1. User information to be collected and method of collection
For the purposes of this Policy, “User Information” shall mean information pertaining to the identification of users, action history on communication services, and other information generated or accumulated in connection with users or their terminals, which is collected by us in accordance with this Policy. The user information that we collect in the Service is as follows, depending on the method of collection.
(1) Information to be provided by the user Information to be provided by the user in order to use the Service or through the use of the Service is as follows.
– Information regarding the name of the business, the name of the person in charge, and other profile information
– Information related to e-mail addresses and telephone numbers
– Information regarding the means of payment, such as bank account information, cryptographic asset address information, and other information entered or transmitted by the User through input forms or other methods determined by the Company.
(2) Information provided by other services when the user permits linkage with such other services in the use of the Service.
When a user permits linkage with other services such as social networking services in using the Service, the following information will be collected from such external services based on what was agreed upon when the user permitted such linkage.
– ID used by the user for the external service
– Other information that the user has authorized to be disclosed to the linked service according to the privacy settings of the external service.
(3) Information we collect when you use the Service
We may collect information about how you access and use the Service. This includes the following information
– IP addresses
– Server access log information
– Cookies, ADIDs, IDFAs, and other identifiers
(4) Information we collect based on the user’s individual consent when the user uses the Service
When a user individually consents by the method specified in 3-1, we will collect the following information from the terminal being used.
– Location information
2. purpose of use
The specific purposes of use of user information related to the provision of this service are as follows
(1) To provide, maintain, protect, and improve the Service, such as for accepting registrations, identification, user authentication, recording user preferences, and calculating payment of usage fees.
(2) To measure user traffic and behavior
(3) To deliver and display advertisements and to measure their effectiveness
(4) To provide information on the Service and to respond to inquiries, etc.
(5) To respond to activities that violate the Company’s terms, policies, etc. (hereinafter referred to as the “Terms, etc.”) regarding the Service. To respond to violations of the Company’s terms, policies, etc. (the “Terms, etc.”) regarding the Service
(6) To notify you of changes to the Terms of Service, etc.
3. Method of notification, publication, or obtaining consent, and method of requesting discontinuation of use
3-1 The following user information shall be subject to user consent prior to its collection
– Location information
3-2 The user may request that the collection or use of all or part of the user information be stopped by making the prescribed settings for the Service, and in this case, SBM will promptly stop the use of such information in accordance with the provisions of SBM. In addition, since the collection or use of some items of user information is a prerequisite for the Service, the Company will stop the collection or use of such information only when the user withdraws from the Service in accordance with the Company’s prescribed method.
4. existence of external transmission, provision to third parties, or information collection modules
4-1 In the Service, the following partners may store cookies on the user’s terminal and use them to store and use user information.
(3) Opt-out (disable) URL of the above partner
4-2 The Service incorporates the following information collection modules. In accordance with this, we will provide user information to the information collection module providers (including those located outside of Japan) as follows.
(1) Name of the information collection module
(2) Information collection module provider
(3) Items of user information to be provided
(4) Means and methods of provision
(5) Purpose of use by the above providers
(6) Whether or not the information is provided to third parties by the above providers
5. provided by third parties
We will not provide personal information among user information to any third party without obtaining the prior consent of the user. However, this does not apply to the following cases where there is a need to provide personal information to a third party
(1) When we outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
(2) When personal information is provided as a result of the succession of business due to merger or other reasons
(3) When personal information is provided to a business partner or information collection module provider in accordance with the provisions of Section 4.
(4) Cases in which the provision of personal information is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining user consent is likely to impede the execution of such affairs.
(5) Other cases permitted under the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Law”) when permitted by other laws and regulations.
6. Security management measures
To prevent and correct unauthorized access to personal information and leakage, loss, or damage of personal information, we have established internal regulations and safety measures. In order to achieve the above objectives, we have taken the following measures
(1) Establishment of a basic policy for the appropriate handling of personal information and personal data, as well as for the implementation of measures prescribed by laws, regulations, and guidelines.
(2) Establishment of various regulations that stipulate each action to be taken, including acquisition, use, storage, provision, deletion, and disposal, as well as the responsible person and his/her role.
(3) Organizational security control measures, such as the establishment of a responsible person, clarification of the employees who handle personal data and the scope of personal data handled, establishment of a reporting and communication system to the responsible person in case any fact or indication of violation of laws and regulations is detected, and regular inspections of the handling status
(4) Personnel security control measures, such as stating matters concerning confidentiality of personal data in employment regulations and conducting periodic training on matters to keep in mind concerning the handling of personal data.
(5) Physical security control measures, such as access control for employees, restrictions on equipment brought into the company, and restrictions and controls on the removal of equipment, electronic media, and documents that handle personal data to prevent theft or loss of such data
(6) Technical security control measures, such as the introduction of systems to protect information systems that handle personal data from unauthorized external access or unauthorized software
7. joint use
We will jointly use users’ personal information as follows
(1) Items of personal information to be shared
(2) Scope of joint use
(3) Purpose of use by the joint users
(4) Name and address of the person responsible for the management of personal information (name of representative in the case of a corporation)
8. disclosure of personal information
When a user requests disclosure of personal information in accordance with the provisions of the Personal Information Protection Law, we will confirm that the request is made by the user himself/herself and disclose the information to the user without delay (if the relevant personal information does not exist, we will notify the user to that effect). (If such personal information does not exist, the Company will notify the user of such fact. However, this does not apply to cases in which we are not obligated to disclose the information under the Personal Information Protection Law or other laws and regulations. Please note that a fee (1,000 yen per case) will be charged for the disclosure of personal information.
9. Correction and Suspension of Use of Personal Information
9-1 If a user requests us to correct the content of personal information in accordance with the provisions of the Personal Information Protection Law because (1) the personal information is untrue, or (2) the personal information has been handled beyond the scope of the purpose of use publicly announced in advance or has been collected through deception or other wrongful means, we will conduct the necessary investigation without delay after confirming that the request is made by the user, and based on the results of the investigation, we will correct the personal information or suspend its use. If a user requests that the use of his/her personal information be discontinued in accordance with the provisions of the Personal Information Protection Law because (1) the information is handled in a manner that exceeds the scope of the purposes of use disclosed in advance or (2) the information was collected through deception or other wrongful means, we will conduct the necessary investigation without delay upon confirmation that the request was made by the user himself/herself, and based on the results, correct or discontinue the use of the information and notify the user thereof. If we decide not to correct or suspend the use of personal information, we will notify the User to that effect.
9-2 If a user requests deletion of the user’s personal information, and if we deem it necessary to comply with the request, we will delete the personal information after confirming that the request is made by the user himself/herself, and notify the user to that effect.
10. contact information
Please direct any comments, questions, complaints, or other inquiries regarding the handling of user information to the following contact point.
Address: 8-2-11 Kanda-Konyacho, Chiyoda-ku, Tokyo
Name of business: Shirushi Co.
We will change this policy as necessary. However, in the event that the Company modifies this Policy in a manner that requires the consent of the user under the law, the modified Policy shall apply only to those users who have agreed to the modification in the manner prescribed by the Company. In the event of any modification of this Policy, we will notify users or publicize the effective date and content of the modified Policy by displaying the modified Policy on our website or by any other appropriate means.
Established April 1, 2022