Brilliantcrypto, Inc. (Midtown East 6F Akasaka 9-7-2, Minato-ku, Tokyo 107-0052, Japan)
("Brilliantcrypto" or "we" or "our") takes data privacy seriously. This App Privacy Policy ("Policy")
informs users of the game app named Brilliantcrypto and any other Brilliantcrypto-owned websites on which
this Policy is displayed (together "App") how we collect and process data and information of any kind
(e.g., your email-address etc.) about or related to you, even if such information cannot directly
identify you on its own but can identify you in combination with other information that is stored by us
("Personal Data") in connection with the App and our games distributed via the App (collectively, the
"Service").
- Content Overview
- 1. Categories of Personal Data
- 2. Processing Purposes
- 3. Processing Basis and Consequences
- 4. Categories of Recipients and International Transfers
- 5. Retention Periods
- 6. Your Rights
- 7. Accuracy of Personal Data
- 8. Questions and Contact Information
- 9. Changes to this Policy
1.Categories of Personal Data - What Personal Data do we process about you?
We process the following Personal Data related to your use of the App.
a.Personal Data you provide to us
Account data: If you create an account in our App, you may be asked to provide the following Personal
Data:
Discord username, nickname, email address, serial code and wallet address.
Communications: If you contact, or are contacted by, us with any queries, requests or complaints, for
marketing
service, customer support or technical support, or exercise your rights, we may collect and process
the
following types of data: your name, email address, SNS ID, in-game activities, message ID and
achievements if
necessary and any other information provided by you in the communication.
Payment account data: If you are qualified to receive any cryptocurrency, you may be asked to provide
the
following types of data: your name, address, wallet address and type of wallet service.
Contents: If you posted any text, characters, symbols, images, videos, audios, voice, and all other
expressions
which are created by you, including, but not limited to, any comments or posts by you (collectively
"Contents")
on Discord in order to communicate with us or other users, we may collect and process such Contents.
Ambassador information: When you enter our ambassador program, we may collect and process the
following
types
of data: your name, email address, address, languages spoken, SNS ID, reason for application.
Beta tester information: When you apply to tester participation in the Brilliantcrypto, we
may collect and process the following types of data: email address, region of residence, experience of
web3, crypto asset and NFT, how you heard about the beta test (collectively "Tester Profile").
b.Personal Data we collect by technical means
Metadata: When you use the App, we will collect the following metadata that results from your usage of
the App:
wallet address, device information including device name, name and version of OS, crash report of the
App, and
internet protocol (IP) address.
In-game activities and achievements: When you play the game in the App, we will collect and process
your
in-game activities and achievements.
2. Processing Purposes - Why do we process your Personal Data?
We will use the Personal Data collected from you for the following purposes:
Account creation and management: We use your Personal Data to create and manage your account that
can be
used to sign-in to the App and other related services, and record your game playing.
Service provision:
We use the Personal Data to operate, maintain, enhance and provide features and functions of the
App and
the Service, including the following activities:
・Operating the App and the Service including recording of game play.
We will process your Personal Data to operate the App and the Service. For example, we will process
your
Personal Data to record your game play, to allow you to start playing the game where you left off,
to
make it easy for you to sign-in to the App and provide appropriate game software for your device.
・Conducting events. We will process your Personal Data to pay premiums to the qualified users.
・Identifying and fixing bugs, verifying service reliability.
We will process your Personal Data in order to identify and fix the bug of the App and the Service
and to
verify service reliability. Crash report information will be recorded and processed in order to
identify
and fix the bugs and restore your game play.
・Managing of access log.
We will process your device's IP address to manage your access log.
Communications: We use the Personal Data to communicate with you about the App or the Service for
administrative and informational purposes.
Examples of such communications include responses to your
inquiries or requests, customer/technical support-related communications, and changes to any of our
terms
& conditions or policies.
Improvement and development of App and Service: We use the Personal Data to optimize and improve
our App
or Service, and to develop new services, contents, events, items, features and functions by
analyzing and
understanding the usage trends and preferences of our users in order to enhance your user
experience.
Compliance with law: We use the Personal Data to ensure compliance with our internal policies,
agreements
with our stakeholders, applicable laws and regulations, court orders, government and law
enforcement
requests. We may also use the Personal Data to enforce or defend our legal rights or the terms and
conditions of any our service, or to retain and store your personal information to comply with
specific
legal retention requirements, regulatory audits, and other record keeping purposes (including to
meet
internal and external audit requirements).
Protection of the security or integrity of the App, including fraud prevention and investigation:
We may
use the Personal Data to monitor, prevent, detect, investigate and report illegal and illicit
activities,
including fraud and misuse of the App. We will also use the Personal Data to maintain the integrity
and
security of the App and Service and preventing and detecting security threats, fraud or other
criminal or
malicious activity that might compromise your devices.
Marketing activities: We will use your Personal Data to improve our marketing activities by
analyzing
your interests and contact you for marketing activities.
Recruitment of Ambassador: When you apply for our ambassador program, we will use the Personal Data
to
operate recruitment and selection processes.
