Scope of this Privacy Policy
This Event Privacy Policy for "Another Eden Summer Illustration Contest" (this "Policy") sets out how WFS, Inc.(the "Company") handles personal data in connection with the event "Another Eden Summer Illustration Contest" provided by the Company (the "Campaign"). For matters not provided for in this Policy, please also refer to the "Basic Policy on the Protection of Personal Information."
Scope of Application and Order of Priority of this Policy
This Policy applies to all customers who participate in the Campaign. However, any restrictions or exceptions under applicable law prevail when applying each provision of the Common Provisions. In addition, customers who reside in certain countries or regions are subject to additional provisions accompanying this Policy (see "Supplemental Provisions for Specific Countries and Regions"). If there is any inconsistency or conflict between the Common Provisions of this Policy and such supplemental provisions, the supplemental provisions will prevail to the extent required by applicable law.
Common Provisions
Handling of Personal Data
(1) Personal Data Collected
(a) Collection Methods
The Company collects personal data by the following methods, depending on the nature of the Campaign and your use of it.
•Information collected directly from you: information that you enter or provide in connection with your entry into the Campaign, inquiries regarding the Campaign, or other participation in the Campaign.
•Information collected from external services or third parties: Information collected or made accessible through external services (such as social media or cloud storage) when submitting an entry for the Campaign or when submitting entry data upon winning an award.
(b) Categories of Personal Data Collected
The personal data collected by the Company may vary depending on your participation status in this campaign but may include the following information.
•Social Media User Information: X display name and username; Facebook display name.
•Entry Data: Submitted work.
•Contact and Shipping Information: Full name, ZIP code, address, phone number.
•Customs and Shipping Information (for residents of Indonesia only): One of the following: Taxpayer Registration Number (NPWP), Customs Identification Number (NIK), passport number, or driver's license number.
•Prize Production Information: Name or pen name to be engraved on the trophy.
•Other External Service Information: If you use Google Drive to submit your entry data upon winning, the Google account name and profile photo that we will be able to view due to technical specifications.
•Inquiry information: inquiry content and other information necessary to respond to inquiries, provided at the time of inquiry.
(2) Purposes and Legal Bases for Processing Personal Data
The Company uses the personal data it collects for the following purposes. Where the Company is required to indicate a legal basis for processing under applicable law, the Company processes personal data on one of the legal bases for each processing purpose and category of personal data.
Performance of a Contract with You
The Company uses social media user information, entry data, contact and shipping information, customs and shipping information, prize production information, inquiry information, and other personal data to the extent necessary to operate the Campaign based on the contract with you. This includes the operation of the Campaign, the production and shipping of prizes, responding to inquiries and other operations of the Campaign requested by you.
Compliance with Legal Obligations
The Company may use contact and shipping information, customs and shipping information, inquiry information, and other personal data necessary to perform obligations under applicable laws and regulations or orders of public authorities, to the extent necessary to perform such obligations. This includes complying with applicable laws and customs requirements for international mail (such as the obligation to provide NPWP, etc. when shipping to Indonesia).
Legitimate Commercial Interests
The Company may use the personal data described in the section "Personal Data Collected" above for the following purposes where necessary for the legitimate interests pursued by the Company or a third party and where your fundamental rights and freedoms do not override those interests. Specifically, the Company may use the personal data described in the section "Personal Data Collected" above for the following purposes.
•Smooth operation and management: smooth operation and management of the Campaign using social media user information and entry data.
•Investigation and prevention of breaches of terms and conditions: investigation, prevention and correction of violations of terms and other misconduct using social media user information and entry data.
•Service improvement and development of new projects: statistical understanding, planning and development of new projects, and improvement of services operated by the Company using social media user information and entry data.
•Measurement of effectiveness and statistical analysis: measurement of effectiveness and statistical analysis of the Campaign using social media user information and entry data.
•Publication and promotion: publication and promotion of the winners' and some entrants' social media user information on official social media accounts, YouTube, and other platforms operated by the Company.
Where the Company processes personal data on the legal basis of legitimate interests, the Company will confirm the content of the relevant legitimate interests, the necessity of the processing and the balancing of those interests against your rights and interests before carrying out the processing. To the extent that the Company relies on its legitimate interests as the legal basis for processing your personal data, you have the right to object to such processing. Unless the Company can demonstrate (1) compelling legitimate grounds that override your interests, rights and freedoms, or (2) that it is necessary to process the data for the establishment, exercise or defense of legal claims, the Company must cease processing your personal data (see the section "Your Rights" below).
