Privacy Policy

Good-Feel Co., Ltd. (hereinafter referred to as “the Company”), when engaging in Internet-related business such as the development and sale of software (including game applications) as well as the operation of websites and the Company’s recruitment activities shall appropriately use, sincerely store and manage the personal information (hereinafter simply referred to as the “Personal Information”) of customers and parties involved with the Company's business and recruitment activities (hereinafter collectively referred to as the “Person in Question”) under the principle of compliance (legal compliance) and privacy protection, including the provisions of the Act on the Protection of Personal Information (including the guidelines and other regulations of the Ministry of Economy, Trade and Industry under the same Act).

Chapter I. Handling of Personal Information

1. Provision of Personal Information

(1) The Personal Information handled by the Company includes the name, sex, date of birth, age, email address, language used, name of the country and region of residence, IP address, information on cookies (including technologies similar thereto; hereinafter referred to as the “Cookies”), and browser history, etc. of the Person in Question. If the Person in Question signs up for a service on the Company website through a social media service, the Company may, in addition to the above, acquire the nickname, profile image and other content posted by the Person in Question on the social media service.

(2) In the following cases, the Person in Question is expected to provide Personal Information:

  • In the case of subscribing for and participating in services, events and other things planned and offered by the Company;
  • In the case of conducting a specified transaction between the Company and the Person in Question; and
  • In the case of making an inquiry regarding any of the above, the Company's business, or other matters.

2. Purpose of Use of Personal Information

(1) The Company shall use the Personal Information provided by the Person in Question in accordance with Paragraph 1 above for the purpose of attaining the purpose and within the scope thereof as shown in the following examples. However, the case set forth in (2) below shall not be subject to the restriction under this paragraph:

  • Provision of the Company’s products (including software), services and an after-sale services;
  • Information on the Company’s new products (including software), development and examination of services as well as planned events (including campaigns incidental thereto, offering of and solicitation for a prize contests and other events);
  • Management of contract-related matters concerning the Person in Question;
  • Management of various claims relevant to the Company's business and services (including matters concerning billing, storage, preservation and assignment of claims);
  • Business analysis, statistics, preparation of investigation materials; and
  • Matters related to the above statements.

(2) The cases set forth in the proviso of the preceding (1) are as follows:

  • For disclosure or provision in accordance with laws and regulations;
  • If it is necessary to protect the life, body or property of an individual, and when obtaining the consent of the Person in Question is difficult;
  • If it is especially necessary for improving public health or promoting the sound growth of children, and when obtaining the consent of the Person in Question is difficult;
  • If it is necessary to cooperate with the organs of the State and local public entities or the parties entrusted by thereof in performing clerical work provided for by laws and regulations, and if the performance of the said clerical work is deemed likely to be hindered by the acquisition of the consent of the Person in Question; and
  • When using statistical data, materials, and other information for which the Personal Information is processed so as to prevent the identification of the Person in Question.

3. Change in Purpose of Use

When changing the purpose stated in Paragraph 2-(1) above, the Company shall notify the Person in Question or make an announcement (in principle, such announcement shall be made by posting the information on the website). However, this shall not apply to the following cases:

  • If the notification to the Person in Question of the purpose of use or announcement thereof is deemed likely to harm the life, body, or rights and interests including property of the Person in Question or a third party;
  • If the notification to the Person in Question of the purpose of use or announcement thereof is deemed likely to harm the rights or legitimate interests of the Company;
  • If it is necessary to cooperate with the organs of the State or local public entities in performing clerical work provided for by laws and regulations, and if the performance of said clerical work is deemed likely to be hindered by the notification to the Person in Question of the purpose of use or announcement thereof; and
  • If the purpose of use is clearly evident through the act of acquisition.

4. Ensuring Accuracy of Data Content

The Company shall endeavor to keep personal data (compiled database of Personal Information) accurate and up-to-date to the extent necessary for attaining the purpose of use.

5. Outsourcing

When outsourcing all or part of the handling of personal data, the Company shall perform necessary and proper supervision of the outsourcee so as to facilitate security control.

