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Privacy Policy

Bank of Innovation, Inc. (hereinafter “BOI,” “we,” “our,” or “us”) has established this Privacy Policy (hereinafter “Policy”) for the purpose of specifying how personal information of Users (hereinafter “User,” “Users,” “you”, “their”, or “your”) is handled in every service (hereinafter “Services”) that relates to BOI’s title MementoMori.
If you are a User residing in European Economic Area (“EEA”), then the Privacy Policy for EEA Residents shall apply.

Article 1. The Types of Information BOI Collects and How BOI Collects It

The term “personal information” used in this Policy shall refer to the information regarding a living individual, including information that identifies an individual via the individual’s name, date of birth, and other identifying descriptions, etc., or the individual’s identification code, as stipulated in Article 2, Paragraph 1 of Japan’s governing law regarding the protection of personal information (hereinafter “Act on the Protection of Personal Information”).
Furthermore, the term “individual identification codes” shall refer to the information stipulated in Article 2, Paragraph 2 of the Act on the Protection of Personal Information, which includes passport number, driver’s license number, and social security number.
BOI shall collect personal information appropriately and shall not collect any personal information by deception or other improper means.

Examples of the types of personal information that BOI collects in the Services are detailed below. BOI may not be able to provide any Services, in part or in full, to Users who cannot provide the following information.

Furthermore, all Users under the age of 18 must obtain consent from their legal guardian before providing BOI with their Personal Information.

(1)Information that BOI automatically collects from you when you use the Services.

  • ・Language.
  • ・Email address.
  • ・Any other information, including username, that you provide via the method prescribed by BOI.

(2)Information provided by other services that have been permitted to connect with the Services.

If you permit an outside service, like a social networking service, etc., to connect to the Services as you use the Services, the following information may be provided to BOI.

  • ・User ID of said other services.
  • ・Any other information that you have acknowledged to release to said other services via your privacy settings.

(3)Information that BOI acquires while you use the Services.

BOI may obtain information regarding your access to the Services, or your method of use, which includes the following information.

  • ・Interactions with other Users, including chat messages sent or received by you.
  • ・Device information.
  • ・Log data.
  • ・Cookies and anonymous IDs

(4)If you provide consent via the method prescribed by BOI, we shall obtain the following information from the device you use for the Services.

  • ・Geographic location.

(5)Information provided in connection to inquiries and other forms of communication.

If you send an inquiry to BOI, we may have you provide the following information for the purposes of investigating inquiries and replies, or the verification of your identity.

  • ・Phone number.
  • ・Email address.
  • ・Device information.
  • ・OS information.
  • ・User identification IDs.

(6)Information you provide to BOI in relation to promotional campaigns, etc.

We may have you provide the following information solely for the purposes of questionnaires, promotional campaigns, and any related lotteries, prize shipments, and purchase shipments.

  • ・Full name.
  • ・Shipping address.
  • ・Phone number.
  • ・Gender.
  • ・Date of birth.
  • ・Other information that we determine as necessary.

Apart from everything stipulated in (1) through (6) above, BOI shall not collect any of the sensitive personal information written below. However, this shall not apply should you provide any of the following information on your own volition, or when the acquisition of this information is legally permitted.

  • ・Race and ethnicity.
  • ・Ideology and beliefs.
  • ・Social status.
  • ・Medical history.
  • ・Criminal record.
  • ・Any records that indicate that you were a victim of a crime.
  • ・Any other information defined as sensitive personal information under the Act on the Protection of Personal Information.

NOTE:
The governing laws of this Policy are the laws of Japan, so the language and terminology written in the Japanese version of this Privacy Policy shall take precedence.

Article 2. Intended Use of Personal Information

BOI shall use the personal information acquired from you for the following purposes, goals, and objectives.

  1. (1)For the provision, maintenance, protection, and improvement the Services, including the acceptance of registration for the Services, verification of identity, calculation of usage fees, etc.
  2. (2)For providing guidance and correspondence to inquiries concerning the Services.
  3. (3)For corresponding to any actions that violate our Terms and Conditions Agreement, and other policies, etc., related to the Services.
  4. (4)For ensuring legal compliance.
  5. (5)For conducting questionnaires, monitoring activities, etc., related to the Services.
  6. (6)For creating statistical data, and other marketing purposes related to the use of the Services.
  7. (7)For processing information in a way that does not identify any specific Users for the purpose of creating and providing information for advertising. The username that you register may be made public in marketing, advertising, or promotional videos. In the event that this were to happen, your User information is processed and used as written below.
       
