NOTICE FOR UNITED STATES RESIDENTS
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 collects, uses and discloses the United States residents’ identifiable information ("Personal Data") collected and processed when using our robotic pet product(s), Moflin, ("Product") and the application software, MofLife, connected to the Product ("App"). Please note that California residents have additional rights based on California law. For more information on those rights, please review the California Residents’ Rights section and the Colorado, Connecticut, Utah, and Virginia Residents’ section at the end of this Notice.
1. 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.
2. Information Casio Collects
We collect the following Personal Data about you:
- 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. - Profile Data;
We collect your profile data registered by yourself with the App, including your birth year, gender, nickname and any other profile data, when you choose to provide the data. - Device Data;
When you access or use the App, we collect your system or setting data (consent about privacy and push notification) and other device information of your Devices, including device identifier, model name, OS version, date and time of usage and access to the App. - Product Data;
We collect information of the Product including Bluetooth address, serial number and network settings. 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. - 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. - The 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 analyse 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. 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).
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
3. Use of Personal Data
Casio may use Personal Data collected in connection with the App for the following purposes:
- 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.
- 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.
- 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.
- Contact Purpose, i.e., to
get in contact with you concerning your queries, security and fraud prevention.
- Prevent and Detect Fraud or Other Security Incidents Purposes, i.e., to
prevent, detect, investigate, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity; and protect other users of the App, Casio, its employees, or other persons from harm caused by such activities.
- Legal Compliance Purposes, i.e., to
comply with legal or regulatory obligations, exercise Casio’s legal rights and defend against legal claims.
Casio may use deidentified Personal Data to: improve the App and Product or other services; or demonstrate the effectiveness of the App and Product and related services.
Casio does not use Personal Data collected in connection with the App for any targeted advertising purposes or allow any targeted advertising on the App. Casio does not create a profile of any users except to the extent such a profile is in furtherance of providing the App.
4. Disclosure of Personal Data
Casio does not sell or share, and has not sold or shared in the preceding 12-month period, Personal Data collected in connection with the App.
Casio may disclose Personal Data collected in connection with the App in the following circumstances:
- In furtherance of the purposes of providing App if the recipient of the information does not further disclose the information; these disclosures include disclosures to Casio’s service providers in connection with providing the App (in which case, the service provider will be contractually prohibited from using the Personal Data for any purpose other than providing the contracted service, prohibited from disclosing the Personal Data to any third parties, and required to implement and maintain reasonable security measures to protect the Personal Data).
- To ensure legal and regulatory compliance or take precautions against liability.
- To respond to the judicial process.
- To protect the safety or integrity of the App and Product and other users of the App and Product.
5. Your Choices with Respect to Your Personal Data
Correct Inaccurate Personal Data. You may correct information associated with your CASIO ID account by logging into your account and updating that information. If you believe the App have any inaccurate Personal Data, please contact us using one of the ways described below in Section 9 (How to Contact Us).
Delete Personal Data. Upon your request, we will delete your Personal Data unless we are permitted or required by applicable law to retain it.
Access Personal Data. Casio will provide access to your Personal Data upon receipt of a verified request from you if you are at least 16 years of age or from your parent or legal guardian if you are under 18 years of age.
6. Children’s Privacy
The App is not aimed at or intended for children under age 13 and Casio does not knowingly collect or receive Personal Data from children under the age of 13. If we learn that we have inadvertently collected Personal Data relating to a child under the age of 13, we will delete that information from our records. If you believe we might have any information from or about a child under age 13, please let us know using one of the ways described below in Section 10 (How to Contact Us).
7. Security of Personal Data
Casio has implemented and will maintain reasonable security measures, including administrative, physical and technical safeguards, designed to protect Personal Data from unauthorized access, destruction, use, modification, or disclosure.
8. Applicable Law
Although Casio is headquartered in Japan, United States laws apply to Casio’s collection, use and disclosure of your Personal Data. Depending on the specific situation, federal law and/or the law of the state in which you reside will govern.
