Article 1 (Definitions)

The definitions of terms used in this Policy are as follows:

1. "The Service" refers to various services provided by the Company.
2. "User(s)" refers to the viewers of the website managed and operated by the Company and those who wish to use the Service.
3. "Personal Information" is defined in accordance with the Act on the Protection of Personal Information (hereinafter referred to as "APPI") Article 2, Paragraph 1 and specifically refers to information regarding a living individual includes:
①Information that can identify a specific individual based on their name, date of birth, address, phone number, and other such descriptors, and
②Data related to appearance, fingerprints, voice prints, and information like health insurance policy numbers which can identify a specific individual (personal identification codes).
4. "Personal-Related Information" refers to the "personal-related information" defined in APPI Article 2, Paragraph 7, which is managed in the Company's database.
5. "Cookie" refers to information sent from a website to the User's browser, which is then recorded on the User's device. It should be noted that cookies do not contain any information that identifies an individual, such as their name, address, phone number, or email address, and cookies do not adversely affect the user's device.

Article 2 (Purpose of Use)

The specific purposes for which the Personal Information provided by Users will be used are as follows:

1. For the provision and operation of the Service.
2. For aggregation, analysis, and creation of statistical materials to grasp the usage status of the Service and improve its quality.
3. To respond to inquiries from Users (including the verification of the User's identity).
4. To notify Users of new features, updates of the Service they are using, as well as to introduce other services offered by the Company.
5. To contact Users for maintenance, important notifications, or any necessary communication. 6. To identify Users who violate the terms of the Service or try to use the Service for fraudulent or improper purposes, and to refuse their usage.
7. To allow Users to view, modify, delete their registration information and to check their usage status.
8. For the delivery, display, and measurement of advertising effects.
9. To measure User traffic and behavior.
10. For purposes associated with the above usage purposes.

Article 3 (Provision to Third Parties)

1. The Company will not disclose or provide Personal Information to third parties without obtaining the prior consent of the User, except in any of the following cases:
①Cases in which the provision of Personal Information is based on laws and regulations.
②Cases in which the provision of Personal Information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person.
③Cases in which the provision of Personal Information is specially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person.
④Cases in which Personal Information is provided as a result of the succession of business in a merger or otherwise.
⑤Cases in which the provision of Personal Information is necessary for cooperating with a state organisation, a local government, or an individual or a business operator entrusted to execute the affairs prescribed by laws and regulations and in which obtaining the consent of the person are likely to impede the execution of the affairs.
⑥Cases in which Personal Information is requested to be disclosed or provided by courts, public prosecutors' offices, police, or agencies with similar authority, based on valid reasons.
⑦In other cases where disclosure or provision is allowed by related laws.
2. Notwithstanding the previous paragraph, in the following cases, the recipient of the information is not be deemed a "third party":
①Cases in which the Company entrust the handling of Personal Information in whole or in part within the scope necessary for the achievement of the Purpose of Use.
②Cases in which Personal Information is provided as a result of the succession of business in a merger or otherwise.
③Cases in which Personal Information is used jointly between specific individuals or entities. In such a case the items of the Personal Information used jointly, the scope of the joint users, the purpose for which the Personal Information is used by them, and the name (and name of the representative in the case of a corporation) of the individual or business operator responsible for the management of the Personal Information is, in advance, notified to the person or put in a readily accessible condition for the person.
3. Regardless of paragraph 1, if the Company is requested to provide User's Personal Information based on laws or rules defined by a financial instruments exchange (or those conducting transactions similar to financial instruments exchanges) or a regulatory authority, the Company shall provide the User's Personal Information to the said financial instruments exchange or regulatory authority, and the User shall agree to this.
4. Even when the Company discloses or provides Personal-Related Information to third parties, if it is anticipated that the third party will acquire the Personal-Related Information as Personal Information, the Company will obtain prior consent from the User.

Article 4 (Disclosure of Personal Information and Provision of the Records)

When the Company is requested by the User to disclose the following information based on the provisions of the APPI, after confirming that the request comes from the User themselves, the Company will promptly disclose the information to the User (If the specific Personal Information does not exist, the Company will notify the User accordingly). However, if the APPI or any other laws dictate that the Company is not obligated to disclose such information, this Article will not apply. Please note that there is a handling fee (1,000 yen per item) for the disclosure of Personal Information.