    • ・Excluding individual identification codes, personal information shall be used once identifying descriptions, etc., contained in said personal information are partially deleted. This includes replacing or obscuring any deleted parts of identifying descriptions, etc., with other descriptions, etc., using unregulated methods that can restore or reconstruct said parts of identifying descriptions.
    • ・Individual identification codes shall be used after completely deleting said individual identification codes. This includes replacing or obscuring said individual identification codes with other descriptions, etc., using unregulated methods that can restore or reconstruct said personal identification codes.
  8. (8)For any purpose of use closely associated with any of the purposes of use mentioned above.

When BOI acquires any personal information that is not mentioned above, we shall announce the purpose for collecting and intended use of said information in advance. However, we may not announce the purpose for collecting and intended use of said information in the following cases.

  1. (1)Cases in which notifying a User or disclosing the intended use of said information to the public would potentially endanger or cause harm to a User or a third party's life, body, property, or other rights and interests.
  2. (2)Cases in which notifying a User or disclosing the intended use of said information to the public would potentially harm the rights or legal interests of BOI.
  3. (3)Cases that require cooperation regarding the execution of administrative affairs stipulated by any national or local government institutions, or when notifying a User or disclosing the intended use of information to the public would interfere with the execution of the said administrative affairs.
  4. (4)Cases in which it is acknowledged that the intended use of information is clear, judging from the circumstances that said information is acquired.

Article 3. Provision of Information

When BOI uses information collection modules or advertising distribution tools, etc., we may provide the following User information to third parties. However, any information that specifically identifies individuals will not be provided to any third parties.

  1. (1)User identification IDs.
  2. (2)Device information.
  3. (3)Purchase information.
  4. (4)Log data.
  5. (5)Advertisement data.
  6. (6)Performance data.

Article 4. Restrictions on the Provision of Information to Third-Party Affiliates

BOI shall not provide any personal information (hereinafter “Personal Data”) organized in personal information databases, etc., (a collective body of information which comprises of personal information stipulated in Article 2, Paragraph 4 of the Act on the Protection of Personal Information, systematically structured so that specific personal information can be searched for using a computer. This can also refer to a collective body of information which comprises of personal information organized in accordance to standardized rules and regulations, systematically structured so that specific personal information can be easily searched for; tables of contents; indexes; and other items which possess the functionality to easily facilitate searches) to any third-party affiliates, except for the following cases.
When providing Personal Data to a third party, we shall keep a record in accordance with the Act on the Protection of Personal Information and the rules and regulations stipulated by the Personal Information Protection Commission regarding the dates which any applicable Personal Data was provided, the names or appellations of all concerned third parties, and other matters prescribed by the rules and regulations of the Personal Information Protection Commission.
Furthermore, when BOI is provided with Personal Data from a third party, we shall keep a record in accordance with the Act on the Protection of Personal Information, and rules and regulations stipulated by the Personal Information Protection Commission regarding the names or appellations of all concerned third parties, as well as any concerned third party’s addresses, and, should the third party be a corporate entity, the name of its representative, and the confirmation of the details of the circumstances under which all applicable Personal Data was acquired.

  1. (1)Cases in which a User consents to provide their Personal Data in advance.
  2. (2)Cases based on laws and regulations.
  3. (3)Cases in which providing Personal Data is necessary to protect an individual’s life, body or property, as well as cases in which obtaining a User's consent is difficult.
  4. (4)Cases in which we entrust the handling of the Personal Data, in part or in full, within the necessary scope to achieve our intentions for use.
  5. (5)Cases of business succession due to a merger or other means.
  6. (6)Cases that require cooperation regarding the execution of administrative affairs stipulated by any national or local government institutions, or any individual or party commissioned by said institutions, as well as cases in which obtaining a User’s consent would interfere with the execution of said administrative affairs

Article 5. Joint Use of Personal Information

BOI may share your personal information with other business entities which we are cooperating with to provide the Services. In such cases, BOI shall jointly use your personal information after informing you in advance regarding the content, as well as the items in the jointly used personal data; the scope in which the other business entity can use your personal information; the other business entities’ intended use for your personal information, as well as the names or appellations of parties responsible for managing your personal data. Alternatively, BOI shall notify you in a way that is easily accessible and understandable before jointly using your personal information.

