COCONE PRIVACY NOTICE（CCPA）

1. Summary

1. (1) About the COCONE Privacy Notice

   Cocone Corporation (hereinafter referred to as “Company,” “we,” or “us”) respects the privacy of all individuals associated with the Company and properly protects personal information in accordance with CCPA regulations.
   The COCONE Privacy Notice (hereinafter referred to as “Notice”) describes the types of personal information we collect, how we handle personal information, the third parties with whom we share personal information, and the rights individuals may exercise with respect to our handling of personal information.

2. (2) Applicability

   This Notice applies in relation to California residents (hereinafter referred to as “Consumer” or “Consumers,” defined in detail in “2. Terms”).
   If you are not currently a resident of California, please refer to the COCONE Privacy Policy or COCONE Privacy Notice (GDPR privacy policy) .

3. (3) Miscellaneous

   Business affairs involving the handling of personal information may differ in each country in which we operate in order to reflect local practices and legal requirements.

2. Terms

The definitions of terms used in this Notice are as follows.

3. Personal information we acquire and purpose of use

1. (1) As a provider of smartphone applications or web services (including but not limited to social games, puzzle games, e-commerce services, language services, and other related services; collectively, “Services”), we acquire personal information in a legal and appropriate manner and use it within the scope necessary to achieve the following purposes.

   (i) Personal information of customers of our Services

   Personal information we acquire	Purpose of use
   Name	1. To deliver prizes for campaigns and contests 2. To contact customers as necessary when conducting questionnaires, interviews, etc. 3. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries 4. To prevent and respond to fraudulent acts, etc.
   Date of birth	1. To obtain age-based analysis results when conducting questionnaires, interviews, etc. with customers 2. To provide, solicit, advertise, or otherwise market the Company’s or a third party’s products and services through the Company’s or the third party’s media in accordance with the interests of customers based on gender analysis 3. To determine the legality of the customer’s actions, such as determining whether or not the consent of a person with parental authority is needed when billing for our Services, entering a campaign or contests, etc.
   Gender	1. To provide appropriate and effective after-sales service for our Services 2. To obtain gender-based analysis results when conducting questionnaires, interviews, etc. with customers 3. To provide, solicit, advertise, or otherwise market the Company’s or a third party’s products and services through the Company’s or the third party’s media in accordance with the interests of customers based on gender analysis
   E-mail address	1. For user administration of our Services (e.g., to transfer customer service data between different devices, such as when changing device models) 2. To deliver prizes for campaigns and contests 3. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries
   Address and postal code	1. To deliver products purchased through our Services and prizes for campaigns and contests, and to provide after-sales services related to such products and prizes 2. To obtain analysis results based on the place of residence (country of residence, etc.) when conducting questionnaires, interviews, etc. with customers 3. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries
   Telephone number	1. To deliver products purchased through our Services and prizes for campaigns and contests, and to provide after-sales services related to such products and prizes 2. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries
   Bank account information, wallet address	To process necessary transactions (e.g., payments, revenue processing)
   Credit card data	To use as payment information for customers who chose “credit card payment” as their payment method for our Services.
   In-service user name	1. To manage (identify) users of our Services 2. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries 3. To prevent and respond to fraudulent act, etc.
   Cookie data (e.g., service usage history, browsing history, location information, IP address, device type, OS, browser type, device UID, etc.)	1. To manage users of our Services 2. For the maintenance and administration of our Services (e.g., to maintain stable web sessions) 3. To simplify customer information entry when using our Services, such as saving user settings 4. To process payments for customers who are paying for our Services for the first time, or who purchase products through our services for the first time 5. To improve and enhance our Services, and to plan, research, and develop new services 6. To research and analyze marketing data, and to consider and implement marketing measures 7. To provide, solicit, advertise, or otherwise market the Company’s or a third party’s products and services through the Company’s or a third party’s media in accordance with the interests of Customers based on browsing history analysis 8. To prevent and respond to fraudulent acts, etc.
   Advertising identifier (Advertising Identifier (iOS), Google Advertising ID (Android OS))	1. To determine whether or not our Services are being used on the Customer’s device and to obtain the results of analysis of usage of our Services, etc. 2. To improve and enhance our Services, and to plan, research, and develop new services 3. To research and analyze marketing data, and to consider and implement marketing measures 4. To provide, solicit, advertise, or otherwise market the Company’s or a third party’s products and services through the Company’s or a third party’s media in accordance with the interests of customers based on browsing history analysis
   Other (e.g., information provided by customers when making inquiries, contacting us, etc.)	To respond to inquiries and contact customers

2. (ii) Personal information of business partner representatives

   Personal information we acquire	Purpose of use
   Name	1. To contact representatives regarding business matters 2. To process necessary transactions (e.g., payments, income processing)
   E-mail address
   Address and postal code
   Bank account information
   Telephone number
   My Number (personal identification number)

