PRIVACY NOTICE

Casio Computer Co. Ltd., a Japanese company whose registered office is located at 6-2, Hon-machi 1-chome, Shibuya-ku, Tokyo 151-8543, Japan ("Casio", "we", "us" or "our") takes the protection of your personal data extremely seriously. This Privacy Notice ("Privacy Notice") describes how Casio processes and protects the individually identifiable information ("Personal Data") collected and processed when using our our robotic pet product(s), Moflin, ("Product") and the application software, MofLife, connected to the Product ("App").

This Privacy Notice consists of a "Summary Notice" (see below at section A.) and a "Detailed Notice" (see below at section B.)

A. Summary Notice Scope of applicability

This Privacy Notice exclusively applies to the processing of your Personal Data when using our App. This Privacy Notice does not apply to the processing of your Personal Data when creating and using a membership service called CASIO ID ("CASIO ID"), the user account that allows you to centrally store and manage master data and functions as your access key across various offerings, solely and/or other apps we provide. Such processing is governed by other privacy policies, so when using CASIO ID with the App, the privacy notice for CASIO ID (https://auth.casio-intl.com/casio_contents/terms/index.html) applies to you additionally.

Please read the following carefully to understand how we will process your Personal Data provided via your access and use of the App.

Data Controller

If you live in the United Kingdom ("UK"), Casio Computer Co., Ltd., a Japanese Company, is your data controller and provides the services in connection with the App,.

If you wish to exercise your data subject rights or if you have any other questions concerning this Privacy Notice, you can:

Email us at app17+moflin@casio.co.jp; and
Contact our data protection officer ("DPO") at dataprotection@casio.co.jp.

Processing of your Personal Data (categories of Personal Data)

We process the following of your Personal Data collected during your use of our App: (i) your CASIO ID and data registered therewith; (ii) profile data registered by yourself with the App; (iii) device identifier, model name, OS version and the setting data of your mobile device in which the App is installed and/or you use to access the services (together with the Product, collectively, "Devices"), including consent about privacy and push notification, date and time of usage and access to our App; (iv) information about the Product connected to the Devices (i.e Bluetooth addresss, serial number and network setting) and data regarding Product collects through its sensors such as the usage status; and (v) any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

For more details see 1. of the Detailed Notice.

Processing purposes

We process your Personal Data for the following purposes: (i) providing the functions of the App; (ii) conducting statistical analyses for development of our products and services; (iii) getting in contact with you concerning your queries and customer support; and (iv) sending you information materials by email or via push notifications from us about our` products and services which might be of interest to you. For more details see 2. of the Detailed Notice.

Legal justifications for the processing of your Personal Data

The processing of Personal Data has to have a legal justification under the General Data Protection Regulation (Regulation (EU 2016/679), "GDPR") and the Data Protection Act 2018 of the UK (collectively, "UK GDPR"). Personal Data are processed only after you have given your consent, or if the processing of such data relies on another legal basis under the UK GDPR. For more details and the matching of purposes and corresponding legal justifications see 2. of the Detailed Notice.

Data transfers and recipients and legal justification for such transfers

We use third-party service providers to provide services and products on our behalf and we will share and transfer your Personal Data with them for the provision of the services and products. Within Casio and such recipients, any access to your Personal Data in relation to your use of the App is restricted to those individuals who have aneed to know in order to fulfill their job responsibilities.

We also share your Personal Data with governmental authorities, courts, external advisors, and similar third parties that are public bodies as required or permitted by UK GDPR and the applicable laws. For more details see 3. of the Detailed Notice.

Cross-border data transfer

Some of the aforementioned recipients of your Personal Data are located or have relevant operations outside the UK (namely Japan, Ireland and US). By way of entering into appropriate data transfer agreements or by other adequate means, we have established that all such recipients located outside the UK will provide an adequate level of protection for the Personal Data and that appropriate technical and organizational security measures are in place to protect Personal Data. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law. For details see 3. of the Detailed Notice.

