ZERO-ONE LLC (the “Company”) recognizes the importance of Personal Information protection and complies with the Act on the Protection of Personal Information as well as with the following privacy policy (the “Privacy Policy”). You may withdraw their consent to the Privacy Policy at any time; provided, however, that failure to consent to the Privacy Policy may impede the use of the Company’s services.
- Definition of Personal Information
- Purpose of Use of Personal Information
- Changes of Purposes of Use of Personal Information
- Restrictions on Use of Personal Information
- Proper Acquisition of Personal Information
- Security Control of Personal Information
- Provision to Third Parties
- Your Rights
- International Transfer of Your Information
- Retention Period of Acquired Information
- Use of Cookies and Other Technologies
- Contact
- Continuous Improvement
- representation of GDPR
Definition of Personal Information
In this Privacy Policy, Personal Information means “personal information” as defined in Article 2.1 of the Act on the Protection of Personal Information and any information related to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Purpose of Use of Personal Information
The Company will use Personal Information for the following purposes. If You are located in the EEA and the United Kingdom, the legal basis for the processing of the following first purpose is the performance of a contract as defined in Article 6(1)(b) of the GDPR, the legal basis for the processing of the following second through fourth purpose are the protection of legitimate interests as defined in Article 6(1)(f) of the GDPR (prevention of fraud and illegal activities, protection of the Company’s systems and Company’s users, the exercise of the Company’s legitimate rights and the rights of the Company’s users, the improvement and optimization of the Company’s services for the benefit of the users), and the legal basis for the processing of the following fifth through seventh purpose are Your consent as stipulated in Article 6.1(a) of the GDPR.
- For the provision of the Service provided by the Company (meaning the Service as defined in the Terms of Use separately defined by the Company);
- Notifications and responses to Your inquiries with respect to the Service;
- Notifications of amendment to the Terms of use or the Privacy Police of the Company (the “Terms”);
- Dealing with breach of the Terms with respect to the Service;
- To introduce the Company’s products, services;
- Improvement of the Company’s service and development of new service; or
- Other purposes related to the above purposes.
Changes of Purposes of Use of Personal Information
When the purpose of use of personal information has been changed, the Company shall notify You which can be identified by the personal information of, or publicly announce the purpose of use after the change.
Restrictions on Use of Personal Information
The Company shall not use personal information, without Your consent, beyond the scope necessary for the achievement of the purpose of use, unless permitted by the Act or other laws or regulations; provided, however, that this provision shall not apply if such use is:
- based on laws and regulations;
- necessary for the protection of the life, body or property of an individual and it is difficult to obtain Your consent;
- specially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain Your consent; or
- necessary for cooperating with a national government, a local government, or a person or entity entrusted thereby in executing the affairs prescribed by laws and regulations and acquisition of Your consent may impede the execution of the affairs concerned.
Proper Acquisition of Personal Information
5.1
The Company shall acquire personal information by proper means, and shall not acquire it by a deception or other wrongful means.
5.2
Except in the following cases, the Company shall not acquire special care-required personal information (defined in Paragraph 3 of Article 2 of the Act) without obtaining a prior Your consent.
- cases where such acquisition falls under any of Items of Article 4;
- cases where the special care-required personal information is being made available to the public by You, a government organization, a local government, a person set forth in Items of Paragraph 1 of Article 76 of the Act or other persons prescribed by the rules of the Personal Information Protection Commission;
- cases where the Company acquires special care-required personal information clearly recognized from Your appearance by seeing or taking pictures; or
- ases where the Company receives special care-required personal information from a third party and such provision of the information by the third party falls under any of Items of Article 7.1.
5.3
When the Company receives personal information from a third party, the Company shall confirm the following matters pursuant to the rules of the Personal Information Protection Commission, except where such provision of the personal information by the third party falls under any of Items of Article 4 or any of Items of Article 7.1.
- the name or appellation and address of the third party and, for a corporate body, the name of its representative (for a non-corporate body having appointed a representative or administrator, such representative or administrator)
- circumstances under which the personal information was acquired by the third party
Security Control of Personal Information
The Company shall sufficiently and appropriately supervise the Company’s employees to ensure the security control of personal information against the risk of loss, destruction, alteration or leakage. When the Company entrusts a third party with the handling of personal information in whole or in part, the Company shall sufficiently and appropriately supervise the third party to ensure the security control of personal information.
The Company will process Personal Information in a manner that ensures appropriate security. The Company will also take appropriate technical and organizational measures to ensure a certain level of security that adequately addresses risks.
In the event of a security breach resulting from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access of Personal Information, the Company has mechanisms and guidelines in place to promptly detect and evaluate the breach. The Company will provide the necessary notifications to supervisory authorities and inform You according to the results of the Company’s assessment.
Provision to Third Parties
7.1
The Company shall not provide personal information to a third party without prior Your consent, except where such provision falls under any of Items of Article 4; provided, however, that the following cases shall not be regarded as the provision to a third party:
- Cases where the Company provides personal information accompanied by entrustment to a third party with the handling of personal information within the scope necessary for the achievement of the purpose of use;
- Cases where personal information is provided as a result of the succession of business in a merger or otherwise; or
- Cases where personal information is used jointly with others in accordance with the provisions of the Act.
7.2
Notwithstanding Article 7.1, in cases where the Company provides personal information to a third party (excluding a party establishing a system conforming to the standards specified by the rules of the Personal Information Protection Commission based on Article 24 of the Act) in a foreign country (excluding countries specified by the rules of the Personal Information Protection Commission based on Article 24 of the Act), the Company shall obtain prior Your consent to the effect that You approves the provision to a third party in a foreign country, except where such provision falls under any of Items of Article 4.