3. (iii) Personal information of shareholders

   Personal information we acquire	Purpose of use
   Name	1. To prepare records (shareholder registry, etc.) and manage shareholders in accordance with various laws and regulations 2. To send materials, etc. related to the General Meeting of Shareholders 3. To exercise rights and perform obligations under the Companies Act
   E-mail address
   Address and postal code

4. (iv) Personal information of employees, etc. (including their dependents)

   Personal information acquired	Purpose of use
   Name	1. To perform necessary procedures, including those related to hiring new employees, arrangement of social insurance, provision of benefits, business communications, various procedures required by law, and other procedures required for employment management 2. To contact and perform procedures in the event of a celebration or untimely event, such as marriage and death, and to perform other procedures necessary in connection with personal changes to employees, etc. 3. To perform duties related to wages, bonuses, retirement benefits, corporate pensions, etc. 4. To ensure appropriate health management and safety management, and secure a proper working environment, or to take appropriate measures to enable the Company to fulfill its duty of care for safety and ensure that employees conduct appropriate health management 5. To perform procedures necessary for work-related communication and business activities 6. To perform the following other administrative tasks – Employment insurance notifications, etc. – Health insurance and welfare pension notifications, etc. – Category 3 national pension filings – Preparation and submission of withholding tax certificates and other withholding tax-related matters – Administrative tasks related to each of the above items
   Date of birth
   Gender
   E-mail address
   Address and postal code
   Telephone number
   Current and past affiliations
   Employment history and occupation
   Personnel evaluations and self-assessments
   Education and qualifications
   Family Information
   Bank account information
   Salary Information (e.g., base salary, bonuses, benefits, work status, income tax, resident tax, withholding tax)
   Social insurance information (e.g., health insurance, welfare pension, worker’s accident insurance, employment insurance)
   Health information (e.g., information on medical examination results, health information related to leaves of absence, etc.)
   My Number (personal identification number)

5. (v) Personal information of prospective hires

   Personal information we acquire	Purpose of use
   Name	1. For employment selection 2. To contact and provide information to prospective employees
   Date of birth
   Gender
   E-mail address
   Address and postal code
   Telephone number
   Employment history and occupation
   Education and qualifications
   Family Information
   Salary Information (e.g., base salary, bonuses, benefits, work status, income tax, resident tax, withholding tax)

6. (2) We may change the purposes for which we handle personal data to the extent deemed reasonable in relation to the purposes set forth in the preceding clause.

4. Right to opt-out of the sale of personal information

Consumers can request that we stop selling personal information that relates to them or that we not sell their personal information in the future (refer to CCPA 1798.120(a)).
Please note that we do not sell Consumers’ personal information.

5. Method of acquisition of personal information

• We acquire personal information by the following methods.

• (i) Obtaining information directly from the Consumer (e.g., entry of personal information in application forms, etc.)

• (ii) Obtaining data indirectly from the Consumer (e.g., automatically obtaining IP addresses and other information from persons who visit our website and other sites by using cookies, advertising identifiers, and other similar technologies for tracking or analysis).
  *The Consumer may, at any time, prevent us from retrieving information via cookies or certain types of advertising identifiers (Advertising Identifier (iOS), Google Advertising ID (Android OS)) through their Internet browser settings or smartphone operating system (OS) settings. However, if cookies or advertising identifiers are not provided, we may be unable to provide all or part of our Services.
  *We may use Google Analytics to analyze access to our website and our Services.
Data collected through the use of Google Analytics is handled in accordance with Google’s Privacy Policy. Please refer to Google’s official pages below.

  –Google Analytics Terms of Use

  –Use by Google of information collected from sites and applications that use Google services

6. Provision of personal information

We may provide the personal information we have obtained to the following third parties for the purposes of handling personal information as described in this Notice.

1. (i) Our group companies

2. (ii) Professionals such as lawyers, tax accountants, certified public accountants, and social insurance consultants

3. (iii) Financial institutions

4. (iv) Subcontractors (e.g., system development and maintenance service providers, marketing and sales promotion service providers)

5. (v) Courts, investigative agencies, and other public institutions

7. Consumer rights

Consumers are granted the following rights, with respect to personal information that relates to them, if they meet the requirements under the CCPA.

1. (i) Right to demand disclosure (refer to CCPA 1798.110(a))

   Consumers can request disclosure of the following information regarding personal information related to them that we have obtained in the past 12 months. However, if a request for disclosure is made more than twice in the past 12 months, the request may not be honored.
   – Types of personal information we acquire
   – Type of source from which personal information was acquired
   – Purpose of acquiring personal information
   – Types of third parties with whom personal information is shared
   – Specific details of personal information acquired
   However, we reserve the right to verify the identity of the person requesting information in order to prevent unauthorized persons from accessing personal information, and we reserve the right to refuse to provide such information if we are unable to verify their identity.

