(Last updated: April 30, 2013)
- persons using the GREE online social networking service (the “Users”) provided via the following Internet addresses: http://games.gree.net/ (the “Websites” and collectively the “Services”);
- persons applying for employment with the Company;
- developers registered with any of the Company's developer centers;
- persons or entities applying for advertising transaction support services through the Company; and
- other persons providing personal information to the Company.
Please note that information provided by Information Providers that reside in the European Economic Area and Switzerland shall be controlled by GREE UK Limited.
Information Collected from Information Providers
- When Information is Collected.
The Company collects Information from Information Providers in the following circumstances:
- When joining and/or registering for the Services. (Please see below for more specific information regarding registering for the GREE Messenger application.)
- When creating or editing a profile page in the Services.
- When Users use the Services (including clicking buttons, downloading applications or opening links).
- When contacting the Company's support services or when inquiring about job opportunities.
- When registering with the Company's developer center to develop applications.
- Through Information Providers' Internet browser history information folder at preset intervals set on Information Providers' Internet browser.
- Through web browser cookies.
- Through pixel tags, web beacons, clear GIFs or other similar technologies.
These may be used in connection with the Services and HTML-formatted email messages to Information Providers to, among other things, track the actions of Users and email recipients, including for the purpose of measuring the success of the Company's marketing campaigns and compiling statistics about usage and response rates.
- Information Collected From Users of the Services.
- Guest User Registration. (i.e., Users who register to use restricted applications as designated by the Company).
At the time of registration, the Company may collect the following levels of Information from Guest Users: User ID, unique device ID, UUID, level of registration, membership status, whether the User has used GREE or Open Feint services in the past, date and time of registration, country of residence as confirmed from the IP address, location of residence as confirmed from the IP address, selected language, and time zone based on selected residence. If Users choose to enable certain SNS services, the Company may also collect Users' date of birth. If Users do not provide Users' date of birth (and User ID), that functionality will not be made available to Users.
- Standard User Registration (i.e., Users who register to use restricted applications and SNS services, each as designated by the Company).
At the time of registration, the Company may collect, in addition to the Information obtained at the time of Guest User registration, the following Information: name, sex, nickname, email address, password, date of birth and other membership Information (including voluntarily provided Information such as profile images) and the Standard User registration date. The aforementioned Information is used to create the User's personal profile.
- * If the User is already a member of other Company's platforms (including Open Feint), or other products and services of the Company's affiliates at the time of registration, the User's membership Information from such other platforms, products and services may be shared with the Company and transferred to the registration form.
- * If the User permits the use of Facebook Connect at the time of registration and the User inputs the User's Facebook ID and password, the Company may access Information in the User's Facebook account, including name, nickname, email address, Facebook ID, date of birth and other membership Information (such as the names of the User's Facebook friends), and transfer such Information to the registration form.
- * The Company will retain the Information submitted by the User on the registration form. Please note that Information obtained by the Company is not separately synchronized with Facebook Connect. However, Information obtained via Facebook Connect may be aggregated with Information entered manually on the registration form if the Information obtained via Facebook Connect is not sufficient to meet the registration requirements.
- Certified User Registration (i.e., Users who register to have access to the full functionality of the Services).
At the time of registration, the Company may collect, in addition to the Information obtained at the time of Standard User registration: telephone number and date of birth (if not already collected during Standard User registration).
- * Upon obtaining the User's telephone number, the Company converts it to hashed data for use in confirming identity and preventing multiple registrations, but the Company does not retain the input telephone number itself.
- Additional Information Collected From All Users After Registration.
After registration, the Company may collect the date and time of login of a User and the associated unique device ID. In addition, the Company may collect the Information contained in or available on friend invitations, diaries, communities, message boards, profile photographs, other photographs, User mail, messages and audio (for example, via GREE Messenger) and comments. The Company may also collect IP addresses, the type of devices being used, the language setting of those devices, the type, version and access history of browsers being used, and the names and versions of applications being used.
The Company uses third-party payment services (including payment aggregators; each, a “Payment Vendor”) to collect payments made through the Services or otherwise in connection with the Services. If Users wish to make a payment, Users may be directed to a webpage that is hosted by the Payment Vendor (or the Payment Vendor's service providers) and not by the Company (such page, the “Payment Vendor Page”). In such cases, Users email address will be provided to the Payment Vendor for the purpose of issuing receipts. Any Information, including credit and debit card numbers, passwords, and bank account and wire transfer information, that Users provide through the Payment Vendor Page will be collected by the Payment Vendor and not by the Company. When a Payment Vendor asks the Company about payment, the Company may provide the following Information: inquiry number, the content of service, the date of payment, Users' name, address and contact Information, Users' GREE ID, the date of registration, number of customer support contact, purchase activity and account login/access.
