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GDPR PRIVACY POLICY

COVER Co., Ltd. (hereinafter referred to as “Company”, “we”, “us”, or “our”) has established this privacy policy (hereinafter referred to as “Privacy Policy”) as a policy regarding the handling of personal data provided to us by our customers (hereinafter referred to as “Customers”, “you”, or “your”) residing in the European Economic Area (EEA). Personal data subject to this Privacy Policy (hereinafter referred to as “Personal Data”) is limited to personal data covered by the EU General Data Protection Regulation (“GDPR”).

1. Personal Data that we collect from Customers

(1) Processing of Personal Data at our Company

The categories of Personal Data that we may obtain from Customers are listed below. We respect the privacy rights of individuals and comply with the GDPR and other laws and regulations relating to data protection and privacy. When you visit our website, we may collect certain information from you through cookies in order to provide better services, so please see here for details on what information is collected by cookies and how we use that information.

We render various services to our Customers, and in connection with the provision of these services, we may process your Personal Data. In such cases, we ensure that we will obtain Personal Data by fair and appropriate means, notify the Customer or publicly announce the purpose of use of the Personal Data, and obtain the consent of the Customer, and will acquire and process the Personal Data only within the scope of its purpose.

When we collect Personal Data from the Customers, we will clearly state whether the provision of Personal Data is a legal or contractual requirement for a Customer, or a requirement necessary to conclude a contract, as well as whether the Customer is obligated to provide such Personal Data to us, and of the possible consequences of failure to provide such Personal Data by the Customer.

Moreover, while we may obtain Customer’s consent for the processing of its Personal Data in certain cases, except where the legal basis is explicitly stated as “consent”, the legal basis for processing is typically based on the necessity of processing for pursuing legitimate interests or for the performance or conclusion of a contract.

(2) Withdrawal of Consent

Customers have the right to withdraw their consent at any time by the method specified by the Company at the time of obtaining consent. However, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Customers have an absolute right to opt-out of direct marketing at any time, and they can do this by following the instructions in the communication where this is an electronic message, or by contacting us via the contact details set out in Section 7 of this Privacy Policy.

We do not make decisions based solely on automated data processing which have a legal or similarly significant effect on you.

When the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, the Company will separately inform the Customer whether the Customer is obliged to provide its Personal Data and of the possible consequences of failure to provide such Personal Data.

Specific Purpose	Categories of Personal Data	Legal Basis for Processing
● Account Registration	● Contact Details: Name, telephone number, address, e-mail address ● Date of birth ● Username ● External Service Information: Such as ID and other account information related to external services (Google/Apple/Twitter, etc.)	Performance of contract
● Application for campaigns, projects, etc.	● Contact Details ● Username ● External Service Information	Performance of contract
● Provision of products, services, and contents (including live events)	● Contact Details ● Username ● Date of birth (age), attributes (gender, etc.) ● External Service Information ● In-service billing and purchase information ● Service Usage Information: Content of postings, reactions, selections, etc. on the service	Performance of contract
● Communication between Customers	● Username ● Date of birth (age), attributes (gender, etc.) ● External Service Information ● Login Information and Service Usage Information: (including access logs (including access areas), system logs, action history in games or apps, contents of posts, reactions, selections, etc. on the service, in-service billing/purchase information, language setting information, user identification ID/token, in-service function usage status, IP address, app-launch information)	Performance of contract
● Transactions and payment processing (including affiliation with the Company as a creator or talent, and other transactions with the Company)	● Contact Details ● Date of birth (age) ● Financial Information: Bank account, credit card information, billing information, etc. ● Login Information and Service Usage Information	Performance of contract
	● Rough location information	Legitimate interests: for tax compliance
● Operation, improvement, and development of the Company's website, products, services, contents, etc.	● Age and attributes (gender, etc.) ● External Service Information ● Login Information and Service Usage Information ● Device Information: Name of model, OS, OS version, etc. on which the Customer uses the Company's services, information on the type and version of the browser used, session reference source, GPU model, CPU usage rate, FPS, game version ● Customer information recorded at the Company's live events (photos, videos, etc. in which the Customer is the subject)	Legitimate interests: To maintain and improve quality by investigating the usage status by Customers, etc.
● Detection and investigation of fraudulent acts such as falsification and vandalism of the Company's services, and illegal activities	● Contact Details ● Date of birth (age), attributes (gender, etc.) ● Username ● External Service Information ● Financial Information: Bank account, credit card information, billing information, etc. ● Login Information and Service Usage Information ● Device Information ● Rough location information ● Customer information recorded at the Company's live events (photos, videos, etc. in which the Customer is the subject)	Legitimate interests: For maintenance and management of systems related to our services, prevention of fraud, proper operation of services
● Conduct Questionnaire ● Customer Support ● Response to Inquiries	● Contact Details ● Date of birth (age), attributes (gender, etc.) ● Username ● External Service Information ● Information about your notification preferences ● Information provided by Customers to the Company through questionnaires and inquiries ● Financial Information: Bank account, credit card information, billing information, etc. ● Login Information and Service Usage Information ● Device Information ● Rough location information	Legitimate interests: To provide or receive necessary information in order to provide better products and services, etc., or to respond appropriately to inquiries
● Sending e-mails and other notifications regarding the Company's services, etc. that the Customer has agreed to receive	● Contact Details ● Date of birth (age), attributes (gender, etc.) ● Username ● Information about your notification preferences ● Login Information and Service Usage Information	Customer’s consent
● Notification of various information regarding the services used by Customers (including service maintenance information)	● Contact Details ● Date of birth (age), attributes (gender, etc.) ● Username ● Information about your notification preferences ● Login Information and Service Usage Information	Legitimate interests: To provide necessary information in order to provide better products and services
● Digital Marketing & Advertising	● Username ● Information about your notification preferences ● Login Information and Service Usage Information	Legitimate interests: To provide necessary information in order to provide better products and services
● Communication with Customers on social media and third-party platforms	● External Service Information ● Information posted by Customers on External Services, etc.	Legitimate interests: To provide or receive necessary information in order to provide better products and services, etc., or to respond appropriately to inquiries
● Other purposes for which the Customer's consent was explicitly obtained at the time of acquisition of the Customer's information	● Information with the consent of the Customer	Customer’s consent

