Last updated: January 14, 2027
This global privacy policy (the “Privacy Policy”) for Aniplex Inc. (the “Company” ) provides for the methods of processing personal information of customers ( “customers” , “you” ). Customers use the Company’s online fighting game service (the “Service”) in “ MELTY BLOOD: TWI-LUMINA” (the “Game” ), access the official website of the Game (the “Website”) located at https://meltyblood.twilumina.com/, or contact the customer support for the Game (the “Customer Support” ). The Company is located at 4-5 Rokubancho, Chiyoda-ku, Tokyo, 102-8353 Japan.
In addition to this Privacy Policy, which applies to all of our customers, the Company has prepared exhibits that may also apply to you depending on the area in which you reside or are located. In such case, please refer to the applicable exhibits. If this Privacy Policy conflicts with the country-specific exhibits, such exhibits will prevail.
- 1. Categories of personal information subject to processing
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The Company collects and processes the following personal information about its customers. Some of it may be collected automatically:
- ID and Password for Game accounts and online accounts (Sony Accounts, Nintendo Accounts and Network Service Accounts, Microsoft Accounts, Steam Accounts or Epic Accounts) of customers who use the Service;
- Cookies and other terminal identifiers and attribute information of customers who access the Website (such as, age, gender, interests’ categories, affinity categories, in-market segments. For more information about interests categories, affinity categories, in-market segments, visit https://support.google.com/analytics/answer/12948931);
- IP addresses, provider information, terminal information and web browser information of customers who access the Website;
- Names, email addresses, the play time and date of accessing the Game, ID and Password for online accounts (Sony Accounts, Nintendo Accounts, Microsoft Accounts or Steam Accounts), and system requirements of customers who contacted Customer Support;
- Other personal information collected by the Company in connection with the Services, the Website, and the Customer Support (if required by applicable laws and regulations, the Company shall obtain such personal information after separately notifying the customers).
- 2. Purposes of the processing
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The Company may process personal information of customers for the following purposes:
- to provide the performance of the Service, and to handle faults in the Game and diagnose its problems;
- to analyze the attributes of customers who accessed the Website and improve our customers’ experience when they access the Website;
- to analyze the use of the Website, to maintain, handle faults in and operate and improve the Website, and to diagnose server problems;
- to respond to inquiries made by customers to Customer Support;
- if required, to respond to disputes and litigation and to comply with our legal obligations;
- to conduct other business operations necessary to provide the Service and services incidental thereto;
- to develop new services;
- to send updates, promotions, and marketing materials that may be of interest to you;
- with your consent, or as otherwise disclosed at the time information is collected;
- for our recordkeeping purposes;
- to maintain security of the Service and the Website including preventing fraud and cyber-attacks; and
- for other purposes permitted under applicable laws and regulations.
- 3. Legal basis for processing, etc.
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The Company processes your personal information in accordance with applicable personal information protection regulations. Please refer to the country-specific exhibits regarding the Company’s legal basis for processing.
The provision of personal information may be mandatory for reasons such as being a statutory or contractual requirement, or a requirement necessary to enter into a contract. If you do not provide your personal information, the Company may not be able to provide to you the Service or Customer Support services as they would not operate.
Especially, the provision of your ID and Password for Game accounts and online accounts (Sony Accounts, Nintendo Accounts and Network Service Accounts, Microsoft Accounts, or Steam Accounts) is a requirement necessary for you to use the Service.
Furthermore, your IP addresses, provider information, terminal information and web browser information is a requirement necessary for you to access the Website.
- 4. Retention period for personal information
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The Company retains your personal information as long as it is necessary in order to fulfil the purposes of processing personal information as set out above. Specifically, the retention period for each personal information is as follows.
