Privacy Policy

US-California

BM DISCUSSION DRAFT: AUGUST 22, 2022

The notice at collection must be provided to California users before any personal information is collected. The full Privacy Policy including California specific disclosures can be found starting page 2 and should be easily accessible to users of the App.

Privacy Notice

1. Categories of Personal Information.

MIXI collects email addresses, account details (including screen names of users), device information, including your IP address, when users register or use the App. MIXI also collects device information, user logs, Steam ID, Discord ID, other platform user names or IDs, address, and phone number.

2. Purposes.

MIXI uses the personal information collected from this website and associated technologies to provide you with our services, such as to:

Pre-register, download and use the App;
Process, maintain and service your account(s);
Manage the user relationship, and communicate with you;
Handle and record consumer rights requests, including opt-ins and opt-outs;
Monitor, protect and improve MIXI security assets and resources, including devices, systems, customer data, infrastructure, and MIXI’s network;
Improve our App to provide you with personalized content;
Deliver offerings you may be interested in decided in-part by your cookie consent including providing information on contests, sweepstakes, promotions, surveys, new online features, and community events;
Analyze beta user behavior and survey beta test users; and
Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes.

3. Full Privacy Policy.

To view our full Privacy Policy, visit asymalteredaxis.com/privacy-policy .

4. Contact us:

Via the following:
Postal address: MIXI, Inc., Shibuya Scramble Square 36F, 2-24-12, Shibuya, Shibuya-ku, Tokyo, 150-6136, Japan.
Phone: (+81) 03-6897-9500
Email: asym_contact@ml.mixigroup.jp

PRIVACY POLICY

Effective Date: August 2, 2022

This Privacy Policy (the “Policy”) describes how mixi, Inc. and its affiliates (“MIXI”, "we", "our" or "us") collect and use personal information that you provide when you access, download and/or use Asym (“App”). This Policy also applies to any other services that we may provide in relation to the App, such as customer support, social media, community channels and other websites that we may operate from time to time.

By “personal information,” MIXI means personal information that directly identifies you. In this Policy, “you” means any person who uses our App.

1. COLLECTION OF PERSONAL INFORMATION

MIXI collects certain personal information from users who download or use our App such as your name, email address or telephone number. This information is used in some instances to facilitate future communications, or receive services, information or other materials from MIXI. This Policy sets forth the practices that MIXI intends to follow with respect to such personal information.

MIXI collects or receives personal information from the following sources:

Directly from you. For example, when you create an account through the Google or Apple application platforms, contact or request information via the App, or submit personal information through email communications to us.
Third Parties, including Service Providers. For example, service providers that MIXI uses, and other third parties that MIXI chooses to collaborate or work with, including third party platform operators such as Apple and Google.
Device Information. Using tracking technologies such as Google Analytics, MIXI may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, and mobile network information.
Using cookies and automatic collection methods. MIXI and its service providers may collect information from the computer, tablet, phone, or other device on which you install our App, that you use to access our App, or that you use to open an email or click on an advertisement from MIXI. Methods MIXI uses include:
- Functional cookies, which allow us to customize our App content and communicate with other users.
- Cookies designed for measuring traffic, which do not collect personal data. Traffic monitoring tools are used to gather information 　about how visitors use the App.
- Third party cookies used by third parties we engage to track and analyze non-personal and personally identifiable App data to help 　us administer and improve the quality of the App, and to analyze user behavior.

MIXI will then use the personal information you provide for various purposes, such as to facilitate future communications with you, assist you in navigating our App, and respond to your request for MIXI information and materials.

You will be prompted to provide your personal information as described above. However, you will always have the choice to decline to provide your personal information and not receive the services from MIXI.

2. SHARING OF PERSONAL INFORMATION

MIXI shares your personal information with:

MIXI affiliates. For example, MIXI affiliates within the MIXI group may share business processes and common data systems.
Third parties and service providers that provide products or services to us. For example, companies that help us support our platform, or that provide services to you. MIXI may use third parties or service providers to help with auditing interactions and transactions with you, addressing security, fixing errors, track user behavior, maintaining accounts and providing customer service, helping with our internal research, and verifying service quality or safety.
Third parties connected with business transfers: MIXI may transfer your personal information to third parties in connection with a reorganization, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Policy.

