Glossom, Inc. (hereinafter "Glossom", the "Company," "we" or "us") has established and provided the following Privacy Policy (hereinafter "this Policy") to explain our users (hereinafter "the Users" or "you") how User Information (defined in the Section 1 of this Policy ) is collected, used, disclosed and protected with respect to your use of apps incorporating the SDK Relating to Action History Communication or Source Code Relating to Action History Communication provided by the Company (collectively, hereinafter "the Software").

What Information the Company Collect from the Users:

The Company may collect the following information from you (hereinafter "User Information"). The User Information you provided enables us to analyze your interests and preferences and to display contents and advertising that are customized to such interests and preferences.

  1. Information to identify User's device:
    1. Information that Glossom automatically retrieves

      ・Device information (IFA, Android ID, Mac address, IMEI/MEID/ESN)

    2. Information to identify Users that developers who include the Software in their products ("Developers") individually set (which will not be independently used by us, but only used to notify Developers under the circumstances that Developers designate)
  2. Information related to User's behavior:
    • Information, including without limitation examples such as the below, which will not identify individuals and which enable us to analyze Users' interests or preferences.
    1. Which advertisement appears to Users, and clicks on or installs of such advertisements

    2. Action history in applications
    3. Purchase history in applications

Name of the Company Collecting and Using User Information:

Glossom, Inc.
Roppongi Hills Cross Point 7F, 6-3-1, Roppongi, Minato-ku, Tokyo 106-0032, Japan

How the Company Collects and Uses User Information:

When you use apps built with the Software on your smart device(s), the Company may automatically request and collect one or more of the categories of information described in the Section 1 above from you. Collected information may be stored in the server used for distributing advertisements and used by the Company in accordance with this Policy.

Purposes of Use of User Information and Provision to Third Parties:

The Company will use any collected User Information by analyzing and/or aggregating information collected from you internally for the following purposes: to improve the quality of our contents, products, services and other offerings to you. However, we take your privacy very seriously and, as such, your information will not be used to identify you personally.The Company will use any collected User Information with information related to User’s behavior collected by GREE, Inc. by analyzing and/or aggregating information collected from you internally under the agreement between the Company and GREE, Inc. We take your information related to your behavior collected by GREE, Inc. under this Policy.

Retention Period of User Information:

The retention period of all User Information collected and held by the Company will be no longer than ten (10) years. Any information exceeding the retention period (that is, information for which the retention period expires) shall be removed from our database permanently and destroyed so that no one can recover it.

You acknowledge that the Company will have no obligation to retain any archived User Information beyond the retention period.

The Users' Rights to Opt-Out:

The Company uses targeted advertising to provide the most accurate and relevant contents and advertising to the Users who have chosen to receive them.

We are committed to providing you with the choice to disable ("opt out" of) receiving such promotional/marketing information from us at any time. If you choose to "opt out," you may do so by following the instructions provided by us. Upon your request to opt out, you will not receive any further communications (targeted advertising) from us.

* For more information on Glossom's "How to opt out receiving targeted advertising," please use "Opt out Application Form"

Transferring of User Information to Third Parties:

  1. Transferring of User Information to Developers :

    In some cases we may share your User Information with Developers. In such cases, the Developers will be required to keep your User Information confidential and secure and limit its use to the purpose for which it is disclosed and shared, in accordance with this Policy as well as JIAA Guideline.

  2. Transferring of User Information to Company Affiliates/Subsidiaries:

    The Company may transfer your User Information to our group companies located inside or outside the country where you live (that is, where the information was originally collected).

How the Company Keeps User Information Secure:

The Company shall take all necessary and appropriate security measures to prevent leakage, loss, damage (including destruction, falsification, etc.) and unauthorized access/use of the retained User Information under strict control and guidelines. The Company shall also make continuous efforts to improve and enhance these measures by assessing their performance.

We take your confidentiality and privacy very seriously. Accordingly, we will appoint a person who is responsible for protection and handling of User Information as "Personal Information Manager" and strive to manage your User Information and policies related thereto properly. (Our Personal Information Manager's contact information is provided at the end of this Policy.)

We will provide all of our staff including senior management and employees with appropriate training and experience designed to help them understand their privacy obligations in relation to your User Information and endeavor to establish and maintain a spirit of compliance with this Policy and Glossom’s handling of User Information throughout the Company.

How to Contact the Company:

Please use Contact Form for any inquiries regarding the contents of this Privacy Policy. If Users wish to contact the Company regarding matters covered by this Policy via post, please contact the Personal Information Manager listed below (and please include the company name, department and address set forth below).

Personal Information Manager:

Tsugumasa Egawa
Managing Director and President
Glossom, Inc.
Roppongi Hills Cross Point 7F
6-3-1 Roppongi, Minato-ku, Tokyo
Japan

* For more information on Glossom's "How to opt out receiving targeted advertising," please use "Opt out Application Form"

Change to This Policy:

The Company may change this Policy at any time and from time to time in our sole discretion to ensure proper and secure handling of User Information, and, unless otherwise specified, such changes shall be effective from the date and time the revised Privacy Policy is posted on this Website.

Other (Language of This Policy):

The Japanese version of this Policy is the original and binding version, and this English version is for reference only. In case of any discrepancy between the Japanese version of this Policy and the English version, the Japanese version shall prevail.

* This Policy was created on September 2, 2013.
* This Policy was revised on July 1, 2015.