1．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 (Act Number 57, May 30, 2003) and other relevant laws and regulations are amended, definition of private information will comply with such amendment.
2．Private information to be acquired and its acquisition method
CCReB Group obtains User Information such as below as classified by the acquisition method.
( 1 ) Information directly obtained from Users
CCReB Group obtains information below from Users when Users start using Services:
- – Name
- – Birth date
- – Gender
- – Email address
- – Telephone number
- – Adress
- – Company name
- – Division in Company
- – Office in Company
- – Past history of usage of Services
- – Other information defined to be obtained in the application or website of CCReB Group
( 2 ) Technology information obtained
CCReB Group obtains the following information when Users access Services:
- – Type of device
- – Identifier of the device
- – Type of the browser
- – Referrer
- – IP address
- – Cookie
- – Key word searched
- – History of watching an advertisement and its frequencies
- – Other histories of screen search
- – Identifier for advertisement
( 3 ) Information obtained based on individual consent by Users
CCReB will obtain the following information when individual consent was obtained from Users:
- – Location information
( 4 ) Information when individual consent was obtained from Users:CCReB Group obtains the following information from an external service provider if Users gave a consent on the 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
( 5 ) Others
In addition to the information defined in the previous clauses, CCReB Group will obtain the following information:
- – Information CCReB Group obtained based on a separate consent with Users
- – Information CCReB Group obtained from a third party
3．Purpose of usage
CCReB Group utilizes 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
- – To investigate and analyze utilization of Services
- – To improve operation and quality of Services, To plan and develop new Services, To conduct questionnaire survey and other marketing analysis
- – For other purposes defined in terms of respective services CCReB Group provides
4．Provision of private information to a third party
CCReB Group does not provide private information contained in User Information to a third party without obtaining Users’ consent beforehand. However, please note that in the following cases, CCReB Advisors may exceptionally provide User Information to a third party:
- （1）When CCReB Group provides services by collaborating with an external party or when CCReB Group needs to verify User’s usage of services provided by an external party
- （2）When CCReB Group provides information defined in Clause 2 of this Policy after processing it so that a third party cannot identify an individual User.
- （3）When CCReB Group needs 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.
- （4）When allowed in laws and regulations
- （1）CCReB Group may outsource some of its businesses defined in this Policy to an external company (hereinunder “Contractor”) and in doing so, may provide User Information to Contractor.
- （2）In case of (1) above, CCReB Group will contractually oblige Contractor to limit the usage of User Information to the extent that it is necessary for the implementation of contracted tasks and will further oblige appropriate measures for security and control to be taken.
6．Common usage of private information with others
Currently, CCReB Group does not intend to use private information commonly with others.
7．Disclosure of private information
CCReB Group will 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, CCReB Group may not disclose when CCReB Group id s 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
- （1）When CCReB Group was requested by User for corrections, additions or deletion of private information (hereinafter “corrections”), after confirming the request is from User himself/ herself, CCReB Group will make an investigation without delay and based on the result, CCReB Group will make corrections and inform to User.
（2）When CCReB Group was 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, CCReB Group will make an investigation without delay and based on the result, CCReB Group 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.
- （3）Clause (1) and (2) above are not applied if Act on the Protection of Personal Information or other relevant laws stipulate that CCReB Group is not obliged for corrections or suspension of usage.
（4）Information obtained as a result of collaborations with external parties
CCReB Group will obtain the information below from external parties when User approved CCReB Group’s collaborations with the external parties in his/ her using Services.
– IDs which User uses for external services
CCReB Group will amend Policy with its discretion. However, when Act on the Protection of Personal Information or other relevant laws stipulate necessary procedures for the amendment, CCReB Group will comply with the regulated procedure.
When CCReB Group amends Policy, CCReB Group makes it sure to inform to Users the date of amendment and the content of amendment in one of the following ways:
- – Notification in CCReB Group’s website
- – Direct notification to Users
- – In other relevant ways
10．Date of Enactment, Date of Amendment
Enactment: Feb 17, 2020
Amendment: March 1, 2022
11. Private Information Security Officer in CCReB Group
Please contact Private Information Security Officer below for opinions, questions, complains and any other matters regarding private information.
【by way of Web】
Please use Inquiry Format
【by way of post mail】
1-14-8 Uchikanda, Chiyoda-ku, Tokyo
KANDA SQUARE GATE 8F
Private Information Security Officer of CCReB Advisors Inc. in charge of complaint matters for private information
CCReB Advisors Inc.