Article 6. Disclosing Personal Information

When you request that your personal data be disclosed to you based on the provisions stipulated in the Act on the Protection of Personal Information, after verifying that the demand is from you by confirming your name, date of birth, address, user identification ID, etc., BOI shall disclose all your personal data to you without delay. Furthermore, should your personal data not exist, we shall notify you appropriately. However, this shall not apply to cases in which we do not bear responsibility for disclosing personal information according to the Act on the Protection of Personal Information and other applicable laws and regulations.

If you request us to disclose your personal data to you as described above, please do not hesitate to contact us using the contact details written in Article 10 below. Please note that in order to disclose your personal information, we may charge a handling fee due to postage charges and other expenses. We shall notify you about the fee separately.

Article 7. Revisions to and Cessation of Use of Personal Information

If (1) you request BOI to revise your personal data based on the provisions stipulated in the Act on the Protection of Personal Information due to your personal data not being factual; or (2) request BOI to cease using your personal data based on the provisions stipulated in the Act on the Protection of Personal Information due to your personal data being handled beyond the intended scope of use as previously announced, or being acquired by deceit or other improper means; or (3) request BOI to cease providing your personal data to a third party based on the provisions stipulated in the Act on the Protection of Personal Information due to your personal data being provided to a third party without proper rationale; after verifying that the demand is from you by confirming your name, date of birth, address, user identification ID, etc., BOI shall conduct all necessary investigations without delay, and notify you regarding the result of the investigations as well as how BOI will handle your request. Furthermore, if BOI decides to not revise your personal data, or cease using or providing your personal data based on proper rationale, BOI shall inform you appropriately.
If you request BOI to delete your personal information, and BOI determines it necessary to correspond to your request, BOI shall delete your personal information after verifying that the demand is from you by confirming your name, date of birth, address, user identification ID, etc.

If you request your personal data to be revised or ceased being used, please do not hesitate to contact us using the contact details written in Article 10 below.

Article 8. Management System

BOI shall conduct lawful and fair management of all personal information. Additionally, BOI shall exercise appropriate supervision over all company officers and employees to ensure that all personal information is securely protected.

All the personal information we utilize is stored in Japan to achieve every purpose, goal, and objective written in this Policy.

We shall retain all User information we acquire for as long as is reasonably necessary in the interest of every purpose, goal, and objective stipulated in this Policy.

If a User has consented to allow their information to be handled, then the User possesses the right to revoke their consent at any time, provided, however, that the revocation of consent does not obstruct the lawfulness of any processing that is based on the User’s initial provision of consent.

Article 9. Supervision over Trustees

If BOI entrusts the handling of personal information, in part or in full, to a trustee, we shall form a non-disclosure agreement (NDA) with the trustee, and exercise the necessary and appropriate supervision over the trustee to ensure that all Users’ personal data is securely protected.

Article 10. Contact Us

If you have any questions, comments, concerns, or inquiries regarding the handling of your personal information, please do not hesitate to contact us by using any of the forms of contact written below.

Email us at: support@mememori-game.com
Write to us at:
Attn: Personal Information Inquiries
Bank of Innovation, Inc.
Shinjuku Eastside Square 3F
6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan

Article 11. Changes, Amendments, and Revisions to this Privacy Policy

We shall appropriately review every situation of application regarding the handling of personal information, strive for continuous improvement, and thus may change this Policy as necessary. If we make any significant changes to this Policy, we shall notify Users of the changes in a way that is easy to understand. Additionally, if we make any changes that require the consent of the User, we shall obtain the User’s consent via the method that BOI will prescribe separately.

