個人情報保護方針
合同会社CooperLand（以下「当社」）は、以下のとおり個人情報保護方針を定め、個人情報保護の仕組みを構築し、全従業員に個人情報保護の重要性の認識と取組みを徹底させることにより、個人情報の保護を推進致します。

個人情報の管理
当社は、お客さまの個人情報を正確かつ最新の状態に保ち、個人情報への不正アクセス・紛失・破損・改ざん・漏洩などを防止するため、セキュリティシステムの維持・管理体制の整備・社員教育の徹底等の必要な措置を講じ、安全対策を実施し個人情報の厳重な管理を行ないます。

 個人情報の利用目的
お客さまからお預かりした個人情報は、以下の利用目的のために利用いたします。

(1) 広告配信のため
(2) パフォーマンス分析のため
(3) アプリケーション改善のため
(4) ユーザーへのサポート・不具合対応のため

 個人情報の第三者への開示・提供の禁止
当社は、お客さまよりお預かりした個人情報を適切に管理し、次のいずれかに該当する場合を除き、個人情報を第三者に開示いたしません。
・お客さまの同意がある場合
・お客さまが希望されるサービスを行なうために当社が業務を委託する業者に対して開示する場合
・法令に基づき開示することが必要である場合

個人情報の安全対策
当社は、個人情報の正確性及び安全性確保のために、セキュリティに万全の対策を講じています。

ご本人の照会
お客さまがご本人の個人情報の照会・修正・削除などをご希望される場合には、ご本人であることを確認の上、対応させていただきます。

法令、規範の遵守と見直し
当社は、保有する個人情報に関して適用される日本の法令、その他規範を遵守するとともに、本ポリシーの内容を適宜見直し、その改善に努めます。

 お問い合せ
当社の個人情報の取扱に関するお問い合せは下記までご連絡ください。
合同会社CooperLand
〒153-0061
目黒区中目黒5-3-10
bigbutterentertainment@gmail.com

Last updated: 11 May 2021.

This Privacy Policy explains who we are, how we collect, share and use personal data about you, and how you can exercise your privacy rights. This Privacy Policy applies to Big Butter.Inc websites, games and related services, which we here collectively call the Service. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

THIS PRIVACY POLICY INCLUDES INFORMATION ON

What data we collect about you
How we use your data
Who can see your data?
How we protect your data when transferred internationally
Your rights and options
Our use of cookies and similar technologies
How we protect your data
Age Limits

DATA WE COLLECT

Data you provide us
Contact information (such as name and e-mail address)
Player name or tag and password
Profile information (such as profile photo)
Your messages to the Service (such as chat logs and player support tickets)
Other data you choose to give us (such as data to identify a lost account)

Data we collect automatically

Data about your account and game progress

Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrierData we collect with cookies and similar technologies (see more below)General location data (as derived from IP address)Precise geolocation data (GPS, with your consent)Data about your use of the Service, such as gameplay data and your interactions with other players inside the ServiceData we collect from our partnersData we receive if you link a third-party tool with the Service (such as Facebook, Google or Apple’s Game Center)Demographic data (such as to determine the coarse location of your IP address)Data to fight fraud (such as refund abuse in games or click fraud in advertising)Data from platforms that the games run on (e.g. to verify payment)Data for advertising and analytics purposes, so we can provide you a better ServiceData that you have made available to us from a third party service (such as Google or Facebook) via your privacy settings

WHY DO WE COLLECT YOUR DATA?

We use your data for a variety of business purposes, such as:

To make the Service work

To perform the contract, we process data necessary to

Create accounts and allow you to play our games and use our ServiceOperate the ServiceVerify and confirm paymentsProvide and deliver products and services you requestSend you Service-related communicationsTo make the Service more suitable for our players

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

Update and develop player profilesDevelop and improve the Service and player experienceManage our relationship with youProvide social features as part of the ServiceCustomize your Service experienceRespond to your comments and questions and provide player supportProvide you Big Butter.Inc offers in the Service as well as in other websites and services, and by e-mailSend you related information, such as updates, security alerts, and support messagesEnable you to communicate with other playersEnable and verify certain actionsAnalyze the performance of the advertisements displayed in the ServiceTo show personalized advertisements

To show you personalized advertisements in the Service as well as in other websites and services (including e-mail) we have a legitimate interest to process necessary data to

Track the content you access in connection with the Service and your online behaviorDeliver, target and improve our advertising and the Service

For information on how to opt-out from personalized advertisements, see section ‘Your rights and options’ below.

To keep the Service safe and fair

In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

Analyze and monitor use of the Service and its social featuresModerate chats either automatically or manuallyTake action against fraudulent or misbehaving playersTo analyze, profile, and segment

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

With your consent

With your consent, we may process your data for additional purposes.

WHO CAN SEE YOUR DATA?

Apart from Big Butter.Inc, your data can be accessed by others in the following situations.

Other players and users

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities, leaderboard position and read the messages you have posted.

Partners working for Big Butter.Inc

Big Butter.Inc has partners to perform services for us. These partners process your data only at and according to Big Butter.Inc’ instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.