Use of Personal Data Based on Your Consent
Where consent is required under applicable law, the Company may use personal data based on your consent.
The Company may ask you to consent to the processing of certain personal data for other specific purposes. In such case, the Company will inform you of the categories of personal data it wishes to process and the purposes of the processing so that you can carefully consider whether to give consent.
To the extent that the Company processes personal data on the legal basis of your consent, you may withdraw such consent at any time as provided in the section "Your Rights" below.
(3) Disclosure and Entrustment of Personal Data
The Company may disclose personal data to, or entrust the handling of personal data to, the following persons to the extent necessary for the provision and operation of the Service.
•Company group companies: for the operation, maintenance, analysis, anti-fraud measures, business management of the Campaign, and other group operations.
•Contractors and service providers: for cloud services, prize production, prize shipping, customer support, and other operations necessary to operate the Campaign.
•Third parties permitted by law: for responding to requests from courts, supervisory authorities, investigative authorities and other public authorities, complying with legal obligations, protecting rights and investigating unauthorized use.
•Business successors: in connection with mergers, company splits, business transfers and other business successions.
•Third parties based on your consent or request: where personal data is provided based on your consent or request.
The Company may use or disclose information that has been anonymized or statistically processed so that individuals cannot be identified, for service improvement, analysis, research, marketing and other purposes permitted by applicable law. Such information does not identify individuals. When using, disclosing or otherwise processing de-identified or anonymized information, the Company will maintain and use such information in a non-identifiable form and will not re-identify individuals except in accordance with applicable law.
Handling of Personal Data Concerning Children
The Company does not knowingly collect personal data from persons under 16 years of age (or under the age for protection of children provided by the laws of their country of residence) without the consent of a person with parental authority or a legal representative (a "Guardian").
If it is found that a customer under 16 years of age has provided personal data to the Company without the consent of a Guardian, the Company will promptly delete such information. If you believe that the Company may have collected information from a child under 16 years of age without the consent of a Guardian, please contact the contact point described in "Contact" below.
Cross-Border Transfers of Personal Data
For the operation of the Campaign, prize production and shipping, , anti-fraud measures, responding to inquiries and other purposes described in "Purposes and Legal Bases for Processing Personal Data" above, the Company may transfer your personal data to countries or regions other than your country or region of residence. Transfer destinations may include Japan, the United States and other countries where Company group companies, contractors, cloud service providers are located. In making such transfers, the Company will take appropriate safeguards based on any of the following in accordance with the requirements of applicable laws and regulations.
・Use of adequacy decisions: where personal data is transferred to a country, such as Japan, that has been recognized by the European Commission or other authority as ensuring an adequate level of protection for personal data.
・Execution of standard contractual clauses: for transfers of personal data from the European Economic Area (the "EEA") or the United Kingdom to countries that do not ensure an adequate level of data protection, the Company uses data transfer agreements based on the EU Standard Contractual Clauses adopted by the European Commission (the "Standard Contractual Clauses") or data transfer clauses under other local laws.
・Your consent: where you have given individual consent to a transfer outside the country.
・Performance of a contract and legal obligations: where directly necessary to operate and implement the Campaign under the contract with you or indispensable for complying with legal obligations.
Security Control Measures for Personal Data
The Company implements the following measures to prevent leakage, loss or damage of personal data and otherwise ensure security control. ・Organizational security control measures: formulation of basic policies and rules concerning the handling of personal data,appointment of managers, and establishment of reporting and communication systems, as well as regular audits of compliance with rules.
・Human security control measures: regular training for all employees, including dispatched workers, and obtainment of confidentiality pledges.
・Physical security control measures: restriction of access to offices through entry and exit controls, measures to prevent theft or loss of devices and media, and erasure of data in a manner that makes restoration impossible at the time of disposal.
・Technical security control measures: restriction of access authority, introduction of measures against unauthorized external access (firewalls and, where necessary, encryption during communication and storage, etc.), and regular evaluation of the effectiveness of such measures.
・Understanding of external environments: understanding of personal data protection systems outside Japan and implementation of appropriate security control measures based on such systems.
However, because no information system can guarantee complete security, the Company will endeavor to maintain and improve appropriate security control measures within a reasonable scope.
