In compliance with applicable data protection laws and regulations (including, without limitation, the General Data Protection Regulation (EU) 2016/679 (GDPR), the UK General Data Protection Regulation (“UK GDPR”), and the Swiss Federal Act on Data Protection (“FADP”)), Skyfall Inc. (the “Company,” “we,” “us,” or “our”) hereby establishes this Global Privacy Policy (this “Policy”). This Policy governs the processing of personal information of representatives, contact persons, and personnel of our business partners (“you” or “your”) residing outside Japan in connection with the advertising and related digital services provided by the Company (collectively, the “Services”).
The Company provides digital advertising distribution, attribution, performance measurement, fraud detection, and ancillary services to advertisers, media partners, and other commercial clients. In operating the Services, the Company acts as a data controller with respect to managing its business relationships, and as a data processor on behalf of its clients. Where the Company processes personal information as a data processor on behalf of a client, such processing is strictly governed by the applicable data processing agreement (DPA) executed with that client, and this Policy does not apply to such processing.
If you reside in Japan, please refer to our Japanese Privacy Policy（個人情報保護方針）. If you reside in the State of California, the United States, the provisions set forth in “Appendix I: Processing of Personal Information of California Residents” shall apply to you in addition to this Policy.
1. Categories of Personal Information We Collect
The Company collects and processes the following categories of personal information in connection with the Services:
(1) Business Contact Information: Your name, company name, department, job title/role, email address, telephone number, business address, and related contact details.
(2) Inquiry and Communication Records: Information provided when you contact us, request support, or communicate with us regarding the Services.
(3) Technical and Device Identifiers: Information collected automatically when you or your representatives access our website or digital interfaces, including device type, operating system (OS) version, device identifiers, IP address, browser type and settings, referrer URL, Cookie IDs, advertising identifiers (e.g., IDFA, GAID), and interaction history collected through cookies and similar tracking technologies.
Provision of your personal information is voluntary; however, if you choose not to provide it, we may be unable to deliver the Services to you or your organization.
2. Purposes of Use and Legal Bases for Processing
We process your personal information based on our legitimate business interests (including managing client relationships and maintaining platform security), your consent where required, or compliance with legal obligations. Where we rely on legitimate interests, we balance our business necessity against your individual privacy rights. We do not engage in automated decision-making that produces legal or similarly significant effects concerning you. We process personal information for the following purposes:
To authenticate your identity and conduct credit checks and business partner vetting;
To deliver, operate, and maintain the Services for you and your organization;
To communicate regarding the Services, including sending contractual notices, order confirmations, and technical updates;
To issue invoices, process transactions, and manage accounting records;
To invite you to industry events, exhibitions, and webinars;
To solicit feedback, conduct market research, and analyze service performance;
To provide promotional communications, marketing materials, and surveys relating to the Services and our group entities;
To respond to inquiries, support requests, and complaints;
To investigate, prevent, and address violations of our terms of use, guidelines, or applicable laws;
To notify you of updates to our policies, terms, and service specifications; and
To comply with applicable statutory and regulatory obligations.
Disclosure of Personal Information
We may disclose your personal information to third parties under the following circumstances:
Affiliates and Group Companies:
We may share your business contact information with our corporate affiliates and group companies, specifically Skyfall Inc. (Japan), Skyfall US Inc., and Skyfall Korea Inc., to the extent necessary to achieve the processing purposes outlined in Section 2. Skyfall Inc. remains responsible for the management and protection of such shared personal information;
Service Providers:
We engage trusted third-party service providers, including cloud hosting providers, IT infrastructure partners, security vendors, and data analytics providers, to process personal information on our behalf strictly under contractual confidentiality and data protection obligations to the extent necessary in order to achieve the purposes of use described in Section 2; and
Legal and Regulatory Disclosures:
We may disclose personal information to governmental authorities, regulatory bodies, or law enforcement agencies to comply with binding legal obligations, court orders, or administrative mandates.
Sources of Personal Information
We primarily collect your personal information directly from you, your employer/organization, business partners, referrers or publicly available sources.
