PRIVACY POLICY

CLINK INC. (hereinafter, the “Company”; representative director: Haruki Fujikura) sets forth a privacy policy as follows (hereinafter, the “Policy”) with regard to the handling of user information that includes personal information (referring to the personal information set forth in the Act on the Protection of Personal Information) in the “CLINKme” services (hereinafter, the “Services”) provided by the Company.
The Company shall comply with the provisions of relevant laws, ordinances and regulations and the various rules and the like enacted by the Company with regard to personal information, shall make these well known to all persons engaged in work at the Company, and shall appropriately handle the personal information.

Article 1 (With Regard to Personal Information)

Personal information shall mean information related to a living person that corresponds to any of the following:

  1. The corresponding information containing a name, date of birth, or other descriptions and the like (meaning any and all matters (excluding an individual identification code) stated, recorded or otherwise expressed using voice, movement or other methods in a document, drawing or electromagnetic record (meaning a record kept in an electromagnetic form (meaning an electronic, magnetic or other forms that cannot be recognized through the human senses)) whereby a specific individual can be identified (including those which can be readily collated with other information and thereby identify a specific individual); and,

  2. Information containing an individual identification code.

Article 2 (With Regard to How Personal Information is Collected)

The Company, in the course of registering members and use of services, shall collect minimal personal information as follows for the provision of services via its homepage and the like:

  1. Collection through user input: homepage member registrations, mobile apps, document forms, fax, telephone, online inquiries, e-mail and event applications; and,

  2. Collection through user consent: use of official API platforms supported by third parties (Google, Twitter, etc.), provision by cooperating businesses, partner companies and agents, and collection through generated information collection tools.

Article 3 (With Regard to Collection of Personal Information and Purposes of Use)

The purposes for the Company’s collection and use of personal information are as follows:

  1. For the provision and operation of the Company’s services;

  2. For responses to inquiries from users (including confirmation of identity);

  3. For sending email regarding new functions in the services currently being used by users, updated information, campaigns and the like, and information on other services provided by the Company;

  4. For providing notice on maintenance and other important notices and for otherwise making contact as needed;

  5. For identifying users who have breached the terms of use and users who are attempting to use the services for improper or inappropriate purposes, and refusing use;

  6. For users to view, modify or delete their registered information, and to view their use status;

  7. For billing users use fees for paid services; and,

  8. For other individually prescribed purposes in the Company’s various services.

Article 4 (With Regard to Modification of Purposes of Use)

The Company shall modify the purposes of use for personal information only in those instances where the purpose of use is reasonably found to relevant to the purpose prior to modification.
In the event the purposes of use are modified, users shall be provided with notice of the modified purposes by the method prescribed by the Company, or the modified purposes shall be released to the public on the website.

Article 5 (With Regard to the Provision of Personal Information)

In the following prescribed instances, the Company shall be entitled to provide personal information to third parties:

  1. When consented to by the person subject to the information;

  2. When disclosure of personal information is requested by the courts, public prosecutors, police, tax office, bar associations or other organizations holding commensurate authority thereto;

  3. When disclosure is provided to financial institutions, credit card companies, collection agencies or other operators engaged in settlements or the agency thereof in order to settle the fees or other money payable to the users of the Company’s services;

  4. When all or a portion of the business conducted by the Company is delegated to a third party;

  5. When disclosure is provided to an entity that owes the Company a duty of confidentiality;

  6. When required in the exercising of the Company’s rights;

  7. When disclosure is provided to the entity succeeding to business upon a succession of business by merger, business transfer or other event;

  8. When allowed under the Personal Information Protection Act or other laws and regulations; and,

  9. When otherwise individually prescribed under the respective services.

Article 6 (With Regard to Disclosure of Personal Information)

When receiving a request for the disclosure of personal information from the person subject to that information, the Company shall disclose the information without delay; provided, however, that in cases corresponding to any of the following, disclosure shall not be provided on all or a portion of the information, and if a decision is made not to provide disclosure notice thereof shall be provided without delay. Furthermore, a fee of JPY 1,000 per instance shall be charged when disclosing personal information:

  1. When there is a risk of harm to the life, body, assets or other rights and interests of the person subject to the information or a third party;

  2. When there is a risk of a significant obstruction to the appropriate implementation of business by the Company; or,

  3. When in violation of other laws and regulations.

Notwithstanding the provisions of the preceding paragraph, in principle, disclosure shall not be provided of information, such as history information and characteristics information, other than personal information.

Article 7 (With Regard to Correction of Personal Information and Suspension of Use, etc.)

In the following prescribed cases, the Company, upon confirmation that a user request is from the person subject to information, shall conduct the necessary investigation without delay, shall correct the content of the personal information or suspend the use thereof, and shall provide the user with notice thereof. Furthermore, when a decision is made not to engage in a correction or suspension of use, the user shall be provided with notice thereof:

  1. When a user requests the correction of the content of personal information pursuant to the provisions of the Personal Information Protection Act for the reason that the information is not true; and,

  2. When a request for the suspension of use is made pursuant to the provisions of the Personal Information Protection Act for the reason that information is being handled outside the scope of the purposes of use publicly released in advance, or for the reason that it was collected by deception or other wrongful means.

In addition, in the event the Company receives a request from a user for the deletion of the user’s personal information and the Company has determined that it must comply with this request, upon confirming that the request is from the user who is subject to the information, the Company shall delete the personal information and provide the user with notice thereof;
provided, however, that the foregoing provision shall not apply in the event the Company is not obligated to make corrections and the like or suspend use and the like under the Personal Information Protection Act or other laws and regulations.

Article 8 (With Regard to Safety Management Measures)

The following safety management measures shall be adopted in order to prevent and rectify unauthorized access to personal information, and the leak, loss or impairment of personal information:

  1. Establishment of a fundamental policy on the implementation of the various responses prescribed by laws, regulations and guidelines for the appropriate handling of personal information and personal data;

  2. Establishment of a responsible person, clarification of the scope of employees handling personal data and the scope of the handled personal data, establishment of a system for reporting to and communicating with the responsible person when discerning facts or indications of violations of laws and rules, routine inspections of the handling status and other organizational safety management measures;

  3. Management of employee entry and exit, restrictions on equipment that is carried in, restriction and management of carrying out to prevent the theft, loss and the like of the equipment, electronic media and documents containing personal data, and other physical safety management measures; and,

  4. Introduction of a system to protect against external unauthorized access or unauthorized software attacks on the system handling personal data.

Article 9 (With Regard to Modification of Privacy Policy)

The Company shall review the operating status related to the handling of user information as needed, shall strive for continuous improvement, and may modify this Privacy Policy when needed.
When modifications are made, public notice of the modifications shall be provided on the website or notice of the modifications shall be provided users.
However, except in those instances otherwise prescribed by the Company, the modified Privacy Policy shall take effect when posted on the website.

Article 10 (With Regard to Inquiries Window)

Please direct requests for disclosure and the like, opinions, questions, complaints and other inquiries related to the handling of personal information to the following window.

Address:
Sumitomo Fudosan Aobadai Tower 17F, 3-6-28 Aobadai, Meguro-ku, Tokyo 153-0042
Company Name:
CLINK Inc.
Department in Charge:
Attn: Person in Charge of Personal Information
Email Address:
info@clinkme.jp