9. Updates to this Privacy Notice
Casio may update this Privacy Notice from time to time. Please review the Privacy Notice periodically to make sure you are aware of Casio’s current practices in connection with the App.
10. How to Contact Us
You may contact us concerning privacy inquiries using one of the following contact methods:
Email: app17+moflin@casio.co.jp
11. California Residents’ Rights
The California Consumer Privacy Act (CCPA), California’s “Shine the Light” law, and the California Online Privacy Protection Act provide individuals who are California residents with specific rights regarding their Personal Data. If you are a California resident, this section provides you with additional information, describes your rights and explains how to exercise those rights. For the purpose of this section, “Personal Information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. To the extent this section applies to you, the provisions of this section prevail over any conflicting provisions in other sections of this Privacy Policy.
a. Categories of Personal Information Collected
Casio collects the following categories of Personal Information from California residents:
Category: Identifiers
Types of Information Collected: Name, account name, Internet Protocol (IP) address, and online and device identifier.
Purpose for Collection:
- Creating and managing an account
- Providing the App
- Providing support and security of the App
Category: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Types of Information Collected: Name and email address (some information may overlap with other categories).
Purpose for Collection:
- Creating an account
- Providing the App
- Providing support and security of the Services
- Confirming parental consent
Category: Characteristics of protected classifications
Types of Information Collected: Age (date of birth), gender.
Purpose for Collection:
- Confirming minimum age
- Providing the App
Category: Commercial information
Types of Information Collected: Not collected.
Purpose for Collection: —
Category: Biometric information
Types of Information Collected: Not collected.
Purpose for Collection: —
Category: Internet or other similar network activity
Types of Information Collected: Information on a consumer’s interaction with the App and Product.
Purpose for Collection:
- Providing and personalizing the App
- Improving the App and Product (deidentified data only)
Category: Geolocation data
Types of Information Collected: Not collected.
Purpose for Collection: —
Category: Sensory data
Types of Information Collected: Audio, electronic, visual, or similar information.
Purpose for Collection:
- Providing the App
- Improving the App and Product
Category: Professional or employment-related information
Types of Information Collected: Not collected.
Purpose for Collection: —
Category: Non-public education information (per the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g and 34 C.F.R. Part 99)
Types of Information Collected: Not collected.
Purpose for Collection: —
Category: Inferences drawn from other personal information
Types of Information Collected: Profile data about a user reflecting the user’s time and frequency to access the App, user activities and behaviors within the App and Product only.
Purpose for Collection:
- Providing the App
- Providing support and security of the App and Product
- Providing tailored contents and services to meet user’s needs and preferences
Casio collects Personal Information directly from you or passively from your activities on the App.
Sensitive Personal Information. Some types of Personal Information are subject to a heightened level of protection under data privacy laws. These types of personal information are called “Sensitive Personal Information” and include social security numbers, driver’s license numbers, passport numbers, precise geolocation data, racial or ethnic origin information, and genetic data. Casio does not collect, receive or process Sensitive Personal Information in connection with the App.
b. Disclosure of Personal Information
Casio may disclose or may have disclosed in the preceding 12-month period Personal Information listed in (a) above to its service providers, which are contractually obligated to only use the Personal Information for the purpose of providing the App.
c. Retention of Personal Information
Personal Information is stored by Casio or its service providers only for as long as necessary to provide the App to you, in accordance with applicable data protection laws or, if applicable, our contractual obligations. When we no longer need to process your Personal Information for purposes of providing the App or to comply with our legal or regulatory obligations, the Personal Information will be deleted or will be deidentified and anonymized so that it no longer can be associated with you.
d. Your Rights
Right to Correct Personal Information. You may correct information associated with your CASIO ID account by logging into your account and updating that information. If you believe the App have any inaccurate Personal Information, please contact us using one of the ways described below in Section 10.e. (Submission of Requests).
