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:
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
- (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
- (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.
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