Privacy Policy for End Users Outside of Japan


“Adfurikun” (“the Service”) is an ad-sorting service provided and operated by Glossom Inc. (“the Company”). This Privacy Policy for End Users Outside of Japan ("the Policy") stipulates collected information from the end users outside of Japan (“End Users”) who view and browse the media that the Company operates outside of Japan (“the Media”) using the Service and the processing of information. This processing of information means any operation or series of operations carried out on personal data or a set of personal data, either by automatic means or otherwise and this operation means acquiring, recording, editing, structuring, storing, modifying or changing, restoring, referring to, using, disclosing by transfer, publicizing or making publicizing possible, aligning or combining, restricting, deleting or destroying.
In receiving User Information (defined below) from End Users, the Company will comply with the laws and regulations regarding the protection of personal information outside of Japan including GDPR, other relevant laws and regulations, and other guidelines, etc., and will use such information appropriately and in light of the Company's business activities.
Please note that End Users residing in the United States should also review the terms and conditions of Rules and Regulations in Particular Countries.
End Users should review the Policy before viewing or browsing the Media.

1. Acquisition of User Information
Each time an End User displays or clicks on an advertisement on the Media, the End User’s IDFAGoogle Advertising ID, user agent, IP address, device information, and country of residence information ("User Information") will be automatically transmitted to and stored on the servers of the Company and the servers of the Ad Network Operators contracted by the Company.
If the latest and accurate information is not provided to the Company, the End User may not be able to receive appropriate services.

2. Purpose of Use of User Information and Data Retention Period
The Company will use User Information for the following purposes in the Service.
・Confirmation of Advertising Results
・Content Targeting
・Provision of User Information to third parties as described in "5. Provision and Disclosure of User Information”

Personal information will be deleted when it is no longer needed to fulfill the purposes of use described above, except when it is necessary to comply with applicable laws, regulations, or orders of government, courts, and other supervisory authority.

3. Basis for Handling User Information
The Company processes User Information obtained from the End User based on its legitimate interest in displaying the most relevant advertisements to the End User or the End User’s consent to the privacy policy with a link attached to the Policy. In the case of handling by consent, each End User can withdraw its consent at any time. The legality of the handling based on an End User’s consent before withdrawal will not be affected by the withdrawal of consent. End Users who wish to withdraw their consent shall check "8. Suspension of Acquisition of User Information and the Rights of End Users”.

4. Policy on Children
The Service is not intended for children under the age of 16 and the Company will not intentionally collect or request personal data or allow usage of an app by children under the age of 16. If an End User is under the age of 16, please do not send the Company any personal information such as name, address, phone number, email address, etc. Children under the age of 16 may not provide personal information. If personal data of a child under 16 is found to be collected, the Company will delete such data. If the Company seems to have received data from a child under the age of 16, please contact the Company from “10. Contact” below.

5. Provision and Disclosure of User Information
1. Disclosure to Third Parties
The Company may provide and disclose statistic data of User Information sent and stored in the Company’s servers to third parties.
In addition, the Company may disclose User Information to third parties in the cases set forth in "Provision and Disclosure of User Information" in "PRIVACY POLICY ".

2. Information Collection Module
The Service includes information collection modules provided by third parties that manage and provide ad networks linked to the Service (“Ad Network Operator”). The Company will provide User Information to Ad Network Operators for the purpose of Content Targeting and ad results confirmation, and Ad Network Operators will process the User Information collected by the information collection module in accordance with their own privacy policies. Please check here for the privacy policy of each Ad Network Operator.

6. Information Transfer to Third Parties Outside of Japan
The Company stores User Information by itself in Japan. Additionally, the Company will transfer the User Information to its contracted Ad Network Operators located out of the country or region that the End User resides. In countries in which third parties are located outside of the country or region that the End Users resides, personal data protection laws may not be adequate and appropriate protection measures at the same level as the country or region that the End User resides may not be available. the End User who provides User Information in order to use the Service is deemed to have agreed to the followings:
1. The Company’s handling of User Information in accordance with the Policy
2. Storing and processing of User Information in facilities outside of Japan (including cloud storage and cloud computing operated by third parties) that the Company can use or in contracted contractors of the Company outside of Japan or Ad Network Operators

7. Management of User Information: Security
1. Management of User Information
The Company has appointed a personal information protection manager who is responsible for implementing policies on matters related to User Information and the management of User Information. The Company also provides training and education opportunities to board members and employees to foster a spirit of compliance in accordance with the Policy and the Company’s information handling practices.

2. Security
The Company will use reasonable, organizational, technical, and administrative measures to protect the User Information under our control.

8. Suspension of Acquisition of User Information and the Rights of End Users
The Company complies with the opt-out mechanism set forth by Google or Apple. End Users can suspend or limit the acquisition of User Information by deactivating (opting out of) the User Information acquisition function either on their iOS or Android device.
End Users can also reset User Information on their iOS or Android device. If you wish to restrict the distribution of advertisements using the User Information in the Service, you can do so by configuring the setting on your device.

Opt-out page for iOS users: click here
For Android users: click here

The Company does not integrate, correlate, connect, or associate, either directly or indirectly, any information obtained from IDFA prior to the reset or information associated with the reset with any previous IDFA.
End Users have rights to access, correct, delete, limit processing, data portability, and raise an objection to their own User Information that the Company holds (“Data Subject Rights”).

Please contact the Company if you wish to request any of the rights to your own User Information that cannot be achieved through iOS or Android device settings, or if you have any questions about how to set up your device.

You also have the right to lodge a complaint about the handling of your personal information with the supervisory authority having jurisdiction over your place of residence.

9. Publication, Amendment, etc. of the Policy
i. Publication and Amendment
The Policy is posted and publicized in the privacy policy of the Media and in the privacy policy link at the bottom of the official website of the Service.
The Company may change the Policy from time to time, and the Company will notify you of any significant changes to the Policy within the Service or at each posting location. The revised Policy will be applied from the time it is posted on the Service or at each posting location.

ii. How to Obtain Consent
Before viewing or browsing the Media, please read and agree to the Policy. By viewing or browsing the Media (or viewing or browsing the Media after any modification has been made to the Policy), the End User is deemed to have agreed with the Policy.

10. Contact
For inquiries, consultations, and claims of your rights for handling of User Information, please contact below.
Contact for the handling of adfurikun information

11. Contact information for DPO, Administrator and EU Representative
We have appointed a DPO to ensure proper involvement in issues relating to the protection of personal data.
Contact information of GREE Group’s DPO is as follows:
Position: General Council, Data Protection Officer
GREE, Inc.
Roppongi Hills Gate Tower, 6-11 -1 Roppongi, Minato-ku, Tokyo, Japan

Glossom, Inc.
Sumitomo Fudosan Shinjuku Central Park Tower 13F, 6-18-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo, Japan

Attn: Glossom, Inc. EU Representative
Neuer Wall 54
20354 Hamburg

12. Others
If the latest and accurate information is not provided to the Company, the End User may not be able to receive appropriate services.

Supplementary Provisions
Enacted and effective on May 25, 2018,
Revised on April 1, 2019
Revised on August 1, 2022