MIXI may also access, transfer, disclose, and preserve personal information when doing so is necessary to: comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; operate and maintain the security of MIXI’s systems, including to prevent or stop an attack on our computer systems or networks; protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies; or act in urgent circumstances such as protecting the health or personal safety of an employee or worker, agent, customer, user of MIXI’s services, or member of the public.

3. COOKIE NOTICE

A cookie is a tiny piece of text placed on your computer’s hard drive by an app you visit. Cookies help the App to remember information about your visit, like your preferred language and other settings. This makes the App more user friendly and your visits to the App more productive.

MIXI uses performance and functionality cookies in order to enable and streamline the basic functioning of the App, to simplify your use of our App, to monitor, analyze and improve the performance and effectiveness of our App.

MIXI collects your consent for using cookies via a cookie banner which will appear when you access our website. You can opt-out of the use of personal information for these purposes by changing your cookie settings, either via the cookie banner or through accessing cookie settings at the bottom of our website.

MIXI does not respond to “do not track signals”.

For information on how to adjust your browser settings to delete or control cookies, please visit http://www.aboutcookies.org/.

If you have any further questions, please feel free to contact asym_contact@ml.mixigroup.jp.

4. SECURITY AND FRAUD

MIXI has implemented information security practices designed to help safeguard your personal information. MIXI does not authorize our employees or our service providers to access or use this information unless they have a need to know it in connection with performing their employment duties or providing services to MIXI.

MIXI uses administrative, technical, and physical measures to safeguard personal information against loss, theft and unauthorised uses, access or modifications. While MIXI will continue to exercise diligence and use measures to protect the security of this App, MIXI cannot warrant that all internet communications will be secure. Although we have procedures and security measures in place to protect your personal information, we cannot guarantee the security of your information transmitted to our App; and any transmission is at your own risk. If you have any questions about this Policy, please contact asym_contact@ml.mixigroup.jp.

5. NOTICES, DISCLOSURES, AND JURISDICTION SPECIFIC RIGHTS

Links to Third Party Apps. The App may provide links to other Internet applications, content or videos (embedded or direct links) maintained by third parties. MIXI is not responsible for the apps, content, or videos accessed via the links, and MIXI has not reviewed the privacy practices of those third parties. Please read their privacy policies before you submit any personal information to or otherwise use these applications.
California Privacy Rights. California law entitles California residents to ask us for a notice describing what categories of personal information MIXI collects, from what sources, for what purpose and with whom MIXI shares such information. California law also provides California residents with rights to request access to and deletion of certain personal information, to know whether personal information is shared, and to opt out of the “sale” of personal information. To understand how we honor these California rights, to make requests regarding these rights, and to learn more about how California law defines “personal information,” please visit our [California Privacy Rights Notice].
EEA/UK Privacy Rights: Data protection laws in the European Economic Area (EEA) and the United Kingdom (UK) require us to detail the legal bases for processing your personal information in connection with the provision of our services, and provide users with certain rights including the right to have their personal information deleted, the right to make complaints about our data processing practices, and right to withdraw consent. To understand how we honor these rights, and to make requests regarding these rights, please visit our [EEA/UK Privacy Notice].

6. INTERNATIONAL CUSTOMERS

If you provide your personal information through our App, your personal information will be transferred to and processed in the United States and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of email address in the United States or other countries or jurisdictions in which we transfer or process personal information may be different than the laws and protections in your country. If you are in the EEA or UK, please visit our [EEA/UK Privacy Notice] for more information on how your personal information is protected in these cases.

7. UPDATES TO THIS POLICY

MIXI may make changes to this Policy as permitted by law. MIXI will notify you by posting the updated Policy on its App if there are any material changes to this Policy.