- ID and Password for Game accounts and online accounts (Sony Accounts, Nintendo Accounts and Network Service Accounts, Microsoft Accounts, or Steam Accounts) of customers who use the Service:
As long as it is necessary for the Company to provide the Service. Once the performance of the Service is achieved, the personal information are not kept. - Cookies and other terminal identifiers and attribute information of customers who access the Website:
Within 14 months
- ID and Password for Game accounts and online accounts (Sony Accounts, Nintendo Accounts and Network Service Accounts, Microsoft Accounts, or Steam Accounts) of customers who use the Service:
- 5. Sources of personal information
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The Company collects all of your personal information from you directly, save for:
- ID and Password for Game accounts and online accounts (Sony Accounts, Nintendo Accounts and Network Service Accounts, Microsoft Accounts, Steam Accounts or Epic Accounts) of customers who use the Service which the Company collects from platforms providing the Service such as Sony Interactive Entertainment LLC, Nintendo Co., Ltd., Microsoft Corporation, Valve Corporation and Epic Games, Inc.; and
- attribute information of customers who access the Website which the Company obtains from The Website Traffic Analysis Service Provider such as Google LLC.
- 6. Sharing and disclosure of personal information
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The Company shares with and discloses customers personal information to the following third parties below in order to fulfil the purposes of processing personal information as set out above.
○ Sharing with Processors (service providers)- Platforms providing the Service such as Sony Interactive Entertainment LLC, Nintendo Co., Ltd., Microsoft Corporation Valve Corporation and Epic Games, Inc.;
- The Game Developer such as Lasengle Inc., Unknown Corporation, TAMSOFT CORPORATION, and Gemdrops, Inc.;
- The Website Production and Maintenance Service Provider such as ESBrain,Inc., Kirksville co.,ltd., Aniplex of America Inc. and Amazon Web Services, Inc.;
- The Customer Support Service Provider such as DIGITAL HEARTS Co., Ltd.;
- The Website Traffic Analysis Service Provider such as Google LLC; and
- Other contractors of the Company
○ Legal compliance, etc.
In some instances, the Company may be required to disclose your personal information to public and governmental authorities within or outside your country of residence in accordance with law and/or requests from such authorities. The Company will also disclose your personal information if the disclosure is necessary or appropriate, due to the purposes of law enforcement or handling other issues of public importance. The Company will also disclose your personal information if the disclosure is reasonably necessary to protect the Company’s rights, to pursue available remedies, to enforce the Company’s terms of use, to investigate fraud, or to protect the Company’s operations or customers.○ Other
In addition, we may also share personal information of customers with other parties, including:- As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
- Cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain a principal's consent;
- With your consent;
- Other cases permitted under applicable laws and regulations.
We may share information that has been de-identified or aggregated without limitation.
- 7. Overseas transfer of personal information
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As a result of the above sharing and disclosure, your personal information may be transferred to the following countries:
- United States of America.
In such cases, the Company will take proper protection measures required by the personal information protection regulation of each country. For the protection measures of each country, please refer to the country-specific exhibits.
- 8. Security measures
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For safety management of customers’ personal information, the Company takes the following safety management measures:
- Formulation of basic policies: to secure proper processing of personal information, the Company will form basic security policies e.g. “compliance with related laws, regulations, guidelines, and the like”, “questions and complaints processing center”, etc.
- Preparation of procedures related to processing of personal information: in each of the steps of acquiring, using, storing, providing, deleting, disposing etc, the Company will form processing procedures for personal information regarding processing methods, responsible persons, persons in charge and their duties etc;
- Organizational safety management measures: the Company will, as well as identifying persons responsible for the processing of customers personal information, clarify which employees will process personal information and the scope of personal information that such employee will process, and prepare a reporting and communication system if a breach of such access rights is found or a breach of any personal information is found (in accordance with applicable personal information protection regulations).
- Human safety management measures: The Company will conduct regular training for employees for important matters regarding processing of personal information.
- Physical safety management measures: In the areas that personal information will be processed, the Company will, as well as managing employees’ access of rooms and limiting devices that would be brought into the room, take measures to prevent access to personal information by persons without authority. The Company will, take measures to prevent robbery, loss or unauthorised access etc. devices, electronic media, documents and anything else containing personal information.
