Privacy Policy

(1) Purposes of Use of Personal Information

The Company shall use Personal Information pertaining to a client for the following purposes:

• to provide the Company's services;
• to bill for service usage fees;
• to provide information on the Company's services, and respond to inquiries relating thereto;
• to respond to violations of the Company's terms and conditions, and policies (hereinafter, the “Terms”) relating to the Company's services;
• to notify clients of changes to the Terms relating to the Company's services; and
• to help improve the Company's services, develop new services, etc.

(2) Changes to Purposes of Use of Personal Information

The Company may make changes to the purposes of use of Personal Information within a scope reasonably deemed relevant, and in the event of a change, the Company shall inform clients or make an announcement post on the Company's website page.

(3) Restrictions on Use of Personal Information

The Company shall not handle Personal Information beyond the scope necessary to achieve the purposes of use without the consent of the client, except when permitted by the Personal Information Protection Act and other laws and regulations. However, this shall not apply in the following cases:

• when required by law;
• when necessary to protect the lives, health or property of others and it is deemed difficult to obtain client consent;
• when especially necessary to improve public health or promote the healthy growth of children and it is deemed difficult to obtain client consent;
• when necessary to cooperate with government agencies, local authorities or other entities entrusted with such authority in executing legally prescribed duties and obtaining client consent is deemed likely to hinder the execution of said duties; and
• when it is necessary to obtain personal information (including personal information requiring special consideration) from academic research institutions, etc.

(4) Proper Acquisition of Personal Information

The Company shall acquire Personal Information appropriately and shall not acquire said information through deceit or other unjust means.

(5) Safe Management of Personal Information

The Company shall conduct necessary and appropriate supervision of its employees to ensure safe management of Personal Information against risks such as loss, destruction, falsification or leakage of said information. In addition, in the case that the Company outsources all or part of handling of Personal Information, the Company will provide necessary and appropriate supervision to ensure safe management of Personal Information by the outsourcing party.

(6) Provision of Personal Information to Third Parties

The Company shall not provide Personal Information to third parties without obtaining client consent in advance, except when disclosure is permitted by the Personal Information Protection Act or any other laws and regulations. However, the foregoing provision shall not apply in the following cases:

• when the Company outsources all or part of the handling of Personal Information within the scope necessary to achieve the purposes of use; and
• when Personal Information is provided accompanied with business succession caused by a merger or other reason.

(7) Disclosure of Personal Information

If a client requests disclosure of Personal Information in accordance with the provisions of the Personal Information Protection Act, the Company shall disclose said information to the client without delay after first confirming that the said request is made by the client himself/herself. (In the case that the said information does not exist, the Company shall notify the client to that effect.) However, this shall not apply to cases in which the Company bears no obligation to disclose such information under the Personal Information Protection Act or any other laws and regulations.

(8) Corrections, etc. to Personal Information

If a client requests correction, addition, or deletion of his/her personal information on the grounds that it is untrue, in accordance with the provisions of the Personal Information Protection Act (hereinafter, “Corrections”), the Company shall conduct the required investigation without delay within the scope necessary to achieve the purposes of use after first confirming that the said request is made by the client himself/herself, and based on the results of the investigation, the Company will make Corrections to Personal Information, and shall notify the client of such Corrections (In the case that the Company decides not to make Corrections, the Company shall notify the client to that effect.) However, this shall not apply to cases in which the Company bears no obligation to make Corrections under the Personal Information Protection Act or any other laws and regulations.

(9) Suspension, etc. of Use of Personal Information

If a client requests to stop using or deleting his/her Personal Information (hereinafter, “Suspension of Use”) in accordance with the provisions of the Personal Information Protection Act on the grounds that the Personal Information is handled beyond the scope of the purposes of use publicly announced in advance or that the Personal Information was obtained through deceit or other unjust means, or if a request is made by the client to stop providing Personal Information to a third party without the clients consent (hereinafter, “Suspension of Provision”) in accordance with the provisions of the Personal Information Protection Act, the Company will take measures for Suspension of Use and Suspension of Provisions of Personal Information without delay after first confirming that said request is made by the client himself/herself, and shall notify the client of the said measures. However, this shall not apply to cases in which the Company bears no obligation to take measures as to Suspension of Use and Suspension of Provision of Personal Information under the Personal Information Protection Act or any other laws and regulations.

(1) Creation of Anonymously Processed Information

The Company will take the following measures when creating Anonymously Processed Information:

• Appropriate processing in accordance with the standards stipulated by laws and regulations;
• Take security control measures to prevent the leakage of deleted information and information regarding the method of processing in accordance with the standards stipulated by laws and regulations;
• Disclosure of the items of information contained in the Anonymously Processed Information created; and
• Not take any action to identify the individual whose Personal Information was the basis of the creation.

(2) Provision of Anonymously Processed Information

When providing Anonymously Processed Information to a third party, the Company will disclose the items of Personal Information contained in the Anonymously Processed Information to be provided and the method of provision, and clearly indicate to the third party that the information to be provided is Anonymously Processed Information.

(3) Security Control Measures for Anonymously Processed Information and Processing Methods, etc.

The Company will implement appropriate security control measures for the handling of Anonymously Processed Information and information on method of provision, etc., and will supervise employees who handle such information to ensure that security control measures are implemented in accordance with the Company's internal regulations.