PRIVACY POLICY

In recognition of the importance of the protection of personal information, Akatsuki Inc. (having its registered office address at 8F oak meguro, 2-13-30 Kamiosaki, Shinagawa-ku, Tokyo, Japan 141-0021, and hereinafter referred to as “we/us”CEO:Tetsuro Koda.) handles information from customers (hereinafter referred to as “User(s)”) appropriately in the following manner in order to ensure the protection thereof.

Article 1. Application

１ This Privacy Policy (hereinafter, this “Policy”) is to be applied to the usage of applications, websites and services (hereinafter, “Services”) distributed by us.
２ In case we establish a privacy policy separately in our Services, this Policy is to be applied along with the privacy policy set forth separately in such Services.
３ “Personal information” in this Policy refers to the information relating to a living individual that contains first and last names, date of birth or other descriptions, etc. whereby a specific individual can be identified (including information which can be easily collated with other information and thereby identify a specific individual). (Article 2, Paragraph 1 of the Act on the Protection of Personal Information).

Article 2. Acquisition of Information

１ We will acquire information including personal information (hereinafter, collectively “User Information”) at our Services in the following manner.
1. （１） Information provided by Users
  
  (a) Basic information: phone number, e-mail address, etc.
  This information is to be registered by a User in order to create an account, identify the User and prevent abuse.
  
  (b) Other registration information: first and last names, address, age or date of birth, gender, user name or nickname and other profile information
  This information may be registered by a User in order to provide our Services including creation and disclosure of the profile page or features to communicate with other Users, etc.
  
  （２） Information we collect when a User uses our Services
  
  (a) Device information
  
  We may collect peculiar information of the User’s device (information for individual identification, etc. such as device identifiers, etc.) in order to maintain and improve our Services or prevent abuse.
  
  (b) Log information and action history records
  
  We may collect information such as IP address, date and time of the request from a User and operation history within the application that are generated and preserved automatically when a User uses our Services, in order to maintain and improve our Services or prevent abuse.
  
  (c) Location Information
  
  We may collect location information transmitted by User’s smartphone device, tablet device, or other information device, etc. in order to provide Services using information such as User’s current location, to the extent necessary to provide such Services. A User may, by changing the settings of their information devices, suspend transmitting location information; provided, however, some of our Services may become unavailable for such a User.
  
  (d) Cookies and Anonymous ID
  
  We may use “Cookies” or other similar technologies available at our Services. Cookies are industry-wide standard technology tool for web servers to identify the User’s computer. A User may, by changing the settings of their information devices, disable Cookies; provided, however, some or all of our Services may become unavailable for such a User.
  
  We may acquire, with User’s consent, ID that a User uses with tie-up services and other information which a User accepts to disclose to collaboration partners by privacy setting of such tie-up services.
2. We will acquire User Information only through appropriate means, and not by deception or other wrongful means. We will also notify or publicly announce in advance the purposes of use when we acquire User Information by means other than acquisition through usage of our Services.

Article 3. Purpose of Use

1. We will appropriately handle User Information we acquire through use of our Services for the purposes which are categorized as follows. We will not use any of the User Information beyond the stated purpose of use. However, this shall not apply in cases that fall under sub-paragraphs of Article 16, Paragraph 3 of the Act on the Protection of Personal Information.

Purpose of Use	Purpose of Use in Detail	Information We Use
Provision, Maintenance, Improvement, etc. of our Services	– to identify Users and prevent abuse of our Services; – to smoothly provide, maintain and improve our Services including notifying other Users, transmission and other communications features; – to have a questionnaire, etc. for Users relating to our Services; and – other purposes incidental or related to the foregoing.	– Basic information: phone number, e-mail address – Other registration information: first and last names, address, date of birth, gender, user name or nickname and other profile information – Other relevant information
Notification, Correspondence, etc. to Users	– to provide information and respond to inquiries, etc. relating to our Services; – to notify or provide new services relating to our Services; – to notify changes to the terms of Services or this Policy, suspension, discontinuance, cancellation of Services and other important notices relating to our Services, etc.; and – other purposes incidental or related to the foregoing.	– Basic information: phone number, e-mail address – Other registration information: first and last names, address, date of birth, gender and other profile information – Device information – Other relevant information
Provision of Information to third parties, etc.	Third parties provided with information in the right column will use such information for the following purposes: – to provide tie-up services; – to display advertisement information, etc. targeted to cater to the User’s needs or interests; – to analyze advertising effectiveness; – to do market analysis and marketing; and – other purposes incidental or related to the foregoing.	– Device information – Cookies and Anonymous ID – Log information and action history records – Location information – Other relevant information
Creation of Statistical Data and Provision of Such Data to third parties, etc.	We will use information in the right column for the following purpose: ・to create an anonymously processed statistical data (“Statistical Data”) by analyzing information in the right column from perspectives of gender, age, interests, etc. Third parties who receive from us Statistical Data of information in the right column will use such information for the following purposes: – to analyze advertising effectiveness; – to do market analysis and marketing; and – other purposes incidental or related to the foregoing.	– Device information – Cookies and Anonymous ID – Log information and action history records – Location information – Other relevant information

