Protection of personal information

REALITY Studios, Inc. (“the “Company”) recognizes the importance of personal information, views the complete protection of personal information as its social responsibility, and promises to comply with the Act on the Protection of Personal Information, other relevant laws and regulations, guidelines, and the like, and to properly handle the personal information collected from the customers who use the Company’s services and the Company App in accordance with this Policy.

Scope

This Policy will apply to all of the Company’s services provided by the Company. The personal information that will be collected and the purpose of use of such information will be specifically provided for each of the Company’s services in the individual privacy policy for the Company’s service.

Collection

Collection for Company’s services

To manage Company’s services, the Company will clearly state the purpose of use in the privacy policy and collect the personal information required for providing the Company’s services through lawful and fair means.

Collection for Company’s corporate operations

To manage Company’s corporate operations, the Company will collect the personal information regarding contact such as name, email address, address, telephone number for Company’s stockholder management, commercial transaction, response to inquiries, public relations, and human-affairs procedure. In these cases, the Company collect the personal information through lawful and fair means.

Purpose of use

Purpose of use for Company’s services

The Company will only use the collected personal information for improving the quality of the Company’s services, delivering ads, or for any other purpose of use set forth in the privacy policy, and the Company will not use such information for any other purpose without the customer’s consent or in the absence of any law or regulation to the contrary.

Purpose of use for Company’s corporate operations

The Company will only use the collected personal information for Company’s business administration, internal management, stockholder management, commercial transaction, analysis and improvement of our business activities, announcement of our services or events, response to inquiries, contact for our services, public relations, and human-affairs procedure.

The Company will not use for any other purpose without the customer’s consent or in the absence of any law or regulation to the contrary.

Establishment of the basic policy and rules for handling personal information

In order to ensure the proper handling of personal data as an organization, the company have established the basic policy (see “Basic Policy”, etc.).

The company have established rules for handling personal data, including handling methods, responsible persons, and their duties.

Technical and physical security control measures

The company manages access to personal data (limiting access rights to authorized personnel (including measures such as immediately revoking the accounts of employees who have moved or retired) and monitoring access status, managing physical entry controls, etc.).

The company takes security measures to prevent unauthorized access from outside the company (e.g., installation of firewalls) .

Organizational security control measures

In addition to appointing the “Group Personal Information Protection Manager” as the person responsible for personal information management, the company have clearly defined the responsibilities and authority of employees regarding the management of personal information.

Employees (including temporary employees) In addition to supervising employees (including temporary employees), the company has established a system for reporting to the person in charge in the event that a violation of the law or regulations is detected or signs of such a violation are detected.

The company has established internal rules and procedures and ensure that employees comply with them, and conduct appropriate audits of compliance.

Supervision over employees and trustees

For employees, the company obtain written pledges and conduct regular education and training on the management of personal information.

For trustees, the company confirm their information security measures at the time of selection and on a regular basis, and conclude contracts with trustees.

Disclosure to third parties

In the following cases, the Company may disclose personal information to third parties:

• The Company outsources work to a third party to the extent necessary to achieve the purpose of use
• The Company performs a merger, corporate spin-off, transfer of business, or disposes all or some of the Company’s business, assets, or stock (including cases where it is performed in connection with bankruptcy or similar proceedings)
• The Company requests the customer’s consent for the disclosure and the customer gives such consent

However, with regard to any information that has been statistically processed so that individual customers cannot be identified, the Company may use such information for purposes other than those listed above.

Disclosure at the request of a government body, local government, public agency, or the like

In the following cases, the Company may disclose personal information to a public agency or the like:

• Pursuant to laws and regulations (including any laws and regulations outside of the country of residence of the party that will be providing the information)
• Disclosure is necessary to protect a person’s life, body, or property, and it is difficult to obtain the consent of the customer
• It is particularly necessary to improve public health or to promote the healthy development of children, and it is difficult to obtain the consent of the customer
• There is a need to cooperate with the performance of administrative work provided for by law or regulation by a national government body, local government, or a contractor for such body, and obtaining the customer’s consent may interfere with the performance of such administrative work

Joint utilization

The Company may use the provided personal information of suppliers, etc. jointly with GREE Inc. and its group companies and Moguna Inc.

(1) Items of personal information used jointly

• Name
• Birthday
• Street address
• phone number
• mail address
• Transfer account information

(2) Scope of shared users

• GREE Inc. and its group companies and Moguna Inc.
• About the latest situation such as the name of company included in the range of joint use of GREE Inc., please visit GREE Inc.’s homepage

(3) Purpose of jointly using personal information

• For trading partner management

(4) Person in charge of managing personal information to be shared

• GREE, Inc. (The address and name of the corporate representative are posted on the corporate profile of GREE, Inc. )

Information collection module

The Company’s corporate website contains the following information collection modules provided by the following third parties for purposes such as providing the features included in the Company’s corporate website, displaying advertisements, and analyzing usage. With regard to the purpose of use of the information that will be collected or has been collected through such information collection module, please review the privacy policy that has been provided by each company providing an information collection module:

• Google Inc.「Google Analytics」
  https://policies.google.com/privacy?hl=en
  (To analyze the access for the company’s corporate website)

Cookie is a mechanism that stores a small file in the user’s browser from a website where you access. For example, when a user visits the website again, a unique ID on the Cookie file make user identifiable, so that switching the contents of website or advertisement is possible by browser (user).
Google Analytics used on this Company’s corporate website uses cookies to collect traffic data. This traffic data is collected anonymously and is not personally identifiable.
Users can refuse collection by disabling cookies, so please check the settings of your browser.

Request for disclosure, correction, addition, deletion, suspension of use, etc.

If you or your agent makes a request to disclose, correct, delete, or suspend the use of your personal information, 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 contact the “REALITY Studios Customer Information Disclosure and Inquiry Desk” set forth below. Please note, however, that if any personal information required to provide the Company’s services is corrected, deleted, or suspended from use, there may be cases where you will not be able to use all or part of the Company’s services.

Contact information

If you wish to make an inquiry, to discuss, or to file a complaint with regard to the handling of personal information in connection with the Company’s services, please contact the “REALITY Studios Customer Information Disclosure and Inquiry Desk” set forth below:

Customer Information Disclosure and Inquiry Desk

realitystudios@gree.net