   *We may request certain personal information (including but not limited to name, e-mail address, user ID, etc.) already in our possession for the purpose of identity verification. For requests made by proxy through a third party, a power of attorney document may be requested.

   Upon receipt of a request for disclosure, we will contact the requestor within 10 business days of receipt, and upon verification of the requestor’s identity, we will disclose the information within 45 calendar days from the date of receipt of the request.

2. (ii) Data portability rights associated with disclosure requests (refer to CCPA 1798.100(d))

   When disclosure is made by electronic means in response to a disclosure request by a Consumer, the Consumer has the right to receive the disclosed information in an easily usable format that can be transported and transferred to other entities.

3. (iii) Right to demand deletion (refer to CCPA 1798.105(a))

   Consumers have the right to request that personal information related to them be deleted.

   However, we reserve the right to verify the identity of the person requesting information in order to prevent unauthorized persons from accessing personal information, and we reserve the right to refuse to provide such information if we are unable to verify their identity.

   *We may request certain personal information (including but not limited to name, e-mail address, user ID, etc.) already in our possession for the purpose of identity verification. For requests made by proxy through a third party, a power of attorney document may be requested.
   Upon receipt of a request for deletion, we will contact the requestor within 10 business days of receipt, and upon verification of the requestor identity, we will delete the information within 45 calendar days from the date of receipt of the request.

4. (iv) Right not to be discriminated against (refer to CCPA 1798.125(a)(1)(A)-(D))

   Consumers have the right not to be discriminated against as a result of exercising their right to request disclosure or deletion of personal information from or by the Company, and the Company shall not engage in such discriminatory treatment.

8. Retention period of personal information

We retain personal information only for as long as is reasonably necessary to fulfill the purposes for which it is used (including fulfillinf legal, regulatory, governmental, tax, accounting standards, and disclosure requirements).
We promptly delete personal information when the retention period has expired.

9. Safety control measures

We establish proper security and maintain adequate technical and organizational safety control measures to protect personal information from accidental loss, unauthorized handling, unauthorized access, falsification, and leakage.
Also, if a data leak or equivalent occurs where a report is required by law, we will report it to the Data Subject and the authority in question.

10. Privacy notice updates

In order to reflect changes in our policy regarding the handling of personal information, or to respond to changes in applicable laws and regulations, etc., we may post an explicit notice on our website, application, or other service screen and indicate the date of the last update at the beginning of this Notice, and then change the content to the updated content after a certain grace period.

11. Contact address

Name: cocone corporation
3-1-18, Wakabayashi, Setagaya-ku, Tokyo Prefecture, 154-0023
Email：info@cocone.co.jp
Website：https://www.cocone.co.jp/
*Our head office is located in Japan.
Please note that we may be unable to respond immediately to your inquiry depending on when it is made, as it may be after business hours.

12. Miscellaneous (use of personal information within the past 12 months)

1. (1) The Company has acquired the following types of personal information during the past 12 months.

   Type	Example
   Identifier	User name, user ID, online identifier, Internet protocol address, email address, social media (Twitter, Facebook, etc.) ID, device identification number, cookies
   Types of personal information enumerated in CCPA 1798.80(e)	The above identifiers, employment information
   Characteristics of protected categories under CCPA or federal law	Age, sex, gender, and citizenship, etc.
   Personal asset information/information on products and services purchased, acquired, or considered for purchase, and other commercial information such as purchase and consumption history and trends	Settings related to events and direct marketing to customers
   Internet or other similar network activities	Browsing history, search history, and information about interactions with the Company’s Internet websites and applications
   Geolocation data	Location information
   Occupational or employment-related information	Company name, industry, position, length of time in position, job title, career level, employment classification, job description, skills, qualifications, current/recent annual salary, resume, job application, questionnaires, answers to questions we have established for prospective hires, and other information provided in similar correspondence, date of birth, name, age, languages spoken, and language ability
   Non-public education information	Education information (e.g., university name, major category, major, degree, GPA, and other educational and academic information)

2. (2) The Company has provided Consumers’ personal information to the following types of third parties in the past 12 months.

   Types of personal information	Types of third parties with whom we have shared personal information for business purposes
   Identifier	– Marketing and sales promotion service providers – System development and maintenance service providers
   Types of personal information enumerated in CCPA 1798.80(e)	N/A
   Characteristics of protected categories under CCPA or Federal Law	– Marketing and sales promotion service providers
   Personal asset information/information on products and services purchased, acquired, or considered for purchase, and other commercial information such as purchase and consumption history and trends	– Marketing and sales promotion service providers – System development and maintenance service providers – Product shipping companies
   Internet or other similar network activities	– Marketing and sales promotion service providers
   Geolocation data	– Marketing and sales promotion service providers
   Occupational or employment-related information	N/A
   Non-public education information	N/A