Privacy Policy

This Privacy Policy stipulates how Preferred Networks, Inc., (hereinafter referred to as the “Company”) and its Subsidiaries*1 (together with the Company referred to as the “Companies”) will acquire and manage Personal Data (as defined below) and other information.*2,*6

1. Definition

The terms used in this policy shall have the following meanings.

[1] “Personal Data” shall mean any information related to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

[2] “Subsidiaries” shall mean subsidiary companies as set forth in Article 2, item 3, of the Japanese Company Law (Law No. 86 of 2005); provided, however, that if this Privacy Policy separately specifies the Subsidiaries to which this Privacy Policy applies, that specification shall take precedence.

[3] “Individual Service” shall mean, individually or collectively, the services provided by the Company; provided that when referring to a specific Individual Service, it may be referred to as the “Service”.

[4] “User Information” shall mean the Personal Data of the users of websites provided by the Company or Individual Service, history information on communication services, and other information generated or stored on the users’ smartphones, PCs, or other devices in relation to the users or the users’ devices.

2. Basic policy concerning the protection of Personal Data

All of the Companies’ executive officers and employees understand the importance of Personal Data obtained through their business activities and will seek to properly handle and protect the Personal Data while taking the utmost preventative measures to protect it against or from unauthorized access, loss, or leakage and will strive to safely manage the Personal Data.

3. Acquisition of Personal Data

Companies will obtain your Personal Data by legitimate and fair means. Furthermore, Companies will not receive Personal Data and any data that includes your Personal Data from a third party without confirming the legality of the data acquisition and data provision by the third party.

4. Personal Data to be acquired and purpose of use

Personal Data (hereinafter in this Section 4, including “User Information”), which Companies may acquire, and its purpose of use are as stated below. Companies will use Personal Data acquired by the Companies for and within the purpose of use, and only to the extent necessary to perform the Companies’ research, development, and other business activities. Companies will not use Personal Data for other purposes without obtaining your permission in advance. The Personal Data acquired by the Company may be used in combination with the Personal Data already held or the Personal Data separately acquired from a third party, such as a service contractor.

In addition, the Company will protect the Personal Data of minors in the same way as those of adults. Please note that for Individual Services available to minors, the Company may obtain the consent of parents regarding the acquisition of the Personal Data of minors as necessary to provide Individual Services.

4.1 General

 

(1) Hiring
Object: The Personal Data you provide when applying through the hiring section of Company websites.
Purpose of Use: The Company’s hiring purposes.

(2) Inquiry
Object: The Personal Data you provide when contacting Companies.
Purpose of Use: For correspondence and to reply to your inquiry.

(3) Presentations, Lectures, and Events
Object: Videos, images, or other data recorded by Companies at presentations, lectures, and events.
Purpose of Use: Companies may publish videos, images, or other data above as materials for other presentations, lectures, and events and on the websites managed by Companies (hereinafter referred to as “Company websites”), social media, or other media for purposes, such as introducing Company businesses. Companies may also use such recorded data for their research and development activities.

(4) Public Information
Object: Personal Data collected by Companies from publicly disclosed information.
Purpose of Use: Companies may use such information for their research and development activities.

(5) Joint Business, Joint Research, and Joint Development
Object: Personal Data that Companies collect on joint business, joint research, and joint development projects with partners.
Purpose of Use: Companies may use such information for those joint business, joint research, and joint development projects above, and may also use such information for their business, research, and development activities.
Companies maintain and use the Personal Data, which is provided by partners in joint business, joint research, and joint development projects, on contracts in accordance with the contract terms.

(6) Websites provided by Company / Individual Service
Object: The Company will obtain or may obtain in the future the following information in order to provide websites operated by the Company and/or Individual Service.

 

[1] Information required to provide our websites and/or Individual Service
・ Email address, Username, and other information to be entered by the user in the input form designated by the Company on the Service
・ Information to be entered by the user when using our websites and/or Individual Service
・ History information of using our websites and/or Individual Service
・ Information provided when using our websites and/or Individual Service through feedback forms, email, or other means.

