Communitio Corporation. (hereafter referred to as “we”) recognizes the importance of protecting the personal information of those who avail of our products/services and website (hereafter referred to as “user”) and will protect that information in accordance with the following privacy policy (hereafter referred to as “this privacy policy”) and the Act on the Protection of Personal Information (hereafter referred to as “APPI”) as well as related regulations and guidelines. For users from the EU, please refer to the EU Users Privacy Policy. This privacy policy uses the same definition of “personal information” as defined in the APPI Article 2, Item 1. More specifically, personal information is defined as information about a living individual which contains a name, date of birth, or other descriptions etc. whereby a specific individual can be identified (including those which can be readily collated with other information and thereby identify a specific individual) or information about a living individual which contains an individual identification code.
１．Purpose of Use
The personal information we collect can be used for the following purposes:
・Providing our services or improving our services
・Providing campaign information relating to our services
・Responding to user inquiries
・Producing statistical and/or analytic documents
Excluding cases when it is allowed by the APPI and related regulations, we will not utilize user personal information beyond the necessary scope to achieve the above purposes without obtaining in advance the user’s consent .
２．Appropriate Data Collection
We will not acquire user personal information by deceit or other improper means. All data collection will be conducted via fair and appropriate means.
３．Providing Information to Third Parties
We will not provide user personal information to third parties without obtaining in advance the user’s consent except in the following cases:
・cases based on laws and regulations
・cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain a principal's consent
・cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain a principal's consent
・cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a principal's consent would interfere with the performance of the said affairs
We will endeavor to implement necessary and appropriate measures, such as concluding contracts on the protection of personal information with third parties, when we provide or disclose user personal information to third parties in the case of obtaining in advance the user’s consent or in any of the cases above.
４．Security Measures
In order to protect personal information from unauthorized access, data loss, destruction, manipulation, and leak, we take appropriate security measures. Should personal information be entrusted with a subcontractor, we will carefully select a subcontractor with the necessary security safeguards in place as well as conduct appropriate supervision to ensure personal information is being properly protected.
５．Personal Information Access, Correction, and Deletion
When a user requests the disclosure, correction, deletion or utilization cease of a personal information, except in cases where disclosure, etc. is deemed unnecessary based on laws and regulations, we will address that requests without delay after confirming the identity of the user. However, the user may lose access to our services during or after processing such requests.
６．Inquiries
For inquiries regarding this privacy policy, requests regarding personal information, complaints, or questions regarding the use of the personal information, please contact us at the address listed below.
Communitio Corporation.
Personal Information Team
e-mail: privacy@communitio.net
７．Changes to this Privacy Policy
This privacy policy is subject to change at any time in accordance with social conditions as well as developments regarding the APPI and other laws, regulations, and guidelines. To see when this privacy policy was last updated, please refer to the bottom of this page. Any changes to this privacy policy will be published on this page, and any major changes will be clearly outlined and publicly announced.
＜EU Users Privacy Policy＞
The following EU Users Privacy Policy applies to all users (hereafter referred to as “EU user”) from the European Union, Iceland, Lichtenstein, and Norway (hereafter collectively referred to as “EU). The personal data procedures outlined in this privacy policy were set out in accordance with the EU General Data Protection Regulation (hereafter referred to as “GDPR”).
１．Data Processing Purposes and Legalities
We may process EU user personal data for the following purposes:
(1) It is necessary for the fulfillment of a contract in which the EU user is a concerned party and when the EU user deems it necessary for use in procedures before the contract’s conclusion.
a. Providing our services to the EU user
When availing of our services, the EU user registers the EU user’s name, address, telephone number, email address, date of birth, and other profile information as well as credit card numbers and billing information necessary for payment processing. Other necessary information may be processed when availing of other services.
b. Service maintenance and improvement
We may process EU user service usage data as necessary for our services maintenance and improvement.
c. Responding to EU user inquiries
We may process EU user personal data as necessary to respond to EU user inquiries.
(2) It is necessary for the fulfillment of legal obligations
We may process EU user personal data as necessary to fulfill legal obligations in accordance with EU regulations.
(3) It is necessary to protect EU user or related third party’s important interests
We may process EU user personal data as necessary to protect the life or other important interests of the user or related third party.
(4) it is necessary for the performances of duties performed in public interests or executions of public services
We may process EU user personal data as necessary for the performances of duties performed in public interests or executions of public services in accordance with EU regulations.
(5) It is necessary to protect the legitimate interests of the controller or other third party.
a. Providing our security services to third parties
We may process EU user personal data gathered by our security service applications including IP address, MAC ID, device and model names, operating system information, UUID, package names, hacking information, injection information, and other relevant security information as necessary in providing our security services.
b. Service research and analysis
We may process EU user service usage information as necessary to produce analytic or statistical data.
c. Service usage promotion
We may process EU user personal data as necessary to inform the EU user regarding our service campaigns.
２．EU User Rights
In accordance with GDPR, EU users have the right to access processed personal data, request a copy of all processed personal data, correct personal data, delete personal data, utilization cease of personal data, personal data portability, or object to the usage of personal data. We shall endeavor to fulfill any EU user requests without delay after confirming that the request has met all of the requirements as outlined in GDPR.
Furthermore, EU users have the right to lodge a complaint with the appropriate legal authorities, more specifically the member state of their residence, employment, or member state where the alleged infringement took place.
３．Consent
We may collect and use EU user personal data based on the consent of the EU user. EU user retains the right to withdraw the consent at any time; however, the EU user that has withdrawn the consent may lose access to some or all our services. For an EU user under sixteen years of age, the EU user’s legal guardians must give their explicit consent or grant permission to gather and use the EU user’s personal data.
４．Data Storage Duration
EU user personal data will be deleted once it is no longer necessary to maintain except in cases when there is legal obligation to do so.
５．Transferring Personal Data outside the EU
In fulfilling the purposes listed above, we may transfer EU user personal data to a country outside the EU – including Japan - as GDPR allows or with the EU user’s explicit consent. When transferring personal data, we will ensure that all necessary and appropriate security procedures, such as concluding contracts regarding personal data protection with the transfer destination, are in place at the transfer destination.
６．Inquiries
For inquiries regarding this privacy policy, requests regarding data processing, complaints, or questions regarding how data is processed, please contact us at the address listed below.
Communitio Corporation.
Personal Information Team
e-mail: gdpr@communitio.net
７．Changes to this Privacy Policy
This privacy policy is subject to change at any time in accordance with social conditions as well as developments regarding GDPR and other laws, regulations, and guidelines governing personal data. To see when this privacy policy was last updated, please refer to the bottom of this page. Any changes to this privacy policy will be published on this page, and any major changes will be clearly outlined and publicly announced.
Established on May 15, 2019
Revised on November 6, 2019