8. CONTACT FOR MORE INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and use your email address, your choices and rights regarding such use, please do not hesitate to contact us at:

Postal address: MIXI, Inc. Shibuya Scramble Square 36F, 2-24-12, Shibuya, Shibuya-ku, Tokyo, 150-6136, Japan.

Email: asym_contact@ml.mixigroup.jp

California Personal Privacy Notice

Last Modified: August 22, 2022

This notice and policy supplements information contained in the Privacy Policy from MIXI and applies solely to residents of the State of California (“consumers” or “you”). MIXI adopts this notice and policy to comply with the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice and policy. This notice and policy does not reflect our collection, use, or disclosure of California residents’ personal information where an exception under the CCPA applies. You can download a pdf version of the California Consumer Privacy Act Notice and Policy at asymalteredaxis.com/privacy-policy.

1. RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, AND DISCLOSED

You have the right to request that we disclose what personal information we collect, use, or disclose about you specifically (“right to know”). To submit a request to exercise the right to know, please submit an email request to asym_contact@ml.mixigroup.jp and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

MIXI will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. MIXI will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

2. PERSONAL INFORMATION HANDLING PRACTICES

We have set out below categories of personal information we collect about California residents and have collected in the preceding 12 months. For each category of personal information, we have collected, we have included the reference to the enumerated category or categories of personal information in California Civil Code § 1798.140(o)(1) that most closely describe such personal information.

Corresponding reference to category of personal information under CCPA definition of personal information: Category of personal information

A. Identifiers.: Email address, phone number, address, device and platform user names and IDs, IP address, geolocation, web browsing history.

D. Commercial information.: Email address

F. Geolocation Data: Geolocation data when accessing the App

J. Inferences: Web browsing history

MIXI collects such information from the following categories of sources:

Directly from you. For example, when you create an account through the Google or Apple application platforms, Discord, Steam, enter giveaways, respond to surveys, contact or request information from via the App, or submit personal information through email communications to us.
Third Parties, including Service Providers. For example, service providers that MIXI uses, and other third parties that MIXI chooses to collaborate or work with, including third party platform operators such as Apple, Google, Discord, and Steam.
Device Information. MIXI may collect information about your mobile device and internet connection, including the device’s IP address, location data, and other web browsing history.
Using cookies and automatic collection methods. MIXI and its service providers may collect information from the computer, tablet, phone, or other device that you install our mobile application on, that you use to access our App, or that you use to open an email or click on an advertisement from MIXI. Methods MIXI uses include:
- Functional cookies, which allow us to customize our App content and communicate with other users.
- Cookies designed for measuring traffic, which do not collect personal data. Traffic monitoring tools are used to gather information about how visitors use the App.
- Third party cookies used by third parties we engage to track and analyze non-personal and personally identifiable App data to help us administer and improve the quality of the App.

MIXI collects, uses, retains, and discloses your email address for the purposes described below:

Pre-register, download and use the App;
Process, maintain and service your account(s);
Manage the user relationship, and communicate with you;
Handle and record consumer rights requests, including opt-ins and opt-outs;
Monitor, protect and improve MIXI security assets and resources, including devices, systems, customer data, infrastructure, and MIXI’s network;
Improve our App to provide you with personalized content;
Deliver offerings you may be interested in decided in-part by your cookie consent including providing information on contests, sweepstakes, promotions, surveys, new online features, and community events;
Analyze beta user behavior and survey test users; and
Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes.

3. SHARING OF PERSONAL INFORMATION

In the preceding 12 months, MIXI disclosed email addresses to the following categories of third parties for a business purpose, in some cases as directed by you:

MIXI Affiliates. For example, MIXI affiliates may share business processes and common data systems.
Third parties and service providers that provide products or services to us. For example, companies that help us support our App, or that provide services to you. MIXI may use third parties or service providers to help with auditing interactions and transactions with you, addressing security, fixing errors, maintaining accounts and providing customer service, helping with our internal research, and verifying service quality or safety.

