • Delete certain information we have about you.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.

If you would like to exercise any of these rights, please contact us at support@pococha.com or at the postal address under Contacting Us below. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. In all cases in which you (or your authorized agent) make a request to exercise your CCPA rights, you will be required to verify your identity directly with us, which may include, verifying certain information regarding your use of the Services. If you are unable to verify your identity, we will be unable to respond to your request.

To the extent that any of our mobile applications of the Services collects personally identifiable information, that is done only as strictly necessary to enable us to provide those Services (see The How, above), and this cannot be disabled by "do not track" or other mechanisms available via your mobile Device's browser.

Contacting Us

If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, please contact us at support@pococha.com or by post:

Attn: DeNA Customer Support Center, Shibuya Hikarie, 2-21-1 Shibuya,
Shibuya-ku, Tokyo
150-8510 JAPAN.