6. Notification of Purpose of Use

If the Person in Question requests that the Company notify them of the purpose of use of the retained personal data (personal data which the Company is authorized to disclose, correct and delete), the Company shall, in principle, verify the identity of the Person in Question, and then give such notification without delay. However, this shall exclude the cases stated in the proviso of Paragraph 3 above.

7. Provision to Third Parties

The Company shall not provide or disclose Personal Information the Company receives to any third party without obtaining the consent of the Person in Question beforehand. However, the following cases are exceptions:

  • When subject to laws and regulations;
  • If it is necessary to protect the life, body, or property of an individual, and when obtaining the consent of the Person in Question is difficult;
  • If it is especially necessary for improving public health or promoting the sound growth of children, and when obtaining the consent of the Person in Question is difficult; and
  • If the Company cooperates with the organs of the State, local public entities or the parties entrusted by them in performing clerical work provided for by laws and regulations, and if the performance of the said clerical work is deemed likely to be hindered by the acquisition of consent from the Person in Question.

8. Jointly Utilization

The Company may jointly utilize the personal information provided as follows. In addition, jointly utilizing persons are responsible for protection, handling of personal information, formulation and change of the privacy policy, etc. of the jointly utilized persons, however the Company bears absolutely no responsibility for thereof.

9. Request for Disclosure

If the Person in Question requests that the Company disclose the retained personal data which can be used to identify the said individual, the Company shall verify the identity of the Person in Question, and then disclose such information without delay. However, this shall exclude the case where such disclosure violates laws and regulations, or where such disclosure is deemed likely to significantly hinder the proper operation of the Company's business.

10. Correction and Suspension of Use of Personal Information

If the Company receives a request from the Person in Question for the correction or other alteration of the retained personal data concerning the said individual on the grounds that there is an error in the data, the Company shall in principle, upon verifying the identity of the Person in Question, make the correction and notify the Person in Question without delay. If the Company receives a demand for suspension of use and deletion of the retained personal data (hereinafter referred to as the “Suspension of Use, etc.”) on the grounds that it violates a law or regulation, and when the grounds for the Suspension of Use, etc. are found, the Company shall implement the Suspension of Use, etc. to the extent necessary for correcting such violation and also notify the Person in Question without delay.

11. Security Control of Personal Information

The Company shall perform security control of personal data and take preventive measures against unauthorized access, leakage, loss, falsification, etc.

12. Others

(1) Use of Cookies
The Company may use Cookies to improve the experience of those who access the Company website. However, the use of Cookies shall be within the standard industry scope and shall not deviate from the scope of the purpose of use stated in the Privacy Policy.

(2) If the Person in Question is under 16 years old
As stated in Chapter III, Paragraph 6, when the Person in Question is under 16 years old, the Person in Question is expected to provide Personal Information after obtaining the consent of a person with parental authority.

Chapter II. Handling of Personal Information in respect to the Company’s Recruitment Activities

Regarding the handling of personal information in connection with the Company’s recruitment activities, the following provisions of Chapter II shall apply instead of "1. Provision of Personal Information", "2. Purpose of Use of Personal Information" and "8. Jointly Utilization" of Chapter I. In addition. the provisions of Chapter I shall apply to the contents which have not stipulated in Chapter II.

1. Provision of Personal Information

(1) The personal information handled by the Company regarding recruitment activities includes the following personal information of the applicant.

  • Name, age, address, date of birth, telephone number, email address, educational background, work history, information of qualifications and the like, current annual income and/or desired annual income.
  • Information contained in documents submitted by applicants to the Company to apply for recruitment activities, regardless of format such as resume, curriculum vitae, entry form, questionnaire, etc.
  • Content of any form of communication (including communication in an interview, but not limited to) between the Company and the applicants, including dialogue, communication, telephone, etc.
  • Information that the Company obtains through background checks, reference checks, and other confirmation procedures for employment screening and
  • History of application/participation in recruitment activities and selection results in recruitment selection.