The Company may also collect: Information obtained by the User's “Life Log,” and other access logs. A “Life Log” is Information regarding the services and applications that a User uses, the products and services that a User purchases, the web pages and ads that a User visits, and the times of day during which such person engages in the foregoing activities.
- Information Collected if a User Opts-In.
If a User opts-in to search for other Users by using address book synchronization functionality or functionality to connect with third-party services, and the Company may collect the email addresses registered in the User's mobile telephone. If an address matches with an email address that is already registered as a GREE user, the Company will show to the User the nickname and avatar of the person associated with the matched address. If a User has opted-in to “Auto Sync Phone Book”, the User's address book on his or her mobile device will be accessed and stored (in hashed format) on the Company's servers. The stored numbers from such User's address book, and the names of the individuals associated with those numbers, will be synchronized with other Users who have made (or subsequently make) their phone numbers available via the Services. Following that synchronization, the names of such other Users will automatically be shown in the contact list of the User (as it is written in the User's address book) if the phone number of the other User is in the User's address book. Such phone numbers will be shown along with the corresponding name as stored in the User's address book.
- Information Collected if a User Connects to a Third Party Service.
When a User uses the Services to connect with a third party service, the Company may collect the ID and password used to connect with such third party service; the Company may retain such Information after the Services connect with such third-party service.
- When registering as a User through GREE Platform, the Company may collect the User's mobile phone number, nickname, birth date, User ID and unique device ID.
- When registering as a User through Google, the Company may collect the User's Google access token information, nickname, birth date, email address and profile image.
- When registering as a User through Facebook, the Company may collect the User's Facebook access token information, nickname, birth date, email address and profile image.
Please note that if a User has not provided his or her birth date to the service through which the User registers, the Company requests that the User registers his or her birth date separately.
- Guest User Registration. (i.e., Users who register to use restricted applications as designated by the Company).
- Information Collected From Employment Applicants.
- Information Collected From Developers.
When a developer registers with any of the Company's developer centers, the Company collects the developer's name postal address, email address, and telephone number.
- Information Collected From Website Visitors.
When an individual accesses the Company's website, the Company collects the person's IP address and other access log data. When a User accesses the Company's website, the Company and certain third parties under non-disclosure agreements with Company (including content and/or Information Providers, advertisers and publishers) collect and share certain history and characteristics, such as access logs to the Service, Information Providers' history on the Service (such as services and software Information Providers used, products Information Providers bought, pages and ads Information Providers read, time slots Information Providers used and Information Providers' technical environments), Information Providers' IP addresses, cookie Information, geo-location Information and unique identification (UID) numbers. In addition to the purposes described in Section 2 below, the Company collects this Information in order to improve its quality of service, understand Information Providers' preferences and optimize display of ads. To opt out of having this Information collected and used through our Websites, go to Contact Form. The Company may compare the Information third parties obtain with our cookie Information, and coordinate and share such Information so that Company may optimize the display of ads.
- Information Collected From Advertisers.
When a person or company registers with the Company for the placement of ads or sales representation services (that is, services provided by a vendor that buys and sells advertisements for a customer), the Company collects the person's or company's name and contact Information, which may include a department (of a company), the name of the contact person (for a company), the address, e-mail address and phone number.
How the Information Collected by the Company Is Used.
The Company may use Users' Information in any of the following ways.
- Creation of Profile Pages.
The name, gender, photograph, date of birth and other Information registered with the Services may be used to create a profile page for each User. By using the Services, Users are consenting to the Company making the Information and content registered to Users' profile page available to other Users. Please note that Users' email address and phone number will not be published on Users' profile page.
- Communication between Users.
- Communication between the Company and the User.
The Company and its service providers may use the User's email address and device feature phone identifier registered with the Services as a means of communicating with the User, including, for example, to provide the User with information about the Services, marketing communications that may be of interest to the User (such as advertising optimized to the User's preferences), and daily “update notice” e-mails. The Company and its service providers also may use the User's e-mail address and feature phone identifier to respond to inquiries about the Services.
- Communication with Parties Other Than the User.
The Company and its service providers may use the User's name, email address, photograph, feature phone identifier registered with the Services and other Information when the User makes use of the Services' invitation functionality to invite new friends to the Services. In such cases, the registered profile photograph may be publicly viewable through anyone from the URL included in the e-mail message sent to the recipient of the invitation.
