PRIVACY POLICY

Our company acquires personal information of the Individual to the extent necessary to provide services that our company manages. Our company appropriately acquires personal information, and does not acquire personal information through feigning or any other illicit means. If receiving personal information from the Individual, our company clearly shows, or notifies our intent of acquiring the information to the Individual or disclose it to the public. In addition, our company does not acquire, use or provide personal information that contains the following.

1. Matters related to any thought, belief or religion
2. A race, ethnic group, family origin, legal domicile (excluding information on the prefecture), physical/mental disorder, criminal record, or any other matter that may cause social discrimination
3. Matters related to workers’ right to organize of, collective bargaining, or any other act of collective action
4. Matters related to participation in collective demonstration, exercise of the right of petition, or exercise of any other political right
5. Matters related to healthcare or sex life

Only those granted with authority according to a specific operation shall use the acquired personal information of the Individual within the scope of the utilization purpose stated below only if it is necessary to use the information for the execution of the operation. In addition, such information may be mutually used for our company’s respective services, etc.
Our company handles personal information with the due diligence of prudent merchant in accordance with the Act on the Protection of Personal Information (hereafter called “Personal Information Protection Act”).

Utilization Purpose

① Conducting recruitment activities（checking documents, conducting interviews, contacting applicants, etc.）

② Security management for crime and disaster prevention, etc.

③ Making withholding certificates, making payment reports or other documents regarding taxation.

④ Making and managing notifications, applications, requests or certificates regarding health insurance, employees pension insurance, employment insurance, industrial accident compensation insurance.

⑤ Managing personal, labor and welfare matter.

⑥ Making payment and sending bills regarding transactions

⑦ Making payment of dividends

⑧ Reviewing transaction, conducting credit check and making contact in relation thereto.

⑨ Making contact in relation to sales calls (including business meetings)

⑩ Responding to inquiries (e-mail and telephone, etc.)

⑪ Identity verification (including age verification) and confirmation of order details

⑫ Delivery of mail and products

⑬ Making contact in relation to the introduction of our products and services

⑭ Making contact and introduction in relation to the campaign, event, questionnaire, seminar

⑮ Issuance of password

⑯ Distributing e-mail news letters

⑰ Installing services or making contact in relation thereto

⑱ Notifying the violation of the provisions of terms and conditions, or agreement

⑲ Login authentication for services

⑳ Distributing and selling of services

Our company recognizes personal information as information on living individuals defined in the Personal Information Protection Act (information that enables us to identify a specific individual such as a name and address and an individual identification code), information such as an e-mail address, access record, user ID, password and credit card that are used as integrated with a specific individual, and attribute information related to an individual such as taste, family makeup and date of birth integrated with personal information .

Our company does not recognize cookies, IP address information, and mobile identification numbers (individual identification numbers)、advertising ID, action history data, any other information which is unable to identify a specific individual as personal information since it is impossible to identify a specific individual with such information alone. However, if such information is used as integrated with personal information, our company considers even such information as personal information since it enables us to identify a specific individual.
In services that our company provides, if our company uses a cookie, IP address information, mobile identification number, advertising ID, action history data, any other information which is unable to identify a specific individual (individual identification number), our company intends to disclose the purpose as below, even if such information does not enable us to identify a specific individual.
Our company may share and use a cookie, IP address information, mobile identification number, advertising ID, action history data, any other information which is unable to identify a specific individual with our affiliates, including subsidiaries etc. to the extent that the utilization purpose stated below.

Utilization Purpose

① Reporting advertising effectiveness to advertisers

② Reporting to improve the evaluation of advertisement post requests

③ Making notification in relation to services such as SSP, etc.

④ Reviewing and improving advertising results

⑤ Improving services and Improving convenience

⑥ Categorizing customer, analyzing customer, and researching consumer trend

⑦ Distributing optimum advertisement and providing services.

⑧ Analyzing, editing, and processing for statistical information, and using as marketing information to report to business partners and any other companies.

If our company acquires and handles personal information of the Individual, our company identifies the utilization purpose use as much as possible, clearly shows or notifies the utilization purpose to the Individual or discloses it to the public in advance. However, this does not apply in the cases set forth below. Our company shall, in case of altering a utilization purpose, not do so beyond the scope recognized reasonably relevant to the pre-altered utilization purpose and inform the Individual of, or disclose to the public, a post-altered utilization purpose.

1. cases in which there is a possibility that informing the Individual of, or disclosing to the public, a utilization purpose would harm the Individual or third party's life, body, fortune or other rights and interests;
2. cases in which there is a possibility that informing the Individual of, or disclosing to the public, a utilization purpose would harm the rights or legitimate interests of our company;
3. cases in which there is a need to cooperate in regard to a central government organization or a local government performing affairs prescribed by laws and regulations, and when there is a possibility that informing the Individual of, or disclosing to the public, a utilization purpose would interfere with the performance of the said affairs;
4. cases in which it can be recognized, judging from the acquisitional circumstances, that a utilization purpose is clear.

Our company does not handle personal information beyond the scope necessary to achieve the utilization purpose without consent of the Individual. However, this does not apply in the following cases

1. cases based on laws and regulations;
2. cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain the Individual’s consent;
3. cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain the Individual's consent;
4. cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining the Individual’s consent would interfere with the performance of the said affairs;
5. cases in which the use of personal information is limited to the extent that a specific individual cannot be identified.

Our company does not provide personal information of the Individual to a third party without consent of the Individual in principle.
However, our company may provide personal information to a third party in the following cases.

