Privacy Policy

K.K. Tokenz (株式会社Tokenz), a company incorporated in Japan with its registered office in Tokyo (hereinafter referred to as "Tokenz", "we", "us", or "our"), is the data controller of your personal data and collects and processes digitized personal information (hereinafter referred to as "personal data") from customers only when necessary for us or in connection with transactions with customers. This Privacy Policy (hereinafter referred to as "this Privacy Policy") sets forth our privacy practices regarding the collection, processing, use, disclosure, transfer, retention, storage, and disposal of your personal data when providing our services to you, and applies to all users of Tokenz services worldwide. Region-specific terms are set out in the regional annexes at the end of this Privacy Policy (Annex A — EEA & UK; Annex B — California; Annex C — Japan) and apply in addition to this Privacy Policy if you are located in the relevant region.

In the event of any inconsistency between this Privacy Policy and other privacy policies/notices on our platform, this Privacy Policy shall prevail to the extent necessary to resolve the inconsistency. References in this Privacy Policy to Tokenz group companies describe recipients or service providers acting on our behalf; they are not the data controller. Where a regional annex applies to you, the terms of that annex prevail over the main body of this Privacy Policy to the extent of any inconsistency. If more than one annex applies to you, the annex conferring the greater protection prevails in respect of the matter concerned.

"Personal information" refers to information about a living individual that can identify a specific individual by name, date of birth, or other description contained in the information (including information that can be easily collated with other information to identify a specific individual, even if the information itself cannot identify an individual). Personal information collected and processed by us includes the following:

Tokenz's contact information is as follows:

We collect, process, use, disclose, transfer (including overseas transfer), retain or store, and dispose of your personal data on the legal bases described in this Privacy Policy and, where applicable, Annex A. Where applicable law requires your consent for a specific processing activity (for example, marketing communications), we obtain that consent separately; browsing our website or using Tokenz services does not by itself constitute consent.

This Privacy Policy applies only to personal information held or controlled by us.

We collect and process your personal information for the purpose of enabling you to purchase digital content provided by third-party merchant partners (hereinafter referred to as "Publishers") from us, your mobile network operator, or relevant payment channel operators (hereinafter referred to as "Payment Channels") through Tokenz's mobile platform, server or database application, or website www.tokenz.one (hereinafter referred to as "Platform").

We reserve the right to change this Privacy Policy from time to time without prior notice to you. Any changes will be posted and available for viewing on our Platform and will take effect on the effective date at the end. You can determine if changes have been made by referring to the last updated date of this Privacy Policy at the end. We recommend that you check this Privacy Policy regularly to confirm the latest version. If you continue to use Tokenz services and/or our Platform after the changes, you will be deemed to have reviewed and accepted such changes to the extent permitted by applicable laws.

We collect personal information when you use Tokenz services and/or our Platform and/or contact us. You may provide personal information directly to us, or our affiliates or subsidiaries, Payment Channels, or Publishers may share personal information with us based on your consent to such third parties.

The personal information we collect and process includes:

Collection of Additional Personal Data: Only in cases where we need to refund you, we collect the following personal data (hereinafter referred to as "Additional Personal Data") on behalf of certain Payment Channel partners, in addition to the personal data specified in Section 2.2 of this Privacy Policy:

Additional Personal Data is collected from you only when you request a refund or when we determine that you are entitled to a refund, and when the payment method you originally used requires the collection of Additional Personal Data to process the refund.

Additional Personal Data will not be used for any other purpose.

If you wish to delete the Additional Personal Data after the refund has been processed, please contact our Data Protection Contact at privacy@tokenz.one.

You may provide personal information to us through other methods, including:

We collect personal information that you have agreed to share through that social media site or third-party platform.

We collect transaction information such as purchase amount, purchase date, digital content, goods, or services purchased (hereinafter referred to as "Transaction Data"). In many cases, you cannot be identified personally from this information, so it is not considered personal information. However, to the extent that you may be identified from the Transaction Data, such information is considered and processed as personal information under this Privacy Policy. We collect such Transaction Data when you use Tokenz services and/or our Platform, on the legal bases described in this Privacy Policy and, where applicable, Annex A.

We do not request or knowingly collect information or data related to medical conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information or data, biometric information or data, criminal history, or accusations. Identity documents you provide for verification (Section 2.2) are used only to verify your identity and not to collect any of the above categories of information.

We do not knowingly directly or indirectly collect information or data that could identify individuals under the age of majority in your country (hereinafter referred to as "minors"), except where a parent or guardian has provided consent as described in Section 9. If we become aware that a minor has provided us with personally identifiable data without such consent, we will delete such information or data from our database. If a guardian becomes aware that a minor has provided us with personal information or data without consent, please contact us at privacy@tokenz.one.

You shall provide us with accurate and non-misleading information. In this regard, we reserve the right to request submission of materials to verify the information you have provided to us.

Your personal data will be processed for the following purposes:

Where the GDPR or UK GDPR applies to you, the legal bases on which we rely for these purposes are set out in Annex A.