MIXI may also access, transfer, disclose, and preserve email addresses when doing so is necessary to: comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; operate and maintain the security of MIXI’s systems, including to prevent or stop an attack on our computer systems or networks; protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies; or act in urgent circumstances such as protecting the health or personal safety of an employee or worker, agent, customer, user of MIXI’s services, or member of the public.

4. RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

You have a right to request the deletion of the email address that we collect from you. To submit a request to delete your email address, please submit an email request to asym_contact@ml.mixigroup.jp and include “California Request to Delete” in the subject line or fill out [Portal Request]. Please specify in your request that you would like to have your email address deleted, as required by the CCPA.

MIXI is required to verify your identity. The information that MIXI asks you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, MIXI will respond to your request in accordance with the CCPA. MIXI will provide an explanation for denying a request.

5. “SALE” OF PERSONAL INFORMATION.

Under the CCPA, “sale” is broadly defined to mean the sharing of personal information with third parties who are not acting as our service providers or who are otherwise not restricted from using data only on our behalf or pursuant to an applicable CCPA exception.

Please note that we do not knowingly sell your personal information or the personal information of minors under 16 years of age without legally-required affirmative authorization.

6. RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF CCPA RIGHTS

You may not be discriminated against because you exercise any of your rights under the CCPA in violation of California Civil Code § 1798.125.

7. AUTHORIZED AGENT

You can designate an authorized agent to make a request under the CCPA on your behalf if:

The authorized agent is a natural person, or a business entity registered with the Secretary of State of California and the agent provides proof that you gave the agent signed permission to submit the request; and
You directly confirm with MIXI that you provided the authorized agent with permission to submit the request.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please ensure authorized agent sends an email to asym_contact@ml.mixigroup.jp with subject “California Request to Delete” with the attachment of both the user in question and the Authorized agent’s ID with a notarized letter verifying the relationship (e.g. parent or guardian) with detailed information on the requested data to be deleted.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

8. CONTACT FOR MORE INFORMATION

Canada

Last Updated: October 19, 2022

MIXI, Inc. (“MIXI”, “we”, or “our”) is committed to protecting the privacy of beta users (“Users”, “you”, or “your”) who are testing and using the Asym game app ("App"). Please read this privacy notice (“Privacy Notice”) carefully before using the App as it contains information about the personal information that MIXI collects from you and uses to facilitate future communications, analyze and test the App, or receive services, information or other materials from MIXI.

By registering for, or by using the App, you acknowledge that:

you have read this Privacy Notice in its entirety;
you have reached the age of majority in your jurisdiction;
you are giving consent to MIXI to collect and use your personal information as described herein.

Collection of Personal Information

We collect the following personal information (“Personal Information”) when you register or use the App:

your email address
account details, including your screen name
device information, including your IP address,
web browsing history, user logs, Steam ID, Discord ID, other platform user names or IDs, address, and phone number

How We Use Your Personal Information

We may use your Personal Information for the following purposes:

Pre-register, download and use the App;
Process, maintain and service your account(s);
Manage the User relationship, and communicate with you;
Handle and record consumer rights requests, including opt-ins and opt-outs;
Monitor, protect and improve MIXI security assets and resources, including devices, systems, customer data, infrastructure, and MIXI's network;
Improve the App to provide you with personalized content;
Analyze beta user behavior and survey beta test users; and
Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes.

To achieve the stated purposed, your Personal Information may be transferred and stored outside of Canada in a jurisdiction with a legal regime that differs from the privacy rights afforded in Canada.

We use Google Analytics and Benchmark Analytics to process Personal Information we collect from you to understand how you're interacting with the App and to deliver relevant marketing materials to you.

Retention

We retain each category of Personal Information for as long as needed or as permitted under applicable laws in light of the purpose(s) for which we collected the Personal Information.

Choice of Language

You agree that this Privacy Notice is to be drawn up and communicated to you in English only.
Vous acceptez que la présente Avis de confidentialité soit rédigée et communiquée uniquement en anglais.

Your Privacy Rights

Depending on where you live, you may have certain rights including but not limited to the right to request access to or deletion of your Personal Information. To exercise any such rights, or to appeal our decisions in response to your exercise of rights, please contact MIXI as detailed in the "Contact Us" section below.