NOTE:
This English translation is provided for reference purposes only.
In the event that a part of the translated version of this Policy conflicts with the original Japanese version, the original Japanese version shall take precedence.

Last Updated: August 1st, 2021

Privacy Policy for EEA Residents

This Privacy Policy (the “Policy”) explains the way of treating the Personal Data which is provided or collected while using MementoMori service (the “Service”) operated by BANK OF INNOVATION (the “Company”).

The Company is the controller of the Personal Data provided or collected in the course of using the Service. The Company treats the Personal Data of the users as important, hence, through the Policy informs the users of the purpose and method of the Company’s using the Personal Data provided by them and the measures taken by the Company for protection of those Personal Data.

1. What data do we collect?

The Personal Data concerns any information concerning an identified or identifiable natural person that is processed by the Company. The Personal Data the users are requested to provide may be necessary to provide the users with the Service. Therefore, when a user rejects to provide such data, the user may not be able to use the Service.

(1) Data directly provided by the users when signing up the Service

The following Personal Data may be provided when signing up the Service.

  • ・Language in use, email address, Name, birth date, the User’s ID(which includes ID of the Service, IDFA and Advertising ID), national information, any other data the users directly fill in the form provided by the Company
  • ・For minors(under age of 16), additional data of legal representatives (name, birth date, email address, telephone number)

(2) Personal Data provided by other service providers who are allowed to connect with the Service

The following information may be provided by other service providers

  • ・The user’s ID of other service providers
  • ・Any other information which the user consented to provide to other affiliates

(3) Personal Data collected while using the Service

The following Personal Data may be collected when using the Service.

  • ・Device information: Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of browser and use information of website or application
  • ・Log information: IP address, log data, use time, internet protocol address, cookies and web beacons
  • ・Service usage history: Email or text messages, game play contents, inquiry history, search word input by the users, contact information with other users including chat history, performance data

(4) Personal Data collected only with specific consent of the users

The following Personal Data may be collected only when the Company obtains specific consent from the users.

  • ・Location information: Information of device location including specific geographical location detected through GPS, Bluetooth or Wi-Fi (limited to the region permissible under the laws)

(5) Personal Data directly provided by the users when using online payment system

The following Personal Data may be provided when using online payment system in the Service

  • ・Purchase information: Purchase history, purchase ID, purchase date, purchase item, purchase amount, postal code

(6) Personal Data directly provided by the users through inquiry system of the Company

The following Personal Data may be provided by the users.

  • ・email address, the user’s ID, operation system, device identifier, hardware version, set-up status

(7) Personal Data directly provided by the users through events operation, marketing, and any other related matters

The following Personal Data may be provided by the users.

  • ・Name, address, telephone number, sex, birth date, other information which is required to operate the events, marketing, and any other related matters

The Company collects Personal Data of the users as above, but it does not collect sensitive Personal Data which includes but not limited to the below.

  • ・Race and ethnicity, ideology and beliefs, political views and criminal record, social status, medical history, the fact that suffered from a crime, and any other information which may infringe upon the basic human rights of the users.

2. The purpose the Company collects Personal Data and grounds for processing

The company may collect and process the users’ Personal Data solely for the purposes and grounds for processing below;

  1. (1)To sign up for the Service, confirm identification, provide, maintain, protect, and improve existing services and develop new services; This is necessary for the performance of the contract between the Company and the user (the “Contract”)
  2. (2)To make notice related to the Service and respond to inquiry from the users; This is necessary for the performance of the Contract and/or for a legitimate interest of the Company, namely to communicate with the users and provide customer service
  3. (3)To detect and respond to unauthorized or fraudulent use of or abuse of the Service; This is necessary for the performance of the Contract and/or for a legitimate interest of the Company, namely to prevent fraudulent use of or abuse of the Service
  4. (4)To comply with applicable laws or legal obligation; This is necessary for compliance with a legal obligation under EU laws to which the Company is subject and/or for a legitimate interest of the Company with respect to laws of other jurisdictions
  5. (5)To institute questionnaires and monitor the Service; This is necessary for the performance for a legitimate interest of the Company, namely to communicate with the users and secure the Service environment
  6. (6)To make statistics on member’s service usage to provide services and place advertisements based on statistical characteristics; This is necessary for a legitimate interest of the Company, namely to offer the users other services or products in which the users may be interested or based on prior consent
  7. (7)To use the personal information in non-identified form for marketing purpose (the user’s ID may be open to public through advertising images). In this case, Personal Data of the users will be processed as follows; This is necessary for a legitimate interest of the Company, namely to invite new users to the Service which make the users explore new experience with them or based on prior consent
    • ・The company may use non-identifiable Personal Data after deleting or changing some of it with a method which cannot restore the data.
    • ・The company may use identifiable Personal Data after deleting or changing all of it with a method which cannot restore the data.
  8. (8)For other purposes which are incidental to the purposes stated above; This is necessary for the same grounds with the main purposes of the incidental purposes