International Data Transfer
In providing the Services, the Company may transfer your personal information to recipient entities located outside your country of residence (for those residing in the EU, the United Kingdom, or Switzerland to outside of such jurisdiction), specifically to Japan and United States, for the purpose described in Section 2.
When transferring personal information to other countries without an adequacy decision, the Company implements appropriate cross-border safeguards, such as executing Standard Contractual Clauses (SCCs) issued by the European Commission or equivalent UK/Swiss transfer mechanism. To request further details or copies of the relevant safeguards, please contact us by using the contact details provided in Section 11 (Inquiries and Contact Details) below.
Retention Period and Data Security Measures
We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the nature and sensitivity of the data, the potential risk of harm from unauthorized use, the ongoing nature of our business relationship, and applicable statutory limitation period.
To protect your personal information, the Company has implemented internal rules, an organizational structure, and appropriate supervision of employees, and has taken technical, physical, and organizational security measures designed to prevent unauthorized access, accidental loss, destruction, alteration, or unlawful disclosure.
Your Data Protection Rights
Subject to applicable local laws (including the GDPR, UK GDPR, and FADP), you may exercise the following rights regarding your personal information:
Right to seek access to and receive copies of your personal information held by us;
Right to request correction of inaccurate or incomplete personal information;
Right to request deletion of your personal information under certain statutory conditions (“Right to be Forgotten”);
Right to request that we restrict or suspend the processing of your personal information; and
Right to receive your personal information in a structured, commonly used, and machine-readable form (“Right to Data Portability”).
These rights are not absolute and may be limited under applicable laws and regulations, for example, where fulfilling your request would adversely affect the rights of the Company or a third party, or where we are legally required to retain certain information.
To exercise any of these rights, please contact us by mail or email using the contact details provided in Section 11 (Inquiries and Contact Details) below.
Right to Object to Processing
Where our processing of your personal information is based on our legitimate interests, you have the right to object to such processing at any time on grounds relating to your particular situation. Upon receiving your objection, we will cease processing your personal information unless we can demonstrate compelling legitimate grounds for the processing that override your interests and rights, or where the processing is required for the establishment, exercise, or defense of legal claims.
Right to Withdraw Consent
You have the right to withdraw your consent whenever the Company handles your personal information based on your explicit consent under applicable laws and regulations. Withdrawal of consent does not affect the lawfulness of any processing conducted prior to such withdrawal.
Right to File a Complaint
You have the right to lodge a complaint with a competent supervisory authority under applicable laws and regulations in the jurisdiction where you reside or work.
Inquiries and Contact Details
If you have any questions, comments, or requests regarding this Policy or our data handling practices, please contact us at:
Skyfall Inc. Privacy Policy Contact Desk
Midtown Tower 19F, 9-7-1 Akasaka, Minato-ku, Tokyo 107-6219, Japan
E-mail：sf_privacy@skyfall.co.jp
Last updated: October 1, 2026
Appendix I: Processing of Personal Information of California Residents
In addition to the Global Privacy Policy, this “Appendix I: Processing of Personal Information of California Residents” (this “Appendix I”) applies to the processing of personal information of consumers residing in the State of California, the United States, in accordance with the California Consumer Privacy Act of 2018 (the “CCPA”). In the event of any conflict or inconsistency between the provisions of this Appendix I and the main Global Privacy Policy, the provisions of this Appendix I shall control and prevail for California residents.
1. Definitions
Terms used in this Appendix I shall have the meanings ascribed to them under the CCPA. Specifically:
“Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating your personal information by a business to a third party (meaning anyone other than the Company, our service providers and contractors, hereinafter the same applies in this Appendix I) for monetary or other valuable consideration.
“Share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating your personal information by a business to a third party for cross-context behavioral advertising.
2. Notice of Personal Information Collected
During the preceding twelve (12) months, the Company has collected, and will collect, the following categories of personal information regarding California residents:
Identifiers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Commercial information
Internet or other electronic network activity information
For specific examples of personal information collected under each category, please refer to Section 1 (Categories of Personal Information We Collect) of the Global Privacy Policy.
The Company does not collect or process any sensitive personal information (as defined under the CCPA).