Transaction Processing and Content Delivery

(i) Tokenz uses your personal information and shares it with third parties (including affiliates or subsidiaries, Payment Channels, and Publishers) for the purpose of providing Tokenz services as a payment channel aggregator, online digital content delivery company, and related service provider, or when necessary for transactions with you.

(ii) Your personal information is processed specifically for the purposes set out in Section 3.1.

Marketing and Promotional Campaigns

(i) We occasionally conduct marketing and promotional campaigns to reward users who have achieved top usage on our Platform in specific countries, publishers, or other categories. For this purpose, we may analyze your Transaction Data and use your personal information to contact you in order to award prizes (usually free credits from publishers or Payment Channels or other free gifts) offered in such promotional campaigns. These promotional campaigns are conducted by Tokenz, and your personal information will not be shared with third parties for this purpose.

(ii) If you wish to opt out of receiving gifts and other prizes from our promotional events, please contact us. If you wish to receive marketing and promotional communications, we may use your personal information and share your name, email address, and/or mobile phone number to notify you of marketing and promotional campaigns related to Tokenz services or conducted jointly or in partnership with publishers, Payment Channels, or third parties. If you wish to opt out of receiving marketing and promotional communications or refuse the disclosure of your personal information for this purpose, please contact us. You can opt out of receiving marketing and promotional emails by clicking the unsubscribe button included in the emails.

Disclosure and Provision to Third Parties

We disclose or provide your personal information to third parties only as described below and in accordance with applicable law. Where the law applicable to you regulates the provision of personal data to third parties (for example, the APPI in Japan), such provision is subject to the requirements of that law, including any applicable consent requirement, as further described in the relevant regional annex.

(a) To the parties involved in your transaction: the Publishers of the digital content you purchase and the Payment Channels you select as your payment method.

(b) To Tokenz group companies (our affiliates and subsidiaries) and to service providers acting on our behalf, for the purposes set out in Section 3.1.

(c) In connection with a merger, sale of company shares or assets, financing, acquisition, divestiture, or dissolution of all or part of our business.

(d) Where we determine that disclosure is reasonably necessary to (i) comply with applicable laws, regulations, legal process, or government requests, (ii) cooperate with investigations or legal proceedings, or (iii) protect the safety or integrity of Tokenz services, us, our users, or the public from harm or illegal activities.

When we process your personal information solely based on your consent, you have the right to request deletion of your personal information or withdraw your consent and request cessation of use. If you wish to have your personal information deleted or do not want it to be used or processed for the above purposes, please contact us. However, please note that if your personal information is deleted or you withdraw your consent for the above purposes, we may not be able to continue providing Tokenz services or process and complete the transactions you desire on the Platform, depending on the nature of your request.

You have the right to request access, update, or correction of the personal information you have provided to us at any time. You also have the right to request information about the purposes for which personal information or personal data is shared, the legal framework, recipients, or types of information received, and information about transfers to third countries. If you wish to access, update, or correct your personal information held by us, please contact us. We handle such requests free of charge, except where a charge is permitted by applicable law; if a permitted charge applies, we will notify you as soon as reasonably practicable.

Your personal information will be retained for the period necessary to achieve or complete the purpose for which it was collected, and for as long as it is necessary for other legal or business purposes. Thereafter, we will dispose of your personal information by methods (including, but not limited to, deletion or irreversible anonymization) that prevent further access or processing.

Tokenz makes reasonable efforts to protect your personal information from loss, misuse, alteration, or unauthorized or accidental access, disclosure, tampering, or destruction. Unfortunately, we cannot guarantee that data transmission or storage on the Internet is completely secure. However, within our reasonable capabilities, we adopt and implement administrative security, organizational security, technical security, and physical security measures (including, but not limited to, the following) to protect your personal information:

Limiting access to personal information to authorized and/or necessary personnel

Implementing technical solutions to ensure information security

Continuous monitoring and review of personal information protection measures

Other security measures required by laws and regulations applicable in your country of residence.

Tokenz operates internationally. Therefore, you acknowledge and understand that we may store your personal data in different countries or share your personal information with recipients (such as publishers, Payment Channels, or Tokenz's affiliates/subsidiaries) located in countries other than the country where your personal data was originally collected, subject to applicable data localization regulations, for the purpose of providing Tokenz services, processing and completing transactions you desire on the Platform, or for other purposes set forth in this Privacy Policy.

In the above cases, we apply the transfer mechanism required by the law applicable to the transfer, as further described in the regional annexes to this Privacy Policy. Where personal data is transferred out of Japan, we take measures to ensure a level of protection equivalent to that required by the Act on the Protection of Personal Information (Act No. 57 of 2003) and its related regulations, guidelines, and circulars (see Annex C). Where personal data is transferred out of the European Economic Area or the United Kingdom, we apply the mechanisms described in Annex A. Transfers subject to the law of any other region are governed by the corresponding annex, where one applies.

The following is a list of countries and regions to which your personal data may be transferred: Japan (our primary infrastructure, hosted on Google Cloud Platform in the Tokyo region, and our operations); Singapore, Taiwan, and the United States (Tokenz group companies that process transactions and payouts, with operations and support staff located in Japan and Taiwan); the United States (service providers such as cloud, analytics, and support tools); and the countries and regions in which the Publishers and Payment Channels involved in your transaction operate. Further information about the categories of recipients and subprocessors we use is available on request via privacy@tokenz.one.