7.3
When the Company has provided personal information to a third party, the Company shall make and maintain a record pursuant to Article 25 of the Act.
7.4
When the Company receives personal information from a third party, the Company shall conduct necessary confirmation pursuant to Article 26 of the Act, and make and maintain a record concerning such confirmation.
Your Rights
You have the following rights regarding the Personal Information collected and processed by the Company. To exercise these rights, you may contact the address listed in “Contact.” The above provisions shall not apply if the Company is not obliged under applicable laws and regulations. In addition, if it is extremely difficult to meet Your demands due to processing capacity or technical difficulties, the Company may not respond.
- General
- Right to demand access (Disclosure of the purposes of the processing, the categories of Personal Information concerned, the recipients or categories of recipient, and the envisaged period for which Personal Information will be stored)
- Right to demand corrections
- Right to demand erasure
- Right to demand restriction of processing
- Right to demand data portability and forwarding to enable the use of Personal Information for services provided parties other than the Company
- Right to object
- Right to revoke any consent you have given at any time
- Right to lodge a complaint with a supervisory authority
- For California residents
You, as a resident of the state of California who meets the requirements of CPRA, have the following rights under CPRA concerning Personal Information. In such case, the Company will respond to Your request for the following rights in accordance with the provisions of CPRA within 45 days.- The right to access information concerning the processing of Personal Information
You have the right to request disclosure of the following Personal Information that the Company collected in the preceding 12 months.
・The categories of Personal Information collected by the Company about You
・The categories of sources from which Personal Information was collected
・The purpose of collecting, or selling or sharing Personal Information
・The categories of third parties to whom Company discloses Personal Information - The right to correct inaccurate Your information or delete Personal Information
You have the right to request the correction of inaccurate Personal Information or deletion of the Personal Information the Company collected from You in accordance with the provisions of CPRA. - The right to opt out of the sale or sharing of Your information
You have the right to request the suspension of the sale or sharing of their Personal Information by the Company or request that the Company not use nor disclose sensitive data. - The right not to be penalized by exercising rights
The Company shall not penalize You nor treat You differently from others when exercising rights or having exercised the above rights.
- The right to access information concerning the processing of Personal Information
International Transfer of Your Information
The Company may provide Personal Information to third parties located in not only the countries or regions other than the countries stipulated by the rules of the Personal Information Protection Commission as a country that has a Personal Information protection system recognized as being at the same level as Japan (as of last update date of this privacy policy, stipulated countries and regions are the EEA and the UK) but also other countries and regions outside of Japan (hereinafter “other countries and regions outside of Japan” do not include the EEA or the UK).
Countries and regions outside of Japan include the countries and regions listed below:
United States of America, People’s Republic of China, Hong Kong, Republic of Korea, Republic of India, Republic of Singapore, Swiss Confederation, Commonwealth of Australia, and New Zealand
Please refer to the link below for the system regarding the protection of Personal Information in each country or region.
Retention Period of Acquired Information
In accordance with laws and regulations and the operational policy established by the Company, the Company will promptly delete the Acquired Information when it is no longer necessary to retain such information, such as when the purpose of use related to the Acquired Information is achieved.
Use of Cookies and Other Technologies
Cookies and similar technologies (limited to those essential for the operation of the Company’s website (the “Website”) and the Service, but including others if You agree) may be used in the Service. Such technologies help, including but not limited to, the Company to recognize the status of use of the Company’s service and contribute improvement of the service. When You intends to disable cookies, You may disable cookies by changing the web browser’s settings. Please note that when cookies are disabled, a part of the service may be unavailable.
The Company may use Cookies and similar technologies for the following purposes:
a. To identify the cause of an incident or problem that occurs on a server and solve it.
b. To improve the contents of the Websites, emails, and others
c. To customize the contents of the Websites, emails, and others for you
To customize the contents of the Service and the Website, the Company sets a cookie to retain login information and screen display information. The login cookie is retained for two days. The screen display option cookie is retained for one year. If “Keep me logged in” is selected, the login information is retained for 2 weeks. The login cookie is deleted when You log out. When You edit or publish a post, a further cookie is stored in Your browser. This cookie does not contain any Personal Information, but simply indicates the ID of the modified post. The cookie expires after one day.
The Website contains embedded content provided by third parties. Embedded content from other sites may use Your cookies, embed additional third-party tracking, and monitor interactions with embedded content.
The Website uses Google Adsense, a third-party advertising service.
Third-party ad-serving providers such as Google may use cookies (e.g., information about your visits to this and other websites) to display advertisements that are relevant to Your interests.
You may opt out of Your tailored advertising in their advertising preferences. You can disable the use of personalized ads. You can disable cookies from third-party distributors used for Personalized Advertising by visiting www.aboutads.info.
If you do not disable third-party advertising, you may still see advertisements on the site that are served by third-party distributors or ad networks.
Contact
With respect to requests for disclosure, exercising Your right based on law or this Privacy Policy, comments, questions, complaints and other inquiries regarding the handling of personal information, please contact the following.
Continuous Improvement
The Company shall endeavor to review timely the status of the operation regarding handling of personal information and to improve such operation continuously. The Company may amend this Privacy Policy as necessary
representation of GDPR
Personal Information Handling Business Operator
ZERO-ONE LLC
CEO: MATSUBA Kai
2-5-1 Azuma, Tsukuba City, Ibaraki Prefecture Tsukuba City Industrial Promotion Center 1F