Privacypolicy

Suguny (the “Administrator”) sets forth this Privacy Policy (this “Policy”) with regard to the treatment of user information, including but not limited to personal information, in the course of the performance of Service provided by the Administrator (the “Service”), as follows;

目次

1 User Information to be Collected and Method of Collection

For purposes of this Policy, “User Information” means information identifying users, history of actions in the Service and other information created or accumulated in relation to users or their devices, that are collected by the Administrator pursuant to this Policy.

The User Information that the Administrator may collect in the course of the Service is as follows, depending on the method of collection.

(1) Information provided by the user
The information to be provided by the user for or through the use of the Service is as follows:
  • e-mail address.
  • information transmitted by the user through entrance forms or other methods specified by the Administrator;
(2) Information provided from another service, based on the user’s permission for the Service to associate with such another service in relation to the user’s use of the Service
If the user permits the Service to associate with other services such as social networking services (“Outside Service”) in relation to the user’s use of the Service, the Administrator may collect the following information from the Outside Services in accordance with the conditions agreed by the user at the time of such permission:
  • ID used by the user for the Outside Service; and
  • other information for which the user, in the privacy settings in the Outside Service, permits the disclosure to its associated services;
(3) Information automatically collected by the Administrator in the course of the user’s use of the Service
The Administrator may collect information regarding access to or use of the Service, which includes the following.
  • referer
  • IP address
  • information regarding server access logs
  • cookies, ADID, IDFA and other identifiers
(4) Information collected by the Administrator with the consent respectively given by the user in the course of the user’s use of the Service
If the user respectively gives the consent in the manner set forth in Section 3.1, the Administrator may collect the following information from the device used by the user.
  • location information

2 Purpose of Use

Specific purposes of use of the User Information for the provision of the Service are as follows:
(1) provision, maintenance, protection and improvement of the Service, including but not limited to acceptance of registration for the Service, identification, record of user settings and payment of use fees that are related to the Service;
(2) measurement of traffic and actions of the user
(3) distribution, display and measuring effect of advertisements
(4) guidance and response to inquiries relating to the Service;
(5) addressing a violation of rules, regulations or policies of the Administrator relating to the Service (the “Rules”); and
(6) notice of modification to the Rules or related matters.

3 Method of Notice, Publication and Consent; Method of Requiring Discontinuance of Use

3.1 The user’s consent must be obtained before collecting the following User Information;
(1) location information
3.2 The user may require the Administrator to discontinue the collection or use of the all or a part of the User Information by choosing the applicable setting as prescribed in the Service, and promptly upon such request the Administrator shall discontinue such collection or use in accordance with the rules prescribed by the Administrator. Certain User Information is necessary to be collected or used for providing the Service, and the Administrator shall discontinue such collection or use of the User Information only if the user withdraws from the Service pursuant to the procedures as determined by the Administrator.

4 Outside Transmissions; Provision to Third Parties; Information Collection Modules

4.1 The following affiliated parties may save cookies in the user’s devices and  thereby accumulate and use the User Information.
(1) Affiliated Party
(2) URL of Privacy Policy of Affiliated Party above
(3) URL for Opt-out (invalidation) of Affiliated Party above
4.2 The following information collection modules are incorporated into the Service. Thus, the Administrator provides the User Information to the providers (including but not limited to those outside Japan) of such information collection modules in accordance with the following descriptions:
(1) Name of Information Collection Module
(2) Provider of Information Collection Module
(3) Items of User Information to be Provided
(4) Means and Methods of Provision
(5) Purposes of Use by above Provider
(6) Whether or not above Provider Intends to Provide Information to Third Parties
(7) URL of above Provider’s Privacy Policy

5 Provision of Personal Information to Third Parties

The Administrator shall not provide to any third party (including the same outside Japan) personal information contained in the User Information without the prior consent of the user, except where such provision is required due to any of the following circumstances:
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(1) The Administrator authorizes such third party to handle the personal information in whole or in part to the extent necessary to accomplish the purpose of the use;
(2) The personal information is provided through a business transfer by way of merger or other similar transactions;
(3) The personal information is provided to an affiliated party or a provider of an information collection module pursuant to Section 4 hereof;
(4) The Administrator is required to cooperate with state or local governmental organizations or their agents to perform their duties or obligations pursuant to applicable laws and regulations, and such performance is likely to be precluded if the consent of the user must be obtained; and
(5) In addition to the foregoing, the Administrator is entitled to provide information pursuant to the Act on the Protection of Personal Information (the “Act”) or other applicable laws and regulations.

6 Joint Use

The Administrator may jointly use personal information of the users as follows:
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(1) Items of Personal Information to be Jointly Used
(2) Party to Jointly Use Personal Information
(3) Purposes of Joint Use
(4) Name of Party Responsible for Management of User Information

7 Disclosure of Personal Information

Upon request from the user to disclose its personal information under the Act, the Administrator shall, without delay, disclose to the user such information (or, in the event of non-existence of such personal information, notify the user to that effect) after confirming that the request is made by the user itself, to the extent required to do so under the Act and other applicable laws and regulations.

Please note that you must pay a commission (1,000 yen per disclosure) for disclosure of personal information.

8 Correction and Suspension of Use of Personal Information

8.1 If the Administrator is required pursuant to the provisions of the Act by the user to (1) correct the content of personal information due to the reason that such information is false, or (2) suspend use of personal information due to the reason that such information is being handled beyond the scope of the purpose of the use previously made public, or has been collected in a fraudulent or otherwise illicit manner, then the Administrator shall, without delay after confirming that the request is made by the user itself, conduct an appropriate investigation and based upon the results thereof, correct the content or suspend the use of such personal information, and notify the party to that effect. In cases where the Administrator decides not to make such correction or suspension of the use, the Administrator shall notify the user to that effect.

8.2 In the event that the Administrator is required by the user to delete its personal information and has determined that it is necessary to accept such request, the Administrator shall, after confirming that the request is made by the user itself, delete such personal information and notify the party to that effect.

8.3 Should the Administrator not be obligated to correct, or suspend use of, information under the Act and other applicable laws and regulations, Sections 8.1 and 8.2 shall not apply.

9 Inquiries

Any suggestions, questions, complaints, or other inquiries on the handling of the User Information must be submitted to:

TAKAFUMI KAWAI
#101 4-10-20
Minamiazabu,Minato-ku, Tokyo-to 106-0047 Japan
+81-50-5534-9084

10 Procedure to Amend this Privacy Policy

The Administrator may amend this Privacy Policy as necessary; provided, however, that in the event of an amendment to this Privacy Policy that legally requires the consent thereto of the users, this Privacy Policy after the amendment shall be applied only to the users that have given the consent in the manner specified by the Administrator. In the event of any amendment to this Privacy Policy, the Administrator shall inform the effective time and content of the amended Privacy Policy by posting on the website of the Administrator or other appropriate way, or notify the user of the same.

‍This Policy shall be executed in the Japanese language. Japanese shall be the governing language and any translation of this Policy into any other language is for convenience of reference only and shall not bind the parties hereto.
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[Prescribed on 01/15/20]