Article 1 (Information Acquired by the Company for the Services)

The Company may acquire the following information from the customer for the Services. If the information is not provided, the customer may not use the Services in whole or in part.

• 1) Information acquired directly from the customer through registration for the Services or changes to registered information, or through inquiries and communications from the customer

  (Example)
  • Information about the customer, including name, email address, and telephone number
  • Information about the customer's company, including company name and company department
  • Login information, information about usage plans (this includes contract details, billing dates, and expiry dates), and information concerning the customer's use of the Services, such as the purpose for using the Services and job details
  • Information entered or sent by the customer using methods stipulated by the Company, including information from customer inquiries, evaluations, and complaints

• 2) Information automatically collected from the customer through the use of the Services

  (Example)
  • Location information
  • Information on service usage (e.g., information on operating settings, number of files uploaded, device orientation at the time of crashes, etc.)
  • Dates and times of access of the Services
  • The type of device applications and browsers used to view the Services and the pages viewed (this includes the websites of third-party services used by the customer prior to using the Services)
  • Information regarding devices used to access the Services, hardware models, device IP addresses, MAC addresses and other unique identifiers, OS and their versions, selected languages, advertising identifiers, serial numbers, device operating information, and mobile network information
• 3) Information acquired through services operated by third parties
  If the Company is permitted to acquire customer information through a service operated by a third party, the Company may acquire this Information. In such cases, the Company may adapt the information it acquired on its own and the information obtained from third parties in order to improve the Services and provide advertisements that are of interest to the customer.

Article 2 (Purpose of Use of Personal Information)

The Company uses acquired personal information concerning the Services for the following purposes.

• 1) For the purpose of providing, maintaining, protecting, and improving the Services, such as accepting registration of Services, identifying individuals, and calculating usage fees, etc.
• 2) To announce information about the content of the Services, updated information, information on events and campaigns, and information regarding rule changes, etc.
• 3) For conducting business in relation to the Services and responding to communications, procedures, inquiries, etc.
• 4) For providing information concerning the Services, other of the Company's services the Company (including business partners and outsourcing contractors) deems beneficial, and other companies' services and responding to inquiries, etc.
• 5) For responding to acts violating the Company's rules for the Services and other terms and conditions, complaints, disputes, and litigation, etc.
• 6) For generating statistical data regarding use of the Services within the scope of not being able to identify individuals
• 7) For the planning, proposal, and implementation of future Services
• 8) For identity authentication when logging in and logging out when using the Services
• 9) For analyzing registered information and usage in order to improve usefulness for the customer of the content and advertising provided by a third party to be viewed during use of the Services
• 10) For understanding the distribution status of advertising, measuring advertising effectiveness, and displaying behavioral targeting advertising
• 11) In order to provide partial information to our advertising business partners (hereinafter simply "Advertising Provider") (information that identifies a particular individual is not included in the information provided for use in advertising services of the particular business partner)
• 12) For the distribution or display of advertisements from the Company or a third party
• 13) For sending prizes to customers who have been selected in campaigns, etc.
• 14) For researching market and customer trends and for marketing initiatives
• 15) For any purpose incidental to those mentioned above

Article 3 (Provision to a Third Party)

The Company may provide acquired personal data to a third party in the following cases:

• 1) Cases when the customer consents
• 2) Cases when the there is sufficient grounds for the Company to determine it is forced to disclose personal information in order to protect the Company's rights, property, and services, etc. when the customer is in violation of the Company's rules
• 3) Cases in which the provision of personal information is necessary for the protection of life, wellbeing, and property of an individual and consent of the person is difficult to obtain
• 4) Cases in which the provision of personal information is necessary for cooperating with a state organ, a local government, or an individual or entity entrusted by either a state organ or local government to execute affairs prescribed by law, and in which obtaining the consent of the customer is likely to impede the execution of the affairs concerned
• 5) Cases when requested by public institutions, including judicial agencies, etc.
• 6) In the event of the succession of the Company's business, including the provision of personal information as a result of merger, company split, transfer of business, or otherwise
• 7) Cases recognized by laws and regulations including the Act on the Protection of Personal Information.