Recruitment of beta tester: When you apply to tester participation in the Brilliantcrypto, we will
use
the Personal Data to operate recruitment and selection processes.
3. Processing Basis and Consequences - What is the legal justification for processing your Personal
Data and what happens if you choose not to provide it?
We rely on the following legal grounds for the collection, processing, and use of your Personal Data:
・the processing is necessary to provide the App and its Services to you;
・your consent to the processing of your data for one or more specific purposes;
・the processing is necessary for the performance of a contract to which you are a party or to take
steps
at your request prior to entering into a contract;
・the processing is necessary for compliance with a legal obligation to which we are subject;
・the processing is necessary for the purposes of the legitimate interests pursued by us or by a third
party, except where such interests are overridden by the interests or fundamental rights and freedoms
of
you which require protection of Personal Data, in particular if you are a child; such legitimate
interests are the fulfilment of the processing purposes set out above in Section 2, in particular we
have
a legitimate interest in using the Personal Data to improve and develop our App or Services and
improve
the safety, security, integrity and performance of the App and Service. When we process the Personal
Data
for our legitimate interests, we make sure to consider and balance any potential impact on you, and
your
interests, rights and freedoms under any applicable laws. We will not use your Personal Data for any
processing where our interests are overridden by the impact on you, unless we have your consent for
our
processing, or are otherwise required by law. You have the right to object to processing that is based
on
our legitimate interests, as indicated in Section 6 below;
The table below summarizes the Personal Data processed for the respective purposes as well as the
applicable legal basis.
| Processing purposes |
Collected data involved |
Legal justification |
Account creation and
management
|
Discord username
Nickname
Email address
Wallet address
Serial code
|
Necessary for the performance of a contract
|
| Service provision |
|
|
| ・Operating the Service including recordation of game play |
・In-game activities and achievements
・Device information including device name
・OS version
・Contents
・Wallet address
・Serial code
・IP address
|
Necessary for the performance of a contract
|
| Conducting events |
・In-game activities and achievements
・Nickname
・Name
・Address(country, state, city)
・Wallet address
・Wallet service name
・Remittance service information
|
Necessary for the performance of a contract
|
|
Identifying and fixing bugs, verifying service reliability
|
・Wallet address
・Serial code
・OS version
・OS name
・Clash report information
・Device information including device name
・IP address
|
Necessary for the performance of contract
|
|
・Managing of access log
|
・IP address |
・Necessary for the performance of contract
|
| Communications |
・Name
・Wallet address
・Serial code
・Email address
・SNS ID
・In-game activities and achievements
・Any other information provided by you in the communication
・Message ID
|
Necessary for the performance of contract |
| Improvement and development of App and Service |
・Wallet address
・Serial code
・IP address
・OS name
・Device information including device name
・In-game activities and achievements
・Type and amount of items
|
Legitimate Interest
|
| Compliance with law |
・IP address
・In-game activities and achievements
|
Compliance with a legal obligation under laws in your jurisdiction
Legitimate Interest, in the case where we need to comply with laws other than your
jurisdiction (e.g. Japan)
|
| To protect the security or integrity of the App, including fraud prevention and
investigation |
・IP address
・Device information including device name
・In-game activities and achievements
・Contents
|
Legitimate Interest |
| Marketing activities |
・Email address
・SNS ID
・IP address
・Tester Profile
|
Legitimate Interest |
| Recruitment of ambassador |
・Your name
・Email address
・Address
・Languages Spoken
・SNS ID
・Reason for application
|
Consent |
| Recruitment of beta tester |
・Email address
・IP address
・Tester Profile
|
Consent |
The provision of your Personal Data is necessary to enter into a contract with us or to receive our
services as requested by you.
Not providing your Personal Data may result in disadvantages for you--for example, you may not be able
to receive certain services. However, unless otherwise specified, not providing your Personal Data
will not result in legal consequences for you.
4. Categories of Recipients and International Transfers - Who do we transfer your Personal Data to and
where are they located?
We will not share any of your Personal Data that we have collected except as described below:
Service providers: We may use service providers to process Personal Data for the purposes described in
Section 2, including lawyers, accountants, auditors, etc., in accordance with applicable laws.
Government authorities: We may transfer Personal Data to law enforcement agencies, governmental
authorities, judicial authorities and courts in order to comply with any applicable laws, respond to
any legal claims against us, protect or defend ourselves or other third parties against any illegal,
criminal or harmful activities.
Business transactions: In the event of a corporate merger or acquisition, Personal Data may be
transferred to the third parties involved in the merger or acquisition.
International transfers. You should expect that the recipients identified above which will receive or
have access to your Personal Data, are located inside or outside your country.
・For recipients located outside your country, some are located in a country that the data privacy
authority in your country has deemed to provide an adequate level of protection for Personal Data
under the applicable data protection law.