Changes to our Privacy Notice

We may change this Privacy Notice at any time for any reason.
If we make material changes to this Privacy Notice, we will post the updated version on our website:

https://asymalteredaxis.com/privacy-policy/

Without prejudice to your rights under applicable law, we reserve the right to update and amend this Privacy Notice without prior notice to reflect technological advancements, legal and regulatory changes, and good business practices to the extent that it does not materially change the statements in this Privacy Notice.

Contact Us

If you have questions or comments regarding this Privacy Notice or our privacy practices in general, please contact us at asym_contact@ml.mixigroup.jp. You can contact our Personal Information Personnel at the following address:

MIXI, Inc.
Shibuya Scramble Square 36F, 2-24-12, Shibuya, Shibuya-ku, Tokyo, 150-6136, Japan.

EU/UK (European Union/United Kingdom)

BM DRAFT: 20 July 2022

Privacy Notice

MIXI collects certain categories of personal information from beta users who are testing and using the Asym game app (“App”), including email addresses and web browsing history. This personal information is used to facilitate future communications, analyze and test the App, or receive services, information or other materials from MIXI.

1. Categories of Personal Information. MIXI collects email addresses, account details (including screen names of users), device information, including your IP address, when users register or use the App. MIXI also collects web browsing history, user logs, Steam ID, Discord ID, other platform user names or IDs, address, and phone number.

2. Purposes. MIXI uses the personal information collected from this website and associated technologies to provide you with our services, such as to:

Pre-register, download and use the App;
Process, maintain and service your account(s);
Manage the user relationship, and communicate with you;
Handle and record consumer rights requests, including opt-ins and opt-outs;
Monitor, protect and improve MIXI security assets and resources, including devices, systems, customer data, infrastructure, and MIXI’s network;
Improve the App to provide you with personalized content;
Analyze beta user behavior and survey beta test users; and
Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes.

3. Full Privacy Policy. To view our full Privacy Policy, visit https://asymalteredaxis.com/privacy-policy/.

4. Contact us. Via the following:
Postal address: MIXI, Inc., Shibuya Scramble Square 36F, 2-24-12, Shibuya, Shibuya-ku, Tokyo, 150-6136, Japan.

Phone: (+81) 03-6897-9500

Email: asym_contact@ml.mixigroup.jp

PRIVACY POLICY

Effective Date: [22 July 2022]

This Privacy Policy (the “Policy”) describes how MIXI, Inc. and its affiliates (“MIXI”, "we", "our" or "us") collect and use personal information that you provide when you access, download and/or use Asym (“App”). This Policy also applies to any other services that we may provide in relation to the App, such as customer support, social media, community channels and other websites that we may operate from time to time.

By “personal information,” MIXI means personal information, also known as "personal data", that directly or indirectly identifies you. In this Policy, “you” means any person who uses our App.

For the purposes of applicable data protection laws, the controller is MIXI, Inc..

1. COLLECTION OF PERSONAL INFORMATION

Directly from you. For example, when you create an account through the Google or Apple application platforms, contact or request information via the App, or submit personal information through email communications to us.
Third Parties, including Service Providers. For example, service providers that MIXI uses, and other third parties that MIXI chooses to collaborate or work with, including third party platform operators such as Apple and Google.
Device Information. Using tracking technologies such as Google Analytics, MIXI may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, and mobile network information.
Using cookies and automatic collection methods. MIXI and its service providers may collect information from the computer, tablet, phone, or other device on which you install our App, that you use to access our App, or that you use to open an email or click on an advertisement from MIXI. Methods MIXI uses include:
- Functional cookies, which allow us to customize our App content and communicate with other users.
- Cookies designed for measuring traffic, which do not collect personal data. Traffic monitoring tools are used to gather information about how visitors use the App.
- Third party cookies used by third parties we engage to track and analyze non-personal and personally identifiable App data to help us administer and improve the quality of the App, to analyze usage and for advertising and marketing purposes.