Implementation of security measures

We provide appropriate security measures to protect your Personal Data, including establishment of necessary rules to protect Personal Data, providing training to our employees, and taking other appropriate organizational, physical and technical security measures. For details of the security measures we take, please refer to 4. of the Detailed Notice.

Retention periods for and deletion of your Personal Data

Your Personal Data are stored by Casio and/or our service providers, strictly to the extent necessary for the performance of our obligations to you respectively the performance of the service providers' obligations to us and strictly for the time necessary to achieve the Purposes for which the Personal Data are processed, in accordance with applicable data protection laws. When we and/or our service providers no longer need to process your Personal Data, the Personal Data will be deleted and erased from the systems and/or records and/or steps will be taken to properly anonymize the Personal Data so that you can no longer be identified from the Personal Data unless we need to keep your information: to comply with legal or regulatory obligations to which we and/or our service providers are subject; and/or with regard to a judicial action. For more details see 5. of the Detailed Notice.

Your statutory rights

You have a number of rights with regard to the processing of your Personal Data, which are defined in applicable law, such as (i) the right to have access; (ii) the right to obtain a copy of your Personal Data undergoing processing; (iii) the right to rectification; (iv) the right to erasure ("right to be forgotten"); (v) the right to restriction of processing; (vi) the right to data portability; (vii) the right to object; and (viii) the right to lodge a complaint with the competent data protection supervisory authority.

If you have declared your consent to any Personal Data processing activities, you can withdraw this consent at any time. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Please refer any of your questions to app17+moflin@casio.co.jp . For more details see 6. of the Detailed Notice.

Google Analytics

This App uses Google Analytics, an analytics service provided by Google LLC. ("Google"). Google uses cookies, which are text files placed on your mobile device or other hardware device, or certain unique identifiers for your device to help us analyze how users use the App. By selecting the appropriate setting on the App following the App’s guidance, you may refuse or opt-out of the processing of information relating to your usage of the App by Google using the cookies or unique identifiers. For more details see 7. of Full Notice.

Children’s Privacy

If you have not yet reached the age of legal majority but are at least 16 years of age or as defined by applicable laws and legal requirements ("Under Age"), certain parts of this Privacy Notice also apply to the parent, legal guardian of a child or the holder of parental responsibility over you ("Parent").However, if you are between 13 and this age threshold to give a lawful consent, we will request your Parent consent to using this App. If you are below the age of 13, we do not offer the services regarding this App to you. If we learn we have mistakenly or unintentionally collected or received Personal Data from a childwithout appropriate consent, we will delete it.

If you are Under Age, certain legal restrictions may apply and we may need the authorization of your Parent in order to process your Personal Data with regard to provision of the App. Therefore, we collect the Personal Data with the consent of your Parent.

Personal Data required to enter into a contract

You only have to provide Personal Data that is marked as mandatory in the respective forms during the use of the App. Without such Personal Data, we cannot conclude the requested contract, or we will no longer be able to execute an existing contract and may have to terminate it.

Personal Data that are not marked as mandatory in the corresponding forms during the use of the App do not have to be provided. For details, please refer to 8. of the Detailed Notice.

Changes of the Privacy Notice

This Privacy Notice is subject to change. You will be notified of any such changes via in-app notification and/or email to your registered email address. You may also be notified through further relevant privacy notices (e.g. for specific purposes) in case such is not covered by this Privacy Notice.

B. Detailed Notice

We are delighted about your interest in our App. Your privacy is important to us. Hereafter we provide you with detailed information on dealing with your personal data on this App.

This Detailed Notice applies to information you provide to us or that we collect automatically when you access or use our App.