- Technical safety management measures: The Company will limit the number of persons in charge and the scope of personal information databases accessible by persons. The Company will install systems to protect information systems that process personal information from unauthorized access and unauthorized software from outside.
- Grasping the external environment: The Company will take safety management measures after grasping systems regarding protection of personal information in the United States where personal data are stored.
- 9. Cookies and similar technologies
- When a customer accesses the Website and such customer enables cookies, etc. (including tracking technologies such as flash cookies and web beacons, and other technologies; “Cookies, etc.”), the Company may automatically acquire information about the PC, mobile phone, tablet, or other information regarding the communication devices used by the customer etc. If the Company acquires such information, the Company will handle the information as personal information. If you do not wish to use cookies or other tracking technologies, you may disable them by changing your web browser settings.
- 10. Regarding acquisition of information accompanied by service tools provided by third parties
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○ Digital advertising and analytics
We may work with third parties that collect data about your use of the Website over time for non-advertising purposes. For example, the system may use Google Analytics for analytics and marketing purposes. In Google Analytics, user information will be collected by using Cookies, etc. For more information about how Google Analytics collects and uses data when you use our Site, visit https://policies.google.com/technologies/partner-sites, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout. Google Analytics advertising function that the Company uses is as follows:- Reports on user attributes and interest categories of Google Analytics
The Company and third-party vendors including Google Analytics combine first party cookies (or other first party IDs) and third party cookies such as Google advertising cookies (or other third party IDs) to analyze customers attributes and interests.
○ Third-Party Links and Tools
The Website and Service may provide links to third-party websites or apps. We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy. You should review the privacy policies of other websites or apps that you use to learn about their data practices. The Website also includes integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Site, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.
- 11. Rights of customers
- The Company will respect the rights you hold regarding personal information protection regulations applicable to you. Customers may require disclosure, correction, addition, and elimination of content, suspension and erasure of usage, and suspension of provision to third parties, of personal Information, or disclosure of records of personal information provided to a third party in accordance with Japanese laws regarding protection of personal information. In addition, in personal information protection regulations of each country that will be applied, rights may be granted to customers. For rights granted in each country, please refer to the country-specific exhibits. If you wish to exercise your rights, please make an inquiry using the contact in Article 13 (Contact details) of the Privacy Policy.
- 12. Personal information of children
- Regarding personal information of children, the Company will take necessary measures in accordance with applicable laws and regulations. Please refer to the country-specific exhibits for more information.
- 13. Contact details
- For questions and inquiries regarding the Privacy Policy, please contact the consultation center stated below: twilumina_support@aniplex.co.jp
- 14. Changes to the Privacy Policy
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The Company may, in making changes to the Privacy Policy (including country-specific exhibits), change or add all or part of the Privacy Policy by publishing on the Website, sending e-mail to customers, or giving notice by any other method that the Company deems appropriate (subject to applicable laws and regulations, if any).
In such case, the amended Privacy Policy will be applied from:
- the earlier of the date on which you use the Service, access the Website, or make inquiries to the Customer Support for the first time after receiving such notice, or
- the date stated in such notice.
If there are any necessary procedures in personal information protection regulations that will be applied, such procedures will be taken.
- Exhibit: EEA (European Economic Area) and UK
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Last updated: January 14, 2027
This Exhibit applies to customers located or residing in the EEA (European Economic Area) and the UK. The controller for the purposes of the obligations set out in the Privacy Policy and this Exhibit is the Company Aniplex Inc.
- 1. Legal basis for processing
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The legal basis for the Company’s processing of personal information (in this Exhibit “personal information” means the same as “personal data” as defined within the GDPR and the UK GDPR (collectively, the “GDPR”)) under the GDPR is as follows. There may be cases where we obtain consent from you in connection with your personal information, but unless item (3) below applies, even in such a case, the legal basis for processing will be, “processing is necessary for the performance of a contract ” or “processing is necessary for the pursuit of legitimate interests. ”
(1) Processing is necessary for the performance of a contract (GDPR Article 6(1)(b))
We process your personal information on the basis that processing is necessary for the performance of a contract (GDPR Article 6(1)(b)) for the following purpose:
• to respond to inquiries made by customers to Customer Support
(2) Processing is necessary for the pursuit of legitimate interests (GDPR Article 6(1)(f))
We process your personal information on the basis that processing is necessary for the pursuit of legitimate interests (GDPR Article 6(1)(f)) for the purposes specified in Section 2 (Purposes of the processing) of the Global Privacy Policy other than the purposes specified in items (1) and (3) (for details of the balancing test for legitimate interests, please contact us using the contact details specified in Section 13 (Contact details) of the Global Privacy Policy.
