PRIVACY POLICY

1. Handling of personal information and browser history and other information

D2C R Inc. (hereinafter referred to as “D2C R”) fully recognizes the need for and the importance of protection in the handling of personal information, browser history, and other information as a company involved in the communications sector, and it is committed to handling such information properly. D2C R requires all of its employees to understand and comply with the protection of personal information, browser history and other information, establishing internal systems to rigorously manage such information.

Furthermore, to ensure objectivity in its policies, D2C R undergoes third party audits by Japan Institute for Promotion of Digital Economy and Community (JIPDEC), an organization authorized by Japan’s Ministry of Economy, Trade and Industry (METI), as an entity which is licensed to use the PrivacyMark and ISMS Certification. D2C R has received approval to use the PrivacyMark in accordance with the “compliance program on protection of personal information (JISQ15001)” and to use ISMS certification in compliance with the Information Security Management Program (ISO27001).

2. Policies on protection of personal information

  • To designate a chief personal information protection officer and a personal information protection system to manage personal information properly.
  • To be clear about the purpose of use of personal information in advance when collecting such information, and to limit the use and sharing of personal information to the extent necessary to achieving the purpose of use.
  • To employ the best appropriate management systems in order to protect personal information, to prevent and remedy unauthorized access, loss, destruction, alteration, disclosure, etc., of such information.
  • When providing personal information, to limit its provision to that which is properly agreed to by the individual, and to share information under strict supervision.
  • To provide strict supervision when it contracts a D2C R subcontractor to process personal information.
  • To comply with legislation, government policies, other rules and internal information management regulations on personal information, and to continuously maintain and update its personal information management system to take account of changes in circumstances and the environment with respect to the handling of personal information.
  • To respond promptly to requests for disclosure or revision of personal information and any other complaints or inquiries through the organization stated below.

3. Business summary

The summary of D2C R’s business is as follows (as of April 1, 2013)

(1) Media development for mobile
(2) Mobile advertising

4. Personal information

(1)Collection, use, and provision of personal information

  1. D2C R specifies purpose of use in advance and collects personal information with the consent of the individual. Furthermore, personal information refers to information on a living individual, which is capable of identifying the specific individual, and includes information that can be easily cross-referenced with other information to allow identification of a specific individual as provided for in Japan’s Act on the Protection of Personal Information (Act No. 57 of May 30, 2003).
  2. D2C R does not collect sensitive personal information without obtaining the prior consent of the individual.
  3. D2C R may commission external entities to perform some or all of its work within the limits required to achieve the purpose of use. In this event, D2C R requires the external entity to adopt equivalent safety management practices to ensure the personal information of an individual is not lost, damaged, or disclosed.
  4. D2C R does not provide personal information to a third party without obtaining the prior consent of the individual. When D2C R does provide personal information to a third party, it expressly states the necessary matters and provides the information after obtaining the consent of the individual.
  5. D2C R may provide the personal information of an individual in order to execute joint business with its affiliated companies or associations to which it belongs. In this event, it expressly states the necessary matters in advance and provides the information after obtaining the consent of the individual.
  6. When D2C R engages in business that it subcontracts from other entities, the personal information it handles is within the limits required for engaging in the relevant business.
  7. Websites provided by D2C R may use cookies to enhance the usefulness of the site. Information obtained through the use of cookies is limited to information that is not capable of identifying a specific individual.

(2) Purpose of use for personal information

D2C R’s purpose of use for personal information is as follows. D2C R does not collect personal information that exceeds the limits of the purpose of use below.

  1. Personal information of users
    • Member registration and provision of contents on websites and in applications
    • Delivery of e-mail magazines and notifications and information about websites and applications
    • Responses to opinions and inquiries from customers
    • Sending of gifts, etc., for promotional campaigns
    • Questionnaire surveys (D2C R removes customers’ personal information from the questionnaires when using survey results.)
    • Holding, managing, running and providing information on mobile-related events and seminars
    • Fulfillment of contracts with customers, settlement of payments and related after sales service, etc.
  2. Personal information of shareholders
    • Preparation of shareholders’ register, and shareholder administration based on Japan’s Companies Act and other legislation
  3. Personal information of company officers, employees and temporary staff
    • Personnel and labor administration, and welfare benefits, etc.
    • Reports, etc., to the relevant departments based on legislation
  4. Personal information of job applicants
    • Communications regarding interviews, notification about employment outcomes, and other communications
  5. Personal information collected through inquiries
    • Responses to opinions and inquiries, measures to improve services, etc.,
  6. Information on business partners
    • Proper management of contracts with business partners, communications on the details of contracts, etc.

