Privacy policy EEA

Custom Cast, Inc. (“the Company”) recognizes the importance of protecting personal information, and strives to appropriately handle data provided by customers residing in the European Economic Area (EEA) and protect their privacy in compliance with General Data Protection Regulations (GDPRs) and related laws and regulations (“Laws and Regulations”). Please read this privacy policy before using the Company’s website and services.

The term “personal information” here shall refer to addresses, names, telephone numbers and any other information enabling identification of specific customers (including information outside the definition of Personal Data in Article 4 of the GDPRs).

1. Personal Information Collected by the Company
The Company may collect the following and other personal information from customers:
- Name, address, telephone number, email address, user name
- Access history data such as IP addresses and cookie data obtained during periods of access to the Company’s website
- Purchase information, details of inquiries, customer account information, order and contract information, delivery details, billing information, bank account information, transaction and contact history, and information on communications with customers on the Company’s website
- Terminal identification information

2. Purposes of Personal Information Usage
The Company generally collects personal information from customers for the following purposes:
- to process registration for and provide services (performance of contracted duties);
- to process entries for prizes, gifts, contests and the like, notify winners and deliver winnings (performance of contracted duties);
- to check orders for goods or services, confirm payment therefor, and deliver orders (performance of contracted duties);
- to engage in services jointly provided by the Company and third parties, with user information provided to the relevant parties only to the minimum extent required for service provision (performance of contracted duties);
- to answer queries from customers (performance of contracted duties);
- to provide customers with information on maintenance, important notifications and other information as necessary (performance of contracted duties);
- to process applications for employment, make recruiting decisions and inform applicants of career seminars and the like (legitimate interests);
- to provide information on new products, services and the like (first-person informed consent);
- to conduct market research, planning and research and development (legitimate interests);
- to develop new products, services and the like (legitimate interests);
- to improve the customer experience on the Company’s website by personalizing advertisements, content and services, including customization of the Company’s advertising and content that may be shown on third-party websites (first-person informed consent);
- to analyze and monitor usage (legitimate interests);
- to aggregate personal information and compile statistics, without identifying specific individuals, for marketing, development of new products or services, service quality improvement and joint research with affiliates (legitimate interests);
- to provide information on the services of sponsors and affiliates in advertising (first-person informed consent);
- to identify violators of the Company’s terms of use and discontinue usage to such users (legitimate interests); and
- to contact customers regarding the Company’s use of information uploaded to the Company’s service (legitimate interests).

3. Sharing of Personal Information with Outside Parties
The Company may share personal information with its group companies and partners/other third parties as detailed below.
・Service providers
The Company may outsource to third parties such as marketing companies and IT service providers, and share personal information with such parties as necessary for service provision. Shared personal information shall be used under the instruction of the Company and exclusively for the primary purposes specified.
・Legal obligations
In accordance with relevant Laws and Regulations, the Company may disclose personal information to public authorities engaging in enforcement of laws or court orders, or at the request of government authorities or law enforcement agencies (as required for national security or law enforcement) or governmental authorities and courts in countries where the Company operates).

To the extent permitted by law, the Company may disclose personal information as necessary to third parties (including legal advisors) to prove, assert or defend against legal claims, exercise rights, protect the Company’s property or rights and the property or safety of others, and support external audits and the Company’s compliance and corporate governance functions.

4. Transfer of Personal Information to Third Parties outside the EEA
The Company shall take appropriate protective measures in any necessary transfer of personal information to any country outside the EEA.

5. Point to Note
The Company shall assume no responsibility for the handling of personal information on external websites linked to from its own website, or for independent collection of personal information by third parties via advertisements in the Company’s output.

6. EEA Customer Rights
In relation to their own personal data, EEA customers shall have the right to:
（1）access information held;
（2）request correction;
（3）request deletion;
（4）request restricted processing;
（5）be provided with content in a structured, commonly used and machine-readable format; and
（6）object to processing.
EEA customers shall also have the right to withdraw consent in relation to processing of their personal data at any time.

For information on exercising these rights see “7. Contact for Inquiries” below.

7. Contact for Inquiries
Contact the Company in relation to feedback, inquiries or complaints regarding personal information. Besides, you are also welcomed to send your comments, inquiries or complaints to our EU Representative at the following contact details:

Atsumi & Sakai Europa Rechtsanwalts- und Steuerberatungsgesellschaft mbH
Address: Bockenheimer Landstraße 2-4, 60306 Frankfurt am Main, Germany
Email: info@aplaw.de
Tel.: +49 69 7474 5050

For requests relating to “6. EEA Customer Rights,” please provide the following:
（1）Details of the personal information in question
（2）Name of the service used
（3）Reason for the request
（4）Requested action
The Company will require documentation to verify the identity of the customer before addressing the request.
Proxy requesters will need to submit documentation certifying proxy authority.

Contact:
Personal Information Inquiries
Custom Cast, Inc.
Kabukiza Tower, 4-12-15, Ginza, Chuo-ku, Tokyo 104-0061 Japan

8. Administrator Details
Custom Cast, Inc.
Kabukiza Tower, 4-12-15, Ginza, Chuo-ku, Tokyo 104-0061 Japan

9. Handling for Personal Data of Minors
The Company will require consent from a parent or guardian for customers under 16 years of age before collecting personal data.

10. Data Retention
The Company will not retain personal information for any purposes other than those specified or beyond the requirements set by applicable laws and regulations.

11. Cookies
Cookies and other automatic information collection means may be used on the Company’s website, as is standard in the online space.

Cookies are used to store user information on the user’s computer via the Company’s website. This saves time by removing the need to re-enter information already provided.

The Company may also use cookies to improve the online experience by recording details of usage and timing thereof, thereby contributing to usability improvement.

Cookies can be disabled within the browser, but this may impair service provision.

12. Use of True Depth API
The Company will record customer facial expressions for reflection in 3D characters in its Custom Cast app (“the App”). Such data will not be used for other purposes, saved or provided to third parties.

13. Google Analytics
The Company’s usage analysis and monitoring for the Custom Cast app (“the App”) involves the use of Google Analytics, Google Analytics 360 and other tools. Based on Cookies and Similar used by the Company or Google, user device identification and other user information may be acquired by Google. By using the app, users shall be deemed to have permitted this acquisition. Such information does not include data enabling identification of specific individuals. For information on how Google uses such information, see Google’s Terms of Use ( https://marketingplatform.google.com/about/analytics/terms/jp/) and Privacy Policy (http://www.google.com/intl/ja/policies/privacy/).

14. Other Matters
Service provision may be impaired if personal information is out of date or incorrect.

Customers may object to the processing of their personal information with their local data protection supervisory authority.
15. Privacy Policy Amendment
The Company may amend or update this Privacy Policy without limiting any of the individual rights specified herein, and shall specify the date of validity of amendments.


Valid as of August 10, 2022