Astellas – Privacy Policy – Moomin Move

March 30, 2021

Astellas Pharma Inc., 2-5-1, Nihonbashi-Honcho, Chuo-Ku, Tokyo 103-8411, Japan (“Astellas Japan”) and Astellas US LLC., 1 Astellas Way, Northbrook, IL  60062, United States of America (“Astellas USA”) (collectively “Astellas Pharma, “we”, “us” or “our”) are committed to protecting your privacy.

In connection with the real-world augmented reality Moomin Move Game App and the Services available through it (“Services”, “App”, “Moomin Move”) operated by Tribered Oy, Lapinlahdenkatu 16, 00180 Helsinki, Finland (“Tribered”), we are conducting a research project on how mobile walking games may influence player's wellness by behavior change and how mobile walking games may change player’s behavior, including using the research results for the development of new products and services.

To do that, we need information about how you use the App and your wellness. In this privacy policy (Privacy Policy), references to “you” means any person accessing, downloading or otherwise using the Services.

This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you play Moomin Move. For more information on how Tribered processes your Personal Data when you play Moomin Move, please visit Tribered’s Privacy Policy at https://www.moominmove.com/privacy/.

  1. Who decides how your information is used and how to contact us

Astellas Japan and Astellas USA are the independent data controllers responsible for making decisions about how your personal information is used in connection with the research project as further described in this Privacy Policy.

If you have any questions about our data processing practices or this Privacy Policy, you may contact Astellas Japan at Japan.privacy@jp.astellas.com and Astellas USA at US.Privacy@astellas.com.

You can reach the Astellas Pharma Data Protection Officer at privacy@astellas.com.

  1. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information, which cannot be used to identify you ("Anonymous Data"). The Personal Data we process may include sensitive Personal Data concerning your health (“Health Data”). The Personal Data we process is pseudonymised. This means the Personal Data cannot be attributed to you without the use of additional information kept separately by Tribered and is subject to technical and organizational measures to ensure that the Personal Data are not attributed to you.

When playing Moomin Move, the App provides you with choices, which information you agree to share, including whether you want to use the wellness function and participate in our research project for which we collect the following pseudonymised information about you with your consent.

With your separate consent Tribered may collect and share pseudonymised location information, demographic information, and information about in-game actions with us for research purposes. Astellas Japan and Astellas USA may process such data independently for its research on how mobile walking games may influence player's wellness by behavior change and how mobile walking games may change player’s behavior, including using the research results for the development of new products and services.

 

With your separate explicit consent Tribered may collect Health Data, including gender, height, weight, information related to your levels of fitness and nutrition, including your physical activity level and type, food and nutrient intake and share this data in a pseudonymised form with us for research purposes. Astellas Japan and Astellas USA may process such data independently for its research on how mobile walking games may influence player's wellness by behavior change and how mobile walking games may change player’s behavior, including using the research results for the development of new products and services. Astellas Japan and Astellas USA may connect these pseudonymised data for the above purpose with your pseudonymised location information, demographic information, and information about in-game actions if you have provided your separate consent to the processing of these data categories.

When you start the game or make use of the wellness task menu and prior to processing the above data, you will be prompted with a screen where you can manage your consent options for the above purposes.

Without your consent, you will not be able to use the wellness function of the App and participate in our research project. The denial of your consent does not affect any other parts of the Services.

You may withdraw your consent with effect for the future at any time by contacting Tribered at contact@tribe.red. Processes are in place to ensure that your withdrawal of consent by contacting Tribered is effectuated with regard to your pseudonymised Personal Data in our systems. Alternatively, you may contact us under the information provided above under ‎1.

  1. Who we share information with

We will not share any Personal Data that we have collected from or regarding you with other parties.

  1. Is your data transferred internationally

The transfer of your pseudonymised Personal Data collected by Tribered to Astellas Japan takes place on the basis of the EU Commission’s adequacy decision for Japan (available here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) according to which Japanese data protection law provides for an adequate level of protection for your information. In cases, in which your pseudonymised information is transferred from Astellas Japan to Astellas USA, we comply with Japanese data protection laws applicable to such onward transfer.

  1. How long we will keep your information

We keep your pseudonymised Personal Data for as long as we need to fulfill the purposes set out in this Privacy Policy and you have not withdrawn your consent.

When we no longer need to use your Personal Data, or in case you have withdrawn your consent and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove your Personal Data from our systems or anonymize it, so that your Personal Data can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.

  1. Your rights and choices

You may be entitled

  • to obtain access to information on the processing of your Personal Data,
  • to object to certain processing of your Personal Data,
  • to request data portability, and
  • to have your Personal Data rectified, deleted, or otherwise restricted in terms of processing,

in each case as permitted under applicable law and subject to certain exemptions under applicable law.

You may also be entitled to withdraw any consent given with effect for the future with respect to the processing of your Personal Data.

You can exercise these rights by sending a request via email to Tribered’s customer service team at contact@tribe.red. Alternatively, you may contact us under the information provided above under ‎1. Any request is subject to identity verification, which includes that your email will be verified through the Moomin Move app. Processes are in place to ensure that your request is also followed by us.

If you are not satisfied with the response or believe that your Personal Data is not being processed in accordance with the law, you also may contact or lodge a complaint with the competent supervisory authority or seek other remedies under applicable law. However, we highly encourage you to work with Tribered or us in good faith and contact us first.

  1. Special note about children’s privacy

Astellas Pharma does not knowingly collect or solicit Personal Data from anyone under the age of 13, and Tribered does not knowingly allow such persons to use the Service. If you are under 13, please do not use the Service. No one under the age of 13 may provide any Personal Data. In the event that we learn that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you believe that, we might have any information from or about a child under the age of 13, please contact Tribered at contact@tribe.red. Processes are in place to ensure that your request is also followed by us. Alternatively, you may contact us under the information provided above under ‎1.

  1. Changes to this Privacy Policy

Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.