・Other recipients might be located in countries that do not adduce an adequate level of protection from
the applicable data protection law perspective. We will take all necessary measures to ensure that
transfers out of your country are adequately protected as required by applicable data protection law
and to ensure that appropriate technical and organizational security measures are in place to protect
Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized
disclosure or access, and against all other unlawful forms of processing.
・With respect to transfers to countries not providing an adequate level of data protection, we will
base the transfer on appropriate safeguards, such as appropriate data transfer agreement including
standard data protection clauses adopted by the European Commission or by a supervisory authority,
approved codes of conduct together with binding and enforceable commitments of the recipient, or
approved certification mechanisms together with binding and enforceable commitments of the recipient.
You can ask for a copy of such appropriate safeguards by contacting us as set out in Section 9 below.
・The data transfer to processors which are not in a country providing an adequate level of data
protection will typically also be protected by such appropriate data transfer agreement.
・Any onward transfer is subject to appropriate onward transfer requirements as required by applicable
law. Nonetheless, this may impact your data subjects rights in your local jurisdiction and also in the
applicable overseas jurisdiction(s). These overseas jurisdictions may also need to disclose your
Personal Data to a third party, e.g., an overseas authority. If you have any questions or concerns
about our data transfer arrangements, please contact us as stated under Section 9 below.
5.Retention Periods - How long do we keep your Personal Data?
Your Personal Data will be retained as long as necessary to provide you with the services requested.
If you have consented to the processing of your Personal Data, we will store such Personal Data to
enable us to process your personal data for any of the purposes set out in this Policy at least until
you revoke your consent. If we need your Personal Data to carry out a contract between you and us, we
will store such data for as long as the contractual relationship or statutory retention periods allow
us. If we use your Personal Data based on our legitimate interests, we will store such data for as
long as our purposes continue and so long as your fundamental rights do not override our legitimate
interests. Please note that we may be required to retain certain information by law. In principle, we
will retain the Personal Data only as long as required or permitted by applicable law, in particular
as long as the Personal Data may be needed to fulfill or defend against claims that are not yet
time-barred.
6. Your Rights - What rights do you have and how can you assert your rights?
Right to withdraw your consent: If you have declared your consent regarding certain collecting,
processing and use of your Personal Data, 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. You can withdraw your consent as follows by contacting us as stated under Section 9 below.
Additional data privacy rights: Pursuant to applicable data protection law, you may have the right to:
(i) request access to your Personal Data (ii) request rectification of your Personal Data; (iii)
request erasure of your Personal Data; (iv) request restriction of processing of your Personal Data;
(v) request data portability; and/or (vi) object to the processing of your Personal Data (including
objection to profiling). Below please find further information on your rights. Please note that these
rights might be limited under the applicable local data protection law.
・Right to request access to your Personal Data: As provided by applicable data protection law, 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. This access
information includes – inter alia – the purposes of the processing, the categories of Personal Data
concerned, and the recipients or categories of recipient 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 may have the right to obtain a copy of the Personal Data undergoing processing free of charge. For
further copies requested by you, we may charge a reasonable fee based on administrative costs.
・Right to request rectification: As provided by applicable data protection law, you have the right to
obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes
of the processing, you may have the right to have incomplete Personal Data completed, including by
means of providing a supplementary statement.
・Right to request erasure (right to be forgotten): As provided by applicable data protection law, you
have the right to obtain from us the erasure of Personal Data concerning you and we may be obliged to
erase such Personal Data.
・Right to request restriction of processing: As provided by applicable data protection law, you have
the right to obtain from us that we restrict the processing of your Personal Data. In such case, the
respective data will be marked and may only be processed by us for certain purposes.
・Right to request data portability: As provided by applicable data protection law, 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 may have the right to transmit those data to another entity
without hindrance from us.
・Right to object:
Under certain circumstances, 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 and we are required to no
longer process your Personal Data. Such right to object especially applies if we collect and
process your Personal Data for profiling purposes in order to better understand your interests in
our products and services or for certain types of direct marketing.
If you have a right to object and if you exercise this right, your Personal Data will no longer be
processed for such purposes by us. You may exercise this right by contacting us as stated in
Section 8 below.
Such a right to object may, in particular, not exist 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.
Please note that the aforementioned rights might be limited under the applicable national data
protection law. To exercise your rights, please contact us as stated under Section 9 below. You may
also have the right to lodge a complaint with the competent data protection supervisory authority in
the relevant country.
7. Accuracy of Personal Data
We rely on Personal Data provided by you. In order to ensure that the Personal Data provided to us is
current, complete and accurate, please update us if there are any changes to the Personal Data provided
to us.
8.Questions and Contact Information
If you have any questions about this Policy or if you want to exercise your rights as stated above in
Section 6, please contact us at: privacy@brilliantcrypto.net
9.Changes to this Policy
We may update this Policy from time to time in response to changing legal, regulatory or operational
requirements. We will notify you of any such changes, including when they will take effect, by updating
the "Last revised" date above or as otherwise required by applicable law. Your continued use of our App
after any such updates take effect will constitute acceptance of those changes. If you do not accept
updates to this Policy, you should stop using our App and Services.