Other business in connection with that stated in each of the above.

(3)Procedures for requests for disclosure, etc., and complaints and inquiries

Use the following method to submit a personal information disclosure, etc., request procedure (request for disclosure, revision, addition, suspension, deletion) or a complaint, or inquiry concerning personal information held by D2C R.

  1. Download the standard Disclosure, etc. Request Procedure Form or Complaint and Inquiry Form from the link below, and then enter the necessary information.
  2. Send the completed documents by post to the address listed at the bottom of this page.
  3. There is a handling fee of 1,000 JPY for each disclosure request.
  4. The requested disclosure of information will be sent to the individual who made the request (the address on the Disclosure, etc., Request Form) or to the address stated on the agency confirmation document.
  5. To make a telephone inquiry, contact the number listed at the bottom of this page after checking the required information in the standard form first.
  6. If your complaint or inquiry cannot be resolved by contacting the number listed at the bottom of this page, you can lodge your complaint with a third party organization (authorized personal information protection organization).

D2C R has been granted the PrivacyMark, which Japan Institute for Promotion of Digital Economy and Community confers on entities that handle personal information properly.

■ Name of authorized personal information protection organization

Japan Institute for Promotion of Digital Economy and Community (JIPDEC)
Contact for resolution of complaints
PrivacyMark Promotion Center, Personal Information Complaint and Consultation Office
<Address> Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
<Tel> 03 5860 7565 or 0120 700 779

Please see the JIPDEC website for more details.

■ Standard Disclosure, etc., Request Procedure Form and Complaint and Inquiry Form

5. Browser history and other information

(1) Collection, use and provision of browser history and other information

  1. D2C R collects browser history and other information within the limits required to achieve targeted advertising and other purpose of use when customers view websites and advertisements, including those of D2C R and D2C R’s business associates (includes advertisers, advertising distributors, etc., hereinafter referred to as “business associates”). Furthermore, browser history and other information refer to information, such as the history of websites and advertisements viewed, and cookies, which does not identify a specific individual. Multiple browser histories or the Likes may be collected and used in the distribution of targeted advertising, but this does not create information capable of identifying a specific individual.
  2. As browser history and other information are not personal information, it is not capable of identifying a specific individual. However, D2C R regards browser history and other information as equal in importance to personal information, and D2C R is committed to handling browser history and other information properly, and to ensuring the establishment of an internal system and information management.
  3. D2C R expressly states the purpose of use, the details of the provision of browser history, and other information to customers when it uses browser history and other information, or provides it to a third party. Moreover, D2C R will not use browser history and other information, or provide it to a third party for any purpose other than one that it has expressly stated.

(2) Purpose of use for browser history and other information

  1. Delivering targeted advertising, provision of other products, services and related information tailored to customers’ interests
  2. Distribution settings (frequency control) to prevent continuous repeated delivery of the same advertisement to customers
  3. Surveys of user numbers and referral numbers on websites provided by D2C R and its business associates
  4. Analysis in order to enrich and improve the content of services and advertisements, provided by D2C R and its business associates, and investigate and develop new services
  5. Confirming customers’ use status in order to respond to customers’ inquiries
  6. Improving user-friendliness, and ensuring security for websites and applications provided by D2C R.

6.Offering personal information to third parties

For the purpose of use described in Article 5 above, D2C R may offer the personal information collected by it to D2C through written documents, or electronic or electromagnetic methods. If you do not want us to disclose this information to D2C, when request as per the methods stipulated in Article 7, D2C R will stop disclosing this information to D2C.

7.Contact office for inquiries

Nomura Ginza Building., 6-18-2 Ginza, Chuo-ku, Tokyo 104-0061, JAPAN
Phone: 03-6226-8920
D2C R Inc., Legal Department
D2C R Inc.
Yuki Oka, President
Date of establishment: October 1, 2013