Privacy Policy for the Data Subjects in the European Union

(Last updated: 1, 7, 2020)


Pokelabo, Inc. (the “Company”) have adopted this privacy policy (“Privacy Policy”) to describe the Company’s policy for the processing(‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction) of personal information and other information provided by customers in European Union (“Information Provider(s)”). The Company recognizes the importance of personal information, and promises to comply with the General Data Protection Regulation (GDPR), other relevant laws and regulations, guidelines, and the like.


This Privacy Policy does not apply to websites, applications or services that display or link to different privacy statements.For the processing of personal information by the applications distributed to EU, please refer to the privacy policy of the applications.

1.Information Collected from Information Providers

Information Providers’ name, postal address, telephone number, email address, Internet Protocol(IP) addresses, cookies, or details of your visits to our website and so on(the “Information”).

2.Purpose of Use and Retention Policy

The Company will use the Information for the following purposes:

  • Business developments and service improvements. Marketing activities such as survey.
  • Handling inquiries
  • Security measures and access analysis of our website
  • To provide other services related with those listed above

We retain the Information during we have to retain them to achieve the above purposes or as required by applicable law. We will delete the Information as soon as possible when it became unnecessary.

3.Legal basis

The legal basis for the processing of the Information is to meet the Company’s contractual obligations to the Information Providers or their consent to the Privacy Policy. If the legal basis is the consent, the Information Providers can withdraw it at any time.

4.Disclosure to third parties

The Company may share aggregate or de-identified the Information with business partners and other third parties. We may also disclose the information to third parties when the Company obtained consent of third parties, or necessary for in order to comply with legal requirements or to protect the rights, property or safety of others.

5.Transfer of Information to Affiliates and Third Parties Located Outside of the EU

The Company stores the Information in Japan. In addition, the Company may transfer the Information of Information Providers to business partners of the Company located in countries outside of EU/EEA.

The company may transfer the Information to third parties located in countries outside of the EU/EEA, where the Information may not receive the adequate protection, as they do not have legal frameworks for the protection of Information equivalent to that of the EU.

By agreeing the any form of documents which refers to the Policy, the Information Provider shall be deemed to have consented to (a) the processing of Information by the Company in accordance with this Privacy Policy, (b) the storage and processing of the Information Provider’s Information in any country where the Company or its affiliates may use facilities (including cloud storage and cloud computing operated by third parties) or in which the Company engages service providers

6.Information Management; Security

Information Management.

The Company has appointed an Information Manager to manage the Company’s policies and enforcement of matters regarding Information. The contact Information for the Company’s information Manager can be found at the end of this Privacy Policy. The Company also provides training and educational opportunities for its executives and employees and endeavors to foster a spirit of compliance with this Privacy Policy and the Company’s handling of Information.


The Company endeavors to use reasonable organizational, technical and administrative measures to protect Information under the Company’s control.

7.Rights of Information Provider

The Information Providers are entitled to : (i) makes a request (a) to access, correct, or delete your personal information, (b) to restrict or suspend the use of your personal data, or (c) data portability; or (ii) exercise the right to object the use of your personal data. If The Information Providers wish to make such request, please inform us by following the process described on our support page as follows.

8.Amendments to this Privacy Policy.

The Company may change this Privacy Policy at any time. Please refer to the “Last updated” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted through the Services or otherwise made available to Information Providers. Information Providers’ use of the Services after revisions are made to the Privacy Policy shall be deemed as acceptance of and consent to the revised Privacy Policy.

9.Contact Information for Inquiries.

Please use Contact Formfor any inquiries regarding the contents of this Privacy Policy or regarding the rights of the Information Provider.

10.Controller, Data Protection Officer(DPO) and EU Representative and these contacts

The Company designated the data protection officer and a representative.

Contacts of DPO:

DPO, General Council

GREE, Inc.

Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku, Tokyo, Japan

Email: dpo@gree.net

Contacts of EU Representative

Pokelabo Inc. EU Representative



Neuer Wall 54, 20354 Hamburg, Germany

Email: eu_representative@planit.legal


Data subjects have the right to lodge a complaints regarding processing his or her personal data with a supervisory authority in the Member State of his or her habitual residence. The list of supervisory authority is available below.



<Controller and its contacts>

Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku,

Pokelabo, Inc.