①Personal Information of the said User.
②Cases where the User's Personal Information has been provided to a third party (excluding cases corresponding to each item of Article 3 paragraph 1 and each item of Article 3 paragraph 2), the date of such provision, as well as the name or designation of the said third party and any other items mandated to be recorded by laws.
③Cases where the User's Personal Information was acquired from a third party (excluding cases corresponding to each item of Article 3 paragraph 1 and each item of Article 3 paragraph 2), the date of receiving such data, the background of its reception, and the name or designation of the said third party, along with any other items required to be recorded by laws.

Article 5 (Correction and Suspension of Use of Personal Information, etc.)

1. If the User claims, based on the APPI, that Personal Information is not accurate and requests correction, addition, or deletion (hereinafter referred to as "correction, etc.") of its content, the Company will, after confirming that the request is from the User themselves, promptly conduct the necessary investigation. Based on the results of such investigation, the Company will make the correction, etc., of the Personal Information and notify the User of this fact. If a decision is made not to make the correction, etc., the Company will notify the User of this decision.
2. If the Company is requested by the User, based on the provisions of the APPI, to stop using or delete Personal Information (hereinafter referred to as "suspension of use, etc.") on the grounds that any of the following applies, the Company will, after confirming the request is from the User themselves, promptly conduct the necessary investigation. Based on the results of such investigation, the Company will execute the suspension of use, etc., of the Personal Information and notify the User of this fact. If a decision is made not to suspend the use, etc., the Company will notify the User of this decision.
①The User's Personal Information is being handled beyond the scope of the publicly announced purpose of use.
②The User's Personal Information is being used in a way that might promote or induce illegal or improper activities.
③The User's Personal Information was collected through deception or other illicit means. Regarding the User's Personal Information, there has been, or is a possibility of, a leak, loss, or damage.
④There is a risk that the handling of the User's Personal Information might harm the rights or legitimate interests of the individual concerned.
3. If the APPI or other laws stipulate that the Company does not have an obligation for correction, etc., or suspension of use, etc., the provisions of the paragraph 1 and paragraph 2 of this Article will not apply.
4. The Company will appropriately dispose of or delete Personal Information that is no longer necessary to use, in accordance with relevant laws and internal regulations.

1. The Company's website uses Cookies. Please note that Users can disable the Cookie function by changing their browser settings.
2. The purposes for using Cookies in the Company are as follows:
①To refer to the saved User's information when the User utilizes the Service, enabling us to provide the Service customized for each User.
②To display the most appropriate advertisements on other companies' websites based on the content the User is interested in and their usage status on the Company's website (for the optimization of ad distribution).
③To survey the number of Users and traffic on the Company's website (for site access analysis).
④To improve the Service.

Article 7 (Safety Management Measures for Personal Information)

The Company takes the following safety management measures for Personal Information to prevent its leakage, loss, or damage, etc., and for its proper management.

1. Establishment of Rules Related to Handling Personal Data
The Company have formulated the "Personal Information Handling Regulations" that outline basic handling methods when acquiring, using, and storing data.
2. Organizational Safety Measures
①The Company have appointed an administrator responsible for handling Personal Information and have clarified the scope of Personal Information handled by employees and the employees themselves. The Company have also established a system for reporting to the administrator when there are facts or signs of violations of the APPI.
②The Company periodically conduct self-checks on the handling status of Personal Information and carry out audits by other departments or external parties.
3. Staff Safety Measures
①The Company regularly conduct training for employees on matters to be aware of regarding the handling of Personal Information.
②The Company have included matters related to the confidentiality of Personal Information in rules of employment.
4. Physical Safety Measures
①In areas handling Personal Information, the Company manages the entry and exit of employees, restrict devices brought in, and implement measures to prevent unauthorized viewing of Personal Information.
②The Company takes measures to prevent theft or loss of devices, electronic media, documents, etc., that handle Personal Information. Including when moving within the office, the Company ensures that Personal Information isn't easily discernible when transporting said devices and media.
5. Technical Safety Measures
①The Company utilises access control, limiting the range of responsible parties and the databases containing Personal Information.
②The Company have introduced mechanisms to protect information systems handling Personal Information from unauthorized access from the outside and malicious software.

Article 8 (Inquiries)

Article 9 (Procedure for changes of the Privacy Policy)

The Company may change this policy as needed. However, when making changes to this policy that require User consent according to laws, the changed policy will only apply to Users who have consented to such changes through the methods specified by the Company. Moreover, when the Company change this policy, the Company will announce the enforcement time and contents of the changed policy on the Company's website or notify Users through other appropriate methods.

【20th September 2023】