Article 4 (Joint Use of Acquired Personal Data)

• The Company may use personal data jointly within the scope provided below to further improve the Services.
  • Categories of personal data that may be used jointly
    Information stipulated in Article 1 Paragraph 1 and 2
  • Scope of entities that will jointly use personal data
    The Company's Group companies listed on the following website:
    https://www.kubell.com/about/company/
  • Purpose of use for entities
    Purposes provided in Article 2
  • Name and address of the person responsible for management of personal data for joint use and name of the representative
    WeWork Nogizaka, 1-24-3 Aoyama, Minato-ku, Tokyo
    kubell Co., Ltd.
    Masaki Yamamoto Representative Director
• In addition to the above paragraph, if the Company requires a business partner to jointly conduct its business in the provision of Services to the customer, the customer's personal data shall be jointly used by this particular business partner. In that case, before the joint use, the Company will disclose to the customer the categories of personal data that may be used jointly, the scope of entities using the data jointly, as well as the name and address of the personal responsible for management of personal data for joint use and name of the representative.

Article 5 (Entrustment of Acquired Personal Data)

• Upon the outsourcing of work to contractors, the Company may entrust the handling of acquired personal data, in whole or in part, to the contractor within the scope necessary for the achievement of the purpose of use. In this event, the Company will sufficiently examine the eligibility of outsourcing contractors and establish a system to appropriately manage information by stipulating matters concerning confidentiality obligations in the contract.
• Upon using external services, the Company may entrust the handling of acquired personal data, in whole or in part, within the scope necessary for the achievement of the purpose of use. In this event, the Company will sufficiently examine the eligibility of the external services and establish a system to appropriately manage information by stipulating matters concerning confidential obligations in the contract.
• The Company may store or process acquired personal data in foreign countries upon the implementation of Paragraphs 1 and 2 above. In that case, the Company will research regulations etc. for each individual country as well as provide necessary information on the following webpage Provision of Personal Data to Third Parties in Foreign Countries. Please read and agree to this before use of the Services.

Article 6 (Retention Period of Personal Data and Secure Management, etc.)

The Company shall keep personal data accurate and up-to-date to the extent necessary to achieve the purpose of use, and when the retention period prescribed by law has expired, or when the personal data is no longer required to be used for achieving the purpose of use, the Company will strive to delete personal data without delay. The Company has established an Information Security Policy as a policy for measures regarding information security. The Company shall take necessary and appropriate measures for the secure management to prevent the leakage of personal data or the loss or damage of other personal data (this includes personal information acquired by the Company or being acquired and intended to be handled as personal data by the Company).

Article 7 (Disclosure, Correction, and Suspension of Use, etc. of Held Personal Data)

• When the Company receives a request from the customer to disclose the personal data that it holds in accordance with the Act on the Protection of Personal Information, the Company will disclose the personal data that it holds without delay after confirming that the request is from the customer itself and provided the Company has an obligation for disclosure under the Act on the Protection of Personal Information. For each disclosure of personal data held, the Company may charge a disclosure fee in accordance with separately established procedures.
• When the Company receives a request from the customer to revise the personal information that it holds in accordance with the Act on the Protection of Personal Information due the personal information in the Company's possession being incorrect, or for the suspension of the use of the personal information on the grounds that the information has been handled beyond the scope of already announced purposes of use or when the information has been acquired through deception or other wrongful means in accordance with the Act on the Protection of Personal Information, the Company will undertake the necessary investigation after confirming that the request is made from the customer themselves, and based on the results of the investigation, the Company will revise the particulars of the personal data it holds or suspend use and notify the customer to the effect.
• When the Company receives a request from the customer to delete the customer's personal data it holds, provided the Company deems that it must comply to the particular request, the Company will delete the personal data in its possession without delay after confirming the request is from the customer themselves and notify the customer to the effect.
• When making a request as prescribed in the preceding paragraphs, the customer will send the details stipulated below as well as the information and documents required by other companies.
  • 1) Name, address, telephone number, email address
  • 2) Details of the request, background information, supporting documents
  • 3) Documents confirming identity
• The Company may not be able to comply with the requests in Paragraphs 1 and 2 when any of the following below apply. In such cases, the Company will notify the customer to the effect and explain the reasons.
  • 1) When it may harm the life, wellbeing, and property or other rights or interests of the customer or third party
  • 2) When disclosure may severely interfere with the proper implementation of the Company's business
  • 3) When doing so would be in violation of laws
  • 4) When confirmation cannot be made that the request is from the customer themselves