[2] Information when visiting our websites and/or Individual Service (access logs)
・ Date, time, and IP address*3
・ Cookies*4 (Only Cookies that are required for the operation of the websites and/or Individual Service; provided that, however, other cookies will be included only if users agree. Please also refer to Section 6 “Handling of Cookies etc.”)
・ Terminal information and other usage environments
・ History information of using our websites and/or Individual Service or other information about the status of users

Users shall have the right to withdraw consent at any time, provided that, however, please note that the Company may be unable to provide the Service unless users provide the above User Information.

Purpose of Use: The Company may use and process the acquired User Information above for the following purposes.

 

・ For the purpose of providing our websites and/or Individual Service*7
・ To debug, improve, optimize, or further develop our websites and/or Individual Service*8
・ To perform analytics and statistics of the use of our websites and/or Individual Service*8
・ To prevent potential violation of laws, regulations, or rules*8
・ To enforce our rights or the rights of users of our websites and/or Individual Service *8
・ To ensure the proper functionality and security of our websites and/or Individual Service *8
・ To contact users for the purpose of seeking their feedback related to the use of our websites and/or Individual Service *9
・ To develop new services*9
・ To grasp the distribution status of advertisements, measure advertising effects, and display behavioral targeting advertisements*9
・ To describe the Company services, products, promotions, campaigns, and events*9

(7) Others
In addition to the above, Companies will obtain Personal Data that are needed for Companies’ research, development, and other business activities by legitimate and fair means. Companies will use Personal Data for and within the purpose of use reported at the time of acquisition and only to the extent necessary to perform the Companies’ research, development, and other business activities.

4.2 Individual Services

(1) Crypko(https://crypko.ai/

Object: The Company will obtain the following User Information in order to provide the Service.

 

[1] Information required to provide the Service
・ Email address, Username, and other information to be entered by the user in the input form designated by the Company on the Service
・ Identification information for logging in to the Service
・ History information on the Content (languages, images, videos, and other information that are accessible through the Service), information on the usage status of the character generation function and other functions provided in the Service, and history information of using the Service.
・ Information set by the user on the setting section of the Service (including information entered by the user in the profile section and other sections of the Service)
・ Information to be entered in the comment field and other fields of non-public assets (referring to a character, image, or other product created by using the Service, which is not made open to the public by the user) held by the user through the Service
・ Information provided when using the Service through feedback forms, email, or other means.
Users can provide consent to the acquisition of User Information by the Company when creating the user ID required to use the Service.

[2] Information when visiting the website related to the Service (access logs)
・ Date, time, IP address, and method of using the website
・ Cookies (Only Cookies that are required for the operation of the website and/or Individual Service provided that, however, other cookies will be included only if users agree. Please also refer to Section 6 “Handling of Cookies etc.”)
・ Terminal information and other usage environments
・ History information on the Service or other information about the status of users

[3] Information obtained from a third party when cooperating with a service provided by such third party
・ ID used by a user in a third-party service
・ Other information users have authorized to be disclosed to the Company

Users can provide consent for the acquisition of User Information by the Company through coordinating with the service provided by the third party. Please refer to the terms of use and privacy policy established by the third party regarding the management of the various information and data by such third party.

Users shall have the right to withdraw consent at any time, provided that, however, please note that Company may be unable to provide the Service unless users provide the above User Information.

Purpose of Use: The Company may use and process the acquired User Information for the following purposes.

 

・ For the purpose of providing the Service*7
・ For identity authentication during or after logging in when using the Service*7
・ To announce information on the content of the Service, update information, and provide information regarding changes to the rules*7
・ To contact users to answer inquiries or forward any requested information*7
・ To debug, improve, optimize, or further develop the Service*8
・ To perform analytics and statistics of the usage of the Service*8
・ To make a payment regarding the Service*7
・ To prevent potential violations of laws, regulations, or rules*8
・ To enforce our rights or the rights of users of the Company services*8
・ To ensure the proper functionality and security of the Company services*8
・ To describe Company services, products, promotions, campaigns, and events*9
・ To contact users for the purpose of seeking their feedback related to the use of services provided by the Company*9
・ To develop new services*9
・ To grasp the distribution status of advertisements, measure advertising effects, and display behavioral targeting advertisements*9

(2) Playgram Typing(https://typing.playgram.jp/

Object: Company will obtain the following User Information in order to provide the Service.