When the company intends to collect other Personal Data which is not listed above, it will give a prior notice to the users about the purpose except the situations as below;

  1. (1)When the Company reasonably believes that a prior notice of the purpose may cause damage to a third party’s life, safety, property and any other rights Company’s other contracts, or to protect other person’s rights, property or safety
  2. (2)When the Company reasonable believes that a prior notice of the purpose may cause damage to the Company’s legitimate interests
  3. (3)When the Company is requested to cooperate with national government, local public authorities, administrative office, other equivalent organizations or individuals in dealing with affairs prescribed in the laws and regulations and a prior notice of the purpose may cause disturbance with the affairs
  4. (4)When the purpose is objectively clear from the circumstances

3. When does the Company disclose the Personal Data to a third party?

Except for the following cases, the Company will not disclose or provide Personal Data to a third party;

  1. (1)When the Company obtained the prior consent of the users
  2. (2)When the disclosure is required by the law
    • ・If required to be disclosed by the laws and regulations; or
    • ・If required to be disclosed by the investigative agencies for detecting crimes in accordance with the legitimate procedure and method as prescribed in the laws and regulations
  3. (3)When the disclosure is required to protect a person’s life, safety, and property but it is difficult to obtain the user’s consent
  4. (4)When the Company is requested to cooperate with national government, local public authorities, administrative office, other equivalent organizations or individuals in dealing with affairs prescribed in the laws and regulations and obtaining consent form the users may cause disturbance with the affairs
  5. (5)When the Company transfers Personal Data to a third party in/outside Japan
    • ・When the Company needs to transfer the Personal Data to its subsidiaries, affiliates, partners and service providers, outside contractors of the Company to provide, maintain, improve the Service; or
    • ・When the Company sells or buys any business or assets to a third party; or
    • ・WWhen the company reasonably believes that it is necessary to disclose the Personal Data to comply with the Company’s other contracts

The users should be aware that the Personal Data collected by the Company may be transferred, processed, stored and used outside of EEA, which includes Japan. For the places where the Personal Data is transmitted, retained or processed, the Company takes reasonable measures for protecting those Personal Data. When the users give their consent to this Policy, they agree with the following terms;

  • ・Outside EEA, the level of the data protection law may be lower than EEA therefore data subjects may not be able to receive the same rights as those in EEA.
  • ・The users’ Personal Data may be disclosed to third parties located outside EEA.
  • ・In order to accomplish the purposes set forth above, the users’ Personal Data may be provided to not only the Company but also to third parties located outside EEA, where the users’ Personal Data may be processed by such third parties.
  • ・The Company provides Personal Data to a third party as below;
Name
AppsFlyer Ltd.
Country
The United States
Purpose
To analyze information for Marketing
Personal Data to be provided
User’s ID, Device information, Log information, Purchase information, Performance data stipulated in Article 1 above
Duration
Until the user withdraws the Service or the agreement between the Company and the third party is expired
When
When the user uses the Service or appropriate time stipulated in the contract between the Company and the third party
How
Via users’ network of the Service or provided by the Company based on Standard Contractual Clauses

4. When the Company jointly use Personal Data with third parties

When the Company needs to share the Personal Data with third parties to provide the Service, the Company may use the Personal Data with the necessary third parties jointly.