Article 8 (Cookies and External Transmission of User Information)

• The Company and Advertising Providers may send cookies through the Services to browsers used by the customer and use that technology.
• The customer can disable or refuse to accept cookies by changing browser settings themselves. However, some of the Services may not work properly if the customer disables or rejects cookies. The settings of each browser are as follows.
  • Chrome
  • Edge
  • Firefox
  • Safari
• The Company uses Google Analytics to collect and analyze data from how the customer uses the Company's websites. For details about Google Analytics, please view the following pages.
  • Google Analytics Terms of Service
  • Google Policy & Terms
• If the customer's settings enable acceptance of cookies, the Advertising Provider may obtain cookie information such as the browsing history of the customer using the Services and distribute the Company's advertisements on the Advertising Provider's media.
• The Advertising Provider may use cookies, accessed data, the Company's identifiers, and customer attributes to distribute advertisements that match the customer's interests and preferences.
• Cookie information obtained by the Advertising Provider will be handled in accordance with the Advertising Provider's privacy policy.
• The customer may be able to stop cookies and the use of accessed data by the Advertising Provider by accessing and disabling (opting out) on the opt-out page of the Advertising Provider. In such cases, ads not matching the customer's interests and preferences may not be distributed, or the same ads may be repeatedly distributed. When the customer wants to disable (opt out) cookies, please access the following privacy policies and opt-out pages of individual Advertising Partners and follow the steps on the websites of the Advertising Providers to set settings.
  Advertising Provider Privacy Policies and Opt-Out List
• In order to improve the customer experience of the Services, display content and advertising matching the customer's interests and preferences, and improve the Services through access analytics, the Company may use third-party tools and cookies, etc. (hereinafter　referred to as "Tool") and collect and distribute information about the customer (user information) to external parties. Please read the following in regard to information to be public based on rules governing the external transmission of user information under the Telecommunications Business Act (name of the external provider for each external transmission Tool and Tool names, the names and service names of external providers, details about user information transmitted to the external provider, and the purpose of use of the information distributed to the external provider).
  External Transmission of User Information

Article 9 (Use of Information for Service Improvement)

In order to develop functions and improve the quality of the Services (except as stipulated in this Article and Article 1 Paragraph 2) the Company may use the following information that has been statistically processed or anonymized in order to prevent identification of individual customers. However, the Company will strictly protect the communicated content in accordance with laws that protect the secrecy of communications, and the Company will not view or use messages, images, video content, or call content, etc. between customers.

• Information about the use of chat
  This includes the number of group chats, number of messages, number of emoticons, number of reactions, number of files, task creation information, video and voice call usage, and contact management information, etc.
• Information about usage plan
  This includes contract details, billing dates, expiry dates, etc.
• Information about active users
  This includes devices, OS, browsers, etc.

Article 10 (Disclaimer)

For websites provided by operators other than the Company and linked to from the Services, the particular operator may acquire personal information. However, in such cases, this Privacy Policy shall not apply and the Company assumes no obligation or responsibility concerning the acquisition of personal information by the particular operator.

Article 11 (Inquiries)

For comments and questions concerning this Privacy Policy (except as otherwise noticed in this Article and Article 1 Paragraph 2) and other inquiries about the handling of personal information and requests based on Article 7, please contact the Company on this form.

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