２ We may change the purposes of use described in the preceding paragraph to the extent reasonably considered that the purposes of use after the change is duly related to that before the change, and in such a case, we will notify or publicly announce to Users by means as set forth separately by us. However, this shall not apply in cases that fall under Article 18, Paragraph 4 of the Act on the Protection of Personal Information.

Article 4. Provision of Information to Third Parties

1. Among User Information, we will not provide personal information to third parties except under the following circumstances:
1. （１） where we obtain User’s consent;
2. （２） where we provide information specified in the preceding Article that we will acquire with the purpose of “Provision of Information to Third Parties” (In such case, we shall provide information in writing or electronic form, etc.);
3. （３） where a User will, on the use of our Services, cause disadvantage to others, or take or intend to take any action against the public order and morals or any other action against the terms of Services, and we shall implement necessary measures against such action;
4. （４） where it is necessary in order to protect a person’s life, body or assets and obtaining the User’s consent is difficult;
5. （５） where it is specifically necessary for the improvement of public health or the sound growth of children, and obtaining the User’s consent is difficult;
6. （６） where it is necessary to cooperate with a governmental organization or a local government, or a person designated by the same in the performance of administrative work prescribed by laws and regulations, and obtaining the User’s consent thereto will likely hinder the performance of such administrative work;
7. （７） where we transfer business including User’s personal information due to merger, corporate split, transfer of business or other events;
8. （８） where we outsource personal information handling in whole or in part to the extent necessary to achieve purposes described in the preceding Article; and
9. （９） where it is permitted by the Act on the Protection of Personal Information or other laws and regulations.
２ Users may request us to suspend provision of information to third parties under sub-paragraph 2 of the preceding paragraph. The procedure in such a case shall be applied mutatis mutandis to Article 10, Paragraph 2.

Article 5. Outsourcing of Personal Information Handling

１ We may outsource handling of personal information acquired from Users in whole or in part to third parties, such as outsourcing to operators, the management of information including personal information. In such a case, we execute a non-disclosure agreement, etc. in advance in conformity with this Policy with such outsourcing company as well as exercise necessary and proper supervision to ensure effective security control of the information provided to such an outsourcing company.

２ We may process and use users’ personal information outside of Japan. Laws and regulations concerning the protection of personal information outside Japan may differ from those in Japan. We will take necessary and appropriate security control measures to ensure that your personal information is protected in accordance with the laws and regulations applicable to us. If you would like to confirm the details of these measures, please contact us at the contact information listed at the end of this document.

Article 6. Joint Use

We may jointly use Users’ personal information with our parent company, subsidiaries and affiliates to achieve the purposes of use set forth in this policy or as individually notified by us.

The items of personal information to be jointly used are the same as those described in “Article 2” above.

The purpose of use of personal information to be jointly used are the same as those described in”Article 3″ above. (However, “our company” shall be defined as “our parent company, subsidiaries, and affiliates”).

In the case of joint use, we are responsible for the management of personal information. We will responsibly manage your personal information in accordance with this policy.

We may jointly use Users’ personal information with collaboration partners to the extent necessary to provide tie-up services. In such a case, we will publicly announce in advance name of the collaboration partner (including the name of the chief administrator), purposes of joint use and the type of information to jointly use.

Article 7. Information Gathering Modules

We may install information gathering modules within Services in order to measure information such as usage of Services and advertising effectiveness, etc. In such a case, we will gather User Information excluding information that can identify an individual and provide the gathered User Information to information gathering module operators. The provided information shall be managed under the privacy policy and other regulations established by each information gathering module operator.