2. SHARING OF PERSONAL INFORMATION

MIXI shares your personal information with:

MIXI affiliates. For example, MIXI affiliates within the MIXI group may share business processes and common data systems.
Third parties and service providers that provide products or services to us. For example, companies that help us support our platform, or that provide services to you. MIXI may use third parties or service providers to help with auditing interactions and transactions with you, addressing security, fixing errors, helping us with advertising or marketing, maintaining accounts and providing customer service, helping with our internal research, and verifying service quality or safety.
Third parties connected with business transfers: MIXI may transfer your personal information to third parties in connection with a reorganization, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Policy.

3. COOKIE NOTICE

A cookie is a tiny piece of text placed on your computer’s hard drive by an app you visit. Cookies help the App to remember information about your visit, like your preferred language and other settings. This makes the App more user friendly and your visits to the App more productive.

MIXI uses performance and functionality cookies in order to enable and streamline the basic functioning of the App, to simplify your use of our App, to monitor, analyze and improve the performance and effectiveness of our App, and for certain advertising and marketing purposes. Certain advertising third parties working on our behalf may use cookies and other tracking technologies to provide interest-based advertisements on the App or other unaffiliated services, and measure the effectiveness of our advertisements.

MIXI collects your consent for using cookies via a cookie banner which will appear when you access our website. You can opt-out of the use of personal information for these purposes by changing your cookie settings, either via the cookie banner or through accessing cookie settings at the bottom of our website.

MIXI does not respond to “do not track signals”.

For information on how to adjust your browser settings to delete or control cookies, please visit http://www.aboutcookies.org/.

If you have any further questions, please feel free to contact asym_contact@ml.mixigroup.jp.

4. SECURITY AND FRAUD

5. NOTICES, DISCLOSURES, AND COUNTRY/STATE-SPECIFIC RIGHTS

Links to Third Party Apps. The App may provide links to other Internet applications, content or videos (embedded or direct links) maintained by third parties. MIXI is not responsible for the apps, content, or videos accessed via the links, and MIXI has not reviewed the privacy practices of those third parties. Please read their privacy policies before you submit any personal information to or otherwise use these applications.
EEA/UK Privacy Rights: Data protection laws in the European Economic Area (EEA) and the United Kingdom (UK) require us to detail the legal bases for processing your personal information in connection with the provision of our services, and provide users with certain rights including the right to have their personal information deleted, the right to make complaints about our data processing practices, and right to withdraw consent. To understand how we honor these rights, and to make requests regarding these rights, please visit our EEA/UK Privacy Notice.

6. INTERNATIONAL CUSTOMERS

If you provide your personal information through our App, your personal information will be transferred to and processed in the United States and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of email address in the United States or other countries or jurisdictions in which we transfer or process personal information may be different than the laws and protections in your country. If you are in the EEA or UK, please visit our EEA/UK Privacy Notice for more information on how your personal information is protected in these cases.

7. UPDATES TO THIS POLICY

MIXI may make changes to this Policy as permitted by law. MIXI will notify you by posting the updated Policy on its App if there are any material changes to this Policy.

8. CONTACT FOR MORE INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and use your email address, or your choices and rights regarding such use, please do not hesitate to contact us at:

Postal address: MIXI, Inc., Shibuya Scramble Square 36F, 2-24-12, Shibuya, Shibuya-ku, Tokyo, 150-6136, Japan.

Email: asym_contact@ml.mixigroup.jp

EEA/UK Privacy Notice

Last Modified: October 19, 2022

This notice and policy supplements information contained in the Privacy Policy from MIXI, and should be read in parallel with the Privacy Policy. This notice and policy applies solely to residents of the European Economic Area and United Kingdom.

1. LEGAL BASES FOR THE COLLECTION AND USE OF YOUR PERSONAL DATA

MIXI uses your personal information as described in the Privacy Policy for the following purposes:

We may use your personal data to:

Provide you with goods and services
Contact you to tell you about our services and goods (provided you have consented to this)
Diagnose problems with our server or administer our App
Analyse user traffic to measure use of our App or websites and to improve the content of our services
Comply with legal requirements and exercise or defend legal claims
Process your personal data where this is necessary to keep our website safe and secure

How does MIXI use personal data for this purpose?

