Personal Information Protection Statement
PAON DP Inc. (the “Company,” “we,” “us,” or “our”) is engaged in the IT entertainment business, centered on the development and operation of applications and websites for mobile devices, including smartphones and tablets (our “Business Activities”).
We regard the personal information we obtain from customers through our Business Activities, as well as the personal information of our employees, as an extremely important information asset, and we recognize that reliably protecting such information is an important social responsibility.
Accordingly, we will handle personal information obtained through our Business Activities in accordance with the policy set out below, and will fulfill our social responsibility by giving our customers and employees peace of mind regarding the protection of their personal information.
Policy
1. Acquisition, Use, Provision, and Entrustment of Personal Information
Acquisition
- When we acquire personal information through our Business Activities, we will notify the individual of, or publicly announce, the purpose for which the information will be used (the “Purpose of Use”), except as otherwise provided by laws, government guidelines, and other applicable norms (“Laws and Regulations”).
- We will acquire personal information only by lawful and fair means, and only to the extent necessary to achieve the Purpose of Use.
Use
- We will use personal information obtained through our Business Activities only within the scope of the Purpose of Use.
- If it becomes necessary to use personal information for any other purpose, we will obtain the individual’s consent before using it for the new purpose.
Provision
- Except as otherwise provided by Laws and Regulations, we will not provide personal information to any third party without the consent of the individual concerned.
Entrustment
- To the extent necessary to achieve the Purpose of Use, we may entrust all or part of our operations involving the handling of personal information, such as data processing, the running of campaigns or surveys, and product delivery, to outside contractors (“Entrustment”).
- When we do so, we will enter into the necessary contracts with the contractor, limit the personal information entrusted to the minimum necessary to achieve the Purpose of Use, and exercise necessary and appropriate supervision over the contractor.
2. Compliance with Laws and Regulations
- We will keep ourselves informed at all times of the Laws and Regulations applicable to businesses that handle personal information, and will ensure that the employees and business partners engaged in our Business Activities are aware of and comply with them.
3. Security Management of Personal Information
- We will implement thorough security measures for our computers, networks, facilities, and equipment to prevent leakage of personal information.
- We will prepare for events such as disasters and system failures to reliably prevent the loss or destruction of personal information, and will securely store backup data for use in emergencies.
- We will conduct inspections, promptly correct any violations, incidents, or accidents discovered, and take corrective and preventive actions to address vulnerabilities.
- We will provide thorough security training to our employees and business partners.
4. Complaints and Inquiries
- We will respond appropriately and promptly to complaints and inquiries.
5. Continuous Improvement
- Under our personal information protection management system, we will monitor and audit compliance with our internal rules in order to implement this personal information protection policy, strive to identify violations, incidents, accidents, and vulnerabilities, and conduct management reviews. We will reflect the results in our management measures and internal rules, and will continuously improve our personal information protection management system in compliance with Laws and Regulations.
Handling of Customers’ Personal Information
This Privacy Policy, together with the privacy policies, terms of use, and any related rules or guidelines established for each application, website, or service distributed by us (each, a “Service”), applies to your use of the Services.
1. Personal Information We Collect and How We Collect It
(1) Information You Provide Directly
When you register for a Service, we may ask you to provide the following information:
- Your age or date of birth
- Your name, username, or nickname
- Your email address
- Your password and other information needed to verify your identity when accessing your account
- Your user profile (profile image, username or nickname used on the Service, gender, biography, links to your social media profiles, other information you provide as part of your profile, and your user ID)
- Information we have determined to collect within the Service
- Other information about you that we specify
(2) Device Information
When you use the Services on a device (including a mobile device), we may collect device identifiers and IP addresses. We may also collect other information you choose to provide, such as the name associated with your device, device type, phone number, country, and username or email address.
(3) Location Information
If you use the Services on a device and allow us to access your location, we may collect information about your current location.
(4) Payment Information
When you purchase in-game currency or other content, or a license to use such content, within the Services directly from us, we will collect the payment information necessary to process the transaction, such as your billing address and email address. If your purchase is processed by a third-party payment service provider (including but not limited to Apple Inc. and Google LLC), we may obtain the billing and payment information you provided to that provider.
(5) Shipping Information
When you purchase a product through the Services, we will collect the product and shipping information necessary for delivery, such as your address, phone number, and name. If your purchase or shipment is processed by a third-party sales agent, we may obtain the product and shipping information you provided to that agent.
(6) Customer Support Information
When you contact us for support, we may collect and store the contact information you provide (typically, but not limited to, your name and email address), information about your activity on the Services, and your user ID. We may also keep records of our correspondence with you and any information contained in it.
(7) Information About Your Activity
We may collect and store information you provide directly to us when using the Services, as well as information provided through contractors that help us provide the Services. We may also collect information about how you use the Services and how you interact with other users. Most of this information is collected and stored in log files, which are server files that record actions taken on the Services.
