PRIVACY POLICY

Privacy Policy

Handling of Personal Information

1. 01. Collection of Personal Information

   We collect personal information from the Individual to the extent necessary to provide the services we operate and to manage those services. We collect personal information through proper means and will not collect it through deception or other improper methods. When the Individual provides personal information to us, we will clearly indicate, notify, or publicly disclose to the Individual that we are collecting such information. We will not collect, use, or disclose personal information that includes the following:

   1. (01)Matters relating to ideology, beliefs, and religion
   2. (02)Matters relating to race, ethnicity, family origin, registered domicile (excluding prefecture of residence), physical or mental disability, criminal history, and other matters that may cause social discrimination
   3. (03)Matters relating to workers’ rights to organize, collective bargaining, and other collective action
   4. (04)Matters relating to participation in collective demonstrations, the exercise of the right to petition, and the exercise of other political rights
   5. (05)Matters relating to health, medical care, and sexual life

2. 02. Use and Handling of Personal Information

   Personal information collected from the Individual will be used only by authorized personnel to the extent necessary for performing specific operations, within the scope of the purposes of use described below. It may also be shared across our respective services.
   We handle personal information with the care of a prudent manager, in compliance with the Act on the Protection of Personal Information (hereinafter, the "Personal Information Protection Act").

   Purposes of Use

   1. (01)Recruitment activities (screening of documents, contacting applicants, etc.)
   2. (02)Security management for crime prevention and disaster preparedness
   3. (03)Preparation of tax documents such as withholding tax statements and payment records
   4. (04)Preparation of documents and administration related to social insurance, including health insurance, employees’ pension insurance, employment insurance, and workers’ accident compensation insurance
   5. (05)Management of human resources, labor affairs, employee benefits, and related matters
   6. (06)Billing and payment for various transactions
   7. (07)Payment of dividends
   8. (08)Transaction screening, credit assessment, and reporting and communication of assessment results
   9. (09)Communication regarding sales visits, including business negotiations
   10. (10)Responding to inquiries (via email, telephone, etc.)
   11. (11)Identity verification (including age verification) and order confirmation
   12. (12)Delivery of mail, products, and other items
   13. (13)Various notifications and communications regarding products and services
   14. (14)Various notifications and communications regarding campaigns, events, surveys, seminars, and similar activities
   15. (15)Password issuance
   16. (16)Distribution of newsletters
   17. (17)Communication upon introduction or use of individual services
   18. (18)Communication in cases of violations of terms of service, contracts, or laws
   19. (19)Login authentication for individual services
   20. (20)Delivery and sales of individual services

3. 03. Definition of Personal Information

   We define personal information as information relating to a living individual as prescribed under the Personal Information Protection Act (including name, address, and other information that can identify a specific individual, as well as information containing personal identification codes), together with email addresses, access logs, user IDs, passwords, credit card information, and similar data used in conjunction with a specific individual, as well as preference information, family composition, date of birth, and other attribute information combined with personal information.

4. 04. Information That Does Not Identify a Specific Individual

   Information that cannot identify a specific individual on its own — such as cookies, IP addresses, mobile device identifiers, advertising identifiers, and browsing history — is not treated as personal information. However, when such information is used in conjunction with personal information, it becomes capable of identifying a specific individual and is therefore treated as personal information.
   In the services we provide, even when a specific individual cannot be identified, we will disclose the purposes of use as described below when using information such as cookies, IP addresses, mobile device identifiers, advertising identifiers, browsing history, and other information that does not identify a specific individual.
   We may also share information such as cookies, IP addresses, mobile device identifiers, advertising identifiers, browsing history, and other non-identifying information with subsidiaries and affiliated companies, and use such information jointly with those affiliates within the scope of the purposes described below.

   Purposes of Use

   1. (01)Reporting advertising effectiveness measurement results to advertisers
   2. (02)Reporting to advertising media to improve ad placement decisions
   3. (03)Notifications regarding ad placements for services such as SSPs
   4. (04)Verification and improvement of advertising results
   5. (05)Improving individual services and enhancing usability
   6. (06)Customer segmentation, customer analysis, and consumer trend research
   7. (07)Delivering optimized advertising and providing service features
   8. (08)Analysis, editing, and processing as statistical data, and use as marketing information for reporting to companies and other purposes

5. 05. Notification, Disclosure, and Changes to Purposes of Use

   When we collect and handle personal information, we will specify the purposes of use as precisely as possible and clearly indicate, notify, or publicly disclose those purposes to the Individual in advance. When changing purposes of use, we will not exceed the scope reasonably recognized as related to the original purposes, and will notify or publicly disclose the revised purposes to the Individual. The following cases are exceptions:

   1. (01)When notifying or disclosing the purpose of use to the Individual is likely to harm the life, body, property, or other rights and interests of the Individual or a third party
   2. (02)When notifying or disclosing the purpose of use to the Individual is likely to harm our rights or legitimate interests
   3. (03)When it is necessary to cooperate with a national or local government agency in the performance of duties prescribed by law, and notifying or disclosing the purpose of use to the Individual is likely to impede such duties
   4. (04)When the purpose of use is clearly apparent from the circumstances of collection

6. 06. Scope of Personal Information Use

   We will not handle personal information beyond the scope necessary to achieve the stated purposes of use without the Individual’s consent.
   The following cases are exceptions:

   1. (01)When required by law
   2. (02)When necessary to protect the life, body, or property of the Individual or a third party, and it is difficult to obtain the Individual’s consent
   3. (03)When particularly necessary for the improvement of public health or the promotion of the sound development of children, and it is difficult to obtain the Individual’s consent
   4. (04)When it is necessary to cooperate with a national or local government agency, or a party commissioned by such agency, in performing duties prescribed by law, and obtaining the Individual’s consent is likely to impede such duties
   5. (05)When handled in a manner that does not identify any individual

