This privacy policy (this “Privacy Policy”) is made to: (i) protect personal information as defined below, (ii) establish certain rules and procedures to protect personal information, and (iii) ensure that our employees observe and understand the importance of protecting personal information and taking the necessary measures to protect such personal information carefully, including by promoting such protection.
Article 1 (Personal Information)
“Personal Information” in this Privacy Policy means “personal information (kojin jouhou)” as defined in the Act on the Protection of Personal Information of Japan (Act No. 57 of May 30, 2003; “Personal Information Protection Act”); and therefore, means information which can identify a specific living individual by name, date of birth or other description contained in such information; or which includes a code that can identify a specific individual.
Article 2 (Purpose of Use of Personal Information)
We may acquire and use Personal Information of users (individually “User” or collectively “Users”) of our services (the “Services”) within the scope necessary for the following purposes. If we seek to use such Personal Information beyond the following purposes, we will obtain the prior written consent of the User whose Personal Information is concerned:
(a) to perform the Services;
(b) to improve and refine the Services, or to develop new services;
(c) to notify Users of new functions or updated information of the Services, campaigns, and our other services (including via e-mails, flyers, and other direct mails);
(d) to inform Users of any maintenance of the Services or important news regarding the Services;
(e) to answer comments and questions from Users regarding the Services (including to confirm Users identification);
(f) to report to Users the situation regarding the use of the Services;
(g) to request Users to answer any questionnaires and questions regarding the Services or to attend events, or to report the answers of such questionnaires and questions or results of such events to such Users;
(h) to conduct research on and provide analysis of the history of the Services and to utilize the results of such research and analysis for the improvement and development of the Services and to deliver any promotional materials;
(i) upon the approval or application by the Users, to provide Personal Information to third parties, including companies participating in an event that we hold; and
(j) to identify Users who have violated the Terms of Use or who intend to use the Services for unlawful or illegitimate purposes, and to block their use of Services.
Article 3 (Management and Protection of Personal Information)
We will carefully and closely manage Personal Information and will not disclose or provide such Personal Information to any third parties without the prior written consent of Users whose Personal Information is concerned, except in the following circumstances and shall take precautional and correctional measures to an illegal access to personal information, risks of loss, destruction or leakage of personal information considering a security perspective:
(a) if such disclosure of Personal Information is necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of such person;
(b) if such disclosure of Personal Information is necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person whose Personal Information is concerned;
(c) if such disclosure of Personal Information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by such state organ or local government in executing the affairs required by laws and regulations, and if obtaining the consent of the person whose Personal Information is concerned is likely to hinder the execution of such affairs; and
(d) if it is permitted by laws and regulations.
We will, take preventive and corrective measures against risks resulting from any unlawful access to Personal Information, or any loss, destruction, falsification, or leakage of Personal Information.
Article 4 (Entrustment of Personal Information Handling)
We may entrust an individual or a business operator to handle Users’ personal data in whole or in part. In such case, we will examine their eligibility sufficiently, obligate such individual or business operator to maintain confidentiality obligations by contract, and will perform the necessary and appropriate supervision over such individual or business operator.
Article 5 (Joint Use)
We may jointly use Personal Information of Users to the extent necessary for the following scope and purpose of use:
Purpose of joint use
To provide and improve our services
Scope of personal information to be shared
The minimum necessary information for the above purposes.
Scope of joint use
Only contractors that adhere to the same or higher level of personal information protection as this policy.
The party responsible for the management of personal information
Kinobo inc. (Representative: Ryo Horiki)
Article 6 (Disclosure of Personal Information)
Upon a request of a User (only the person whose information is concerned; the same will be hereinafter applied.), we will promptly disclose such User’s Personal Information held by us. However, we may keep all or part of such Personal Information undisclosed, if such disclosure falls under any of the following categories; and in this case, we will promptly notify such User:
(a) if such disclosure is likely to harm the life, body, property, or other rights or interests of such User or any other third parties;
(b) if such disclosure is likely to hinder the proper execution of our business; and
(c) if such disclosure may result to violation of any laws and regulations.
Article 7 (Correction of Retained Personal Data)
- If Personal Information of a User held by us is false, the User may request that we make the correction of, the addition to, or the deletion of (“Correction”) such Personal Information.
- If we receive the request as stipulated in the preceding paragraph, we conduct necessary research without delay. If we consider as a result of such research that such request is well-grounded, we will implement Correction of such Personal Information without delay.
- If we make any judgment as to whether to implement Correction in accordance with the preceding paragraph, we will notify the User of such judgment without delay.
Article 8 (Discontinuation of Personal Information Use)
- Any User may request that we cease to make the utilization of, make the erasure of, or cease the third-party provision of (“Cessation”), personal data retained by us.
- Upon request as stipulated in the preceding paragraph, we will conduct necessary research without delay. If we consider as a result of such research that such request is well-grounded, we will implement Cessation of such personal data without delay; provided, however, that if such Cessation is unduly expensive or is otherwise difficult to implement and alternative measures to protect the rights and interests of the User are available, then we will take such alternative measures.
- If we reach any conclusion as to whether to implement Cessation in accordance with the preceding paragraph, we will notify the User of such conclusion without delay.
Article 9 (Procedures for Amending Privacy Policy)
We will review the content of this Privacy Policy appropriately and endeavor to improve this Privacy Policy. The content of this Privacy Policy can be amended unless otherwise stipulated in laws, regulations, and this Privacy Policy. The amended Privacy Policy will be valid when notified to all Users or uploaded on our website in accordance with our procedures.
Article 10 (Compliance with Laws, Regulations and Norms)
We will comply with the laws and regulations in Japan and other rules that are applicable to the use of Personal Information we retain.
Article 11 (Response to Complaints and Consultations)
We will respond to any complaints from Users and will provide consultation to any User whose Personal Information is concerned as to the handling of his or her Personal Information. We will respond properly and promptly to any request for disclosure, correction, addition, deletion, refusal of use or provision regarding Personal Information.
Article 12 (Security Measures)
As to Personal Information provided by Users to the Company shall be protected from illegal access, lost, destruction, falsification, leakage and other issues through organizational, physical, personal and technical measures such as restricting access to Personal Information files, recording access logs, and taking security measures to prevent illegal access from outside. If, by chance, any leakage and other incidents are occurred, we will make report to relevant authorities in accordance with the Personal Information Protection Act and relevant guidelines, and as per instructions to be given by the authorities, will take required measures to avoid an occurrence of similar incidents or the same type of incidents. Please refer to the “Security Measures for Personal Information” attached for details.
Article 13 (Address, Name of Representative and Personal Data Protection Officer)
Address, name of representative and name of the personal data protection officer of the Company are:
Address: 4-11-7 Ebisu, Shibuya-ku, Tokyo, Japan
Representative: Ryo Horiki
Personal Data Protection Officer: Ryo Horiki
Article 14 (Customer Desk)
For inquiries concerning our policy of handling of Personal Information, please contact us as below at:
Customer Desk of Kinobo inc.
4-11-7 Ebisu, Shibuya-ku, Tokyo, Japan
E-mail: privacy@kinobo.co.jp
Established on and valid from October 1, 2015.