 

[1] Information required to provide the Service
・ Email address, Username, and other information to be entered by the user in the input form designated by the Company on the Service
・ Identification information for logging in to the Service
・ Information to be entered by the user when using the Service
・ History information of using the Service
・ Information provided when using the Service through feedback forms, email, or other means.

Users can provide consent to the acquisition of User Information by the Company when creating the user ID required to use the Service.

[2] Information when visiting the website related to the Service (access logs)
・ Date, time, IP address, and method of using the website
・ Cookies (Only Cookies that are required for the operation of the website and/or Individual Service; provided that, however, other cookies will be included only if users agree. Please also refer to Section 6 “Handling of Cookies etc.”)
・ Terminal information and other usage environments
・ History information on the Service or other information about the status of users

[3] Information obtained from a third party when cooperating with a service provided by such third party
・ ID used by a user for a third-party service
・ Other information users have authorized to be disclosed to the Company

Users can provide consent to the acquisition of User Information by the Company through coordinating with the service provided by the third party. Please refer to the terms of use and privacy policy established by the third party regarding the management of the various information and data by such third party.

Users shall have the right to withdraw consent at any time, provided that, however, please note that the Company may be unable to provide the Service unless users provide the above User Information.

Purpose of Use: The Company may use and process the acquired User Information for the following purposes.

 

・ For the purpose of providing the Service*7
・ For identity authentication during or after logging in when using the Service*7
・ To announce information on the content of the Service, update information, and provide information regarding changes to the rules*7
・ To contact users to answer inquiries or forward any requested information*7
・ To debug, improve, optimize, or further develop the Service*8
・ To perform analytics and statistics of the usage of the Service*8
・ To make a payment regarding the Service*7
・ To prevent potential violations of laws, regulations, or rules*8
・ To enforce our rights or the rights of users of Company services*8
・ To ensure the proper functionality and security of Company services*8
・ To describe Company services, products, promotions, campaigns, and events*9
・ To contact users for the purpose of seeking their feedback related to the use of services provided by the Company*9
・ To develop new services*9
・ To grasp the distribution status of advertisements, measure advertising effects, and display behavioral targeting advertisements*9

5. Provision to third parties

5.1 Provision of Personal Data to third parties

The Companies may provide your Personal Data possessed by Companies to a third party in those cases set forth in the following:
[1] Cases based on laws and regulations
[2] Cases in which there is a need to protect a human life, body, or property, and when it is difficult to obtain your consent
[3] Cases in which there is a special need to enhance public hygiene or promote the fostering of healthy children, and when it is difficult to obtain your consent
[4] Cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing duties prescribed by laws and regulations, and when there is a possibility that obtaining your consent would interfere with the performance of the said duties
[5] Cases where Companies obtained your consent

5.2 Contractor

Companies may outsource the processing (including data analysis, e-mailing, hosting, and other cloud services; the same shall apply hereinafter) of each acquired information listed in Section 4 Personal Data to be acquired and purpose of use (hereinafter referred to as the “Acquired Information”) to a third party when required to conduct its business or provide Individual Services. Companies may provide the Acquired Information to the contractor with regard to such consignment (including the storing of Acquired Information on various cloud services).

Companies will select contractors after confirming that the security level of Personal Data is sufficient when consigning the processing of the Acquired Information to a third party. Companies will provide the necessary and appropriate supervision through contracts and other methods with regard to such consignment.

In addition, in linking to a Twitter account, Facebook account, Google account, and other external services, Companies may, with the consent of the user, provide the Acquired Information to third parties that operate such external services.

In the event of the reorganization, merger, or transfer of business, Companies may transfer all or part of the Acquired Information to the third parties concerned.