(3) We obtain your consent in advance (GDPR Article 6(1)(a))
We will obtain your consent before using cookies and other terminal identifiers, except for cookies and other terminal identifiers that are strictly essential in order to provide services to you. We process cookies and other terminal identifiers of you who access the Website on the basis of your consent (GDPR Article 6(1)(a)) for the following purpose:
• to analyze the attributes of customers who accessed the Website and improve our customers’ experience when they access the Website.
• to advertise to you on the Website or on other services by providing you with tailored information of products, contents and services, as well as
recommendations, advertisements, promotions, or offerings that may be of interest to you.
Where required by law, we will obtain your consent before engaging in direct marketing. You have the right to withdraw your consent at any time by the means separately specified at the time we obtain your consent. However, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before its withdrawal.
- 2. Overseas transfer of personal information
- When we transfer personal information to a country outside the EEA (European Economic Area) and the UK, we do so on the basis of an adequacy decision for countries where an adequacy decision has been made (GDPR Article 45), and for other countries, we implement appropriate safeguards by executing standard data protection clauses adopted by the European Commission (and where applicable the UK Information Commissioner) (GDPR Article 46(2)(c) and Article 46(5)) with the recipient. If you wish to receive copies of documents regarding these safeguards, please contact us using the contact details specified in Section 13 (Contact details) of the Privacy Policy.
- 3. Your rights
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You have the following rights.
- Obtaining information regarding data processing: You have the right to obtain from us all necessary information regarding our processing of your data (GDPR Article 13 and Article 14).
- Access to personal information: You have the right to obtain confirmation from us as to whether or not personal information concerning you are being processed, and, where that is the case, to access personal information and certain information (GDPR Article 15).
- Rectification and erasure (“right to be forgotten”) of personal information: You have the right to have us rectify inaccurate personal information concerning you without undue delay and have incomplete personal information completed by us (GDPR, Article 16). You also have the right to have us erase personal information concerning you without undue delay when certain grounds apply (GDPR Article 17).
- Restricting processing of personal information: You have the right to restrict our processing of personal information concerning you when certain conditions are met (GDPR Article 18).
- Objection to processing of personal information: You have the right to object to our processing of personal information concerning you when certain conditions are met (GDPR Article 21(1)).
- Objection to direct marketing: You have the right to object at any time to processing of personal information for direct marketing, which includes profiling to the extent that it is related to such direct marketing (GDPR Article 21(2)).
- Personal information portability: You have the right to receive personal information concerning you in a structured, commonly used and machine-readable format, and to transmit those data to another controller without hindrance from us, when certain conditions are met (GDPR Article 20).
- Freedom from automated individual decision-making, including profiling: You have the right to not be subject to a decision based solely on automated (no human involvement) processing (including profiling), which produces legal effects or similar significant effects on you, when certain conditions are met (GDPR Article 22).
- You may lodge a complaint regarding our processing of your personal information with the data protection supervisory authority of the member state where you live or work or where the alleged infringement took place (GDPR Article 77) or, if you live in the United Kingdom, with the Information Commissioner of the United Kingdom.
Our representative in the EU:
Name: Sony Europe BV
Address: Taurusavenue 16, 2132LS Hoofddorp, the Netherlands
email: privacyoffice.SEU@sony.com
Our representative in the UK:
Name: Sony Europe BV
Address: The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom
email: privacyoffice.SEU@sony.com
- Exhibit: California/Nevada
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Last reviewed: January 14, 2027 For a printable version of the Privacy Policy, please click here(https://meltyblood.typelumina.com/privacy/en_globalprivacypolicy_2024.pdf).