Your Rights
The Company respects your rights (the "Rights") with respect to the handling of your personal data to the extent permitted under applicable laws and regulations.
(1) Details of Rights
Subject to restrictions and exceptions under applicable law, you may have the following rights with respect to your personal data collected by the Company.
・Right of access: you have the right to request access to your personal data held by the Company and information concerning the processing of your personal data.
・Right to rectification: if personal data held by the Company is inaccurate or incomplete, you may request that it be updated or corrected.
・Right to deletion: except where the Company is required by law to retain your personal data, where retention is necessary to exercise or defend claims, where there is a legitimate purpose, or in other exceptional cases, you may request the Company to delete your personal data.
・Right to object: where the Company processes personal data based on legitimate interests, you have the right to object to the processing of your personal data by the Company on grounds relating to your particular situation, unless the Company can demonstrate compelling legitimate grounds for processing your personal data.
・Right to withdraw consent: where the Company processes personal data based on your consent, you have the right to withdraw consent at any time with effect for the future.
・Right to restrict processing: in certain circumstances, you have the right to restrict the processing of your personal data by the Company, such as where (i) the personal data concerning you held by the Company is inaccurate, (ii) the personal data has not been lawfully processed but you wish processing to be restricted instead of having the personal data deleted, or (iii) the Company no longer needs your personal data for the purposes for which it was collected, but you believe that the personal data is necessary for the establishment, exercise or defense of legal claims.
・Right to data portability: in certain circumstances, where the Company processes personal information based on your consent or for performance of a contract with you and the processing is carried out by automated means, you have the right to request that the personal information you provided to the Company be transferred to a third party.
(2) Scope of Application and Method of Exercise
The specific details, conditions for exercise and restrictions of the Rights are governed by the applicable laws and regulations of your place of residence. Please refer to "Supplemental Provisions for Specific Countries and Regions" below for individual supplemental matters concerning specific countries and regions. Even in regions where no individual provisions are provided, the Company will appropriately respond to the exercise of the Rights based on the laws and regulations of that region. If you wish to exercise your Rights, please contact the contact point described in "Contact" below. The Company will respond in accordance with laws and regulations after verifying your identity.
Contact
For inquiries, consultations and complaints regarding the handling of personal data in the Campaign, please contact the Company's Data Protection Manager below.
(1)Contact
https://www.wfs.games/en-us/contact/
(2) Company Data Protection Manager
Title: Data Protection Manager
WFS, Inc.
Roppongi Hills Gate, 6-11-1 Roppongi Minato-ku, Tokyo, Japan
privacy@help.wfs.games
(3) Data Protection Officer (DPO)
The Company has appointed a Data Protection Officer who is involved properly and in a timely manner in all matters relating to the protection of personal data.
Title: Data Protection Officer
GREE Holdings, Inc.
Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku, Tokyo, Japan
dpo@gree.net
(4) EU Representative
The Company has appointed the following EU representative.
Title: EU Representative of WFS, Inc.
PLANET // LEGAL
Jungfernstieg 1, 20095 Hamburg, Germany
eu_representative@planit.legal
Management Policy
(1) Retention Period
The Company sets retention periods for your personal data. Such information will be deleted when it is no longer necessary to achieve the purposes of processing described in "Handling of Personal Data" above. Specifically, will be retained for 5 months after the Campaign begins. Information obtained based on your consent will be deleted when the consent is withdrawn. However, where necessary to comply with applicable laws and regulations or respond to orders from governments, courts or other supervisory authorities, the Company will retain such information for the relevant period after implementing security control measures.
(2) Method of Notice, Publication or Obtaining Consent
This Policy is posted and published within the Entry Terms and the personal information collection form of the Campaign. The Company may amend this Policy, and when making material amendments, the Company will provide notice on official social media or on the official website. The amended Policy will apply from the time it is posted in each place where it is made available.
Please participate in the Campaign after reviewing and consenting to the Entry Terms and this Policy. You entry into the Campaign (and, with respect to the amended Policy, your continued use after the amendment) will be treated as your consent to this Policy.
However, where, under applicable law, treating your entry into the Campaigns' consent to this Policy is not recognized as valid consent, the Company will separately obtain the necessary express consent in accordance with applicable law before commencing the relevant processing.