(2) Personal information handled by the Company may include information on gender, health condition, nationality, etc. (hereinafter collectively referred to as "sensitive information"). Providing sensitive information is voluntary, and the Company shall only obtain such sensitive information with the prior consent of the applicants. The acquired sensitive information shall only be used to the extent necessary to improve recruiting process including increased diversity in recruitment activities, to ensure appropriateness of the Company’s business (assignment, etc.) and health assurance, and to support the acquisition of necessary entry visas and work permits.

(3) The provision of personal information provided by the Person in Question shall assume in the followings:

  • In the case of applying for recruitment of the Company’s business (including regular and temporary employment) and
  • In the case of inquiring regarding the above.

2. Purpose of Use of Personal Information

(1) The Company shall use the Personal Information provided by the Person in Question for achievement of each purpose and within the scope thereof as shown in the following examples. However, the case set forth in (2) below shall not be subject to the restriction under this paragraph:

  • Evaluating for applicants eligibility;
  • Improving in recruiting process of the Company;
  • Ensuring appropriateness of the Company’s business (assignment, etc.) and health assurance;
  • Supporting the acquisition of necessary entry visas and work permits;
  • Contacting applicants;
  • Managing for applicants’ information; and
  • For purposes pertained recruiting activities such as statistical use for future recruitment plans, etc.

(2) The cases set forth in the proviso of the preceding (1) are as follows:

  • For disclosure or provision in accordance with laws and regulations;
  • If it is necessary to protect the life, body, or property of an individual, and when obtaining the consent of the Person in Question is difficult;
  • If it is especially necessary for improving public health or promoting the sound growth of children, and when obtaining the consent of the Person in Question is difficult;
  • If it is necessary to cooperate with the organs of the State and local public entities or the parties entrusted by thereof in performing clerical work provided for by laws and regulations, and if the performance of the said clerical work is deemed likely to be hindered by the acquisition of the consent of the Person in Question; and
  • When using statistical data, materials and other information for which the Personal Information is processed so as to prevent the identification of the Person in Question.

3. Jointly Utilization

The Company may jointly utilize the personal information provided as follows. In addition, jointly utilizing persons are responsible for protection, handling of personal information, formulation and change of the privacy policy, etc. of the jointly utilized persons, however the Company bears absolutely no responsibility for thereof.

  • Jointly utilized information
    Personal information specified in "1. Provision of Personal Information"
  • Scope of jointly utilizing persons
  • Purpose of utilization for jointly utilizing persons
    To achieve "2. Purpose of Use of Personal Information"
  • Responsible manager for jointly utilization
    The Company

Chapter III. Handling of Personal Information of a Person in Question Residing in the European Economic Area

EIn accordance with the EU General Data Protection Regulation (the “REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC”; hereinafter referred to as the “GDPR”), the provisions in Chapter III in addition to Chapter I and II shall apply to the handling of Personal Information of the Person in Question residing in the European Economic Area comprised of the EU member countries, Norway, Iceland and Liechtenstein (hereinafter collectively referred to as the “EEA”). If the provisions of Chapter I and II come into conflict with those of Chapter III, the provisions of Chapter III shall prevail.

1. Preamble

The purpose of this Policy is to explain how the Company, acting as the controller, gathers and processes personal data, which has been provided and disclosed by a person residing in the EEA (hereinafter referred to as the “Data Subject”), or which the Company has received and acquired through a third party.

2. Handling of Personal Information

The method and purpose for handling the Personal Information of the Person in Question by the Company, types of the Personal Information of the Person in Question handled by the Company, and the provision and jointly utilization of the Personal Information of the Person in Question to third parties are as stated in Chapter I, Paragraph 1 through Paragraph 8 and Chapter II, Paragraph 1 through Paragraph 3.