(8) Communication Features
If you take part in activities on the Services that involve communicating and sharing content with other users (including text, user profiles, messages, photos, images, audio, video, applications, and other content), we may record and retain such communications.
(9) Cookies and Similar Technologies
When you access the Services, we and service providers acting on our behalf use log files and tracking technologies to collect and analyze information such as cookies, IP addresses, device types, device identifiers, browser types, browser language, referring and exit pages, platform types, number of clicks, domain names, landing pages, pages viewed and the order in which they were viewed, page URLs, time spent on particular pages, Service status, dates and times of activity on the Services, and other technical information. For internal purposes, we may associate this information with your user ID.
We may also use web beacons to determine whether a particular page has been viewed or an email has been opened. In addition, we may use other technologies, such as tracking pixels, to make our advertising more effective, for example by excluding existing customers from certain promotional messages, identifying the source of new installations, or showing you advertisements on other websites.
(10) Information from Linked External Services
If you link your account with an external service, we may collect the ID you use on that service and any other information you have authorized the external service to share with us through its privacy settings.
2. Purposes of Use
We use the personal information you provide for the following purposes:
- To provide our products and services
- For billing and fee calculation
- For identity verification and authentication
- To conduct surveys
- To run sweepstakes and campaigns and to ship prizes
- To administer points programs, including earning and redeeming points
- For system maintenance and troubleshooting
- To send you important notices, such as communications about your purchases and changes to our terms, conditions, and policies
- To deliver advertisements and measure their performance
- For market research, statistics, and other analysis
- To develop and deliver targeted advertisements for our own or third parties’ products and services
- To improve existing services and announce new ones
- To provide technical support and after-sales service, and to respond to your inquiries
- For our recruitment activities
- To perform services entrusted to us by third parties
- To prevent fraudulent or potentially illegal activity and to enforce our Terms of Use
- For other purposes we specify for each Service
3. Providing Personal Information Is Voluntary
You may choose not to provide personal information. Please note, however, that if you do not provide it, you may not be able to use the Services.
4. Sharing and Disclosure to Third Parties
We may share your personal information with third parties in the following cases:
(1) With Your Consent
We may provide your information to third-party companies, organizations, or individuals with your consent.
(2) With Contractors
We may provide personal information to contractors that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting, and customer service, and to contractors that support our marketing activities. All contractors are instructed to keep the information disclosed to them confidential and not to use it for any purpose other than providing services on our behalf.
(3) Linking with External Services
When you link your account with, or sign in through, external services such as Facebook, X (formerly Twitter), or LINE, we may provide your information to the operators of those services.
(4) With Third-Party Advertisers
We may share certain technical information (including IP addresses and device identifiers), statistical information that does not personally identify you, and non-personally identifiable information about your use of the Services with third-party advertisers. You agree that we or third-party advertisers may use such information for customer trend analysis, demographic analysis, web analytics, and interest-based (behavioral) advertising directed at you.
(5) Legal Reasons
We may need to disclose your personal information, within or outside your country of residence, in response to laws, regulations, legal proceedings, or requests from public or governmental authorities.
We may also disclose information about you if we determine that doing so is necessary or appropriate for national security, law enforcement, or other matters of public importance.
In addition, we may disclose information about you if we determine that disclosure is reasonably necessary to enforce our Terms of Use, operate our business, or protect our customers.
(6) Reorganization, Merger, or Business Transfer
In the event of a reorganization, merger, or business transfer, we may transfer all or part of the personal information we hold to the successor entity.
5. Disclosure, Correction, Deletion, and Suspension of Use
You may request disclosure, correction, deletion, or suspension of use of the personal information you have provided to us.
After verifying your identity, we will respond to your request within a reasonable period and to a reasonable extent.
We may decline requests that are unreasonably repetitive, require disproportionate technical effort, risk infringing the privacy of others, are extremely impractical, or are not required under applicable law.
6. Information of Customers Under the Age of 16
We take special care to protect the information of customers under the age of 16.
Customers under the age of 16 must obtain the consent of a parent or legal guardian before providing any personal information.
7. Retention and Disposal
We will dispose of personal information when we reasonably determine that it is no longer necessary for our normal business activities.
Third-Party Sites Linked from the Services
This Privacy Policy applies only to our Services. We are not responsible for the handling of personal information by any third-party websites, services, businesses, or individuals linked from the Services.
Changes to This Privacy Policy
We may revise this Privacy Policy in response to changes in Laws and Regulations. We will notify you of any changes by posting them on the Services for a certain period of time.
If you do not agree to the revised Privacy Policy, please discontinue your use of the Services.
Contact Us
For inquiries about this Privacy Policy or about the handling and disclosure of personal information, please contact:
PAON DP Inc. Personal Information Inquiry Desk
Email: info@paon-dp.com