Supplemental Provisions for Specific Countries and Regions If you reside in any of the following countries or regions, in addition to the Common Provisions, supplemental provisions specific to each region apply.
United States: Supplemental Provisions for United States Residents
Supplemental Provisions for United States Residents
This section applies to customers residing in the United States. This section supplements the provisions on the handling of personal information set out in this Policy. If there is any inconsistency or conflict between this section and other provisions of this Policy, this section will prevail to the extent required by applicable law.
(1) California Residents
The "California Privacy Notice" below applies to customers residing in California. The California Privacy Notice includes additional information under the California Consumer Privacy Act and related regulations concerning the categories of personal information the Company collects, uses, discloses, sells or shares about California residents, the sources of such personal information, purposes of use, retention periods, and the rights of California residents and how to exercise them.
(2) Residents of Other U.S. States
Customers residing in other U.S. states may have, in addition to the rights set out in "Your Rights" in the Common Provisions above, rights under applicable state laws, such as the right to opt out of the sale of personal data, processing for targeted advertising purposes or profiling that produces legal or similarly significant effects concerning you, and the right to appeal the Company's response to a rights request, as well as other rights.
The availability, content, conditions for exercise and restrictions of these rights are governed by the applicable laws and regulations of your state of residence. If you wish to exercise your rights, please contact the contact point described in "Contact" above. The Company will respond after verifying your identity in accordance with applicable law.
California Privacy Notice
This California Privacy Notice (this "Notice") applies to customers residing in California and provides additional information under the California Consumer Privacy Act and related regulations (collectively, the "CCPA") concerning the Company's handling of personal information and the rights of California residents.
This Notice supplements this Policy. If there is any inconsistency or conflict between this Notice and any other provision of this Policy or any other notice, this Notice will prevail with respect to personal information of California residents subject to the CCPA to the extent required by applicable law.
In this Notice, the terms "personal information," "sensitive personal information," "sale," "sharing," "business purpose," "service provider" and other terms defined in the CCPA have the meanings defined in the CCPA unless otherwise stated.
Scope of this Notice
This Notice applies to personal information that the Company collects from or about California residents in connection with operation of the Campaign and other interactions with customers.
This Notice does not apply to information exempt from the CCPA, anonymized information, de-identified information, aggregate information or other information that does not constitute personal information under applicable law. A separate applicable notice may apply to personal information handled in connection with employment or business relationships with the Company, such as employees, officers, applicants and contractors.
Personal Information Collected, Used, Disclosed, Sold or Shared by the Company
The categories of personal information that the Company collects or has collected in the past 12 months, the sources of information, purposes of collection and use, and whether the information is disclosed for a business purpose, sold or shared are as follows. The personal information actually collected varies depending on the status of the Campaign.
Categories of Personal Information Collected or to Be Collected Whether Collected：
Identifiers (Social media display name/username, full name, address, name to be printed on trophies, Google account name) Personal information contained in California customer records (name, telephone number, name to be printed on trophies, inquiry content) Audio, electronic, visual and similar information (entry date, Google account profile image, inquiry content)
Whether Collected / Categories of Sources
Collected directly from you; collected from external services or third parties
Collected directly from you
Collected directly from you; collected from external services or third parties
Purposes of Collection and Use
Operation of the Campaign, selection of winners, communication regarding the Campaign, production and shipping of prizes, publication on the official website, etc., responding to inquiries, investigation and prevention of violations of terms, service improvement, and development of reprojects, and measurement of effectiveness and statistical understanding of campaigns Communication regarding the Campaign, production, and shipping of prizes Operation of the Campaign, responding to inquiries
Whether Disclosed for a Business Purpose, Sold or Shared / Categories of Recipients, Purchasers or Third Parties with Whom Shared
Disclosure for business purposes: Company group companies, service providers, third parties permitted by law
Sale: None
Sharing: None
Disclosure for business purposes: Company group companies, service providers, customer support providers, third parties permitted by law
Sale: None
Sharing: None
Disclosure for business purposes: Company group companies, service providers, customer support providers, third parties permitted by law
Sale: None
Sharing: None
At present, the Company does not collect Characteristics of protected classifications, Commercial information, internet or other electronic network activity information, biometric information, professional or employment-related information, education information, GPS information or other precise location information of customers, inferences, Sensitive personal information. If the Company collects new categories of personal information in the future, the Company will provide necessary notice in accordance with applicable law.
The Company may use or disclose information that has been anonymized or statistically processed so that individuals cannot be identified, for service improvement, analysis, research, marketing and other purposes permitted by applicable law. Such information does not identify individuals. When using, disclosing or otherwise processing de-identified or anonymized information, the Company will maintain and use such information in a non-identifiable form and will not re-identify individuals except in accordance with applicable law.
Sale and Sharing of Personal Information
The Company does not sell and share your personal information to third parties for monetary consideration in connection with the Campaign.
Retention Period for Personal Information
The Company deletes your personal information when it is no longer necessary to achieve the purposes of processing described in "Handling of Personal Data" in the Common Provisions above, in accordance with the retention periods set out in "Management Policy" in the Common Provisions above.
Specifically, will be retained for 5 months after the Campaign begins. Information obtained based on your consent will be deleted when the consent is withdrawn. However, where necessary to comply with applicable laws and regulations, respond to orders from governments, courts or other supervisory authorities, handle disputes, protect rights, or investigate or prevent unauthorized use, the Company may retain such information for the necessary period after implementing security control measures.
Rights of California Residents
Customers residing in California have the following rights under the CCPA, subject to certain restrictions and exceptions.
(1) Right to Know and Right of Access
You have the right to request disclosure of the following matters concerning your personal information collected, used, disclosed, sold or shared by the Company.
・Categories of personal information collected by the Company
・Categories of sources of such personal information
・Business or commercial purposes for collecting, using, selling or sharing such personal information
・Categories of recipients, purchasers or third parties with whom such personal information is shared
・Specific pieces of personal information collected by the Company
(2) Right to Deletion
You have the right to request deletion of your personal information collected or held by the Company. However, the Company may refuse a deletion request where permitted by the CCPA, such as for compliance with laws and regulations, ensuring security, preventing unauthorized use, completing transactions, providing services requested by you, protecting rights or other purposes.
(3) Right to Correction
You have the right to request correction of inaccurate personal information concerning you that is held by the Company.
(4) Right to Opt Out of Sale or Sharing
※The Company does not sell or share your personal information in the Campaign.
(5) Right to Limit the Use and Disclosure of Sensitive Personal Information
※The Company does not collect, use, or disclose Sensitive Personal Information in the Campaign.
(6) Right Not to Be Discriminated Against or Retaliated Against
You have the right not to be subject to discriminatory or retaliatory treatment prohibited by the CCPA, such as refusal to provide goods or services, application of different prices or rates, or provision of a different quality of service, on the grounds that you exercised rights under the CCPA.
How to Exercise Rights
If California residents wish to exercise the right to know (right of access), right to deletion or right to correction, they may submit a request through the contact point described in "Contact" in the Common Provisions above provided by the Company.
The Company verifies identity for requests concerning the right to know (right of access), right to correction or right to deletion under the CCPA. In verifying identity, the Company may compare information provided by you with information contained in the Company's records. You may be asked to cooperate with procedures that the Company reasonably considers necessary, such as providing necessary information to the contact point above.
The Company may request additional information where necessary to confirm or process a request. If the Company cannot sufficiently verify a request, the Company will notify the requester accordingly and respond in accordance with applicable law. The Company may refuse to respond to a request unless you or your authorized agent provides sufficient information to reasonably verify that the request concerns your personal information.
Depending on the content of the request, the Company may ask you to provide to respond to the request. The Company uses information obtained for identity verification only for identity verification and responding to the request.
You may exercise the rights set out in this Notice through an authorized agent permitted under the CCPA. In such case, the Company may request proof that the agent is a business registered to conduct business in California, written authorization or a valid power of attorney showing that the agent has authority to make the request on your behalf, and information necessary to verify your identity or the agent's authority.
Financial Incentives
At present, the Company does not provide any program that constitutes a financial incentive under the CCPA. If the Company provides such a program in the future, the Company will provide necessary notice in accordance with applicable law.
Changes to this Notice
The Company may amend this Notice from time to time in response to changes in the Company's handling of personal information, applicable laws and regulations or the content of the Campaign. If the Company makes material changes, it will notify you on the Company's website or by other appropriate means.
Contact
For inquiries regarding this Notice, the Company's handling of personal information or the exercise of rights under the CCPA, please contact the contact point described in "Contact" in the Common Provisions above.
Date of Establishment: July 07, 2026