Sony Group Japan Common Corporate Privacy Policy

Each company of the Sony Group (collectively, "Sony") is willing to build an environment in which the personal information of customers is safely stored, used and handled in line with the intention of customers, as well as gaining the trust of customers, and hopes to continue to provide numerous services, under this environment, which inspire and fulfill the curiosity of each customer.

Under this policy, and in accordance with Sony's philosophy of being honest and fair, Sony has prescribed the following policy on the handling of personal information, and is working to ensure the proper handling of personal information relating to its customers that it collects.

(*)This Policy encompasses Sony Corporation and its subsidiaries within Japan.

Handling of Personal Information

(Definition of Personal Information)

1.

"Personal information" in this Policy refers to information relating to an individual that includes a name, date of birth, or other description, etc., that could be used to identify a specific individual, or that includes a individual identification code (*1). All obtained information relating to customers that does not contain information in itself by which a specific individual could be identified, but which could be used to identify a specific individual by collating it with other information, shall be regarded as "personal information" within the scope that it can be handled in combination with other information.

(Compliance with Laws)

2.

When handling personal information, Sony shall comply with the obligations set forth in the Act on the Protection of Personal Information, various other laws and regulations relating to the protection of personal information, guidelines published by the Personal Information Protection Commission and the competent authorities, as well as to this Policy.

(Use within the Scope of Utilization Purpose)

3.

Except where the prior consent of the individual has been obtained, or where it is permitted by law, Sony shall handle personal information only within the scope required to achieve the previously specified purpose of use, and shall take measures to achieve this.

(Acquisition of Personal Information)

4.

Sony shall endeavour to obtain personal information after expressing in advance the items, purpose of use, and contact point for inquiries, etc., of the personal information to be handled, and after obtaining the consent of the individual.In the event that special care-required personal information such as race and creed, etc., is included in the personal information, except where permitted by law, Sony shall not acquire such personal information without the consent of the individual. When obtaining personal information from a third party, if a legal obligation to check or create records arises when receiving provision from a third party, Sony shall comply with this.

(Personal Information of Customers Under the Age of 15)

5.

Sony shall endeavour to comply with all laws and regulations applicable to the collection, storage, and use of personal information relating to customers under the age of 15. In the event of a child having provided personal information to Sony without the consent of their parent or guardian, we ask that a parent or guardian contacts us at the address specified in this Policy.

(Security Control Action)

6.

Sony shall endeavour to keep the content of personal information accurate, complete, and up to date within the scope of the purpose of use, shall take the necessary and appropriate secure management measures in accordance with technological standards at that point in time in order to prevent unauthorised access, leakage, tampering, loss, or damage, etc., and shall make corrections as necessary.

(Supervision Over a Trustee)

7.

Sony, within the scope required for the achievement of the purpose of use, may entrust the handling of personal information to another Sony Group company or a third party. In such a case, the appropriate secure management measures shall be taken under the Sony Group common information security policy. In addition, with regard to the contracting of business to a third party, efforts shall be made to ensure that secure management is performed as strictly as possible in relation to the handling of personal information, such as through the execution of a contract. If a third party in a foreign country is contracted to perform business, and a legal obligation to create records arises, Sony shall comply with this.

(Third Party Provision)

8.

Except where permitted by law, Sony shall not provide personal information to a third party without obtaining the consent of the individual. If personal information is provided to a third party, and a legal obligation to create records arises at the time of such third party provision, Sony shall comply with this.

(Respond to a Demand etc. for Disclosure etc.)

9.

Sony shall respond appropriately to requests for the disclosure, amendment, ceasing of use (for introducing products and services, etc.), and deletion of personal information, as well as other comments and inquiries regarding the handling of personal information, based on the provisions of laws and regulations. Please contact the address of the company to which you provided information for assistance.

(Strengthening of Systems, Training, Etc.)

10.

To ensure the appropriate handling of personal information, Sony shall endeavour to continually strengthen and improve internal systems, including reviewing this Policy, by appointing a manager for personal information, establishing internal regulations, training officers and employees, and implementing the appropriate internal audits, etc.

