1.
Scope of Application
Tokenz Inc. (hereinafter referred to as "Tokenz") 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 if you reside or are located in Japan. 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.
"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:
- 株式会社Tokenz
- 東京都千代田区有楽町 1-5-2 東宝日比谷プロムナードビル 11 階
- 代表取締役: リン プオファン
- Email: hello@tokenz.one
If you browse our website and/or use Tokenz services and/or our platform, you agree to the collection, processing, use, disclosure, transfer (including overseas transfer), retention or storage, and disposal of your personal data in the following ways.
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.
2.
Collection of Personal Information
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:
Your name.
Email address.
Mobile phone number (or MSISDN).
Merchant affiliation and/or IP address.
Cookies or statistical/analytical data (such as your browsing behavior) to the extent you are identified.
Materials that may help us verify the accuracy of information you provided to us (such as identification documents).
Your social media links or public profiles and personal information displayed therein that you provide to us during the customer support process.
Contents of your resume or curriculum vitae when applying for our job openings.
Account password you create.
Other personal information you provide to us in the course of using Tokenz services
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:
Refund amount.
Bank name.
Branch name.
Account type.
Account number.
Account holder name
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 Officer at privacy@tokenz.one.
You may provide personal information to us through other methods, including:
Responding to our communications.
Social media or online forums.
Participating in offers, programs, or promotions we conduct.
Applying for job openings from the "Careers" page of www.tokenz.one
Subscribing to our newsletterFilling out the partnership and marketing inquiry form on our website (www.tokenz.one).
Signing in to Tokenz services using social login or credentials from third-party platforms (such as Facebook, Gmail, etc.).
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") to pursue our legitimate interests and comply with our contractual obligations to provide access to Tokenz services and/or our Platform. 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. You agree that we may collect such Transaction Data when you use Tokenz services and/or our Platform.
We do not 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.
We do not directly or indirectly collect information or data that could identify individuals under the age of majority in your country (hereinafter referred to as "minors"). If we become aware that a minor has provided us with personally identifiable data, 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.
3.
Use and Disclosure of Personal Information
Your personal data will be processed for the following purposes:
Transaction processing and content delivery.
Marketing and promotional campaigns.
Other permitted uses and disclosures
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 following purposes:
Facilitating your use of Tokenz
services.
Processing and confirming your online transactions and payments on our Platform.
Resolving disputes related to your transactionsMinimizing fraudulent activities.
Legitimate protection of our interests.
Exercising contractual rights.
Providing you with information you have requested from us.
(iii)Tokenz may share your personal information with the following parties for the above purposes:
Publishers of digital content you have purchased.
Payment Channels you have selected as your payment method.
Additionally, personal information may be shared between Tokenz and its current or future subsidiaries for the purposes set forth in this section.
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.
Other permitted Uses and Disclosures
(i) You agree that we may use your personal information for the following purposes:
Maintaining and protecting user accounts you have created with Tokenz.
Notifying you of matters related to your account or transactions that may require your attention.
Processing service requests, resolving concerns, and responding to inquiries or feedback from you to us.
Managing or complying with our internal security mechanisms or risk management mechanisms.
Conducting statistical analysis or market research and customer surveys (including customer satisfaction surveys). Please note that for this purpose, we may share your personal information with our third-party service providers.
Improving your experience with our customer care services.
Notifying you as necessary of important changes to this Privacy Policy or our terms and conditions.
(ii)You understand and agree that we may disclose your personal information to our affiliates or subsidiaries, publishers, Payment Channels, or other parties as permitted or required by applicable laws (such as government authorities or regulatory bodies) for the following purposes:
Disclosure related to or in connection with negotiations for our merger, sale of company shares or assets, financing, acquisition, divestiture, or dissolution of all or part of our business.
Disclosure when we determine that disclosure is reasonably necessary to (i) comply with applicable laws, regulations, legal processes, or government requests, (ii) cooperate with investigations or legal proceedings, (iii) protect the safety or integrity of Tokenz services, us, or our users, or the public from harm or illegal activities
4.
Your Choices, Rights, and Exceptions
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. Depending on the nature of your request, we may charge a reasonable administrative fee. We will notify you of any administrative fees as soon as reasonably practicable.
You have the right to request a record of all transfers of your personal information and to revoke the transfer of your personal information.
5.
Data Retention and Disposal
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.
6.
Security
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
7.
Transfer of Personal Data to Third Parties in Foreign Countries
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 will take measures to ensure that personal data transferred in accordance with this Privacy Policy is provided with a level of protection equivalent to that provided by the Act on the Protection of Personal Information (Act No. 57 of 2003) and its related regulations, amendments, guidelines, and circulars.
The following is a list of countries to which your personal data may be transferred:
8.
Collection of Statistical Data
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, Amazon Web Services, Facebook, and Google) to collect such information. Statistical information is anonymous by nature and does not identify you. 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 the following third-party partners: (i) third-party partners to whom we provide advertising, (ii) third-party partners who assist in providing or optimizing our services, (iii) third-party partners who wish to sell products or services that you may be interested in, (iv) third-party partners who wish to improve the products or services we provide to you.
9.
Use by Minors
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.
10.
Links to Other Websites
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.
11.
Contact Us
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 Officer at privacy@tokenz.one.
For other issues, please refer to our Help Center.
12.
Governing Law and Dispute Resolution
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.