Policy for Protection of Personal Information

1. Obtaining, Using and Providing Personal Information

• The Company shall obtain the Personal Information in a lawful and fair manner.
• The Company shall use the Personal Information within the purpose of the use.
• The Company shall obtain prior consent from the party when the Company provides the Personal Information to the third party.
• The Company shall not use the Personal Information obtained out of the purpose of the use, and shall take measures against such usage.
• Where there is a necessity for the Company to use the Personal Information out of the purpose of the use, the Company shall obtain another consent from the party for the renewed purpose of the use.

2. Concerning the Acquisition and Regarding Information Without Identifying the Individual

Our system creates a random ID for each browser made up of a unique string of characters (hereinafter referred to as a "Unique ID") and assigns it to the browser's cookies. This Unique ID in no way links with personal information, device information, or any other information which may allow for identification of the individual. In addition, for smartphone applications and other platforms which do not use cookies, the system will use advertising identifiers (advertising identifiers provided by Apple (IDFA) or Google (Google Advertising ID)) as Unique IDs to differentiate users.

When users access or make use of websites or applications using our service on their PC, smartphone, or other devices (hereinafter referred to as "Electronic Device(s)"), we will gather the following information from those users via their Unique ID.

• Information for identifying the medium used to access the service, such as website URL or smartphone application identifier (application name)
• The date and time that the website or application was viewed or used
• Referrer Information (The search term used or information on the original website (URL, etc.) on which the user clicked a link to go to a different website containing our service)
• Information on advertisements which were viewed or clicked
• IP address necessary for transmitting information
• User Agent Information (OS of the Electronic Device and version information for that OS, browser OS used and version information for that OS)

Any of the information listed above which we acquire will be used for the following purposes.

• Transmitting advertisements and content in line with the customer's attributes and interests/preferences
• Measuring advertisement effectiveness
• Marketing surveys and analyses
• Providing measurements of advertisement effectiveness, analyses, and related information to the advertisers, advertising agencies, and publishers who use our service
• Planning, development, provision, and improvement of the products, services, and information which we provide

3. Laws, Regulations and Guidelines Stipulated by the Government or Other Standards (hereinafter collectively referred to as "Laws and Regulations")

The Company shall always obtain and hold the Laws and Regulations regarding its businesses Regarding Personal Information, notify them to its clients and employees that are engaged in the businesses of the Company (hereinafter referred to as "Employees"), and comply with them.

4. Safe Control of Personal Information

• The Company shall take appropriate measures on its computers, network and facilities to prevent any informational leakage.
• The Company shall prepare against any disasters or failures to safely prevent informational loss or damage. The Company shall retain backups of the information just in case.
• The Company shall take corrective measures immediately after any infringement, incident or accident at inspection is discovered, as well as preventive measures against the weakness.
• The Company shall provide the Employees and its clients with thorough educations on safety.

5．Complaints and Inquiries

The Company shall respond to the complaints and inquiries properly and immediately.

6. Continuous Improvements

• The management system for Personal Information of the Company requires that the supervisions and audits shall be conducted over the compliance of internal regulations to discover any infringements, incidents, accidents and weakness to fulfill the purpose of its policy for protection the Personal Information.
  This system shall be reviewed by management of the Company to be reflected in various managerial measures and internal regulations. This constitutes the continuous improvement cycle of the system.
• These improvements shall be conducted in compliance with the Laws and Regulations and JIS Q 15001.