Privacy Policy

IMPROVER Ltd. (hereinafter referred to as the “Company”) has stipulated the following privacy policy (hereinafter referred to as the “Policy”) concerning its handling of privacy information in connection with the Company’s provision of services (hereinafter referred to as the “Service(s)”) offered through this Website.

 

ARTICLE 1  PERSONAL INFORMATION

Out of privacy information, “personal information,” means personal information as defined in the Act on the Protection of Personal Information, referring to information pertaining to individuals who are currently alive that can be used to identify those individuals, including their names, dates of birth, addresses, phone numbers, contact information, and other related information.

Out of privacy information, “records and attributes” are separate from personal information as set forth above, referring to information on users’ previously used services, previously purchased items, previously viewed webpages and advertisements, search keywords previously used, dates and times of use, methods of use, the users’ IT environments, postal codes, genders, occupations, age information, IP addresses, cookie information, location information, identification information of users’ devices, etc.

 

ARTICLE 2  PERSONAL INFORMATION GATHERING METHOD

Each time an individual applies for user registration, the Company may ask the individual to provide personal information such as name, date of birth, address, phone number, email address, bank account number, credit card number, driver’s license number, etc. The Company may also gather the user’s transaction records, including their personal information, and also their payment information from the Company’s business partners (including information providers, advertisers, advertising media, etc.; hereinafter collectively referred to as “business partner(s)”), etc.

The Company may gather information on users in the form of records and attributes when users use the Services and view the webpages that are provided by the Company or business partners, including information on the services and software that are used by the users, items purchased, records of webpages and advertisements viewed, search keywords used, dates and times of use, methods of use, the users’ IT environments (including information on users’ mobile devices, such as their telecommunications status, device settings in effect during access, etc.), IP addresses, cookie information, location information, device identification information, etc.

 

ARTICLE 3  PURPOSES OF PERSONAL INFORMATION GATHERING AND USE

The Company’s gathering and use of personal information is intended for the following purposes.

(1) Indication to users of their own personal information so that they can each view their registered information, make corrections, and view their status and records of use, including their names, addresses, contact information, payment method, and other registered information, services previously used, items previously purchased, payment records, etc.

(2) Use of users’ email addresses to send notices and communications to the users, and use of the users’ names, addresses, and other contact information to ship their orders and communicate with them as needed.

(3) Use of users’ information such as their names, dates of birth, addresses, phone numbers, bank account numbers, credit card numbers, driver’s license numbers, record of delivery certification postal services, etc. to verify the users’ identities.

(4) Use of users’ orders, services used, and payment information, such as purchased item names and quantities, types of services used and periods and numbers of use, billed amounts, users’ names, addresses, bank account numbers, credit card numbers, and other payment information for billing the users.

(5) Indication of users’ information that is registered with the Company on users’ device screens to allow easy data entry by users, and transfer of the aforementioned information to other services, etc. as instructed by users (including services being offered by the business partners).

(6) Use of users’ status and records of use, names, addresses, and other identification information to identify users that previously failed to make payments on time, caused damage to third parties, or otherwise violated the terms of use of the Services and users that intend to use the Services for illegal or unjust purposes, so that the Company can deny use by such users.

(7) Use of information that is necessary for the Company to provide its services to users and information on users’ use of Services, contact information, etc., including the content of inquiries and billing information, etc., to properly respond to inquiries sent from users.

(8) Any other purposes ancillary to the aforementioned purposes.

 

ARTICLE 4  PROVISION OF PERSONAL INFORMATION TO THIRD PARTIES

1. The Company will not provide a user’s personal information to a third party without obtaining the user’s prior consent, except under the following circumstances and where it is permitted under the Act on the Protection of Personal Information or any other applicable law:

(1) if such provision is required or allowed by law;

(2) if such provision is necessary to protect the life, body, or property of an individual but it is difficult to obtain the consent of the individual;

(3) if such provision is especially necessary to improve public hygiene or promote the sound development of children but it is difficult to obtain the consent of the individual;

(4) if such provision is necessary for the Company to cooperate with a national government agency, municipality, or their contracted agent in their execution of a legally required administrative action but obtaining the consent of the individual could interfere with the execution of such administrative action; or

(5) if such provision is notified or published in advance with the following conditions expressly stated:

-that the purposes of use include such provision of information to a third party;

-the types of data that will be provided to third parties are specified;

- the means or methods of information provision to a third party are specified; and

-that such provision of personal information to a third party will cease if requested by the individual to which the personal information pertains.

2. Notwithstanding the provisions of the preceding paragraph, the following circumstances shall not qualify as provision of information to a third party:

(1) if the Company outsources to a third party the entire or partial task of personal information handling to the extent necessary for the Company to achieve the intended purposes of use;

(2) if the Company merges with another entity or transfers its business to another entity, and the personal information in the Company’s possession is provided to such entity as a result;

(3) if the Company jointly uses personal information with other specified parties, where the Company has provided prior notice to the individuals or made such information easily noticeable to the individuals concerning such joint use of personal information, along with what types of personal information are jointly used, the scope of the specified parties that are allowed to partake in the joint use, their purposes in using the personal information, and the individual or corporate name of each such party responsible for managing the personal information.

 

ARTICLE 5  DISCLOSURE OF PERSONAL INFORMATION

1. If the Company receives a request from a user to disclose the user’s personal information, the Company shall make the disclosure to the user without delay; provided, however, that if the disclosure could lead to any of the outcomes specified below, the Company reserves the right to deny the disclosure request entirely or partially, in which case the Company shall notify its decision to the user without delay. In this connection, the Company shall charge a fee of JPY 1,000 per request to each user that requests a disclosure of the user’s personal information:

(1) if the disclosure could negatively affect the life, body, property, rights, or other benefits of the user or a third party;

(2) if the disclosure could significantly disrupt the Company’s normal execution of its operations; or

(3) if the disclosure might constitute a violation of any law.

2. Notwithstanding the provisions of the preceding paragraph, the Company is not obligated to disclose any user information pertaining to records, attributes, etc. that are not personal information, in principle.

 

ARTICLE 6  CORRECTION AND DELETION OF PERSONAL INFORMATION

1. If a user finds any error in his/her personal information that is in the Company’s possession, the user may request the Company to correct or delete the personal information by following the procedure as specified by the Company.
2. If the Company receives a request from a user as set forth in the preceding paragraph and deems it necessary to respond, the Company shall correct or delete the personal information in question and notify the user without delay.

 

ARTICLE 7  SUSPENSION OF USE OF PERSONAL INFORMATION, ETC.

If the Company receives a request from a user to suspend the Company’s use of the user’s personal information or delete the user’s personal information (hereinafter collectively referred to as “suspension of use, etc.”) on the grounds that the personal information is being handled beyond the intended purposes of use or that the personal information has been obtained through unjust means, the Company shall conduct a necessary investigation into such claim without delay and, based on the result of such investigation, conduct suspension of use, etc. of the personal information, and notify the user; provided, however, that if it is difficult to implement such suspension of use, etc. of personal information due to a significantly high cost or for another reason, while there is an alternative action that the Company can take to properly protect the rights and benefits of such user, the Company shall execute such alternative action instead.

 

ARTICLE 8  AMENDMENT OF PRIVACY POLICY

The Company reserves the right to amend this Policy at any time without notifying users.

When this Policy is amended, the amended Policy shall come into effect the moment it is published on this Website, unless otherwise specified by the Company.

 

ARTICLE 9  CONTACT POINT FOR INQUIRIES

If you have an inquiry concerning this Policy, please send it to the Company at the following contact point.

Address: 1^st floor, Watanabe Building, 2-52-11 Gohongi, Meguro-ku, Tokyo

Company name: IMPROVER Ltd.

Email address: contact@keylimetokyo.com