California Privacy Rights
This section applies to customers residing in California and applies only to “personal information” that is subject to the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”). “Personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, device, or household. It includes disclosures required under CCPA. We may update this Privacy Policy from time to time. You should not use the Service if you have any objections to our Privacy Policy, which is binding upon all users of the Service. If you have a question about how your personal information is being used, you can contact us through the methods provided in the “Contact Details” section at the end of this Privacy Policy.
- Notice at Collection
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We may collect or process various categories of personal information described under CCPA (“California Personal Information”).
Section 1. “Categories of California Personal Information collected by the Company” below contain information on the categories of California Personal Information collected. As an overview, we collect identifiers; characteristics of protected classifications under California or federal law; commercial information including products or services purchased, obtained, or considered and in-game play time; inferences.
The purposes for which the categories of personal information are collected or used is described in Section ”3. Why We Collect, Use, and Disclose California Personal Information” below.
The length of time the business intends to retain California Personal Information is described in Section “5. Retention Period.” below. For your rights regarding California Personal Information, please refer to Section “8. Your rights concerning California Personal Information” below.
- 1. Categories of California Personal Information collected by the Company
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We collect information that is subject to CCPA (“California Personal Information”).
We have collected California Personal Information in the following categories within the past 12 months:- Personal and online identifiers (such as first and last name, address, phone number, unique online identifiers, IP addresses, email addresses, account names, etc.)
- Characteristics of protected classifications under California or federal law (age, gender, etc.)
- Commercial information including products or services purchased, obtained, or considered and in-game play time
- Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
- Inferences drawn from the above information about your predicted characteristics and preferences
- Other information about you that is linked to the personal information above
- De-identified information. We maintain and use all de-identified information in de-identified form.
- 2. Categories of sources of California Personal Information
- n the past 12 months we have obtained the California Personal Information specified in Section 1 above from the following categories of sources: information sources specified in Section 5 (Sources of personal information) of the Global Privacy Policy.
- 3. Why We Collect, Use, and Disclose California Personal Information
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Our purposes for collecting, using, and disclosing California Personal Information are as set forth in Section 2 (Purposes of the processing) of the Global Privacy Policy.
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Our business purposes as identified in CCPA include:
Auditing related to our interactions with you;Legal compliance;Detecting and protecting against security incidents, fraud, and illegal activity;Debugging;Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;Internal research for technological improvement;Internal operations;Activities to maintain and improve our services; andOther one-time uses.
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Our commercial purposes as identified in CCPA include:
Advertising;Marketing
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Our business purposes as identified in CCPA include:
- 4. Recipients of California Personal Information
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We may share your California Personal Information by disclosing it to a third party for a business purpose or as otherwise disclosed in this Privacy Policy and/or agreed by you. In the preceding twelve (12) months, we have disclosed California Personal Information for a business purpose to the categories of third parties indicated in the chart below.
Consumers have the right to opt out of any “sale” of California Personal Information or use of California Personal Information for cross-context behavioral advertising or targeted advertising (together “targeted advertising”). We do not sell California Personal Information for money, however, we share certain information to third parties for the purposes of cross-context behavioral advertising or targeted advertising. In the preceding twelve (12) months, we have shared for targeted advertising the following categories of California Personal Information to the categories of third parties indicated in the chart below.
Personal information category Category of recipient Personal and Online Identifiers The Game Developer, the Website Production and Maintenance Service Provider, the Customer Support Service Provider, the Website Traffic Analysis Service Provider, the Ad networks and Other contractors of the Company Characteristics of protected classifications under California or federal law The Website Traffic Analysis Service Provider Commercial information, including products or services purchased, obtained, or considered and in-game play time The Game Developer, and the Customer Support Service Provider Internet or other or other electronic network activity information The Website Traffic Analysis Service Provider and the Ad networks Inferences drawn from the above information about your predicted characteristics and preferences The Website Traffic Analysis Service Provider and the Ad networks Other information about you that is linked to the personal information above The Game Developer, the Website Production and Maintenance Service Provider, the Customer Support Service Provider, the Website Traffic Analysis Service Provider, and Other contractors of the Company
- 5. Retention Period
- We retain California personal Data for the period as explained in Section 4. “Retention period for personal information” of Global Privacy Policy.