6. Handling of Cookies etc.

6.1 Use of Cookies, Web Beacon*5 and IP address

Companies may use Cookies, Web Beacons, and IP addresses on websites provided by Companies for the following purposes:

a. To identify the cause of an incident or problem that occurs on a server and solve it.
b. To improve the contents of websites, emails, and others
c. To customize the contents of websites, emails, and others for individual users
d. To use the information for statistics in a way that cannot identify an individual

You can reject the use of Cookies and Web Beacons by Companies by blocking Cookies in your Internet browser settings. This may, however, cause some restrictions (e.g., some functions, such as customization, may become unavailable)

6.2 Information Collection / Analysis modules

(1) Google Analytics

Several websites provided by Companies use Google Analytics to identify user’s usage of the websites. Google Analytics uses Cookies to collect information to report user information and interest categories. Users can disable Google Analytics at any time by downloading and installing a browser plug-in through the following link:

  1. https://tools.google.com/dlpage/gaoptout?hl=en

For more information about Google Analytics, please visit the following Google web page:

  1. https://www.google.com/analytics/terms/
    https://support.google.com/analytics/answer/6004245?hl=en

Users shall have the right to withdraw consent at any time.※9
In the event of the reorganization, merger, or transfer of business, the Company may transfer all or part of the information to the third parties concerned.

(2) Others

In addition, the various services provided by other companies to prevent unauthorized use of input forms and antispam measures and various information collection / analysis modules are used by several websites and the Individual Services provided by Companies. Please refer to the information below for specific details. This content may change from time to time.

List of Information Collection / Analysis Modules etc.

In the event of the reorganization, merger, or transfer of business, the Company may transfer all or part of the information to the third parties concerned.

7. Information to be entered through payment using a credit card etc.

Users may be able to make payment using a credit card, debit card, and other electronic payment method in the Individual Service provided by Companies. Companies will not acquire the information regarding the payment method (including, but not limited to all digits of the credit card number) entered at the time of payment. The payment agent will acquire such information directly from users and will register them. Companies may change the payment agent in order to ensure a safe payment environment for users in such case when a fraudulent payment occurs in relation to the Service. In this case, for the purpose of ensuring an environment in which the user can continue to use a credit card, debit card, and other electronic payment method for payment, the information regarding the payment method acquired from the user by the payment agent specified in the preceding paragraph may be provided to the new payment agent.

8. Shared use of Personal Data

Companies will share and use Personal Data that they possess reciprocally.

(1)General

[1] The type of Personal Data that will be jointly used:
Personal Data you provide when submitting a job application form via the hiring page.
[2] Parties who will jointly use your personal data:
Company and its Subsidiaries
[3] Purpose of use:
For hiring activities of the Companies
[4] Parties who assume the responsibility to manage your shared Personal Data:
Company

(2) Individual Service

[1] The type of Personal Data that will be jointly used:
User Information acquired through Playgram Typing and Playgram Trial (https://webgl-trial-version.playgram.jp/), which are carried out in Japan.
[2] Parties who will jointly use your personal data:
Company, K.K. Yaruki Switch Group, K.K. YP Switch
[3] Purpose of use:
For the improvement of the quality of the Service based on learning guidance, and examination and improvement of learning support methods
[4] Parties who assume the responsibility to manage your shared Personal Data:
Company

9. Storage and records of processing activities/h2>

Companies will safely store the Personal Data collected by Companies or received from an entrusting party under strict control. Companies will appoint a chief privacy officer within the Company and designate a handler for each dataset that contains Personal Data and properly manage it.

Companies maintain records of the processing activities of Personal Data. In these records, Companies reflect the information necessary in order to cooperate with the privacy supervisory authorities in each country.

10. Security measures

With regard to the measures necessary to protect your Personal Data, Companies will provide training regarding Personal Data protection to all employees, require security software to be installed on all PCs used for their businesses, draw up PC security guidelines, and regularly check the state of compliance with the guidelines for safe management of your Personal Data. The Company processes Personal Data in a manner that ensures the appropriate level of security. The Company uses appropriate technical or organizational measures to achieve a certain level of protection according to the risk.

11. Notification of user information breaches to the supervisory authorities

In the case of a security breach resulting from accidental or illegal destruction, loss, modification, unauthorized disclosure, or access of Personal Data, Companies have the mechanisms and policies in place to identify and assess the security breach promptly.
Depending on the outcome of our assessment, Companies will make the requisite notifications to the supervisory authorities and communication to the affected users.