ForwardWorks Corporation - Public Disclosure etc. on Matters relating Personal Information

The "Act on the Protection of Personal Information" (hereinafter "the Act"), with regard to personal information that is obtained by our company (Name: FowrardWorks Corporation, hereinafter the "Company"), which is a business operator handling personal information, prescribes the statutory matters, such as the purpose of use, that should be published or made easily accessible to the individual.
With regard to the items set forth in 1 to 5 below, the Company states the following (the terms, etc., used are the same as those in the Domestic Sony Group Common Privacy Policy).

1. Information to be obtained: Stated in paragraph 1 of sections I through III below.
2. Utilization Purpose: The purpose of use of personal information (related to Article 18 Paragraph 1 of the Act) and the purpose of use of retained personal data (related to Article 27 Paragraph 1 of the Act) at the time of acquisition (hereinafter collectively referred to as "purpose of use"). Stated in paragraph 2 of sections I through III below.
3. Recipient of Personal Information: Stated in paragraph 3 of sections I through III below.
4. Contact Point: "The address for reporting complaints relating to the handling of retained personal data" prescribed in Article 5 of the "Ordinance for the Enforcement of the Act on the Protection of Personal Information." is as follows:
   
   
   ForwardWorks Inquiry Desk
   Tel.: 03-3515-5171
   Operating Hours: 10:00 a.m. - 5:00 p.m.
   
   *For inquiries regarding individual application content and operations, please contact us using the application form in the corresponding application or via the application's official website.
5. Procedures for responding to requests, etc., for disclosure, etc.: The procedures for responding to inquiries regarding notifications of the purpose of use (Related to Article 27 Paragraph 2 of the Act), disclosure (Related to Article 28 Paragraph 2 of the Act), cessation, etc., of use (Related to Article 30 Paragraph 2 of the Act), and the cessation of third party provision (Related to Article 30 Paragraph 4 of the Act) of retained personal data (hereinafter collectively referred to as "requests, etc., for disclosure, etc."). Please contact the above inquiry desk. The Company will promptly support your request.

I. Inquiry Information

I-1.

Information to be Obtained: service ID, device information, and other information entered into the inquiry form, additional confirmation items requested by the Comapany, and e-mail address

I-2.

Purpose of Use: to respond to the inquiry and confirm the individual's identity

I-3.

Recipients of Personal Information: Company's subcontractors and other partner companies

II. Survey Information

II-1.

Information to be Obtained: specified information to be entered into the survey form

II-2.

Purpose of Use: to study usage motives, improve services, and develop new services

II-3.

Recipients of Personal Information: Company's subcontractors and other partner companies

III. Prize Application Information

III-1.

Information to be Obtained: specified information to be entered into the prize application.

III-2.

Purpose of Use: to conduct prize drawings, contact users, and send prizes

III-3.

Recipients of Personal Information: Company's subcontractors and other partner companies

(Notification or publication of personal information matters relating to job applicants and company employees will be made separately to related parties.)

Remarks

If the Company separately indicates a specific purpose of use, etc., by means of notification to the individual or approval of the terms of use, etc., such specific purpose of use, etc. shall be applied with precedence over the above.

Cookie Policy

In order to analyse how customers use our website, and in order to provide more customised services and advertising to each individual customer, etc.,　ForwardWorks Corporation (herein referred to as "ForwardWorks") may use cookies and similar technology to collect certain information.

1.Cookies and Similar Technologies

"Cookie" refers to a small text file which, when a customer accesses the website, is sent to the browser of the customer's computer or mobile device (hereinafter collectively referred to as "device") from the web server, and is stored on the device's hard drive.

Cookies can generally be divided into two categories, 1st Party Cookie and 3rd Party Cookie. 1st Party Cookies are set by ForwardWorks. Such cookies, in almost all cases, are set for the use of the functions provided on the ForwardWorks website. On the other hand, 3rd Party Cookies are set by a third party partnering with ForwardWorks rather than ForwardWorks itself. For example, some 3rd Party Cookies are set by companies providing advertisement distribution services that are partnering with ForwardWorks, in order to track the customer's browsing activities, so that appropriate online advertisements can be posted in the appropriate location.

Beacon (or pixel) is a technology for transferring information from the customer's device to the server. A beacon can be embedded in email and online content such as images and videos, allowing for servers to read specific types of information from the customer's device, to recognise that the customer has seen specific content, or has opened / previewed an email, and to record information such as the date of viewing and IP address, etc.