This Privacy Notice does not apply to the processing of your Personal Data using CASIO ID, information we collect when you visit or use our websites or otherwise, such as when you communicate with us through email, text, or other electronic means. Such processing is governed by other privacy policies, so when using CASIO ID with this App, the privacy notice for CASIO ID (https://auth.casio-intl.com/casio_contents/terms/index.html) will apply to the processing of that data. For information regarding how we collect and use information when you visit or use our websites, including web-based pages accessible through our App, please refer to our respective website privacy notice.

Casio Computer Co., Ltd., a Japanese Company, is your data controller and provides the services in connection with the App if you live in the UK. If you wish to exercise your data subject rights or if you have any other questions concerning this Privacy Notice, you can:

Email us at app17+moflin@casio.co.jp; and
Contact our "DPO" directly at dataprotection@casio.co.jp.

1. Categories of Personal Data

We process the following Personal Data about you:

(i) CASIO ID Data;
We use your CASIO ID and information registered therewith (including your name, email address and other information registered therewith) (hereinafter jointly "CASIO ID Data"). The data is required to log in to the App with your CASIO ID, and is the only information that is transmitted to the App from your CASIO ID Data.
(ii) Profile Data;
We collect and use your profile data registered by yourself with the App, including your birth year, gender, nickname and any other profile data (hereinafter jointly "Profile Data"), when you choose to provide the data.
(iii) Device Data;
When you access or use the App, we collect and use your system or setting data (consent about privacy and push notification) and other device information of your Devices, including (a) device identifier, model name, OS version, (b) bluetooth address, serial number and network settings; and (c) date and time of usage and access to the App (hereinafter jointly "Device Data").
(iv) Product Data;
We also collect and use data regarding Product collected through its sensors, including data on how many times the Product was touched, turned upside down, shaken, and spoken to, parameterized voice data derived from the sound tone and manner, and data related to the Product‘s behaviour (hereinafter jointly "Product Data").
(v) Form Data
We collect any other information related to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you (hereinafter jointly "Form Data") .

2. Processing purposes as well as categories of data we process and legal bases

This pargraph contains detailed information on:

(i) the categories of Personal Data we collect from you in addition to other Personal Data that you actively provide to us (e.g., when you send an email to us);
(ii) the purposes for which we process these categories of Personal Data; and
(iii) the legal bases for the collection and processing of your Personal Data (unless otherwise provided, e.g., at the time we collect the data from you).

We process your Personal Data to the extent permitted or required under applicable law for the purposes set forth below:

(1) Performance Purposes, i.e., to

(i) authenticate you when you use the App with your CASIO ID to make sure you are eligible and able to use the App;
(ii) operate the App by providing you with the respective functionalities of the App, which includes providing you with some activity log features to obtain accurate time for the automatic time adjustment feature on the App; and
(iii) fulfil the services in connection with the App to you, which includes providing customer supports when you enter a competition, promotion, sweepstakes, survey or communicate with us.

<Categories of Personal Data>; CASIO ID Data, Profile Data, Product Data, Device Data and Form Data,

<Legal basis> We use your Personal Data to provide the App and prevent and detect fraud or other security incidents described as above, based on contract justification under Article 6 (1) (b) GDPR.

(2) Quality Purposes, i.e., to

(i) monitor and maintain the performance of the App and Product in order to review and improve the App, Product and related service;
(ii) conduct user analyses for statistical, marketing or other purposes in order to develop, review and improve the quality of and to promote sales of our products and services, including the App and Product; and
(iii) provide customer supports.

<Categories of Personal Data>; CASIO ID Data, Profile Data, Product Data and Form Data.

<Legal basis> We use your Personal Data for the Quality Purposes, based on the legitimate interests (to optimize the usage of the App and services for you and other users provided by Casio) under Article 6 (1) (f) GDPR.

(3) Service Development Purpose, i.e., to

improve and develop our products and services, predict demand to provide enhanced user experiences for current and future offerings, and develop our advertising and marketing strategies.

<Categories of Personal Data>; CASIO ID Data, Profile Data, Product Data.

Consent.