• cases in which our company has obtained consent of the Individual;
• cases based on laws and regulations;
• cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain a consent of Individual;
• cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain a consent of Individual;
• cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a consent of Individual would interfere with the performance of the said affairs;
• cases in which the court, public prosecutor’s office, police, tax office, bar association or an agency with authority equivalent to these requires our company to disclose personal information;
• cases in which our company discloses personal information to those who are obliged to keep secret for our company, such as a lawyer, accountant, and the Japan Affiliate Service Kyokai (Association);
• cases in which our company commissions part or the whole of a business that our company operates to a third party within the scope necessary to achieve the utilization purpose;
• cases in which our company entrusts personal information of the Individual who uses a paid service to a payment system company or credit company, to which our company commissions our business (concluding a confidentiality agreement), with the aim of charging the user who uses the paid service with a usage fee;
• cases in which our company disclose personal information of the Individual who attends seminars to co-host companies;
• cases in which provision of personal information is required for exercising our company’s right;
• cases in which personal information is statistically processed in a manner that a specific individual cannot be identified;
• cases in which our company discloses personal information to the person inheriting our business when our business is inherited for business transfer or other reasons;
• cases in which the following matters are notified or disclosed to the public in advance without consent of Individual
  • inclusion of the provision of personal data to a third party in the utilization purpose;
  • items of data provided to a third party or a means/method of provision;
  • our company cease the in response to Individual’s request a third- party provision of personal data that can identify the Individual;
  • a method of receiving the Individual’s request.

If our company commissions part or the whole of the handling of personal information to a third party, our company requests the consignee to sign an agreement including confidentiality or agree to a clause that our company establishes, and conducts necessary and appropriate supervision of the consignee so that personal information is safely managed at the consignee.

If the Individual desires to disclose, correct, make an addition to, delete, cease use of, cease the third-party provision of, or erase his/her personal information, etc., our company conducts identification and checks authentication of the information through our company’s prescribed procedures, and promptly performs an action such as disclosure, correction, addition, utilization cease, the third-party provision cease, and erasure of the personal information provided by the Individual. However, if any of the following items applies, our company may not respond to the Individual’s request for disclosure, correction, addition, deletion, utilization cease, the third-party provision cease, or erasure. In such a case, our company notifies the Individual to that effect and explains the reason.

1. cases in which there is a possibility that informing a principal of, or disclosing to the public, a utilization purpose would harm an Individual or third party's life, body, fortune or other rights and interests;
2. cases in which appropriate conduct of the company’s business may be significantly interfered with;
3. cases in which such an act may violate laws or regulations.
4. cases in which that the personal information associated with the Individual’s request for correction, addition or deletion because he/she believes they are not factual, are verified factual after the conduct of necessary investigation;
5. cases in which special procedure is prescribed by the provisions of other laws or regulations;
6. cases in which our company handle the personal information associated with the Individual’s request for utilization cease or deletion within the scope of utilization purpose and are not acquired by deceit or other improper means;
7. cases in which a utilization cease or erasure of the personal information associated with the Individual’s request requires a large amount of expenses or other cases where it is difficult to fulfill a utilization cease or erasure of such personal information and when necessary alternative action is taken to protect an Individual’s rights and interests;
8. cases in which the personal information associated with the Individual’s request for the third-party provision cease are not provided in violation of the provision of Article 23, paragraph (1) or Article 24.
9. cases in which the third-party provision cease of the personal information requires a large amount of expenses or other cases where it is difficult to fulfill the third-party provision cease of such personal information and when necessary alternative action is taken to protect Individual’s right and interests.

If the Individual desires to disclose, correct, make an addition to, delete, cease use of, cease the third-party provision of, or erase his/her personal information, etc., please contact our company by using the contact information stated below, Article 14.

The decision of whether or not to provide personal information to our company is at the Individual’s own discretion. If the Individual provides personal information to our company, our company considers that the Individual permits the use of the personal information in accordance with our company’s privacy policy. However, if the Individual does not provide necessary items of information, the Individual may not receive the services that our company provides in an appropriate manner. The Individual may reject cookie information by appropriately setting the browser of the Individual. Even if the Individual rejects a cookie, the customer may not receive the services that our company provides in an appropriate manner. In such a case, our company also notifies the Individual to that effect, or disclose it to the public it.

The websites that our company operates contain links to several external sites. But, these links do not share personal information. Our company does not assume any responsibility for the collection of personal information performed on the linked websites. So, please be sure to read the privacy policy of the respective linked website.

For the websites that our company operates, our company is doing our best to prevent unauthorized external access and information leakage by managing the websites using a special encryption communication technique called SSL and using a dedicated server protected with a security system called a Firewall for the registration of the Individual’s valuable personal information.

If our company updates the privacy policy, the updating privacy policy is posted on this website. By posting the latest privacy policy on the site, we can make it possible for the Individual to collect the personal information and know how to use it at any time. Please check the policy on a regular basis.

Our company has established the following dedicated contact point for inquiries about the disclosure, correction, addition, suspension of use, erasure, etc. of personal information, and handling of other personal information, in order to facilitate appropriate and prompt response.

● Dedicated contact point ●
Contact point for personal information：privacy@adways.net
Compliance Office, Adways Inc. 5F Sumitomo Fudousan Shinjuku First Tower, 5-1-1 Nishi-Shinjuku, Shinjuku, Tokyo 1600023, Japan
* Please note that we cannot receive any request or inquiry made through direct visit to our office.

* Our request to Individuals

• In the websites that our company operates, Individuals’ registered information may be protected with IDs and passwords. The Individuals must manage their IDs and passwords at their own responsibility.
• For safe use of the services that our company provides and the websites that our company operates, please do not indiscriminately post personal information of others or the Individual on the websites that our company operates.