- 6. “Sensitive personal information”
- We do not collect, use, or disclose “Sensitive personal information” under CCPA.
- 7. Children’s privacy
- We do not knowingly seek or collect personal information from or about children under the age of 16 without the consent of a parent or guardian. If you are a parent or guardian and are concerned that your child has provided us with personal information without your consent, you should contact us as indicated in Section 13 (Contact details) of the Global Privacy Policy. If we become aware that we have received or collected personal information about a child under the age of 16, we will delete that personal information as soon as possible.
- 8. Your rights concerning California Personal Information
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You have certain rights in connection with your California Personal Information. You can exercise these rights free of charge, unless otherwise provided by applicable law. We will endeavor to respond to your request promptly after verification pursuant to the provisions of applicable laws.
- a. The right to know the categories of California Personal Information that we have collected concerning you, the categories of information sources from which we collect that California Personal Information, our business or commercial purpose for collecting or selling California Personal Information, the categories of third parties with whom we disclose California Personal Information, and specific pieces of California Personal Information that we have collected concerning you.
- b. The right to request deletion of the California Personal Information concerning you that we have collected from you.
- c. The right to correct California Personal Information that is inaccurate.
- d. The right to data portability, which is the right to receive the personal information that you have given us, in a structured, commonly used and machine-readable format. You have the right to send that personal information to another controller if the processing is based on consent pursuant on a contract and is carried out by automated means.
- e. The right to opt-out of profiling, which is the right not to be subject to a decision based solely on profiling, except under certain exceptions under applicable laws.
- f. The rright not to be discriminated againstr by us on the grounds of your exercise of privacy rights granted under CCPA.
- g. Shine the Light. As a California resident, under California’s Shine the Light law (California Civil Code § 1798.83) you may request that we provide a list of the categories of personal information that we have disclosed to third parties for direct marketing purposes in the most recent calendar year, and the names and addresses of those third parties. You also may request that we do not share your personal information with third parties for marketing purposes. To make such a request, please contact us through the methods provided in the “Contact Details” section below.
You can make a request to exercise the above rights by contacting us using the contact details specified in Section 9 below.
Verification procedures and necessary information: We may request that you provide additional information to verify your identity or to correctly understand, evaluate and respond to your request, but you are not required to create an account with us in order to submit or achieve any request. We ask you to provide specific personal information for our records and reference. We will require you to provide, at a minimum name and email address.
Agent: You may nominate an agent who is authorized to make requests on your behalf. You may do so by giving your agent written permission to act on your behalf. Even if you choose to use an agent, to the extent permitted by law, there may be cases where we request a new verification when responding to a request.
Minors’ Right to Opt In. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
“Do Not Sell or Share My Personal Information.” You have the right to opt-out of the sale or sharing of your California Personal Information for targeted advertising purposes of your California Personal Information. We do not sell the personal information of consumers we actually know are less than 16 years old. If you wish to exercise this right, you may submit a request to twilumina_support@aniplex.co.jp or you can block the collection of information by our third-party advertising partners in the cookie preference tool also available.
- 9. Contact details for detailed information
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If you have any questions or concerns regarding our privacy policies and practices or your options and rights under California law, please contact us using the contact details specified in Section 13 (Contact details) of the Global Privacy Policy.
Email us at: twilumina_support@aniplex.co.jp
Nevada Privacy Rights
Although we do not currently conduct sales of personal information, Nevada residents may submit a request directing us to not sell personal information we maintain about them if our practices change in the future.
- Exhibit: Hong Kong
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Effective date: January 14, 2027
This Exhibit is in addition to the Privacy Policy and applies to customers located or residing in Hong Kong under the Personal Data (Privacy) Ordinance, Cap. 486 of the laws of Hong Kong (the “PDPO”).