2.Purpose of Use of Cookies and Similar Technologies

1. The cookies and similar technology described above are technologies established so that, when the customer browses the internet in general, or uses a specific online service, the customer's device is recognised automatically, and the service can be used continuously from the previous time, without the customer having to repeatedly input the same information.Today, it is used to track your browsing activities and display appropriate advertisements on the display screen of your browser.
2. ForwardWorks may use cookies and similar technology for the use of collected information, to analyse how the customer uses the website (access status, traffic, routing, etc.), to improve the performance of the website itself, and for improvements to the services provided to the customer by ForwardWorks through the website.

   ① Adobe Analytics

   ◾ Provider: Adobe Systems Incorporated
   ◾ Adobe's Privacy Policy
   http://www.google.com/analytics/terms/jp.html (Japanese Only)
   ◾Information collected through the tool: customer website usage statuss (access conditions, traffic, routing, etc.)

   ② Google Analytics

   ◾ Provider: Google Inc.
   ◾ Google Analytics Terms of Service:
   http://www.google.com/analytics/terms/jp.html (Japanese Only)
   ◾ Google's Privacy Policy
   http://www.google.com/intl/ja/policies/privacy/partners/
   ◾ Google's Privacy Policy
   http://www.google.com/intl/ja/policies/privacy/partners/
   ◾Information collected through the tool: customer website usage statuss (access conditions, traffic, routing, etc.) To stop providing information to these services, see section 3.
   Refer to Section 3 for information on how to stop the provision of information to these tools.

3. ForwardWorks may conduct targeted advertising on its website, or on the websites of partnered advertising service providers. A list of the main advertising service providers used by ForwardWorks is displayed in the following Section. ForwardWorks transmits Cookies to each advertising service provider. These Cookies are retained on each company's server, and handled according to their respective Privacy Policy. To stop providing information used for targeted advertising, see the following Section.

3.Method for Refusing Cookies and Similar Technology

1. Method for Refusing All Cookies
   Cookies on a customer's device will remain on the device until they are deleted by the customer or until the fixed expiration period has elapsed. Almost all browsers are set to automatically accept cookies by default; however, a customer may disable cookies by changing the browser settings. It should be noted that, if cookies are disabled, some website functions may become unavailable, and some pages may no longer display correctly, so please bear this in mind.
   Please refer to the following URLs for information on the most common browsers, and how to change cookie settings.

   Apple Safari(Japanese Only)	https://support.apple.com/ja-jp/HT201265
   Google Chrome(Japanese Only)	https://support.google.com/chrome/bin/-answer.py?hl=ja&answer=95647&p=cpn_cookies
   Microsoft Internet Explorer(Japanese Only)	http://windows.microsoft.com/ja-jp/windows7/How-to-manage-cookies-in-Internet-Explorer-9
   Mozilla Firefox(Japanese Only)	http://support.mozilla.org/ja-jp/kb/Cookies

2. Method for Refusing Specific Cookies
   ・The method for stopping the provision of information for the tools stated in Section (2) of the preceding Article is stated on each of the following respective URLs. However, if you would like to delete all such cookie information, please be aware that you may be subject to restrictions in the use of the products and services provided by each company.

   Main Tool Providers	Privacy Policy	Method for Stopping Information Transmission
   Adobe Systems Incorporated	URL: http://www.adobe.com/jp/privacy/policy.html(Japanese Only)	URL: http://www.adobe.com/jp/privacy/opt-out.html(Japanese Only)
   Google Inc.	URL: http://www.google.com/intl/ja/policies/privacy/(Japanese Only)	URL: https://support.google.com/analytics/answer/181881?hl=ja&ref_topic=2919631(Japanese Only)

   With regard to targeted marketing stated in Section (3) of the preceding Article, the method for stopping distribution is stated on each of the following respective URLs of the advertising distribution service companies. However, if you would like to delete all such cookie information, please be aware that you may be subject to restrictions in the use of the products and services provided by each company.

