Privacy Policy

Who this Privacy Policy applies to

This Privacy Policy applies to the handling of personal data, as defined in Article 4(1) of the GDPR, of customers who use our services from the European Union, Iceland, Liechtenstein or Norway (collectively, the “EU”).

Personal data we collect

We may collect the following personal data:

• Name, including nicknames and pseudonyms
• Age or date of birth
• Gender
• Occupation, employment history and education
• Email address
• Telephone number
• Address
• Photographs and videos
• Information relating to payment methods, including credit cards, bank accounts and electronic money
• IDs used with external services and information the customer permits those services to disclose under their privacy settings
• Identifiers generated through cookies
• Information about the customer’s operating system and device, including OS-generated IDs, device type and device identifiers
• Activity on our website, including time spent, input history and purchase history
• Usage of our applications, including launch times, input history and purchase history
• Location data

Purposes and legal bases for processing

We process personal data on the basis of legitimate interests, performance of a contract, the customer’s consent, or compliance with legal obligations under EU or Member State law.

Where processing is necessary for our legitimate interests

• To accept service registrations and verify or authenticate customers
• To manage service usage history
• To analyse service activity and maintain or improve our services
• To conduct market analysis and marketing
• To provide information about our services
• To respond to violations of our terms or applicable law
• To notify customers of changes to our terms
• To otherwise provide, maintain, protect and improve our services

Where processing is necessary to perform a contract

• To process payments
• To notify customers of changes, suspension, termination or cancellation of services
• To respond to inquiries

Where the customer has given prior consent

Where processing is necessary to comply with EU or Member State law

• To respond to conduct that violates EU or Member State law

Transfer of personal data to Japan

We transfer personal data to Japan where necessary to perform a contract with the customer or to take steps requested by the customer before entering into a contract. Japan has received an adequacy decision from the European Commission regarding the protection of personal data.

Retention period

We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy. Specific retention periods are determined by considering the purpose of collection and processing, the nature of the data, and applicable legal and business requirements.

Your rights

Under the GDPR, customers have the right to obtain information about the processing of their personal data, access their data, request rectification or erasure, restrict processing, exercise data portability, not be subject to automated decision-making including profiling, and object to processing. Customers may also lodge a complaint with the supervisory authority in the Member State of their residence, place of work or the place of the alleged GDPR infringement.

Withdrawal of consent

Customers may withdraw their consent at any time by the method separately specified when consent is obtained. Withdrawal does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

Automated decision-making

We do not make decisions based solely on automated processing that produce legal effects or similarly significant effects for customers.

Changes to this Privacy Policy

We may amend this Privacy Policy as necessary. When we do so, we will communicate the effective date and content of the revised policy by an appropriate method.

Contact

For questions about this Privacy Policy, please use our contact form.