Other companies and public authorities

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

Advertising, Social Media and other third partners

The Service includes features, such as social media interaction tools and in-game advertising, provided by our below listed partners who operate under their own privacy policies as data controllers. These partners can use advertising identifiers, cookies, web beacons, and other tracking technologies to collect or receive data about you and your device (such as your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share data we have collected about you with third-party advertising partners. Our statements under this Privacy Policy do not apply to the features, technologies or practices of such third parties, as we may not control those features and are not responsible for them. We encourage you to check their privacy policies to learn more about their data processing practices.

Facebook https://www.facebook.com/about/privacy/update

Google Play, Admob, Analytics, Firebase and Crashlytics https://policies.google.com/privacy

Apple App Store https://www.apple.com/legal/privacy/en-ww/

Appsflyer https://www.appsflyer.com/product/data-privacy/

Interest-Based Advertising

The Service may use third parties such as network advertisers and ad exchanges to serve you ads, including interest-based ads, on the Service or on third-party services after you leave the Service, and we may use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Service and viewing of ads and of our content. “Interest-based ads” are behavioral ads targeted to you based on your activities across third-party sites and across time, including retargeting of ads after you have left the Service and are on a third-party service.

INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

YOUR RIGHTS AND OPTIONSOpt-out of marketing e-mails and other direct marketing

You may opt-out of receiving promotional communications, such as marketing e-mails from us by following the instructions in such communications.

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your iOS or Android device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). You can also visit the Digital Advertising Alliance (DAA) Opt-Out Page, which provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.  Additionally, some third parties that serve Interest-based ads via mobile apps may offer you choices regarding such practices and their technologies, including offering a device-based opt-out option via a downloadable app available at: http://www.aboutads.info/appchoices. We are not responsible for this app, including without limitation its accuracy or limitations, or any representations made in connection with it.

For personalized in-game advertising you will be asked for consent before watching the first ad. If we have collected and process your personal information with your consent, then you can withdraw your consent at any time using the options provided in the game settings. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Access the personal data we hold about you

If you request, we will provide you a copy of your personal data in an electronic format.

Your other rights

You also have the right to correct your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.

You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority. We will respond to all requests in accordance with applicable laws. To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request, such as by requesting you provide us a purchase receipt or other account information, asking you to link your email address with your game account or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to our customer support staff, as required by applicable law.

You may have a right not to receive discriminatory treatment as a result of your exercise of these rights.

COOKIES AND SIMILAR TECHNOLOGIES

To provide our Games and interest-based advertising, we use advertising identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.

Advertising identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third-party advertising partners to (i) recognise you and your device; (ii) provide interest-based advertising to you; (iii) allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction); (iv) allow our payment processors to process your payment instructions; and (v) enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language (subject to availability).

Advertising identifiers are non-permanent, non-personal identifiers such as the
Android advertising ID and/or Apple’s ID for advertising (IDFA), which are uniquely associated with your device. Similar technologies include cookies on Websites and tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

If you wish to prevent your device’s advertising identifier being used for interest-based advertising, please check the privacy settings of your mobile device and select “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). You can also choose to reset your device’s ad identifier from the device settings. In a similar way, you can also disable cookies from your browser’s settings if you do not want to be tracked by websites. This Privacy Notice does not apply to, and we are not responsible for the data collection practices of these third-party advertisers. Please see more information about these partners under the “With whom do we share your personal information” heading above. You may also see our own advertisements in other games and services. If you click such advertisements and install our Game(s), we may share a device identifier with our partners to verify installs.

How do we keep your personal information secure?

We use appropriate technical and organisational measures designed to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include that only those of our employees, who on behalf of their work are entitled to process personal information, are entitled to use a system containing personal information. Each user has a personal username and password to the system. The information is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and the backup copies are in locked premises and can be accessed only by certain pre-designated persons. We also aim to minimize the personal information that we process, for example, our Games do not require you to register an account with your name and other details. Moreover, we use only advertiser identifiers and other more technical information to recognize players.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, our servers are located in Germany and Finland, and our third-party service providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses or other similar arrangements (such as the Privacy Shield certification regarding transfers to United States) for transfers of personal information between us and our third-party service providers and partners located outside the European Union or European Economic Area.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

AGE LIMITS

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services.  If you are under 13 (or the applicable age in their territory), please do not send any data about yourself to us, including your name, address, telephone number, or e-mail address.  No one under the age of 13 may provide any personal data.  If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible.  If you believe that we might have any data from or about a child under the age of 13, please contact us.

How to contact us?

The data controller is BIg Butter.Inc, Meguroku Nakameguro 5-3-10 Japan.

Should you have any questions regarding this Privacy policy or the processing of your personal information, please contact us at bigbutterentertainment@gmail.com

To restrict the use of your personal data, to remove, correct or access it, please contact us via email bigbutterentertainment@gmail.com

Please note that removing your personal data will also remove the social media link that grants you access to your account. After your data is removed, your account will no longer be accessible or recoverable for use.