The Company shall comply with laws regarding the protection of Personal Information (hereinafter referred to as “Act on Protection of Personal Information”, laws and government agencies’ guidelines for the use etc. of personal identifiable numbers in administrative procedures, and other related laws, regulations, etc. (hereinafter referred to as “Laws, Regulations, etc.”), in order to ensure that Personal Information about the Company’s customers is protected.
2. Safe Management Measures and System
The Company shall take reasonable measures against risks, including, but not limited to, unauthorized access to Personal Information, the divulgation, loss or damage of Personal Information, and establish a system where the Company can respond thereto, in order to secure the accuracy and safety of Personal Information.
3. Acquisition of User Information
User Information which the Company collects in the Services is as follows, depending on the collection method:
(1) Information provided by users
Information which User inputs entry form prescribed by the Company when using the Services and registering as subscriber, including, but not limited to, name, gender, birthdate, address, attribute information such as affiliated institution and occupation, and e-mail address;
(2) Information collected by the Company
Information which the Company collects when User uses the Services, including, but not limited to, information about a terminal which User uses, access and use history of the Services, IP address, cookie information;
(3) Other information incidental to each of the foregoing items.
4. Intended Use
4-1 The Company shall use User Information about User for the following purposes, when operating and providing the Services:
(1) Procedures for using the Services and registering as subscriber;
(2) Provision of the Services;
(3) Analysis of situation of use of the Services;
(4) Enhancement and improvement of the Services, and conducting questionnaires etc. for the purpose thereof;
(5) Advertisement by e-mail or distribution of mail magazines;
(6) Notification of new services relating to the Services;
(7) Response to inquiry etc. from User;
(9) Collection of unpaid member fee etc.; and
(10) Other intended use incidental to each of the foregoing items.
4-2 The Company shall process the following User Information into a format by which each User cannot be identified or specified (hereinafter processed information shall be referred to as “Processed Anonymous Information”) and use the same for the following purposes:
(1) User Information to be processed; and
・Attribute information such as affiliated institution and occupation
・ Information about a terminal which User uses
・ Access and use history of the Services
(2) Intended Use for Processed Anonymous Information;
・ Creation and analysis of statistical data
・Management analysis, marketing, and planning, development and provision of products, services, etc. through the use of statistical data
・Advertisement, and questionnaires distribution and presentation by the Company, its business tie-up partners, business partners, etc. (hereinafter referred to as “Other Companies”)
・ Notification of products, services, etc. of the Company and Other Companies
5. Provision to Third Party
For Personal Information out of User Information, if provided for in Laws, Regulations, etc., with a User’s agreement, and upon the occurrence of any of the followings, the Company shall provide Personal Information about such User to Other Companies within the scope of the intended use set out in Article 4. However, for Processed Anonymous Information, the Company shall provide the same to Other Companies within the scope of the intended use set out in Article 4, and for the purpose of Other Companies’ planning, development and provision of products, services, etc. and the purpose of Other Companies’ advertisement and distribution and presentation of questionnaires etc. and other purpose related thereto.
(1) If the Company outsources the handling of Personal Information, in whole or in part, to a third party, to the extent necessary to accomplish the intended use set out in Article 4;
(2) If, with the succession of business for the purpose of M&A, amalgamation or other causes, Personal Information is provided to the successor entity; or
(3) When the Company needs to cooperate a government agency, local public agency, or person to which each of the foregoing outsources, in conducting administrative work under laws and regulations, if User’s agreement may interfere with the conducting thereof.
6. Outsourcing of Handling of User Information
The Company may outsource the following operations regarding the handling of User Information, in whole or in part, to a third party:
(1) Delivery of e-mail to User;
(2) Primary response to inquiries from User;
(3) Process of Processed Anonymous Information set out in Article 4 creation and analysis of statistical data; and
(4) Other operations incidental to each of the foregoing items.
7. Disclosure of Personal Information
When a User requests the Company to disclose Personal Information by the method prescribed by the Company under the Act on Protection of Personal Information, the Company shall, without delay, disclose the same to such User after confirming it is a request from such User.
8. Correction, Suspension of Use and Deletion of Personal Information
8-1 When a User requests the Company to correct or suspend the use of Personal Information by the method prescribed by the Company, based on any of the following grounds, the Company shall conduct a necessary investigation without delay, after confirming it is a request from such User, correct or suspend the use of Personal Information about such User based on the results thereof, and notify such User to that effect:
(1) If User requests the Company to correct Personal Information under the Act on Protection of Personal Information, based on the ground that it is not true or correct; or
(2) If User requests the Company to suspend the use of Personal Information under the Act on Protection of Personal Information, based on the ground that it is handled beyond the scope of the intended use disclosed publicly or that it was collected through fabrication or by fraudulent means.
8-2 When a User requests the Company to delete Personal Information by the method prescribed by the Company, if the Company judges that it needs to accept such request, the Company shall delete Personal Information about such User after confirming it is a request from such User, and notify such User to that effect.
8-3 If the Company is not obliged to correct, suspend the use of or delete Personal Information under Laws, Regulations, etc., the provisions of the preceding two (2) Paragraphs shall not apply.
*Procedures for seeking the disclosure, correction, suspension of use or deletion of Personal Information
(1) The Company shall respond to a request, from the User or his/her representative via liked form, for the disclosure, correction, suspension of use or deletion of Personal Information (hereinafter referred to as “Request for Disclosure etc.”).
(2) The Company shall respond to it by means of e-mail to registered e-mail address.
(3) The Company shall use and handle Personal Information acquired by it from a Request for Disclosure etc., to the extent necessary to respond to such Request for Disclosure etc.
(4) If Personal Information about a User subject to a Request for Disclosure etc. is not contained in Personal Information acquired by the Company, or if the Company judges that it is not appropriate to disclose, correct, suspend the use of or delete the foregoing Personal Information, based on any of the following grounds etc., the Company shall notify such User by mail, with providing reasons therefor, by the method of response set out in (2) above.
• If the identity of a User cannot be verified, for example, there is a discrepancy between the address described in a linked form or identity verification documents and the address registered at the Company;
• When it is a request from a legal representative and attorney-in-fact of such User, if the power of legal representation and power of attorney cannot be confirmed;
• In this case, the Company may give a notice of confirmation to the User subject to a request.
• If there is a defect in necessary information described in linked form;
• If the subject to a Request for Disclosure etc. does not fall on Personal Information;
• If it interferes materially with the appropriate conducting of the Company’s operations;
• If it falls on a violation of Laws, Regulations, etc.
9. Handling of User Information after Termination of Registration for Use of Services
User terminates the registration for use of the Services, the Company shall completely delete User Information about such User with lapse of specified time necessary for works etc. related to the termination of the registration for use thereof.
10. Response to Complaint and Consultation
The Company shall establish the following point of contact for complaint and consultation, from User, about User Information and respond thereto appropriately.
CEO Kiyoshi Fujiki
1-3-9, Aobadai, Aoba-ku, Yokohama, 227-0062
It is to be noted that the Company cannot accept your request when visiting our office. If the Company cannot confirm that it is an inquiry from the User, we may not respond thereto, depending on the contents thereof.
When the Company collects, uses, transfers, etc. your personal data from countries located within the European Economic Area (EEA) to countries located outside of the EEA, we will ensure that appropriate safeguards are taken as data controller within the meaning of the GDPR (General Data Protection Regulation).
Prepared on June,1st,2022