We will need to use your personal data where this is necessary for us to perform our obligations under a contract with you, for example where you have purchased services from us.
We will need to use your personal data (such as your email address or other contact details) to send you information about services and goods that you may be interested in. Please note we may also share your personal data with other entities in the MIXI group for this purpose.
We may need to use personal data, such as your IP address, to diagnose server problems or administer our websites.
We may sometimes use your personal data (e.g. your IP address) to measure use of our App and assess the effectiveness of our site pages. We may also use this personal data to improve the content of our websites and services.
We may sometimes need to process personal data to comply with legal requirements to which we are subject.
We may need to process your personal data in order to keep our website safe and secure and protect against illegal or fraudulent activity such as cyber-attacks.

What is the legal basis for us processing your personal data in this way?

Using your personal data in this way is necessary for us to perform our contractual obligations to you.
We will ask for your consent before processing your personal data in this way.
We will ask for your consent to the use of cookies.
It is in our legitimate interest to look at user traffic so that we can improve our websites and better meet your needs.
It is in our legitimate interests to process personal data for the purposes of exercising and defending legal claims. Processing personal data may also be necessary to ensure compliance with our legal obligations.
It is in our legitimate interests to monitor how our website is used to detect and prevent fraud, other crimes and the misuse of our website. This helps us to ensure that you can safely use our website.

The provision of your personal data may be necessary for the purposes of entering into a contract with MIXI or to receive the products and services you request, or may otherwise by voluntary. If you do not wish to provide your personal data to us, MIXI may not be able to: (a) provide you with access to or enable you to use the App, or (b) tell you about other products and services offered by us.

2. STORAGE OF PERSONAL DATA

The personal data that MIXI collects from you may be transferred to, and stored at, a jurisdiction outside the UK (if you live in the UK) or EEA (if you live in the EEA). It may also be processed by staff operating outside the UK/EEA respectively who work for us or for one of our Service Providers.

MIXI will take steps that are reasonably necessary to ensure that your personal data is treated in accordance with applicable data protection laws, including, where relevant, entering into standard contractual clauses (or equivalent measures) with the party receiving the personal data. You can request further information regarding the agreements we have in place for this purpose by contacting us as set out in Section 4 below.

Your personal data is stored by MIXI and/or our Service Providers, only to the extent necessary for the performance of MIXI's obligations and only for the time necessary to achieve the purposes for which the personal data is collected, in accordance with applicable data protection laws.

3. RIGHTS RELATING TO YOUR PERSONAL DATA

You have a number of rights in relation to your personal data, which are summarised below:

Access: You have the right to confirm with MIXI whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. MIXI does have to take into account the interests of others though, and if you want to request more than one copy we may charge a fee.
Rectification: You may have the right to rectify inaccurate or incomplete personal data concerning you. In particular, you have the right to have incomplete personal data completed.
Erasure: You may have the right to ask MIXI to erase personal data concerning you.
Restriction of processing: In limited circumstances, you may have the right to request that MIXI restrict processing of your personal data.
Data portability: You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.
Objection and rights relating to automated decision-making: Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by MIXI, and MIXI can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.
Direct marketing: You have the right to withdraw your consent for receiving direct marketing from MIXI at any time. You can do this for example by clicking on the "unsubscribe" link in an email that MIXI has sent to you, or by contacting us at the details in Section 4 below.

To exercise any of these rights, please contact us as at the details in Section 4 below.

You also have the right to lodge a complaint with the competent data protection supervisory authority.

4. CONTACT FOR MORE INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and use your personal data, or your choices and rights regarding such use, please do not hesitate to contact us at:

Postal address: MIXI, Inc., Shibuya Scramble Square 36F, 2-24-12, Shibuya, Shibuya-ku, Tokyo, 150-6136, Japan.
Email: asym_contact@ml.mixigroup.jp