<Legal basis> We rely on your consent where we process your Personal Data for the Service Development Purposes under the Article (1) (a) GDPR. You can unsubscribe from these at any time in your Device settings or App settings.

(4) Contact Purpose, i.e., to

get in contact with you concerning your queries, security and fraud prevention.

<Categories of Personal Data>; CASIO ID Data, Profile Data,Product Data, Device Data and Form Data.

<Legal basis> We use your Personal Data for Contact Purposes, based on the legitimate interests (to address any query you submit as well as to detect and prevent any possible fraud) under the Article (1) (f) GDPR.

3. Data transfers and recipients and legal justification for such transfers

3.1 Recipients

Casio will transfer your Personal Data for the respective purposes and limited to the extent necessary to the recipients and categories of recipients listed below:

(i) Third parties: We may transfer your Personal Data to governmental agencies and regulators, courts, and government authorities, all in accordance with applicable law based on Legal Obligation Justification and to external advisors acting as controllers (e.g., lawyers, accountants, auditors etc.) based on Legitimate Interest Justification.
(ii) Service providers: We contract with third party service providers as part of our normal business operations in connection with operating the App and with other technical and organizational services.

A list of service providers can be found in the Annex containing the identity, short description of the processing activity and location of the relevant service providers.

3.2 Cross-Border Data Transfers

(i) We may transfer your Personal Data outside the country you are located. The countries in which some recipients of your Personal Data are located are Japan, Ireland and the US. Japan and Ireland are deemed by the UK to provide an adequate level of data protection, and transfers to recipients in the US are made to organizations certified under the EU–US Data Privacy Framework (and the UK Extension)..
(ii) By way of entering into appropriate data transfer agreements based on the International Data Transfer Agreement and Addendum which are accessible via the contact details above, we have established that all recipients located outside the UK will provide an adequate level of data protection for your Personal Data and that appropriate technical and organizational security measures are in place to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.

4. Implementation of Security Measures

We have appropriate legal, organizational and technical security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspect Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We also establish the necessary rules to protect Personal Data, conducting trainings to our employees and taking other appropriate organizational, physical and technical security measures. For details of the security measures we take, please contact us by using the contact details provided in paragraph 8.

5. Retention periods for and deletion of your Personal Data

5.1

Your Personal Data which is processed for the purposes hereunder will be stored only to the extent necessary. We may need to keep your Personal Data to comply with legal or regulatory obligations to which Casio is subject. Further, if a judicial action is initiated, your Personal Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by law.

5.2

In principle, we will retain your Personal Data as long as they are required for its purpose or permitted by law. Afterwards, we will delete and remove your Personal Data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.

6. Your statutory rights

If you have declared your consent to any Personal Data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

Under the conditions set out under applicable data protection law (i.e., the UK GDPR and Data Protection Act), you may have the following rights, which you may exercise by contacting us as stated in paragraph 8 below:

6.1 Right of access: You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.

You also have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs. You have the right to access to your Personal Data but not necessarily documents which contain your Personal Data which we may redact as necessary.
6.2 Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data concerning you from us. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
6.3 Right to erasure (right to be forgotten): You have the right to ask us to erase your Personal Data in certain circumstances. This may include (but is not limited to) circumstances in which:

(i) it is no longer necessary for us to retain your Personal Data for the purposes for which we collected it;
(ii) we are only entitled to process your Personal Data with your consent, and you withdraw your consent; or
(iii) you object to our processing of your Personal Data for our legitimate interests, and our legitimate interests do not override your own interests, rights and freedoms;
6.4 Right to restriction of processing: You have the right to obtain the restriction of processing your Personal Data from us in certain circumstances. In this case, the respective data will be marked and may only be processed by us for certain purposes;
6.5 Right to data portability: You have the right to receive the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit those Personal Data to another entity without hindrance from us. This right only applies to Personal Data which you have provided to us.
6.6 Right to withdraw your consent: If you have given your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
6.7 Right to object:

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us which is based on the necessity of processing for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data, in particular if you are child including profiling based on those provisions. We will no longer process your Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Moreover, if your Personal Data are processed for direct marketing purposes, where such processing is permitted without your prior consent, you have a right to object at any time to the processing of Personal Data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case, your Personal Data will no longer be processed for such purposes by us.

Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
6.8 Right to lodge a complaint: In addition to the rights set out above, you also have the right to lodge a complaint with the competent data protection supervisory authority, in particular in the member state of your habitual residence or alleged infringement of the GDPR. In the UK the relevant authority is the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113.

Please note that the aforementioned rights might be limited under the applicable national data protection law. We remain the universal point of contact for your execution of these rights.

Please refer any of your questions to app17+moflin@casio.co.jp .

7. Google Analytics

We may use third-party analysis tools that use cookies or identifiers for mobile devices (including similar technologies) when obtaining information from you according to this Notice. For this purpose, we may provide Personal Data in an anonymous format to the provider of the third-party analysis tools. This information is handled according to agreements such as the privacy policy of the provider of the third-party analysis tools. Except in the case of the existence of any technical or fundamental difficulty, you can opt out of providing Personal Data to the provider of these analysis tools via the method offered by us or the provider of the third-party analysis tools (including the following method).

By contacting Google: For more details about Google Analytics and the privacy policy of Google, see the following site:
https://marketingplatform.google.com/about/analytics/terms/us/
https://policies.google.com/privacy?hl=en

8. Personal Data required to enter into a contract

You only have to provide Personal Data that is required for us to establish and implement a business relationship with you, or that we are legally obligated to collect. Such Personal Data are marked as mandatory in the respective forms when using the App. Without such Personal Data, we cannot conclude the requested contract, or should you remove such Personal Data at a later stage, we will no longer be able to execute an existing contract and may have to terminate it.

Personal Data that are not marked as mandatory in the corresponding forms when using the App do not have to be provided. With regard to the App, we can provide our service and/or conclude a contract only if you provide us with your full name, email address, birth date, gender and country.

9. Children’s Privacy

If you are Under Age, certain parts of this Privacy Notice also apply to your parent. However, if you are between 13 and this age threshold to give a lawful consent, we will request your parent consent to using this App. If you are below the age of 13, we do not offer the services regarding this App to you. If we learn we have mistakenly or unintentionally collected or received Personal Data from a childwithout appropriate consent, we will delete it.

10. How to contact Us and our data protection officer

If you have any questions concerning this Privacy Notice or would like to complain about our handling of your Personal Data or exercise any of your data subject rights (see paragraph 6 above), please contact us, our DPO by using one of the following contact details:

Ordinary mail: CASIO Computer Co. Ltd.
6-2, Hon-machi 1-chome, Shibuya-ku
Tokyo 151-8543
Japan
Email: app17+moflin@casio.co.jp

You may contact our DPO by:

Ordinary mail: CASIO Computer Co. Ltd.
Attention: Data Protection Officer
6-2, Hon-machi 1-chome, Shibuya-ku
Tokyo 151-8543
Japan
Email: dataprotection@casio.co.jp

11. Changes to the Privacy Notice

This Privacy Notice may require an update from time to time – e.g., due to the implementation of new technologies or the introduction of new services or features. We reserve the right to change or supplement this Privacy Notice at any time. You will be notified of any such changes via in-app notification and/or email to your registered email address accordingly. Further, you will be notified adequately through further relevant privacy notice (e.g. for specific purposes) in case such is not covered by this Privacy Notice.

ANNEX

Depending on the purpose of the processing for which we use each service provider, we share certain of your Personal Data (as necessary) with the following service providers:

(i) Amazon Web Service Japan GK (Japan): Support with the provision of the App;
(ii) Google LLC (Ireland, US): Support us with Google Analytics for analyzing your personal data of the App

PRIVACY NOTICE

3.1 Recipients

3.2 Cross-Border Data Transfers

5.1

5.2

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