- Promotional Purposes.
The Company and its service providers may use Users' email address and other Information registered with the Company for the purpose of promoting (a) the products and services of the Company, or (b) the products and services of third parties, for such third parties' own marketing purposes. Such promotions may be directed to Users based on factors such as gender, age, or usage patterns.
- Improvement of the Services.
The Company and its service providers may use Information, such as statistical Information in the form of aggregated and modified Service access logs and histories, for the purpose of improving the quality of the Services, ascertaining User preferences and optimizing advertising displays. Additionally, the Company may use IP addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
- Other Use of Voluntarily-Provided Information.
- Use in the Provision of Advertising Support Services.
The Company and its service providers may provide Information to advertising support service operators as necessary to carry out transactions with such advertising support service operators relating to the purchase and/or sale of advertising on behalf of the Information Provider.
- Other Information.
Disclosure of Information to Third Parties.
The Company may share aggregate or de-identified Information about Users with advertisers, publishers, business partners, sponsors, and other third parties. In addition, the Company may disclose Information in the following circumstances:
- When disclosure is reasonably determined by the Company to comply with applicable laws and ordinances, including laws and ordinances outside of the Information Provider's country of residence, or to comply with legal processes.
- When disclosure is necessary to prevent bodily injury or harm to property or to protect the operations, rights, privacy, safety or property of the Company, its affiliates/subsidiaries, Users or other Information Providers, including to enforce the terms and conditions governing the Company's provision of the Services or to allow the Company to pursue available remedies or limit the damages that the Company may sustain.
- When Company uses the services of third party service providers to provide services such as website hosting, data analysis, payment processing, credit card processing, order fulfillment, infrastructure and network provision (including cloud storage and cloud computing), IT services, support and maintenance, customer service, email delivery services, auditing services and other similar services.
- In the event that the Company undergoes any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Company's business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- When disclosure is necessary for the improvement of public health or the promotion of the sound development of children.
- When a central government agency, local government entity, public authority or a party commissioned thereby requires cooperation, including such agencies, entities, authorities or commissioned parties outside the Information Provider's country of residence.
- When Information Provider gives the Company explicit consent for such disclosure.
Transfer of Information to Affiliates/Subsidiaries and Third Parties Located in Other Countries.
Correction and Deletion of Information.
Choices Regarding Use of Information for Marketing Purposes.
The Company gives Users many choices regarding the Company's use and disclosure of Users' Information for marketing purposes. Users may opt-out from (or choose not to opt in where we ask for Users' consent in advance) having Users' Information used for the following purposes.
- Receiving Electronic Communications from the Company.
If Users no longer want to receive marketing-related emails from the Company on a going-forward basis, Users may opt-out of receiving these marketing-related emails by contacting the Company at Contact Form or by following the opt-out instructions included in such marketing related emails.
- Sharing of Users' Information with Subsidiaries and Other Affiliates for their Marketing Purposes.
If Users would prefer that the Company does not share Users' Information on a going-forward basis with the Company's subsidiaries and other affiliates for their marketing purposes, Users may opt-out of this sharing by informing the Company of Users' preference by contacting us at Contact Form.
- Sharing of Users' Information with Unaffiliated Third Parties for Their Marketing Purposes.
If Users would prefer that the Company does not share Users' Information on a going-forward basis with unaffiliated third parties for their marketing purposes, Users may opt-out of this sharing by informing the Company of Users' preference by contacting us at Contact Form.
The Company will try to comply with Users' request(s) as soon as reasonably practicable. Please note that if Users opt-out as described above, the Company will not be able to remove Users' Information from the databases of some or all of the Company's affiliates or unaffiliated third parties with which the Company has already shared Users' Information. Please also note that if Users do opt-out of receiving marketing-related messages from the Company, the Company may still send Users administrative messages, and Users cannot opt-out from receiving administrative messages.
- Distributing targeted advertisement.
The Company uses targeted advertising to provide the most accurate and relevant contents and advertising to the Users who have chosen to receive them.
We are committed to providing you with the choice to opt out of receiving such promotional/marketing information from us at any time. Users may opt out of those targeted advertisement by contacting us at Contact Form.
Information Management; Security
- Information Management.