3. Purposes of Use, Sources, and Disclosures
Business Purposes for Collection: Please refer to Section 2 (Purposes of Use and Legal Bases for Processing) of the Global Privacy Policy.
Sources of Personal Information: Please refer to Section 4 (Sources of Personal Information) of the Global Privacy Policy.
Retention Period: Please refer to Section 6 (Retention Period and Data Security Measures) of the Global Privacy Policy.
Disclosures for Business Purposes: In the preceding twelve (12) months, the Company has disclosed the categories of personal information listed above for business purposes to its affiliates and group companies (specifically Skyfall Inc., Skyfall US Inc., and Skyfall Korea Inc.) and to its authorized service providers and contractors, as described in Section 3 (Disclosure of Personal Information) of the Global Privacy Policy.
No Sale or Sharing: The Company has not “sold” or “shared” (for cross-context behavioral advertising) any personal information collected from California consumers in the preceding twelve (12) months and will not do so in the future.
4. Your Privacy Rights Under the CCPA
The CCPA provides residents of California with specific rights regarding personal information. If you are a California resident, you have the following rights regarding your personal information, subject to certain exceptions established by law:
(1) Right to Know and Access Personal Information:
You are entitled to request that we disclose certain information to you regarding our collection, use, sharing, and disclosure of your personal information. Upon receiving and confirming a verifiable consumer request from you, we will disclose:
The categories of personal information we have collected about you;
The categories of sources from which the personal information was collected;
Our business or commercial purpose for collecting, selling, or sharing that personal information;
The categories of third parties to whom we disclose that personal information;
The specific pieces of personal information we have collected about you; and
The categories of personal information disclosed for a business purpose and the categories of recipients for each category.
(2) Right to Request Deletion of Personal Information:
You are entitled to request that we delete any of your personal information that we collected and retained, subject to certain exceptions. Upon receiving and confirming a verifiable consumer request, we will delete (and direct our service providers and contractors to delete) your personal information from our records, unless retaining the information is necessary to:
Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall, provide a good or service requested by you, or take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Help ensure security and system integrity, or detect and prevent fraud;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the rights of another consumer to exercise their free speech rights, or exercise another right provided for by the laws and regulations;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. Seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with your expectations and the context in which you provided the personal information based on your relationship with us; or
Comply with legal obligations.
(3) Right to Request Correction of Inaccurate Personal Information:
Taking into account the nature of the personal information and the processing purposes, you are entitled to request that we correct any inaccurate personal information that we maintain about you. Upon receiving and confirming a verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information. We may deny your request for correction if we determine that the contested personal information is more likely than not to be accurate based on the totality of the circumstances.
(4) Right to Opt-Out of Sale or Sharing:
The Company has not sold or shared your personal information in the past twelve (12) months and will not sell or share it in the future. Since the Services are directed to persons who are not under the age of 16, the Company will not intentionally sell or share the personal information of anyone who is under the age of 16.
(5) Right to Limit the Use of Sensitive Personal Information:
The Company does not collect or process any sensitive personal information from California residents, for any purpose other than the following:
Performing the Services or providing the goods reasonably expected by an average consumer who requests such goods or services;
Helping ensure security and integrity;
Performing short-term, transient use (except for those involving profiling or changes to the future user experience);
Performing services on behalf of the Company; and
Maintaining or enhancing the quality or safety of the services (including the Services) and devices of the Company.
(6) Right to Non-Discrimination:
We will not discriminate against you for exercising any of your rights under the CCPA, including by denying goods and services, charging different prices, or providing a different level or quality of services.
5. How to Exercise Your CCPA Rights
To exercise your rights under the CCPA, please submit a verifiable consumer request to us by emailing us at the address set forth in Section 11 (Inquiries and Contact Details) of the Global Privacy Policy. You need to complete or communicate a request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.
Only you, or an agent registered with the California Secretary of State that you authorize to act on your behalf, may submit a verifiable consumer request regarding your personal information.
To protect your privacy and security, we may perform procedures to verify your identity and authority of the agent as required under the CCPA. If we cannot verify your identity to a reasonable degree of certainty, we may request additional verifying information.