7. 07. Disclosure of Personal Information

   We will not handle personal information beyond the scope necessary to achieve the stated purposes of use without the Individual’s consent.
   The following cases are exceptions:

   • ⚬When the Individual has given consent
   • ⚬When required by law
   • ⚬When necessary to protect the life, body, or property of the Individual or a third party, and it is difficult to obtain the Individual’s consent
   • ⚬When particularly necessary for the improvement of public health or the promotion of the sound development of children, and it is difficult to obtain the Individual’s consent
   • ⚬When it is necessary to cooperate with a national or local government agency, or a party commissioned by such agency, in performing duties prescribed by law, and obtaining the Individual’s consent is likely to impede such duties
   • ⚬When disclosure is requested by a court, public prosecutor’s office, police, tax authority, bar association, or other body with equivalent authority
   • ⚬When all or part of our operations is outsourced to a third party within the scope necessary to achieve the stated purposes of use
   • ⚬When disclosure is made, as necessary for our operations, to parties bound by a duty of confidentiality toward us, such as attorneys, accountants, and the Japan Affiliate Service Association
   • ⚬When personal information of the Individual using paid services is entrusted to payment system companies or credit companies (with whom we have concluded confidentiality agreements) for the purpose of billing the Individual for usage fees
   • ⚬When personal information of the Individual participating in a seminar is disclosed to companies co-hosting that seminar
   • ⚬When necessary to exercise our rights
   • ⚬When processed statistically in a manner that does not identify any individual
   • ⚬When disclosed to the party succeeding to the business in the event of a merger, business transfer, or other transfer of business
   • ⚬When the following matters have been notified or publicly disclosed without the Individual’s prior consent:
   • • ⚬That the purposes of use include the provision of personal data to third parties
     • ⚬The categories of personal data to be provided to third parties and the method of provision
     • ⚬That provision of personal data identifying the Individual to third parties will be stopped upon the Individual’s request
     • ⚬The method for accepting the Individual’s requests

8. 08. Supervision of Outsourced Parties

   When outsourcing all or part of personal information handling, we will enter into contracts including confidentiality provisions with the outsourced party, or require agreement to our terms, and provide necessary and appropriate oversight to ensure the outsourced party manages personal information securely.

9. 09. Disclosure, Correction, Addition, Deletion, Suspension of Use, Suspension of Provision, and Erasure of Personal Information

   When the Individual requests disclosure, correction, addition, deletion, suspension of use, suspension of provision, or erasure of their personal information, we will verify the Individual’s identity and confirm the accuracy of the information through our prescribed procedures and promptly take the requested action. However, we may be unable to comply in the following cases, in which case we will notify the Individual and explain the reason.

   1. (01)When there is a risk of harm to the life, body, property, or other rights and interests of the Individual or a third party
   2. (02)When there is a risk of significant interference with the proper conduct of our operations
   3. (03)When compliance would violate applicable laws or regulations
   4. (04)When the Individual requests correction, addition, or deletion on the grounds that personal information is factually inaccurate, but our verification confirms the information is accurate
   5. (05)When special procedures are prescribed by other laws or regulations
   6. (06)When the Individual requests suspension of use or erasure, but the personal information is being handled within the stated purposes of use and was not improperly obtained
   7. (07)When suspending use or erasing personal information would require significant cost or is otherwise difficult, and alternative measures necessary to protect the Individual’s rights and interests have been taken
   8. (08)When the Individual requests suspension of provision, but the provision of personal information does not violate Article 23 or 24 of the Personal Information Protection Act
   9. (09)When suspending provision of personal information to third parties would require significant cost or is otherwise difficult, and alternative measures necessary to protect the Individual’s rights and interests have been taken

   To request disclosure, correction, addition, deletion, suspension of use, suspension of provision, or erasure of your personal information, please contact us at the inquiry address listed in Section 14 below.

10. 10. Voluntary Nature of Providing Personal Information

    Whether to provide personal information to us is entirely at the Individual’s discretion. When the Individual provides personal information to us, we will deem that they have consented to our use of such information in accordance with this Privacy Policy. However, if required information is not provided, our services may not be available in their proper form. Cookie information may be blocked through browser settings. Please note that blocking cookies may also result in our services not being available in their proper form, which we will also notify or publicly disclose.

11. 11. Links

    Our websites contain links to external sites but do not share personal information with them. We bear no responsibility for the collection of personal information on linked websites. Please refer to the privacy policies of those websites.

12. 12. Security

    When the Individual registers personal information on our websites, we use SSL encryption technology and dedicated servers protected by firewall security systems, taking every possible measure to prevent unauthorized access and information leakage.

13. 13. Updates to This Privacy Policy

    When this Privacy Policy is updated, the update will be posted on this website. By posting the latest Privacy Policy on this site, you can always stay informed about how personal information is collected and used. We encourage you to review it periodically.

14. 14. Contact

    For inquiries regarding the disclosure, correction, addition, suspension of use, suspension of provision, and erasure of personal information, as well as other opinions and requests regarding our handling of personal information, we have established the following dedicated contact point and will respond promptly and appropriately.

    Dedicated Contact

    Sumitomo Fudosan Shinjuku First Tower 5F, 5-1-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023

    Adways Inc. — Compliance Department

    Personal Information Inquiry Desk:privacy@adways.net

    Please note that we do not accept in-person requests or inquiries at our offices.

    Notice to Individuals

    • ⚬Our websites may protect registered information with an ID and password. The Individual is solely responsible for managing their ID and password.
    • ⚬To ensure the safe use of our services and websites, please refrain from unnecessarily posting personal information — whether of yourself or others — on our websites.