5. What are the users’ data protection rights?

The Company would like to make sure the users are fully aware of all of your data protection rights. You will not have to pay a fee to exercise any of the rights. However, the Company may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, the Company could refuse to comply with your request in these circumstances. Every user is entitled to the following;

  • ・The right to withdraw – The users have the right to withdraw consent at any time. Provided, however, that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  • ・The right to access – The users have the right to view/change their Personal Data through the Service.
  • ・The right to rectification – The users have the right to request that the Company correct any data they believe is inaccurate and cannot change by themselves.
  • ・The right to erasure – The users have the right to request that the Company erase their Personal Data, under certain conditions.
  • ・The right to restrict processing – The users have the right to request that the Company restrict the processing of their Personal Data, under certain conditions.
  • ・The right to object to processing – The users have the right to object to the Company’s processing of their Personal Data, under certain conditions.
  • ・The right to data portability – The users have the right to request that the Company transfer the data that it has collected to another organization, or directly to you, under certain conditions.
  • ・The right to complain –The users have the right to complain with a supervisory authority in the EU Member State of your habitual residence, place of work or of an alleged infringement of the GDPR at all times.
  • ・If the user makes a request, the Company will take measures without delay; Provided that the Company may reject the request of them only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
  • ・Any user who would like to exercise any of these rights, please contact us at the contract details below;

Email us at: dataprotectionofficer-team@boi.jp
Or write to us: Bank of Innovation, Inc,.
Shinjuku Eastside Square
6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan

6. How does the Company store Personal Data?

  • ・The Company securely stores Personal Data with all necessary and appropriate safety measures from any unauthorized access, release, use or modification. The Company strictly limit access to Personal Data to its employees, agents, contractors, and other third parties who have a need to have access. In addition, these persons are bound by a confidentiality obligation, either under their employment agreements or other contracts.
  • ・The Company will retain Personal Data for as long as reasonably required for the purposes for which the Company has collected such data. Exact periods are determined based on consideration of the purpose for which Personal Data is collected, the nature of the Personal Data, and legal or business requirements for retention of Personal Data.

7. Protection concerning personal information of Children

  • ・The Company will not intentionally collect Personal Data from a user under the age of 16 without prior consent from such user’s parents or legal guardian. In the event that anyone under the age of 16 wishes to use the Service, the Company asks them to make sure that the consent is given or authorized by their parents or legal guardian.
  • ・The Company may grant to parents or legal guardian of children a right to access to Personal Data of those children, correct, delete, or temporarily suspend treating the Personal Data of those children, and request for withdrawal of their consent provided before.

8. Cookies and similar technologies

  1. (1)‘Cookies’ are text files placed on the user’s computer to collect standard internet log information and visitor behavior information. When the users visit and use the Service, the Company may collect information from the users automatically through cookies or similar technologies.
  2. (2)The Company may collect and use cookies below or similar technologies in a range of ways to improve your experience on the Service;
    • ・Necessary cookies: These cookies are necessary for the Service to function properly, including cookies that are necessary to create an account. These cookies do not collect any information which may be used for marketing or memorizing the sites visited by the users.
    • ・Performance cookies: These cookies collects information how the users use the Service such as the information of pages which are visited by the users most. Where users have previously indicated a preference, that user’s preference will be stored in these cookies. Through these cookies the Company can improve the Service and optimize the experience of the users whenever they visit the Service so that the users can search the Service more comfortably.
    • ・Functionality cookies: These cookies are used for memorizing the set-ups such as layout, text size, basic set-up and languages so that the Company provides services and improves visit of the users. Any information collected by this cookie do not identify the users individually.
  3. (3)The Service is set to accept cookies by default. The users can set the browser not to accept cookies, however, in a few cases, certain features of the Service as well as third parties’ services may not function as a result.

9. Privacy policies of other websites

The Service may contain links to other websites or services. The policy applies only to the Service, so if you click on a link to another website, we recommend you to carefully read their privacy policy.

10. Changes to the Policy

The Policy may be amended pursuant to changes in the applicable laws, regulations, and/or the Company’s policy, so please check the Policy from time to time for possible changes when using the Service. This Policy was updated and effective on 1 August 2021.

11. How to contact the Company

If you have any questions about the Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Email us at: dataprotectionofficer-team@boi.jp

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