12. Right regarding Personal Data

You have the following rights regarding the Personal Data collected and processed by the Company. To exercise these rights, you may contact the address listed in Section 17 “Contact.” The above provisions shall not apply if Companies are not obliged under applicable laws and regulations. In addition, if it is extremely difficult to meet the demands of users due to processing capacity or technical difficulties, Companies may not respond.

(1) General
[1] Right to demand access (Disclosure of the purposes of the processing, the categories of Personal Data concerned, the recipients or categories of recipient, and the envisaged period for which Personal Data will be stored)
[2] Right to demand corrections
[3] Right to demand erasure
[4] Right to demand restriction of processing
[5] Right to demand data portability and forwarding to enable the use of Personal Data for services provided parties other than Companies
[6] Right to object
[7] Right to revoke any consent you have given at any time
[8] Right to lodge a complaint with a supervisory authority

(2) For California residents
A user, as a resident of the state of California who meets the requirements of CPRA, has the following rights under CPRA concerning Personal Data. In such case, our company will respond to the user’s request for the following rights in accordance with the provisions of CPRA within 45 days.

[1] The right to access information concerning the processing of Personal Data

Users have the right to request disclosure of the following Personal Data that the Company collected in the preceding 12 months.
・ The categories of Personal Data collected by the Company about the user
・ The categories of sources from which Personal Data was collected
・ The purpose of collecting, or selling or sharing Personal Data
・ The categories of third parties to whom Company discloses Personal Data

[2] The right to correct inaccurate user information or delete Personal Data
Users have the right to request the correction of inaccurate Personal Data or deletion of the Personal Data the Company collected from users in accordance with the provisions of CPRA.

[3] The right to opt out of the sale or sharing of user information
Users have the right to request the suspension of the sale or sharing of their Personal Data by the Company or request that the Company not use nor disclose sensitive data.

[4] The right not to be penalized by exercising rights
The Company shall not penalize users nor treat them differently from other users when exercising rights or having exercised the above rights.

13. International Transfer of User Information

Companies may provide Personal Data to third parties located in not only the countries or regions other than the countries stipulated by the rules of the Personal Data Protection Commission as a country that has a Personal Data protection system recognized as being at the same level as Japan (as of last update date of this privacy policy, stipulated countries and regions are the EEA and the UK) but also other countries and regions outside of Japan (hereinafter “other countries and regions outside of Japan” do not include the EEA or the UK).

Countries and regions outside of Japan include the countries and regions listed below:
United States of America, People’s Republic of China, Hong Kong, Republic of Korea, Republic of India, Republic of Singapore, Swiss Confederation, Commonwealth of Australia, and New Zealand

Please refer to the link below for the system regarding the protection of Personal Data in each country or region.

  1. https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku

14. Retention Period of Acquired Information

In accordance with laws and regulations and the operational policy established by Companies, the said Companies will promptly delete the Acquired Information when it is no longer necessary to retain such information, such as when the purpose of use related to the Acquired Information is achieved.

15. Laws and regulations related to Personal Data

Companies will comply with the applicable laws, regulations, this privacy policy, and other codes relevant to acquiring and managing Personal Data.

16. Review and improvement

Companies will review the status of the management of Personal Data from time to time and will continuously improve the management of Personal Data. The Company may revise this privacy policy at its discretion, and you will confirm the updated policy from time to time; provided that, however, if your consent to the revision of this policy is required by laws and regulations, the Company shall obtain the consent in the manner prescribed by Companies. Any amendment to this privacy policy shall enter into force by placing the amended privacy policy on the website operated by the Company as appropriate.