2. Transfer of Personal Data outside the EEA

In case where the Company needs to transfer the Customer’s Personal Data outside the European Economic Area (EEA), unless otherwise notified to the Customer separately, we will ensure adequate level of safeguard measures by relying on an adequacy decision in the countries where it is recognized, or that the recipient enters into European Commission’s Standard Contractual Clauses with us. If you require to receive the copies of documents relating to such safeguard measures, you can send us your request using the contact details provided under Article 7 of this Privacy Policy.

3. Sources of Personal Data

We may collect Customer’s Personal Data either directly from the Customers or indirectly through third parties, including:

- Companies providing data processing and hosting services.

- Companies that provide data analytics tools (e.g. Google, Unity, Adobe)

- Companies engaged in the play guide business for our events (entertainment) such as live performances (location: Japan)

- Social media platforms to which you have previously provided information (e.g. YouTube, Twitter)

4. Sharing of Personal Data

We may disclose your Personal Data with third parties operating the following categories of businesses for the purposes set out in this Privacy Policy, in accordance with the GDPR.

- Cloud service for managing your information (located in Japan)

- Our service providers who provide services on our behalf (located in Japan)

- Operating companies such as technology vendors, delivery companies, event operators, and payment agents that support our website and other business systems.

The disclosures set out above also include the transfer of your Personal Data outside of the EU and EEA to the UK, Japan or the US (this may change depending on changes in the business environment).

5. Retention Period of Personal Data

We will retain Customer’s Personal Data that we collect only for as long as it is necessary to achieve the purposes of use set out above. The specific period of retention will be determined by taking into account the purpose for which the Personal Data is to be used, the nature of the Personal Data and the legal or business need to retain the Personal Data.

6. Legal Rights of Customers

You have the following rights in relation to the Personal Data that we collect and process. If you wish to exercise any of the following rights, please contact us by using the contact details set forth under Article 7 of this Privacy Policy. You may also object to our processing of your Personal Data to the data protection supervisory authority of the Member State where you reside, work or where the GDPR violation occurred.

(1) Acquisition of Information on Data Processing

You have the right to obtain from us all necessary information regarding our data processing activities relevant to you.

(2) Access to Personal Data

You have the right to receive confirmation from us as to whether or not Personal Data relating to you has been processed, and if so, you have the right to access such Personal Data and certain related information.

(3) Correction or Deletion of Personal Data

You have the right to have inaccurate Personal Data relating to you corrected without undue delay or to have incomplete Personal Data made complete. You also have the right to have Personal Data relating to you erased without undue delay if certain requirements are met.

(4) Restriction on Processing of Personal Data

You have the right to have the processing of your Personal Data restricted if certain requirements are met.

(5) Objections to Processing of Personal Data

You have the right to object to the processing of Personal Data relating to you if certain requirements are met.

(6) Data Portability of Personal Data

You have the right to receive Personal Data relating to you in a structured, commonly used and machine-readable format, and to transfer such data to another controller without hindrance from us, provided that certain requirements are met.

(7) Not to be Subject to Automated Decision-Making

You have the right not to be the subject to decisions based solely on automated data processing (including profiling) that have legal effects or similarly significant effects on you, if certain requirements are met.

7. Contact Details

If you have any questions about this Privacy Policy, or wish to inquire about or make a request in relation to your rights as set out in Article 7 of this Privacy Policy, please contact us at the following address:

(1) Cover Co. Ltd. (Company)

Address: Sumitomo Realty & Development Tokyo Mita Garden Tower, 3-5-19 Mita, Minato-ku, Tokyo, 108-0073, Japan
E-mail address: shop@cover-corp.com

(2) LCA Studio Legale (Agent)

Address: Via della Moscova 18, 20121 Milano, Italy
Tel: +39- 027788751
Email Address: milano@lcalex.it

8. Updates to this Privacy Policy

This Privacy Policy may be updated from time to time. Any substantive or material changes will be communicated to you via our website and, where appropriate, via an email notification to you.

Enacted on December 24, 2024