PRIVACY POLICY for ibis Paint in the EEA / the UK
Last updated: July 23, 2024
We, IBIS INC., respect your privacy. As we operate our website and provide you with our services, we process personal data about you in accordance with applicable data protection laws, including the Act on the Protection of Personal Information of Japan, the General Data Protection Regulation of the European Union (the “GDPR”) and UK GDPR.
This is our privacy policy for residents in the European Economic Area (the “EEA”) and the UK on how we process and protect your personal data who use our “ibis Paint”. We may revise this privacy policy from time to time. You can obtain the latest version of this policy on our site.
Please refer to the “PRIVACY POLICY for ibis Paint in the United States of America” for residents in the United States of America.
Please refer to the “Policy on the Protection of Personal Information” for residents in other areas.
1. RESPONSIBLE CONTROLLER
We, IBIS INC., a company registered in Nagoya, Japan, issue this privacy policy. When we determine the purposes and means of processing your personal data, we are the data controller and responsible for protecting your rights regarding personal data.
2. HOW WE PROCESS YOUR PERSONAL DATA
As we provide you with our services, we collect, use, store, generate or disclose to third-parties (hereinafter collectively referred to as “process”) your personal data for the following purposes:
- To manage your application purchase information on the application store, such as Google Play, App Store, and Microsoft Store:
- Categories of your personal data we process: Purchase ID, Purchased product, Device information on purchase, Date and time of purchase; Continuation, and Cancellation.
- Lawful basis: The processing is necessary for the performance of a contract.
- Period for which we store your personal data: Until the end of the service to maintain purchase information.
- Recipients we disclose your personal data to: Our contractors that assist us in providing ibis Paint.
- To manage your application accounts (ibisAccount, Twitter account, Facebook account, Apple ID, YouTube account, CLIP STUDIO account):
- Categories of your personal data we process: ibisAccount name, ibisAccount access token, Twitter account name, Twitter access token, Facebook account name, Facebook access token, YouTube account name, YouTube access token, YouTube refresh token, CLIP STUDIO account name, CLIP STUDIO access token, Apple account name, Apple access token, Apple refresh token, Apple identity token, and IP address.
- Lawful basis: The processing is necessary for the performance of a contract.
- Period for which we store your personal data: As long as user maintain their account of this service.
- Recipients we disclose your personal data to: Our contractors that assist us in providing ibis Paint.
- To manage our personalized advertising:
- Categories of your personal data we process: Your operational history on our service collected by the application, including Device token, FCM token, App UUID, Platform type, App type, IP address, User-agent, Device language settings, Terminal carrier information, Screen size, Orientation, Resolution, Sound volume, Battery, Memory use, Country, Time zone, Local settings, Network connection type and speed; and Advertisement ID.
- Lawful basis: Your consent. You can withdraw your consent at any time. Your withdrawal of consent does not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
- Period for which we store your personal data: As long as user maintain their account of this service or until you withdraw your consent of our services.
- Recipients we disclose your personal data to: Our contractors that assist us in advertising.
- To analyze your use of our service in order to generate insight that is useful for improving our services, products and marketing:
- Categories of your personal data we process: App UUID, Platform type, App type, Model name, OS version, Region of use, Screen size, User Ad ID, ID created by the UET SDK, and ID that allows Microsoft to identify which ad this application was downloaded from.
- Lawful basis: Your consent. You can withdraw your consent at any time. Your withdrawal of consent does not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
- Period for which we store your personal data: Until loss of relation to personal information via deletion of app or until you withdraw your consent.
- Recipients we disclose your personal data to: Our contractors that assist us in analyzing servicce usage data.
- To investigate App bugs:
- Categories of your personal data we process: App UUID, Platform type, App type, Model name, OS version, Region of use, and Stack trace.
- Lawful basis: The processing is necessary for the performance of a contract and for the purpose of our legitimate interest, i.e. to improve and expand this service for our customers.
- Period for which we store your personal data: Until loss of relation to personal information via deletion of app.
- Recipients we disclose your personal data to: Our contractors that assist us in analyzing service usage data.
- To protect your privacy and security, integrity and availability of our website:
- Categories of your personal data we process: IP address, User-agent, Access time, and Access URL.
- Lawful basis: The processing is necessary for the performance of a contract and for the purpose of our legitimate interest, i.e. protecting your privacy and our website from fraudulent or unlawful access by monitoring web access traffic.
- Period for which we store your personal data: Seven (7) days.
- Recipients we disclose your personal data to: Our contractors that assist us in providing ibis Paint.
- To manage user communication on official postings sites (Online Gallery):
- Categories of your personal data we process: ibisAccount name, Twitter account name, Facebook account name, Apple account name, and Your responses to posts such as comments or Likes.
- Lawful basis: The processing is necessary for the performance of a contract.
- Period for which we store your personal data: The shortest duration of the commented work, or the deletion of the comment, or the deletion of your account.
- Recipients we disclose your personal data to: Our contractors that assist us in managing user communication.
- To manage inappropriate artwork reports:
- Categories of your personal data we process: ibisAccount name, Twitter account name, Facebook account name, Apple account name, Device’s model name, Artwork data, Inappropriate artwork report history, and IP address.
- Lawful basis: The processing is necessary for the performance of a contract.
- Period for which we store your personal data: Until the end of this service.
