1.Privacy Policy
i. Scope
This "Privacy Policy on the Steam Release Early Access" (this Policy) provides for the handling of personal data on the Steam Release Early Access (the Event) provided by WFS, Inc. (the Company). With regard to matters that are not provided for in this Policy, please also review the Basic Policy regarding the Protection of Personal Information.
2. Collection of Personal Data; Purpose of Use
i. List of information that will be collected
The Company may collect the following information from you in connection with the provision of the Event.
<Information to be collected from all participants>
Twitter: User ID, Username
Facebook: Username
Reddit: User ID, Username
Youtube: User ID, Username
Twitch: User ID, Username
<Information to be collected only from prize winners>
Name
Phone number
Address
Survey answers
-Another Eden Game User ID
-Age
-Gender
-Country of Residence
ii. Purpose of use
The Company will use the collected information for the following purposes:
-Operation of the Event
-Communicating with applicants and winners regarding the Event
-Compilation of statistical data
-Service improvement and analysis
-Sending of "Another Eden" Steam access keys to winners
-Delivery of prizes to winners
-Conducting questionnaires to winners
-Rectifying any violations of the Terms of Use
-Handling inquiries
-Providing information to the third parties set forth in "4. Provision to Third parties"
iii. Legal basis
The legal basis for the processing of your personal data is;
-Your consent
-Legitimate interests (to improve and enhance user experience through the Event, to send "Another Eden" Steam access keys and to deliver prizes to winners)
3. Our Policy Regarding Minors
The Event is not intended for children under 13 years of age (In the case that law dictates the age of minors/children to be higher than 13, the law shall take precedent), and we do not knowingly collect or solicit personal data from anyone under the age of 13 or knowingly allow such persons to browse the Event. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or e-mail address. No one under the age of 13 may provide any personal data. In the event that we learn that we have collected personal data from a child under the age of 13, we will delete that data. If you believe that we might have received data from or about a child under the age of 13, please contact us at "Contact information" set forth in "6. Personal Information Inquiry Desk v. person in charge of managing personal information and their contact".
4. Provision to Third Parties
i. Provision to third parties
In the cases set forth in "4. Provision to Third Parties" of the "Basic Policy regarding the Protection of Personal Information", the Company may disclose personal data to third parties inside and outside the country.
ii. Disclosure to third parties outside of the country
When you agree to this Policy, you acknowledge that the collected data set forth in this Policy may be transferred outside of your country or region and that there may be cases where the country or region to which the data is transferred does not have laws or regulations imposing protection obligations that are equal to or greater than the laws and regulations regarding personal data and other privacy protection in your country or region. You agree that the Company will disclose the collected data set forth in this Policy to its parent company, GREE, Inc., and its affiliates as well as its approved subcontractors, media, and/or ad agents located in Japan, or the country other than member states of EEA where the approved subcontractor, media or ad agents establish its hub for the purpose of use set forth in this Policy.
5. Method of notices, announcements, or obtaining consent; method of user involvement
i. Notices and announcements
This Policy is posted and announced on the "Another Eden" official Facebook and Twitter pages. The Company may amend this Policy, and any important changes will be announced on the "Another Eden" official Facebook and Twitter pages. The amended policy will become effective when it is posted on "Another Eden" official Facebook and Twitter pages.
6. Request for disclosure, etc.; inquiries
i. Request for access, rectification, erasure, restriction of processing, object to processing, data portability, etc.
You have the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. With regard to such requests, please review the Company's "6. Personal Information Inquiry Desk v. person in charge of managing personal information and their contact".
You have the right to lodge a complaint with a supervisory authority which governs your habitual residence with respect to processing of your personal data.
ii. Inquiries
If you wish to make an inquiry, to discuss, or to file a complaint with regard to the handling of personal data in connection with the Event, please contact us after reviewing the Company's "6. Personal Information Inquiry Desk v. person in charge of managing personal information and their contact.
iii. Data Protection Officers (DPO)
Company elected the data protection officer is involved, properly and in a timely manner, in all issues which relate to the protection of personal data.
Post: Data Protection Officer
GREE, Inc.
Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku,
Tokyo, Japan
dpo@gree.net
iv. EU Representative
Company appointed the EU Representative as below;
Post: WFS, Inc. EU Representative
PLANET // LEGAL
Neuer Wall 54, 20354 Hamburg, Germany
eu_representative@planit.legal
v. Personal data controller and contacts
WFS, Inc.
Roppongi Hills Mori Tower,
6-10-1 Roppongi, Minato-ku,
Tokyo, Japan
https://www.wfs.games/en-us/privacypolicy.html
7. Administration Policy
i. Amendment of this Privacy Policy
The terms of this Privacy Policy may be revised or amended. Unless otherwise specified by the Company, the revised or amended Privacy Policy will come into effect when it is posted on the "Another Eden" Official Facebook and Twitter pages.
ii. Retention Policy
Except as the case being necessary for the compliance of applicable law, regulation or order by the government, court, or other applicable authority, the personal data will be deleted when the data will be no longer necessary to accomplish the above "Purpose of use".
iii. Other
Please note that if you do not provide the Company with the latest and most accurate information about yourself, we may not be able to provide proper service.
8. Terms for Specific Countries
If you reside in any of the places listed below, the relevant terms shall apply;
United States
This Privacy Notice Section 1 ("California Privacy Notice") supplements and modifies the "Basic Policy regarding the Protection of Personal Information" and the "Privacy Policy" of [WFS, Inc.] (the "Company") and applies solely to the user who resides in United States of America ("consumers" or "you").
i. Your personal information the Company collects
<Information to be collected from all participants>
Twitter: User ID, Username
Facebook: Username
Reddit: User ID, Username
Youtube: User ID, Username
Twitch: User ID, Username
<Information to be collected only from prize winners>
Name
Phone number
Address
Survey answers
-Another Eden Game User ID
-Age
-Gender
-Country of Residence
ii. How the Company collects your personal information
Directly from you: For example, applying for the Event, communicating with the winners
iii. The purpose to collect and sale sell your personal information
(1) The purpose to collect your personal information
-Operation of the Event
-Communicating with applicants and winners regarding the Event
-Preparation of statistical data
-Service improvement and analysis
-Sending of "Another Eden" Steam access keys to winners
-Delivery of prizes to winners
-Conducting questionnaires to winners
-Rectifying any violations of the Terms of Use
-Handling inquiries
-Providing information to the third parties set forth in "4. Provision to Third parties"
(2) The purpose to sell your personal information
Not applicable
iv. Sharing or sales of your personal information
(1) The third-party service provider to provide the service contemplated under the purpose to use your personal information as follows
Not applicable
(2) Company may sell sales your personal information subject to your right to opt-out to those sales
Not applicable
v. Your Rights and Choice
(1) You have the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. With regard to such requests, please review the Company's "6. Personal Information Inquiry Desk v. person in charge of managing personal information and their contact"
(2) Personal Information Sales Opt Out
Not applicable
Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, Company will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include personal information, if necessary to verify your identity and the nature of your request.
Established on: 02/25/2021