Policy is applied to all of the services we provide (hereinafter “Services”), together with private policies, terms of service defined for each service we provide and other relevant policies.
1．Basic policy to treat basic information
- We restrict the purpose of utilizing private information as much as possible and will not utilize private information beyond the necessity to achieve the purpose. Also, we will implement appropriate measures to achieve this goal.
- We observe laws, policies and other regulations ruled by government with regard to the treatment of private information.
- We define an internal rule for complaints and response to such complaints. We will respond to complaints and conduct consultations quickly and faithfully.
- We implement necessary and appropriate measures for security management of private information. Such security management includes prevention of leakage, loss and deterioration of private information as well as appropriate recovery measures.
- We define an internal policy for protection of private information which will be revised timely and adequately and thus, continue constant improvement.
2．Definition of private information
Private information covered in this Policy means, among the information pertaining to an alive individual, 1) information with which identification of a specific individual is possible by name, birth date, gender, email address, telephone number, address, company name and so on (such information includes those which cannot identify a specific individual with the information alone but can identify by easily matching with other information), or 2) information which directly identifies a specific individual such as finger prints and passport numbers. When Act on the Protection of Personal Information and other relevant laws and regulations are amended, definition of private information will comply with such amendment.
3．Private information acquired and the acquisition method
We obtain User Information such as below as classified by the acquisition method
（1）Information directly obtained from Users
We obtain information below from Users when we start providing Services:
– Birth date
– Email address
– Telephone number
– Company name
– Past history of usage of Services
– Other information defined to be obtained in our application or website
（2）Technology information obtained
We obtain the following information when Users accesses Services:
– Type of device
– Identifier of the device
– Type of the browser
– IP address
– Identifier for advertisement
（3）Information obtained based on individual consent by Users
We will obtain the following information when individual consent was obtained from Users:
– Location information
（4）We will obtain the following information when individual consent was obtained from Users:
We obtain the following information from an external service provider if Users gave a consent on our collaboration with an external service provider when utilizing Services:
– ID which Users use with an external service provider
– Other information Users granted an external service provider to disclose based on a privacy rule agreed
4．Purpose of usage
We utilize User Information obtained for the following purposes:
– To provide Services and related merchandize
– To invoice service fees
– To identify User. To verify User
– To measure traffics and behavior patterns of User
– To distribute advertisement and to confirm the result
– To inform important matters such as revision of policies for Services
– To respond to inquiries about Services
– For other purposes defined in terms of respective services we provide
5．Provision of private information to a third party
We do not provide private information in User Information to a third party without obtaining Users’ consent beforehand. However, please note that in the following cases, we may exceptionally provide User Information to a third party:
（1）When we provide services as a collaboration with an external party or when we need to verify User’s usage of services of an external party
（2）When we need to collaborate with Government agencies, local public bodies and those entrusted by them who must fulfill responsibilities defined by laws and further, when obtaining consent from Users may hinder fulfillment of such responsibilities
（3）When allowed in laws and regulations
6．Usage of private information commonly with others
Currently, we do not intend to use private information commonly with others.
7．Disclosure of private information
We disclose private information to User without delay when User requests disclosure of his/ her private information in accordance with the requirements determined in Act on the Protection of Personal Information after confirming the request is duly from the User himself/ herself. However, we may not disclose when we are not obliged to disclose based on Act on the Protection of Personal Information and other relevant laws. Please make a contact as explained in “11. Private Information Security Officer in our company” regarding to whom to make an actual request, necessary procedures and commissions.
8．Correction of private information and suspension of usage
- When we are requested by User for corrections, additions or deletion of private information (hereinafter “corrections”), after confirming the request is from User himself/ herself, we will make an investigation without delay and based on the result, we will make corrections and inform to User.
- When we are requested by User based on the reasons below for suspension or deletion of private information (hereinafter “suspension of usage”), after confirming the request is from User himself/ herself, we will make an investigation without delay and based on the result, we will make suspensions of usage and inform to User.
(1) Private information is used beyond the purposed originally disclosed and explained.
(2) Private information was obtained with false or in an illegal way.
- Clause 1. and 2. above will not apply if Act on the Protection of Personal Information or other relevant laws stipulate that we are not obliged for corrections or suspension of usage.
We amend Policy with our discretion. However, when Act on the Protection of Personal Information or other relevant laws stipulate necessary procedures for the amendment, we will comply with the regulated procedure.
When we amend Policy, we make it sure to inform to Users the date of amendment and the content of amendment in one of the following ways:
- Notification in our website
- Direct notification to Users
- In other relevant way
10．Date of Enactment, Date of Amendment
Enactment: Feb 17, 2020
11．Private Information Security Officer in our company
Please contact Private Information Security Officer below for opinions, questions, complains and any other matters regarding private information.
[Web] Please use Inquiry Format
[Mail] 〒101-0051 2-5 Kanda Jinbocho, Chiyoda-ku, Tokyo, Jinbocho Center Bld. 8F
Private Information Security Officer of CCReB Advisors Inc. in charge of complaint matters for private information