The Company endeavors to use reasonable organizational, technical and administrative measures to protect Information under the Company's control. For example, the Company has chosen a user support services vendor that has received an Information Security Management System (ISMS) certification from the International Organization for Standardization (ISO) and Japanese Industrial Standards (JIS). Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. A firewall is used for the servers and SSL 128-bit encryption is used as a transmitting method. If Information Providers have reason to believe that Information providers' interaction with the Company is no longer secure (for example, if Information Providers feel that the security of any account Information Providers might have on the Services has been compromised), please immediately notify the Company of the problem by contacting the Company's Information Manager at the address below. The servers storing unique user ID information are currently located in Japan and the U.S., and soon may also be located in the Netherlands.
Use by Minors.
The Company does not knowingly collect or solicit Information from any person located in Germany under the age of 14 or any person located outside of Japan and Germany under the age of 13, nor does it knowingly allow such persons to register. If Information Providers are located in Germany and under the age of 14 or located outside of Japan and under the age of 13, the Company requests that Information Providers do not attempt to register or send any Information to the Company, including Information Provider's name, address, telephone number, or e-mail address. It is the Company's policy that no person located in Germany under the age of 14 and no person located outside of Japan and Germany under the age of 13 may provide any Information to Company. In the event that the Company learns that it has collected Information from any person located in Germany under the age of 14 or any person located outside of Japan and Germany under the age of 13, the Company will try to delete that Information as quickly as reasonably practicable. If Information Providers believe that the Company might have received any Information from or about any person located in Germany under the age of 14 or any person located outside of Japan and Germany under the age of 13, please contact us at Contact Form.
California Privacy Rights.
California Civil Code Section 1798.83 permits our customers who are California residents to request certain Information regarding our disclosure of personal information to third parties for direct marketing purposes. For inquiries regarding our disclosure policy, please contact the Information Manager whose contact information is located at 11 .Contact Information for Inquiries.
Contact Information for Inquiries.
Director of IT Strategy Office
Roppongi Hills Mori Tower
6-10-1 Roppongi, Minato-ku, Tokyo
MODIFICATIONS FOR USERS IN SPECIFIC COUNTRIES
- The first two sentences of Section 1.2(e) shall be replaced with the following:
"(d) When a User searches for other Users by using address book synchronization functionality or functionality to connect with third-party services, the Company may collect the email addresses registered in the User's mobile telephone. The Company may also collect Information about the User from the mobile telephones of other Users in this way. In addition, the Company may check whether existing Users are Facebook friends of newly registering Users and, if so, use this Information to notify existing Users that their Facebook friends have registered with the Company."
- Section 2.3 shall be amended by adding the following at the end:
"Any email that we send will identify the Company as the sender and will include the Company's contact details. Promotional emails will also provide an unsubscribe facility. A User's consent to receiving promotional emails will remain current until the User advises us otherwise."
Canada (excluding Quebec)
- Delete and replace the first sentence of Section 1 with the following:
“When the Company has confirmed that Information does not personally identify Users, the Company may use and disclose such Information for any purpose. In some instances, the Company may combine non-personal Information with personal Information. If the Company combines any non-personal Information with personal Information, the combined Information will be treated by the Company as personal Information as long as it is combined.”
- The second to last sentence in Section 1.2(d) which reads:
“The Company may also collect: Information obtained by the User's “Life Log,” and other access logs.”
shall be deleted and replaced with the following:
“The Company may also collect personal Information from the User's ‘Life Log,’ and other access logs.”
- Section 1.2(e) and (f) should be deleted in their entirety.
- The following provision shall be added after Section 3.2 as a new Section 3.2(a):
“When third parties such as digital content providers require data in order to provide the User with digital content via the Services, or to be able to respond directly to queries from Users, pursuant to the digital content provider's policy.”
- Section 6.2 and 6.3 shall be deleted and replaced in their entirety with the following:
“6.2. Sharing of Users' Personal Information with Subsidiaries and Other Affiliates for their Marketing Purposes. If Users would prefer that the Company does not share Users' personal Information on a going-forward basis with the Company's subsidiaries and other affiliates for their marketing purposes, Users may opt-out of this sharing by informing the Company of Users' preference by contacting us at Contact Form, or by choosing not to opt in where we ask for Users' consent in advance.”
“6.3. Sharing of Users' Personal Information with Unaffiliated Third Parties for Their Marketing Purposes. If Users would prefer that the Company does not share Users' personal Information on a going-forward basis with unaffiliated third parties for their marketing purposes, Users may opt-out of this sharing by informing the Company of Users' preference by contacting us at Contact Form, or by choosing not to opt in where we ask for Users' consent in advance.”