When you interact with our Platform, we use "cookies" and similar technologies to collect statistical information about your website usage and online activities, and allow third parties (including, but not limited to, Google Cloud Platform, Facebook, and Google) to collect such information. Statistical information is aggregated and does not directly identify you; to the extent it can be linked to you, it is treated as personal information under this Privacy Policy (see Section 2.2). Statistical information includes page visits, access dates and times, and browser types. This information is collected for analysis and evaluation to improve our Platform and Tokenz services. For more details, please refer to our Cookie Policy.

"Cookies" are a function of internet browsers that store small amounts of data on your computer when you visit a website. This allows us to recognize specific devices or browsers, personalize and curate content according to your preferences, and make our services and Platform more beneficial to you. We do not identify you through "cookies" unless you specifically provide personally identifiable information. You can manage and delete "cookies" by selecting specific options in your browser.

Your statistical data may be shared with third-party partners only to the extent necessary to: (i) provide or optimize Tokenz services, and (ii) support our own advertising and analytics.

Tokenz services are not provided to minors. If you are a minor, you may use Tokenz services and/or the Platform only with the consent, permission, and supervision of a parent or guardian, and within the scope of consent in accordance with specific age restrictions on digital content that may be imposed by the government of your country.

If you are a parent or guardian supervising a minor who wishes to use Tokenz services and accept this Privacy Policy on behalf of the minor, you agree to the processing of the minor's personal information in accordance with this Privacy Policy.

Our Platform may contain links to other websites that we do not control. When accessing such third-party websites, please refer to their respective privacy policies. We are not responsible for the content, use, or privacy practices of third-party websites.

For inquiries regarding this Privacy Policy or your personal information (including, but not limited to, withdrawal of consent, refusal to receive gifts and prizes, opting out of marketing and promotional communications, requests for access to personal information, requests for updating or correcting personal information, or exercising rights under this Privacy Policy or applicable data protection laws), please contact our Data Protection Contact at privacy@tokenz.one.

For other issues, please refer to our Help Center or contact us via privacy@tokenz.one.

This Privacy Policy shall be governed by and construed in accordance with the laws of Japan, without regard to its conflict of law provisions. We will endeavor to resolve any disputes arising from or related to this agreement (including any issues concerning the existence, validity, or termination of this agreement) amicably, but if a resolution cannot be reached, such disputes shall be subject to the exclusive jurisdiction of the courts in Tokyo, excluding all other courts.

If you are a California resident, the following terms apply in addition to this Privacy Policy.

Categories of personal information. In the preceding 12 months, we have collected the following categories of personal information, as described in Section 2: identifiers (such as name, email address, phone number, and IP address); commercial information (such as transaction and refund details); internet or other electronic network activity information (such as browsing behavior collected via cookies); financial information (such as bank account details when we process a refund); and professional or employment-related information (such as resume contents when you apply for a role with us). We collect these categories for the purposes described in Sections 2 and 3.

Notice at collection. The table below summarises the categories of personal information we have collected in the preceding 12 months, their sources, the purposes for which we use them (using the purpose codes in Section 3.1), and the categories of recipients to which each is disclosed for a business purpose. Further detail appears in Sections 2, 3 and 5.

No sale or sharing. We do not sell personal information. We do not share personal information for cross-context behavioral advertising as defined under the CCPA/CPRA. Our analytics providers are configured to act as our service providers and are deployed only on our public marketing website, not in our checkout or payment flows. We have not sold or shared personal information in the preceding 12 months.

Sensitive personal information. Certain information we collect is "sensitive personal information" under the CPRA, namely the account password you create (Section 2.2), the bank account details we collect to process a refund (Section 2.3), and any identity documents we collect to verify the information you provide (Section 2.2). We use and disclose this information only for purposes permitted under California Civil Code Section 1798.121 and 11 CCR Section 7027 - namely providing the Tokenz services you request, securing your account, preventing fraud, and verifying your identity - and not to infer characteristics about you or for any other purpose. Because we limit our use of sensitive personal information to these permitted purposes, we are not required to, and do not, offer a "Limit the Use of My Sensitive Personal Information" option.

Retention. We retain each category of personal information for the period necessary to fulfil the purposes described in Section 5 and to meet our legal, tax, and accounting obligations, after which we delete or irreversibly anonymise it.

Your rights. You have the right to know, the right to delete, the right to correct, the right to opt out of the sale or sharing of personal information, and the right not to receive discriminatory treatment for exercising these rights. You can submit requests via privacy@tokenz.one. To exercise these rights, contact privacy@tokenz.one. We respond to verifiable consumer requests within 45 days of receipt; where reasonably necessary, we may extend this period by a further 45 days and will notify you of the extension. Before responding, we verify your identity to a degree of certainty appropriate to the request. An authorised agent may submit a request on your behalf if they provide signed permission from you, and we may require you to verify your identity directly with us.