- 1. Direct marketing
- We will not send you any direct marketing, or provide your personal information (in this Exhibit “personal information” means the same as “personal data” as defined within the PDPO) to a third party for use by that third party in direct marketing, without obtaining your consent. You have the right to withdraw your consent at any time by the means separately specified at the time we obtain your consent. However, your withdrawal of consent is only valid into the future, and does not affect the lawfulness of processing conducted based on your consent before its withdrawal.
- 2. Legal basis, etc. for processing
- Your personal information is collected, held, processed, and used in accordance with the PDPO.
- 3. Retention period for personal information
- We will take all practicable steps to ensure that your personal information is not kept longer than is necessary for the fulfilment of the purpose for which the personal information is or is to be used as notified to you in the Privacy Policy and above. Where the retention period for any personal information is not specifically set out in the Privacy Policy, this general principle applies.
- 4. Sources of personal information
- As described in the Privacy Policy, we may receive your personal information through third party sources if you have previously submitted such personal information to them. We are not responsible for the collection, retention, processing, use, disclosure, transfer, security, and/or access of your personal information by or from such third-party sources, and we recommend you examine the privacy policy of any third parties to understand their procedures for collecting, holding, processing, using, and disclosing personal information.
- 5. Sharing and disclosure of personal information
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As stated in the Privacy Policy, we may disclose your personal information in order to fulfill the Purposes to certain third parties. “Other contractors of the Company” and other third parties include:
- our affiliates and/or other service providers that provide development and maintenance, administrative, data processing, research and marketing, distribution, IT and telecommunications, digital storage, professional, or other similar services to us. This includes, without limitation, cloud hosting service providers, which provides us with digital storage services on its servers;
- 6. Overseas transfer of personal information
- As set out in the Privacy Policy, your personal information may, from time to time be transferred to and/or stored by us in physical locations and/or servers located within or outside Hong Kong and/or shared with our affiliates and/or other third parties (as set out above) within or outside Hong Kong. Where the specific countries or locations for any overseas transfer of personal information is not specifically set out in the Privacy Policy, we will take proper protection measures required by the personal information protection regulation of each country as set out in the Privacy Policy.
- 7. Safety management measures
- In addition to those specific safety management measures as set out in the Privacy Policy, we will take all practicable steps to ensure that your personal information held by use are protected against unauthorised or accidental access, processing, erasure, loss or use, and we shall procure by contract or use our reasonable endeavours to ensure that our affiliates and/or any other third parties to whom we disclose your personal information do the same. Where the specific safety management measures are not specifically set out in the Privacy Policy, this general principle applies.
- 8. Rights of customers
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You have the right to:
- ascertain whether we hold any of your personal information;
- request access to your personal information held by us (and be given reasons if such a request is refused, and object to such a refusal);
- require us to correct any personal information which is inaccurate (and be given reasons if such a request is refused, and object to such a refusal);
- ascertain our policies and practices (from time to time) in relation to personal information generally, and the types of personal information held by us; and
- withdraw consent from receiving direct marketing from us at any time.
If you would like to make a request in relation to the above (or make any general enquiries), please send us your request or enquiry in writing as set out in the Privacy Policy as supplemented by this Exhibit in paragraph 9 below.
In accordance with the PDPO, we have the right to charge you a reasonable fee for the processing of any personal information access request.
- 9. Contact details
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For any enquiries in relation to the Privacy Policy or this Exhibit, our contact details are as follows:
Legal Department
twilumina_support@aniplex.co.jp
- 10. Changes to the Privacy Policy and this Exhibit
- We reserve the right to modify the Privacy Policy and this Exhibit at any time, so please review each document frequently. Where there are significant changes, we will notify you (as set out in the Privacy Policy) and, where required by law, obtain your acceptance of the changes, consents, and/or opt in (as necessary or applicable). If you do not accept the changes and/or provide your consent, then we may not be able to perform the Purposes and/or provide the Services to you.