   Main Advertising Service Providers	Privacy Policy (Cookies)	Method for Stopping Advertising Distribution
   Yahoo! Japan Corporation	URL: http://docs.yahoo.co.jp/docs/info/terms/chapter1.html#cf2nd(Japanese Only)	URL: http://btoptout.yahoo.co.jp/optout/preferences.html(Japanese Only)
   Amazon Japan G.K.	URL: https://www.amazon.co.jp/gp/help/customer/display.html?nodeId=201909010(Japanese Only)	URL: https://www.amazon.co.jp/adprefs/ref=ya_oo_1?is-secure=true&(Japanese Only)
   Google Japan Inc. and Google Network	URL: https://www.google.com/intl/ja/policies/privacy/#infochoices(Japanese Only)	URL: https://support.google.com/ads/answer/2662922?hl=ja(Japanese Only)
   Microsoft Japan, Limited	URL: https://privacy.microsoft.com/ja-jp/privacystatement/(Japanese Only)	URL: https://choice.microsoft.com/ja-JP/opt-out(Japanese Only)
   Facebook Japan Co., Ltd.	URL: https://www.facebook.com/policies/cookies/(Japanese Only)	URL: https://www.facebook.com/about/ads/(Japanese Only)
   Apple Japan, Inc.	URL: https://www.apple.com/jp/privacy/(Japanese Only)	URL: https://support.apple.com/ja-jp/HT202074(Japanese Only)
   Supership Inc.	URL: https://supership.jp/privacy/(Japanese Only)	URL: https://supership.jp/optout/(Japanese Only)

3. Method for Refusing Beacons
   As web beacons using JavaScript tags are the same as any other content request included in a web page, you cannot opt out or refuse them. However, you can generally disable web beacons in email messages by not downloading images contained in message you receive, this method is dependent on the function of your email software, and it will not necessarily be the case that beacons are always disabled. In such a case, please follow the delivery suspension procedures for the email newsletter to which you are subscribed.

Information Collected Through Game Applications

ForwardWorks Corporation ("ForwardWorks") may collect the following user information through game applications. The majority of this information will be automatically collected during use.
Note that ForwardWorks does not record or save such information with linked to the information that can identify the individual user.

1. Information to be obtained

1. Application Usage Status
   (Examples: boot-up status, purchase status, play status, in-app communications)
2. Device Information
   (Example: model name, version, OS setting information, installed applications, Android or iOS advertising ID)
3. Location Information
   Users can disable location information acquisition via their device settings (generally these settings are under "location information" or "GPS" etc.). Note that disabling location information acquisition may result in portions or all of the game application becoming inaccessible.
4. Payment Information
   (Example: customer billing and payment information from payment service providers)
5. SNS Information
   (Example: the ID used by users in third-party services, or information allowed to disclose by the user in the privacy settings of other related services)
   

The information above (i. through v.) may be used in tandem with Android and iOS advertising IDs. This advertising ID can be reset via the user's device settings.

2. Purpose of Use

ForwardWorks will retain and use the above information for the following purposes.

1. Provision of Game Application and Related Services
2. Development of Products and Services
3. Responding to Customer Inquiries
4. Advertising
5. User Analysis for the Purpose of Improving Advertising, Product, and Service Quality

3. Analytics and Advertising Providers

In order to displays advertisements within game applications, confirm the effectiveness of these advertisements and to acquire information relating to application usage, information about application data access (including the user's usage status), ForwardWorks uses partner enterprises such as networked advertising service providers, advertising agencies, analytics service providers and data access information providers. The above service providers may collect information on a user's game application usage, browsing, and behavior and use such information to conduct targeted advertising. To prevent the user from seeing the same advertisement multiple times, to survey the effectiveness of user advertising, and to conduct targeted advertising, service providers may use or access information collected using their own tracking technologies and other methods. These service providers may repeatedly collect information about a user's game application usage, third party application usage, and usage of other websites and services.
The Privacy Policies of the above service providers, which collect and use customer information, are displayed below.

Adjust：https://www.adjust.com/privacy_policy/

Unity：https://unity3d.com/jp/legal/privacy-policy

Repro：https://repro.io/company/legal/privacy/

4. Recipients Outside of ForwardWorks

The information obtained by ForwardWorks (as described above in Section 1) may be provided to service providers described above in Section 3, affiliates companies, or other third parties.