App Palette LLC ("App Palette", "we" or "us") will process the personal data of users to whom the following regulations apply (the “User", "you" or "your") in accordance with the applicable European Union and European Union Member States’ regulations on data protection, in particular, the General Data Protection Regulation 2016/679 (the "GDPR"), and with the applicable regulations of California pertaining to data protection, including the California Privacy Rights Act of 2020 (“CPRA”). This Privacy Policy (collectively, the “Policy”) explains how App Palette, as the data controller, processes the User’s personal data when the User uses our online services, including the to-do list, the daily planner, and the memo application (collectively, the “Services”).
We do not currently offer or target our Services to users located in the EEA, the United Kingdom, or Switzerland.
Data collected when the User uses the Services:
②Usage Data
We collect data about your activity.
This includes access logs, usage patterns, browser types, and other system activities.
③Transaction data
We collect payment transaction data related to the use of the Services (such as the type of service purchased, payment date, amount charged, and payment method).
④Device data
We will collect data about the devices used by the User to access the Services, including the hardware models, device IP addresses or other unique device identifiers, operating systems and versions, software, preferred languages and time zones, online identifiers such as advertising identifiers, cookies, push notification device tokens, device motion data, mobile network data, and the name of the carrier.
(ii) Purposes and Bases of Use of the User’s Personal Data
Performance of a Contract / Entry into a Contract（Article 6- 1 - (b) GDPR）
We will process the following categories of your personal data for the following purposes to the extent necessary to perform contractual obligations in providing the Services to you.
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Categories
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Purposes of use
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| Personal data described in the above items ① | To communicate with you: |
| 見出し | ここをクリックして表示したいテキストを入力してください。テキストは「右寄せ」「中央寄せ」「左寄せ」といった整列方向、「太字」「斜体」「下線」「取り消し線」、「文字サイズ」「文字色」「文字の背景色」など細かく編集することができます。 |
Legitimate Interests（Article 6 -1 - (f) GDPR）
We will process the following categories of your personal data for the following purposes to the extent necessary to pursue our legitimate interests.
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Categories
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Purposes of use
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| Personal data described in the above items ②,③, and ④ | To provide paid features of the Services |
| Personal data described in the above items ①,②,③, and ④ | To measure and analyze the performance of the Services: |
| Personal data described in the above items ①,②,③, and ④ | To maintain and improve the Services: |
| Personal data described in the above items ①,②,③, and ④ | To develop new products or Services: |
| Personal data described in the above items ① ,②,③ and ④ | To protect us, the User, and the public: |
| Personal data described in the above items ②,③ and ④ | To display personalized advertisements: We may process personal data to deliver advertisements tailored to the Users’ interests. |
| 見出し | ここをクリックして表示したいテキストを入力してください。テキストは「右寄せ」「中央寄せ」「左寄せ」といった整列方向、「太字」「斜体」「下線」「取り消し線」、「文字サイズ」「文字色」「文字の背景色」など細かく編集することができます。 |
2. App Palette will not obtain or process any of the User’s personal data which is sensitive in nature, including religious beliefs and health status.
3. App Palette will not make decision based solely on automated processing, including profiling that may affect the User.
4. App Palette will notify the User separately if the disclosure of the User’s personal data to the other party is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as the possible consequences of failure to provide such data.
App Palette will retain the User’s personal data for as long as necessary to fulfill the aforementioned purposes (prescribed in Section 1 of this Policy) for obtaining and processing the User’s personal data. Specific retention periods are decided based on the following considerations: (i) the purpose for obtaining and processing the personal data; (ii) the nature of the personal data; and (iii) the necessity of retaining the personal data for legal or business reasons.
App Palette will disclose your personal data to the following parties and other third parties to whom you have consented to the provision of your personal data, in accordance with the GDPR for the purposes prescribed in this Policy.
i. Google LLCApp Palette may amend this Policy from time to time and will contact the User through this website, when we make any substantive or material amendments.
For any questions, complaints, or other inquiries regarding the handling of your personal data, please contact the data controller or representative set out below:
Data Controller
The reception time shall be from 10:00 a.m. to 5:00 p.m. Japan time on weekdays.
[Address; post code]
App Palette Inc.
2F Nishishinjuku Mizuma Building,
3-3-13 Nishishinjuku ,
Shinjuku , Tokyo
160-0023 , Japan
[Email Address / Communication form]
Email Address : support@apppalette.co.jp
Communication form: https://forms.gle/bLbs7c4rkzW3T1cf9
California law requires that we make certain disclosures about your data. The following disclosures are made pursuant to CPRA.
1. Your Rights
In addition to the rights listed in Section 4, the User has the following rights.
i. The right to correct inaccurate personal information
ii. The right to opt-out of the sale or sharing of their personal information
ii. The right not to receive discriminatory treatment
2. Exercising Your Rights
If you wish to exercise the rights in item(ⅱ) above , please contact details provided in Article 6 or through the settings menu within the Service. If you wish to exercise any other rights, please contact us using the contact details provided in Article 6.
Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
3. Collection and Use of Personal Data
Over the past 12 months, we have collected the following categories of Personal Data:
i. Identifiers
Username or nickname, email address, name provided when making inquiries, online identifiers (such as IDFA or push token), IP address, and similar information
ii. Commercial information
Records of purchases made through the Services
iii. Internet or other electronic network activity information
Logs of app launches and operations, information on usage patterns, crash logs, details regarding the user's device, operating system, browser, language settings, and time zone
iv. Geolocation data
Approximate location at the country or region level, inferred from the user's IP address
To learn more about the specific information we collect, the sources and purposes of such collection, please see Section1 (“Legal Bases for processing/categories of personal data subject to Processing”).
4. Sale or Sharing of Personal Data
Over the past 12 months, we have sold or shared the following categories of Personal Data:
i. Identifiers
Online identifiers (such as IDFA), IP address
ii. Internet or other electronic network activity information
Logs of app launches and operations, information on usage patterns, crash logs, details regarding the user's device, operating system, browser, language settings, and time zone
iii. Geolocation data
Approximate location at the country or region level, inferred from the user's IP address
5. Disclosure of Personal Data for a Business Purpose
Over the past 12 months, we have disclosed for a business purpose the following categories of Personal Data:
i. Identifiers
Username or nickname, email address, name provided when making inquiries, online identifiers (such as IDFA or push token), IP address, and similar information
ii. Commercial information
Records of purchases made through the Services
iii. Internet or other electronic network activity information
Logs of app launches and operations, information on usage patterns, crash logs, details regarding the user's device, operating system, browser, language settings, and time zone
iv. Geolocation data
Approximate location at the country or region level, inferred from the user's IP address
To learn more about the disclosure of your Personal Data, please see Section 3 (“Disclosure of Personal Data”).
6. The categories of other entities which we disclose Personal Data
We disclose your personal data to service providers that offer cloud backend services, performance analytics services, advertising services, and payment processing services.
we disclose your Personal Information to third parties in order to provide the following functions of our Services: