1.Introduction

TOMY Company, Ltd., (“we“, “us”, or “our”) provides a mobile application named “BEYBLADE XR Project α Ver.” (the “App”) which enables you to simulate Beyblade experiences on your smartphone. We comply with applicable data protection laws and properly handle your personal information collected with regard to your use of the App and any related services (collectively, the “Services”) pursuant to this Privacy Policy (this “Privacy Policy”).

2.Personal Information We Collect

We collect the following categories of your personal information.

• （１）Information with regard to your use of the Services
  We collect your personal information such as that listed below in relation to your use of our Services:
  • User IDs which we assign to you;
  • Type of Beyblade selected in the App; and
  • Settings and preferences of the Services.
• （２）Personal information automatically collected from your device
  At the time when you are using the App, we automatically collect your personal information such as that listed below from the device that you are using:
  • Internet protocol address and approximate geolocation information based thereon;
  • Log information including access times; and
  • Identifiers such as device IDs.
  
• （３）Others
  We collect other personal information that you voluntarily provide to us such as that listed below:
  • Content of inquiries you make.
  ＜Sensitive Personal Information＞ We do not collect, use or disclose any sensitive personal information, such as information revealing your racial or ethnic origin, religious or philosophical beliefs, precise geolocation, or credit card number in combination with password, in relation to the Services.

３.Purposes of the Collection and Processing of Personal Information

We will collect and process your personal information for the following purposes:

• （１）To provide you with the Services, such as:
  • enabling you to use the Services;
  • managing your settings and preferences of the Services and providing notices on necessary matters;
  • answering your inquiries; and
  • ensuring security.
• （２）To improve the quality of the Services and users’ satisfaction.
  In principle, we will collect and process your personal information within the scope of the purposes set forth above, and when we use your personal information outside the scope of those purposes, we will obtain your prior consent unless otherwise permitted by applicable law.

4.Disclosure and Sale/Sharing of Your Personal Information

We may and have disclosed your personal information to our service providers, such as those providing analytics tools, who process your personal information on our behalf for the purposes described in “3. Purposes of the Collection and Processing of Personal Information” above.
However, we will not sell personal information or share it for cross-context behavioral advertising (i.e., behavioral advertising based on personal information collected across multiple websites, applications, etc.). Also, we have not sold, or shared for cross-context behavioral advertising, any personal information in the preceding twelve (12) months.

5.International Transfer of Personal information

In principle, your personal information is stored within the U.S. or Japan. Please note, however, that, to the extent necessary for the purposes specified in “3. Purposes of the Collection and Processing of Personal Information” above, your personal information may be transferred to and stored in countries/regions outside the U.S. and Japan, and that such country/region may not have the same level of data protection as that provided within the U.S. and Japan. In the course of the international transfer of your personal information, we will take adequate measures to protect your personal information and ensure that related collection and processing of your personal information are in accordance with applicable laws.

6.Data Retention

We retain your personal information to the extent reasonably necessary and proportionate to achieve the purposes stated in “3. Purposes of the Collection and Processing of Personal Information” above. Generally, your personal information will be removed from our database 13 months after we collect it.
We use the Unity Analytics service in the App. If you wish to stop sending personal information to Unity Analytics and delete the personal information already sent, please turn off “Unity Analytics ON/OFF” in the settings screen of the App. From that point onward, the transmission of personal information will be stopped, and the personal information already sent will be deleted within 30 days.

７.Security

We implement reasonable security procedures and practices appropriate to the nature of the personal information in order to protect the personal information from unauthorized or illegal access, destruction, use, modification or disclosure. In the case that we delegate all or part of the processing of personal information to our service providers, we will ensure that the service provider is subject to contractual obligation to implement reasonable security procedures and practices and will appropriately supervise the service provider.

８.Your Rights

You may have certain rights regarding your personal information under applicable data protection laws, which may include the following rights. These rights should be exercised based on and in accordance with applicable data protection laws.

• ■Right to Know, Correct and Delete
  (1) The right to know what personal information we have collected about you, including:
  • The categories of personal information;
  • The categories of sources from which the personal information is collected;
  • The business or commercial purpose for collecting, selling, and sharing personal information;
  • The categories of third parties to whom we disclose personal information; and
  • The specific pieces of your personal information
  (2) The right to delete personal information that we have collected from you
  (3) The right to the correction of inaccurate personal information that we maintain about you
  (4) The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by applicable data protection law
  If you wish to exercise any of the rights under applicable data protection laws, please contact us using the contact information set forth in “10. Contact Information” below.
  As required under applicable law, we will take needed steps to verify your identity before responding to your request. We may require you to provide information, depending on the sensitivity of the information you are requesting and the type of request you are making. If you use an agent to submit a request, we will require the agent to provide us with proof that you gave the agent signed permission to submit the request.


• ■Right to Opt-Out of Sale/Sharing
  If we sell your personal information or share it for cross-context behavioral advertising, you may have the right to opt-out of the sale or sharing of your personal information under applicable laws. However, since we do not engage in such selling or sharing of your personal information, you have no such right.

９.Modification to Privacy Policy

We will review this Privacy Policy as necessary and make continuous improvements from time to time in order to reflect your feedback or to comply with changes in our legal and/or regulatory obligations. When we make important changes to this Privacy Policy, we will notify you of such changes in the App, if required under applicable law, we will obtain your prior consent before implementing such changes.

１０.Contact Information

If you have any questions, comments or requests regarding this Privacy Policy, please contact us at:
TOMY Company, Ltd.
Personal Information Protection Desk
Webform： https://inquiry.takaratomy.co.jp/game_appli/
Email：t2webteam@gmail.com
You can also contact us via the “Contact Us” form on the App.

１１.California Privacy Rights

This section applies only if you are a California resident.

• ■Notice at Collection
  Under the California Consumer Privacy Act (CCPA), you are entitled to certain notice of our practices regarding your personal information. The following is intended to provide you with such notice.
  We may collect your personal information and use it for specific purposes. The categories of personal information that we collect are your identifiers and internet or other electronic network activity information as described in “2. Personal Information We Collect” above. For a list of the purposes for which we use such personal information, please see “3. Purposes of the Collection and Processing of Personal Information” above.
  We do not sell your personal information or share it for cross-context behavioral advertising.
  For the criteria used to determine the period for which we retain your personal information, please see “6. Data Retention”.


• ■Right to Know, Correct and Delete
  Under the CCPA, you have the right to know, correct and delete your personal information as described in “8. Your Rights,” with certain exceptions.


• ■Right to Opt-Out of Sale/Sharing
  With regard to your right to opt-out of sale or sharing of your personal information under the CCPA, please see “8. Your Rights”.


• ■Do Not Track signals
  Some online services have a “Do Not Track” feature that allows you to send a signal to the online service you use indicating that you do not wish to be tracked. Please note that our Services do not currently support “Do Not Track” signals.


• ■Collection of Personally Identifiable Information by Third Parties
  Third parties may not collect “personally identifiable information” about your online activities over time and across different websites when you use the App. Some service providers, however, may collect your personal data on our behalf when you use the App.