17. Contact

17.1 Personal Information Handling Business Operator

Otemachi Bldg., 1-6-1 Otemachi, Chiyoda-ku, Tokyo
100-0004 Japan
Preferred Networks, Inc.
Chief Executive Officer Toru Nishikawa

17.2 Data Protection Officer

Data Protection Officer
Koji Horie (Attorney at Law)
dpo-office@preferred.jp

17.3 EU Representative

As we are based outside of the EU, Article 27 of the GDPR required that we appoint an EU representative to handle certain data subject requests and queries. In compliance with this, we have appointed DataRep to act as our representative. Any queries requiring the input of our representative, should please be directed to them as follows:

・ Sending an email to DataRep at datarequest@datarep.com quoting “Preferred Networks, Inc.” in the subject line;
・ Using the online webform at http://www.datarep.com/data-request“; or
・ Mailing your request to the following address:

Data Protection Representative Limited
(Company Number: 616588)
12 Northbrook Road, Dublin, Ireland

Please note that if you choose to mail your enquiry, it is essential that you mark your letters for “DataRep” and not “Preferred Networks, Inc.”, or your enquiry may not reach them. Please refer cleanly to Preferred Networks, Inc. in your correspondence.

17.4 Contact Information

Companies have established an internal system to promptly and appropriately address your concerns about the Personal Data that we handle. Please contact us through this contact form
for a request of the disclosure or correction, complaints, or other inquiries concerning your Personal Data possessed by Companies.

*1: Our subsidiary is Preferred Networks America, Inc. (as of April 1, 2021).
*2: We have a separate privacy policy for the acquisition and management of Personal Data of employees of the Companies.
*3: An IP address is an identification number for a computer connected to a server. (The user of the computer cannot be identified.)
*4: Cookies are identification information sent from a server and stored in your browser for efficient website operation.
*5: Web Beacons are used in combination with Cookies to obtain statistics about access to certain Web pages.
*6: This Privacy Policy is written in Japanese, and the Japanese text is the original (https://www.preferred.jp/ja/policy/). If there is any conflict or inconsistency between the Japanese text and the English text, the Japanese text shall prevail.
*7: If you are located in the EEA or the UK, the legal basis for this processing is the performance or execution of a contract as provided under the Applicable Data Protection Law (i.e., Art. 6 para. 1 (b) GDPR).
*8: If you are located in the EEA or the UK, the legal basis for this processing is the legitimate interest as provided under the Applicable Data Protection Law (i.e., Art. 6 para. 1 (f) GDPR). The legitimate interest that the Company pursues is the prevention of fraudulent and illegal activities, the protection of our systems and of our users, the enforcement of our legitimate rights and the rights of our users, and the improvement and optimization of the Company’s services that are to be used for the benefit of users.
*9: If you are located in the EEA or the UK, the legal basis for this processing is the consent of user as provided under the Applicable Data Protection Law (i.e., Art. 6 para. 1 (a) GDPR).

List of Information Collection / Analysis Modules, etc.

Name   Service Provider   Information to be acquired   Use of the information by Service Provider   Website and/or Individual Service
 
Sentry Functional Software Inc. Unique identifier given by the application, terminal information when an error occurs (OS version, model number, memory, screen orientation, remaining battery level, etc.), user information (user ID, affiliated organization, etc.) The acquired information is stored in the server system managed by Functional Software Inc. Functional Software Inc. will use the acquired information within the scope of its purpose of use in accordance with the terms and conditions (https://sentry.io/terms/). Playgram Typing
PlaygramTrial
Crypko
PFN 3D Scan
 
Amplitude Amplitude, Inc. History information on Individual Service or other information about the status of users   The acquired information is stored in the server system managed by Amplitude, Inc. Amplitude, Inc. will use the acquired information within the scope of its purpose of use in accordance with the terms and conditions (https://amplitude.com/terms). Crypko
 
reCAPTCHA Enterprise Google Inc. Data including IP address Google Inc. (“Google”) collects data including IP addresses for Individual Services. In addition, the data entered for this purpose will be used by Google, provided that, however, in the EU or European Economic Area, the IP address will be anonymized in advance, and in the US, the IP address is anonymized after it is sent to Google.
Google will use this information on our behalf to evaluate your use of this Services. The IP address collected by reCAPTCHA Enterprise from your browser will not associated with any other data held by Google. This data collection is under Google’s data protection rules. Please refer to the Google Privacy Policy (https://www.google.com/intl/ja/policies/privacy/) for details.
Crypko

Contact

Contact us here.