3. Legal Basis

In principle, the consent of the Person in Question provides the legal basis for the use of Personal Information by the Company. If the Person in Question does not give his/her consent, the following form the legal basis for the use of Personal Information; as a necessity for performing a contract with the Person In Question, as a necessity for executing the procedures according to a request from the Person in Question before the execution of the contract, as a necessity for legitimate interests sought by the Company or a third party, or as a necessity for complying with legal obligations which the Company is to assume. An increase in profit, etc. due to improvements, etc. of marketing and services, improvements, etc. of the accessibility and security of the Company website fall under “legitimate interests sought by the Company or a third party.”

4. Handling of Requests concerning Personal Information

In addition to complying with Chapter I, Paragraph 6 (Notification of Purpose of Use), Paragraph 9 (Request for Disclosure), Paragraph 10 (Correction and Suspension of Use of Personal Information), the Company shall respond to requests concerning the Personal Information of the Person in Question residing in the EEA within a reasonable period of time and scope as follows. Note that when processing a request, the Company shall verify the identity of the Person in Question in advance.

  • (1) Requests concerning withdrawal of consent
    Upon confirming the details of a request, the Company shall delete or suspend the use of the content concerning the Personal Information of the Person in Question to the appropriate and possible extent. Note that as a result of the suspension of use or deletion, the Company may become unable to provide services which have been available or services which meet the needs of the Person in Question. Fully understand the above before filing a request.
  • (2) Request concerning data portability
    Upon confirming the details of a request, the Company shall deliver or receive the Personal Information desired by the Person in Question to the appropriate and possible extent.
  • (3) Handling of requests restricting the use of Personal Information
    Upon confirming the details of a request, the Company shall undergo the procedures desired by the Person in Question to the appropriate and possible extent.
  • (4) Requests concerning filing of objections
    Upon confirming the details of a request, the Company shall suspend the use of the Person in Question’s Personal Information to the appropriate and possible extent.
  • Making requests
    The Person in Question may contact the below-mentioned “Contact Address for Inquiries” to exercise the rights provided for in this paragraph.

5. Transfer of Data outside the EEA

If the Company is compelled to internationally transfer the acquired personal data to a third country outside of the EEA, the Company shall take proper protective measures necessary for international data transfer. When conducting marketing, business activities or service provision for the Company's various businesses, the Company may use a server provided by an overseas service operator.

6. Person in Question under 16 Years Old

When using the Company's services and other similar items, if a Person in Question residing in the EEA is under 16 years old or has not reached the age limit under the laws of the EU member country, the Person in Question is expected to obtain the consent of a person with parental authority or obtain the person with parental authority's permission to give him/her consent. If the person with parental authority files or fills out an application for use, etc. of the Company's services on behalf of the Person in Question, the person with parental authority is expected to obtain the consent of the Person in Question with respect to the handling of the Personal Information by the Company before filing the application.

7. Personal Data Retention Period

The Company shall store and manage the personal data acquired or gathered from the Person in Question for a required period according to the purpose stated above. If the personal data becomes unnecessary in light of the purpose stated above, the Company shall, in principle, delete the personal data promptly.

8. Non-existence of Automated Decision-Making Including Profiling

The Company may analyze the access logs of the Company website. However, the Company shall not perform automated processing (including profiling) for analyzing and forecasting the personal preferences and actions of the Data Subject by utilizing the Personal Information provided, and decision-making which legally affects the Data Subject.

9. Appeals to a Supervising Body

With respect to the processing of the relevant Personal Information, the Person in Question has the right to raise an objection to the data protection authorities having jurisdiction over the place of residence of the Person in Question. Data protection authorities in the respective countries can be checked at the URL below:
( http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 )

Supplementary Provisions

(1) This Privacy Policy shall come into effect on December 20, 2021
The contact address for inquiries with respect to Chapter I, Paragraphs 6, 8 and 9, and Chapter II, Paragraph 4 is stated below. The Company shall endeavor to process complaints and opinions sent to us appropriately and promptly.

[Contact Point for Handling Personal Information]

Good-Feel Co., Ltd.
Osaki New City 3rd. 9F, 1-6-3 Osaki, Shinagawa, Tokyo 141-0032

Established on September 1, 2008
Last revised on December 20, 2021
Representative Director, Etsunobu EBISU