Right to Know. Subject to certain limits, you may ask us to provide the following information:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information was collected;
- The business or commercial purpose for collecting the personal information;
- The categories of third parties to which personal information was disclosed for a business purpose;
- The specific pieces of personal information we collected about you;
- Whether your personal information was sold or shared (“shared” in this context means sharing for the specific purpose of cross-context behavioral advertising) – Casio does not sell or share Personal Information collected in connection with the App.
Right to Delete. You have the right to ask us to delete any Personal Information that we have collected about you, subject to certain limitations as set forth under CCPA. We may deny your deletion request if the information is necessary for us or our service providers to, among other things, provide a service you requested, take actions reasonably anticipated in the context of our business relationship with you, perform a contract we have with you, detect and protect against security incidents or illegal activity, comply with a legal obligation, or exercise a right provided for by law.
Right to Nondiscrimination. We will not discriminate against you for exercising your privacy rights under California law. The CCPA permits us to offer you certain financial incentives that can result in different prices, rates, or quality levels, which are related to your Personal Information’s value; however, we do not offer financial incentives in connection with the Personal Information collected in connection with the App and the Product.
Right to Opt Out of Sale or Sharing. Casio does not sell or share Personal Information collected in connection with the App.
e. Submissions of Requests
If you are a California resident, you may submit a request, to correct, to access, to delete, or to opt out in any of the following ways:
- Submit a request using this form: app17+moflin@casio.co.jp
- Call us at: 1-800-706-2534
f. Responses to Requests
We will confirm receipt of your request within 10 business days of receipt and generally will respond to your request within 45 days of receipt. If we need more time to respond, we will inform you of the reason and we may take up to an additional 45 days to respond.
You will not have to pay a fee to access your Personal Information or to exercise any of the other rights. However, we may charge a reasonable fee if your request is repetitive or excessive; alternatively, we may refuse to comply with your request in these circumstances.
For your requests, you have to provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the Personal Information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are unable to verify your identity for your requests to know, delete, or correct, with the information provided, we may ask you for additional pieces of information.
Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation confirming that you are authorized to act on behalf of that individual.
a. California Shine the Light
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), you, as a California resident, may ask us to provide a list of the categories of Personal Data (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Within the meaning of California’s “Shine the Light” law, we do not disclose Personal Data to third parties for their own direct marketing purposes.
12. Colorado, Connecticut, Utah, and Virginia Residents’ Rights
If you are a resident of Colorado, Connecticut, Utah, or Virginia, this Section 12 (Colorado, Connecticut, Utah, and Virginia Residents’ Rights) applies to you.
a. Disclosure of Your Personal Data
Casio discloses to third parties substantially all categories of your Personal Data described in Section 2 (Information Casio Collects) of the Privacy Notice. To learn more about how we disclose your Personal Data, please review Section 4 (Disclosure of your Personal Data) of the Privacy Notice.
b. Targeted Advertising
Casio does not process your Personal Data collected in connection with the App for targeted advertising and disclose Personal Data to any third parties for a business purpose.
c. Profiling and Sensitive Data
Casio does not process your Personal Data for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects under applicable law.
d. Privacy Right Requests
Under applicable law, you may have the following rights, in each case under the conditions and to the extent set out in applicable law:
- Right to know. A right to confirm whether we are processing Personal Data about you and to access such Personal Data (including, if applicable, in a portable and readily usable format).
- Right to delete. A right to delete Personal Data about you.
- Right to correct. A right to correct inaccuracies in certain Personal Data we may maintain about you.
To make a request to exercise these rights, please contact us by using one of the ways described in Section 11.e. (Submission of Requests). As required under applicable law, we will take steps to verify your identity before processing your rights requests by requiring you to submit your [name, email address and country of your residence], and by matching the information you provide with what we already have on file.
If your rights request is denied, applicable law may give you a right to lodge an appeal with us. The response to your rights request will inform you of any appeal rights you may have and tell you how you can exercise them.