- Recipients we disclose your personal data to: Our contractors that assist us in managing user communication.
- To manage user upload:
- Categories of your personal data we process: ibisAccount name, Twitter account name, Facebook account name, Apple account name, Device’s model name, and Artwork data.
- Lawful basis: The processing is necessary for the performance of a contract.
- Period for which we store your personal data: Until the deletion of artwork with the user’s YouTube or Online Gallery account.
- Recipients we disclose your personal data to: Our contractors that assist us in managing user communication.
- To manage contest:
- Categories of your personal data we process: Twitter account name, E-mail address, and Artwork data.
- Lawful basis: The processing is necessary for the performance of a contract.
- Period for which we store your personal data: Two (2) weeks after prize payment.
- Recipients we disclose your personal data to: Our contractors that assist us in managing contest.
- To respond to your Enquiries (bug reports, requests, complaints, etc.):
- Categories of your personal data we process: Name, E-mail address, User-agent, and Inquiry content.
- Lawful basis: The processing is necessary for the performance of a contract.
- Period for which we store your personal data: Until deletion upon request.
- Recipients we disclose your personal data to: Our contractors that assist us in storing the user content.
* This service uses the YouTube API service provided by Google to upload videos of User's creations to YouTube and to play those uploaded YouTube videos.
The YouTube API uses cookies or similar technologies to store, access, and collect information directly or indirectly on the device or browser from which the user uses this service.
You may revoke your access from our service by using the Google Security Settings page.
Please see below for the YouTube Terms of Use, Google Privacy Policy, and the Google Security Settings page.
* The Windows version of this product contains the Microsoft Edge WebView2 runtime (including Microsoft Defender SmartScreen). Microsoft Edge WebView2 and Microsoft Defender SmartScreen may collect information about your use of the software and send it to Microsoft.
For more information about the personal information collected by Microsoft, please visit
https://aka.ms/privacy
https://docs.microsoft.com/en-us/microsoft-edge/privacy-whitepaper#smartscreen
For the avoidance of doubt, we do not process any of the information collected by Microsoft.
3. SENSITIVE PERSONAL DATA
We usually do not collect and/or use sensitive categories of your personal data as defined in Articles 9 or 10 of GDPR / UK GDPR on our service.
4. COOKIES
A cookie is a small text file that our website sends to your terminal device for the purpose of keeping certain records.
By using cookies:
- Your terminal devices (e.g. browsers) remember your preferences (e.g. language used) and activities (e.g. login status, etc.) on our website so that we can deliver a personalized and better user experience on our website (essential cookies);
- We keep track of your interactions with our website, giving us useful and important insight for improving our website (performance cookies).
A cookie identifies your terminal device, typically your web browser, but it cannot identify your individual identity.
5. TRANSFER TO NON-EU COUNTRIES
We may engage third-party contractors, which assist us in processing your personal data for the purposes described above. These contractors are established and located in Japan and United States.
When the Recipients are located in Japan, your personal data is protected in accordance with the Act on the Protection of Personal Information of Japan. The European Commission and the UK have decided that Japan ensure an adequate level of data protection (the “Adequacy Decisions”) and that personal data can be lawfully transferred to Japan without requiring any specific authorization.
In the event that we transfer your data to an entity located outside the EEA, the UK or Japan, we protect your rights with personal data by virtue of a data transfer contract with the relevant recipient in accordance with the GDPR / UK GDPR, which imposes on such recipients contractual obligations to ensure an adequate level of data protection equivalent to those laid down by the GDPR/ UK GDPR.
6. YOUR LEGAL RIGHTS
Provided that certain conditions are met, you have legal rights to request from us the following:
- Revocation of a previously given consent to our processing of your personal data
- Access to your personal data and to certain supplementary information covered by this policy;
- Rectification of your personal data if inaccurate or incomplete;
- Erasure of your personal data in certain circumstances;
- Suspension of using your personal data in certain circumstances;
- Stopping processing your personal data in certain circumstances; and
- Obtaining your personal data in a structured, commonly used, and machine-readable format.
If you wish to exercise your rights, please contact us.
7. COMPLAINT
If you are from EEA and UK, You can lodge complaints about our way of processing your personal data with the data protection supervisory authorities of your country of residence.
8. EU REPRESENTATIVE/UK REPRESENTATIVE
As we are based outside of the EU/UK, Article 27 GDPR/UK GDPR required that we appoint an EU representative/UK representative to handle certain data subject requests and queries. In compliance with this, we have appointed DataRep to act as our representative. Any queries requiring the input of our representative should please be directed to them as follows:
- sending an e-mail to DataRep at datarequest@datarep.com quoting <ibis inc.> in the subject line,
- contacting DataRep on the online webform at www.datarep.com/data-request, or
- mailing your inquiry to one of the following addresses;
DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
DataRep, BPM 335368, 372 Old Street, EC1V 9AU, London, United Kingdom
Please note that if you choose to mail your enquiry, it is essential that you mark your letters for ‘DataRep’ and not ‘ibis inc.’, or your enquiry may not reach them. Please refer clearly to ibis inc. in your correspondence.
9. INQUIRY
ibis inc. PMS Office
Nakamo Building, 4th Floor
3-17-34 Meieki, Nakamura Ward, Nagoya City, Aichi
450-0002, Japan
E-mail: