CLINK Co., Ltd. (hereinafter referred to as the “Company”; Representative Director: Haruki Fujikura) handles personal information (Act on the Protection of Personal Information) in the “CLINKme” service (hereinafter referred to as the “Service”) provided by the Company. We have established a privacy policy (hereinafter referred to as “this policy”) as follows regarding the handling of user information including those specified in Regarding personal information, in accordance with the provisions of related laws and other norms and various regulations related to our formulation, we will make sure that all people engaged in business at our company are aware of and thoroughly handle it.

Article 1 (Personal Information)

Personal information is information about a living individual that falls under any of the following.

1. Name, date of birth, and other descriptions, etc. contained in the information (in documents, drawings, or electromagnetic records (electromagnetic methods [meaning electronic methods, magnetic methods, and other methods that cannot be recognized by human perception) A specific individual can be identified by any item (meaning a personal identification code) written or recorded in a document (meaning a record that is created), or expressed using voice, motion or other methods (meaning a personal identification code) (including those that can be easily collated with other information and thereby identify a specific individual)

2. Items containing a personal identification code

Article 2 (How to collect personal information)

The Company collects the following minimum personal information for providing services through the website, etc. during membership registration or service usage.

1. Collection through user input: homepage membership registration, mobile application, written form, fax, telephone, online inquiry, email, event application

2. Collection through user consent: Use of official APIs of platforms supported by third parties (Google, Twitter, etc.), provision from cooperating, affiliated, or agency companies, collection through generated information collection tools

Article 3 (Purpose of collecting and using personal information)

The purposes for which the Company collects and uses personal information are as follows.

1. To provide and operate our services

2. To respond to user inquiries (including identity verification)

3. To send e-mails about new features, updates, campaigns, etc. of the services currently being used by users and information about other services provided by the Company

4. To contact you as necessary for maintenance, important notices, etc.

5. To identify users who have violated the Terms of Service or users who attempt to use the service for illegal or unjust purposes, and to refuse their use.

6. To allow users to view, change, or delete their own registered information, and view usage status

7. To bill users for usage fees in paid services

8. For other purposes specified individually for each service of the Company

Article 4 (Changes in purpose of use)

We will change the purpose of use of personal information only if it is reasonably recognized that the purpose of use is relevant to the purpose before the change.
If the purpose of use is changed, the changed purpose shall be notified to the user by the method prescribed by the Company or announced on this website.

Article 5 (Provision of personal information)

The Company may provide personal information to third parties in the following cases.

1. With the consent of the individual

2. When disclosure of personal information is requested by a court, public prosecutor's office, police, tax office, bar association, or an organization with authority equivalent to these

3. When disclosing information to financial institutions, credit card companies, collection agencies, or other business operators who perform settlement or act as agents for the settlement of fees or other amounts payable to the Company or users of the Company's services

4. When outsourcing all or part of our business to a third party

5. When disclosing to a person who has a confidentiality obligation to our company

6. When necessary for the exercise of our rights

7. When disclosing to the successor of the business at the time of business succession due to merger, business transfer or other reasons

8. When permitted by the Personal Information Protection Law and other laws and regulations

9. Other occasions individually specified for each service of the Company

Article 6 (Disclosure of personal information)

When the person requests disclosure of personal information, we will disclose it to the person without delay. However, if the disclosure falls under any of the following, we may not disclose all or part of it, and if we decide not to disclose it, we will notify you without delay. A fee of 1,000 yen will be charged for each disclosure of personal information.

1. When there is a risk of harming the life, body, property or other rights and interests of the person or a third party

2. When there is a risk of significant hindrance to the proper implementation of our business

3. In the case of other violations of laws and ordinances.

Notwithstanding the provisions of the preceding paragraph, in principle, information other than personal information such as history information and characteristic information will not be disclosed.

Article 7 (Regarding Correction and Suspension of Use of Personal Information)

In the cases specified below, the Company will conduct the necessary investigation without delay after confirming that the request is from the user himself/herself, and based on the results, correct the content of personal information or suspend use. We will notify the user to that effect. In addition, when we decide not to correct or suspend use, we will notify the user to that effect.

1. When the user requests correction of the content based on the provisions of the Personal Information Protection Act on the grounds that the personal information is not true.

2. Discontinuation of use was requested based on the provisions of the Personal Information Protection Act on the grounds that the information is being handled beyond the scope of the purpose of use that has been announced in advance, or that the information has been collected by deception or other wrongful means. case

In addition, if the Company is requested by the user to erase the user's personal information, and if the Company determines that it is necessary to comply with the request, after confirming that the request is from the user himself/herself, We will delete personal information and notify the user to that effect.
However, the above provisions do not apply if the Company is not obligated to correct, etc. or suspend use, etc., under the Personal Information Protection Law or other laws and regulations.

Article 8 (Safety control measures)

In order to prevent and correct unauthorized access to personal information, leakage, loss or damage of personal information, we have taken the following security control measures.

1. Formulation of basic policies for implementing each response stipulated by laws and regulations and prescribed guidelines for proper handling of personal information and personal data

2. Appointment of a responsible person, clarification of employees who handle personal data and the scope of personal data to be handled, establishment of a report contact system to the responsible person in the event that the fact or sign of violation of laws and regulations is grasped, and handling status Organizational security control measures such as periodic inspections

3. Physical security control measures such as entry/exit control for employees, restrictions on devices brought in, restrictions on taking out devices to prevent theft or loss of devices, electronic media, and documents that handle personal data, management, etc.

4. Technical safety control measures such as introduction of systems to protect against unauthorized external access to information systems that handle personal data or unauthorized software

Article 9 (Changes to Privacy Policy)

The Company shall appropriately review the operation status regarding the handling of user information and strive for continuous improvement, and may change this Privacy Policy as necessary.
In case of change, we will publish it on this site or notify users.
However, unless otherwise specified by the Company, the changed privacy policy shall take effect from the time it is posted on this website.

Article 10 (Contact point for inquiries)

For requests for disclosure, etc., opinions, questions, complaints, and other inquiries regarding the handling of personal information, please contact the contact below.

Address:

17F Sumitomo Fudosan Aobadai Tower, 3-6-28 Aobadai, Meguro-ku, Tokyo 153-0042

CLINK Co., Ltd.

Department in charge:

Person in charge of personal information

E-mail address:

info@clinkme.jp