1. User Information Collected and Method of Collection
Under this Policy, “User Information” means information related to the identification of users, behavior history while using communications services, and information generated or accumulated in relation to users or user terminals on user smart phones and other information processing terminals (devices) that is collected by the Company pursuant to this Policy. User Information collected by the Company under this Policy includes the following information, depending on to the method of collection.
(1) Information provided by users (including Personal Information)
Information provided by users when making inquiries and so on related to the Services is as set forth below
●Date of birth; and
●Other information input by users on input forms.
(2) Information automatically collected by the Company (information collected by the Company does not include Personal Information)
The Company may collect information related to the status of access to the Services by users and other information. Collected information includes the following.
●Advertising distribution identifiers（※1）
●Information related to conversion, viewing, and clicks
●Information related to user agents（※2）
（※1）Text strings generated by smart device operating systems such as IDFA (Identification for Advertisers) issued by Apple Inc. on iOS, advertising IDs issued by Google Inc. on Android, and other text strings issued by smart device operating systems such as unique UUIDs issued by third party information collection modules. Such identifiers are used for behavior targeting advertising to distribute advertising according to user interests and preferences.
（※2）Agents indicate the operating system and browser, etc., used on a smart device and collect version and other information.
（※3）The URLs of websites viewed immediately prior to viewing the target website.
2. Purposes of Use of User Information
(1) Purpose of use of information provided by users (including Personal Information)
To respond to inquiries and consultations regarding the Services
(2) Purpose of use of information automatically collected by the Company (information collected by the Company does not include Personal Information; when using such information, the Company does not identify specific individuals)
(i) To produce statistical data related to the Company’s Services processed in a format that does not allow for identification of individual.
(ii) To distribute or display advertisements of the Company or third-party; and
(iii) For other marketing uses.
3. Method of Notification and Public Notice or Obtaining Consent and Method of Requesting Termination of Use
Users may request termination of the use of all or some User Information by performing the designated Service settings. In this case, the Company shall terminate use of such User Information in accordance with the Company’s provisions. Further, if the Company is requested by a user to suspend use, terminate collection, or delete personal information included in User Information, the Company shall promptly comply with this request.
4. Provision of Personal Information Included in User Information to Third Parties
The Company shall not provide personal information provided by users to third parties except in the following cases and in cases where disclosure is permitted pursuant to the Act on the Protection of Personal Information or other laws and regulations.
(1) When the user consents to the provision of personal information to third parties;
(2) When an appropriate agreement (a confidentiality agreement with the Company) is executed with a service provider in order to achieve the purposes of use and services are outsourced under the Company’s management;
(3) When personal information is provided pursuant to a merger, corporate division, transfer of business, and so on;
(4) When disclosure is necessary for the protection of the life, person, or property of an individual (including a legal person); and
(5) When disclosure is necessary for improvement of public health or promoting the sound development of children.
5. Information Collection Modules
(1) adjust Inc. (adjust SDK)
(2) Acquired information items: advertiser_id (iOS: IDFA Android: AdvertisingID), app_version, uuid, IP address and user agents
(3) Purpose of use: To distribute advertising, verify the effects of advertising distribution, and confirm the status of use of the Services
(4) Whether information is provided to third parties: Yes (information is provided to third parties that have entered into confidentiality agreements with the Company)
6. How to terminate use of information collection modules
If a user wishes that information not be collected, the user can terminate the collection of User Information other than personal information and invalidate behavior targeting advertising by changing settings on the user’s own device. Settings should be changed as specified by Apple Inc. and Google Inc.
●IDFA (Apple Inc.): Settings > Privacy > Advertising > Turn on “Limit ad tracking”
●Google Advertising ID (Google Inc.): Google Play > Help > Advertising ID
7. Joint Use
The Company does not engage in joint use of user personal information.
8. Disclosure of Personal Information Included in User Information
When a user requests disclosure of personal information pursuant to the Act on the Protection of Personal Information, after confirming the user’s ID, the Company shall disclose the information to the user without delay (if the Company does not have any relevant personal information in its possession, it shall provide notice to that effect). This shall not apply, however, in cases where the Company is not under a duty to disclose personal information under the Act on the Protection of Personal Information and other laws and regulations.
9. Correction and Termination of Use of Personal Information, etc.
(1) In the case where (i) a user requests correction of the details of personal information pursuant to the Act on the Protection of Personal Information on the grounds that the personal information is not correct and (ii) a user requests termination of the use of personal information pursuant to the Act on the Protection of Personal Information on the grounds that personal information is being handled in excess of the scope of the purpose of use initially indicated or that the personal information was collected through deceit or other improper means, after confirming the user’s ID, the Company shall without delay perform the necessary investigations and, based on the results, correct the details or terminate use of the personal information, and notify the user to that effect. If the Company decides not to correct or terminate the use of personal information based on reasonable grounds, the Company shall provide notice to that effect to the user.
(2) If the Company receives a request to delete personal information from a user and the Company determines that compliance with this request is necessary, after confirming the user’s ID, the Company shall delete the personal information and notify the user to that effect.
(3) In the case where the Company is not under a duty to correct or terminate the use of personal information or take other actions pursuant to the Act on the Protection of Personal Information or other laws and regulations, the provisions of the preceding two paragraphs shall not apply.
10. Contact Information for Inquiries
Please address opinions, questions, complaints, requests, and other inquiries regarding the handling of User Information to the email address below.
The Company shall suitably review the status of use in relation to the handling of User Information, shall endeavor to make continuous improvements, and shall revise this Policy as necessary. If this Policy is revised, users shall be notified by posting on the Services. In a case where user consent is required by laws and regulations to revise the content of this Policy, user consents shall be obtained by a method designated by the Company.