Article 8. Behavioral Targeted Advertising

１ We collect, accumulate or use following information through information gathering modules described in the preceding Article, while providing our Services or tie-up services in order for us or third parties such as advertisement delivery agencies, etc. to implement targeted advertising (a method of advertisement delivery targeted to the User’s needs or interests):
1. （１） Action history records (Information such as usage history of Services that will be useful by accumulating it for analysis of User’s needs or interests and that shall not lead to identification of a specific individual);
2. （２） Device information; and
3. （３） Location information.
２ We provide information we collect under the preceding paragraph to agencies which deliver behavioral targeted advertising (hereinafter, “Advertisement Delivery Agencies”) with the view to deliver beneficial information for a User by distributing optimal advertisement customized to the User’s needs or interests.
３ We will retain action history records, etc. that we collect from Users for the legitimate term needed for reasonable business purposes.
４ We will endeavor to take following measures for the prevention of leakage, loss or damage, and for other security control of such information, when we provide action history records, etc. to Advertisement Delivery Agencies.
1. （１） We will not disclose any structure such as encryption algorithm, etc. of action history records, etc.;
2. （２） We will provide action history records, etc. to Advertisement Delivery Agencies subject to the use only to the extent of the purposes of use described in the paragraph 2 of this Article; and
3. （３） In case Advertisement Delivery Agencies provide action history records, etc. to other third parties, we will impose the obligation on Advertisement Delivery Agencies to provide information to such third parties on the same condition as in the preceding sub-paragraph.

Article 9. Security Control Measures

１ We take necessary and proper measures for security control of User Information such as implementation of limited access to personal information files, recording of access logs or installation of security software against unauthorized external access, etc. for the prevention of leakage, loss or damage, and for other security control of User Information.　If you would like to know more about the details of the security control measures we take, or if you believe that there has been a leakage of user information, please contact us at the contact information below.
２ We designate a Representative Director as a manager responsible for User Information and implement appropriate management of User Information and strive for continuous improvement thereof.

Article 10. User’s Request for Disclosure, Revision, etc. of Information

１ Users may request for disclosure of personal information provided by Users to us in accordance with the following procedures:
1. （１） Users shall contact us for the request. In case the request is in writing, handling charge will be 1,000 yen for each request; and
2. （２） Upon the request under the preceding sub-paragraph, we will, as we identify the User, disclose personal information to the extent reasonable. However, this shall not apply in case that we are not obligated for disclosure under the Act on the Protection of Personal Information or other laws and regulations, or that the same requests are made unreasonably and repetitively.
２ In case Users’ personal information held by us is inaccurate, Users may request for its revision, addition, suspension or deletion in accordance with the following procedures:
1. （１） Users shall contact to us for the request; and
2. （２） Upon the request under the preceding sub-paragraph, we will investigate personal information without delay and to the extent reasonable as we identify the User, and we will make revision, addition, suspension or deletion of personal information based on the result of such an investigation. However, this shall not apply in case that we are not obligated to do so under the Act on the Protection of Personal Information or other laws and regulations, that the same requests are made unreasonably and repetitively, or that requires disproportionate technical effort.

Article 11. Suspension of Personal Information, etc.

In case a User requests for suspension of use or deletion of User’s personal information in accordance with provisions of the Act on the Protection of Personal Information (hereinafter, “Suspension, etc.”) by reasons that such information is handled beyond the extent of purposes of use which are announced in advance; or that it is acquired by deception or other wrongful means and if we indicate that the request has reasonable grounds, we will suspend such personal information of the User without delay once we confirm it is the request from the User himself/herself and inform the User accordingly. However, this shall not apply in case that we are not obligated to suspend, etc. under the Act on the Protection of Personal Information or other laws and regulations.

Article 12. Changes to This Policy

１ We may modify this Policy from time to time, as necessary as we review operational situation of User Information handling and endeavor for continuous improvement.
２ When we make changes to the Policy, a notice will be posted on our Services website or by other reasonable means. In case the changes to the Policy require Users’ consent by laws and regulations, we will obtain Users’ consent by means we set forth separately.

Article 13. Inquiries

For any concerns, questions, requests under Article 10, complaints and other inquiries about User Information handling, please contact us via the link below.