HIKE ON STARWAY Inc. (“Company”) shall collect and handle personal information (hereinafter referred to as “Personal Information” as defined under Clause 2(1) of the Japanese Protection of Personal Information Protection Act) collected by the Company in connection with the HIKE ON STARWAY service (“Service”) as follows:
Article 1 (General Provision)
In order to protect information collected in connection with the Service, the Company will comply with the Japanese Protection of Personal Information Act (Act No. 57 of May 30, 2003) (“Protection of Personal Information Act”) and other related laws and regulations. The Company shall endeavor to appropriately handle and protect all information, including Personal Information collected from individual or entity using the Service (“User”).
Article 2 (Information to be Obtained)
The Company may acquire the following information in connection with the Service:
Information related to the User
A. User’s Information
In order to verify the identity of User, notify User of the Service, and to prevent unauthorized use by other users, the Company shall obtain the e-mail address, postal code, and other information designated by the Company (“User Information”) from the User.
B. Device Information
When a User uses the Service on any devices including mobile devices, the Company may collect device information (ID information etc. that can identify the device) used by the User in order to maintain and improve the Service or to prevent fraud. In addition, the Company may collect information that is automatically generated and stored when using the Service, such as User’s IP address, request date and time from User, the User’s history accessing the Service, and User’s status (“Log Information”).
C. Cookie and anonymous ID
The Service may use a technology called “Cookie” or other similar technology. For avoidance of doubt, Cookie is an industry-standard technique by which a web server identifies a User’s browser. The Cookie can identify the User’s browser but cannot identify the User’s individually. User may choose to disable the Cookie function by changing the settings on the device setting, however, by doing so, part or all of the Service may not be available.
D. Credit Card Information
The Service allows User to use credit card for payment when User requires to make monetary payment on an agreement between users of the Service. However, in using the payment services which being provided by external online payment platform operators, the Company will not acquire the User’s credit card number, card expiration date, or CVC number.
Transmission Data and Linkage Data
The Company may collect data, including but not limited to, location information of User’s devices, search history, history of use of the Service, any posting to the Service (“Transmission Data”) and other related data, including, but not limited to, login information, texts, images, videos, and other information being transmitted by User to the Service, and information obtained from other services in conjunction with the Service (“Linkage Data”).
When acquiring Personal Information, the Company shall properly acquire such personal information through no falsification or other improper means. In addition, in the event the Company collect any Personal Information from sources other than from using the Service, the Company will notify User to that effect in advance and Company will inform User about the purpose of its use.
Article 3 (Purpose of Use)
The Company strives to appropriately handle the Personal Information only for the following purposes. Without the User’s consent, the Company will never use the User Information for any purpose other than the purposes set out in this Policy.
– [Purpose of Use] To provide, maintain, and improve the Service [Description of Purpose of Use] For the purpose of application and providing the Service / To verify the identity of User and to prevent unauthorized use of the Service / To ensure smooth provision, maintenance and improvement of the Service [Use of Information] User Information / Device information, IP address and Log Information / Cookie and anonymous ID / Transmission Data / Linkage Data
– [Purpose of Use] To notify User, provide support etc. to User [Description of Purpose of Use] For the purpose of responding to inquiries relating to the Service / For the purpose of notifying User of any changes in the terms and conditions of the sale agreement, this Policy, suspension, cancellation, or other important notices relating to the Service [Use of Information] User Information
– [Purpose of Use] Provision to Third Parties [Description of Purpose of Use] In the event the Company provides User Information to a third party, the third party who receives such information shall use the information for the following purposes [Use of Information] User Information / Device information, IP address and Log Information / Cookie and anonymous ID / Transmission Data / Linkage Data
The Company may revise the purpose of use provided for in the preceding paragraph to the extent that such revision is deemed to be reasonably related to the original purpose of use, upon which the Company shall notify User of such revision or post such revision on website operated by the Company in an easy to understand manner. In addition to the right prescribed in Article 1 of this Policy, the Company may process Transmission Data, Linkage Data, and other Personal Information into; (i)anonymized information (“Anonymized Information” as defined in Clause 2 (9) Protection of Personal Information Act) or (ii)statistical information; to the extent that User cannot be identified, and the Company is able to use such information.
Article 4 (Provision to Third Parties)
Withstanding the right prescribed in Article 3 of this Policy, in principle, the Company will not provide Personal
Information to any third parties without prior consent form User. However, in the following circumstances, Personal Information may be provided without User’s consent to a third party, to the extent that such provision does not violate any applicable law and regulations.
(i) Based on laws and regulation;
(ii) When it is necessary to protect the life, body or property of an individual and consent from User is difficult to obtain;
(iii) When it is necessary for improving public health or ensuring the well-being of children and consent form User is difficult to obtain;
(iv) When it is necessary for cooperating with government agencies, local public bodies, or any agents thereof, in executing the affairs prescribed by laws and regulations, and obtaining User’s consent is likely to impede the execution of the affairs concerned; or
(v) When the Personal Information is succeeded due to the Company being merged, spilt, transferred or any other similar business transaction.
In the event the Company provides personal data (“Personal Data” as defined in Clause 2(6) of the Protection of Personal Information Act) to a third party with the consent of User, the Company shall prepare and retain records relating to the following matters:
(i) That prior consent of User has been obtained;
(ii) The name or any other information that able to identify the said third party;
(iii) Sufficient Information for identifying the individual, such as the name of the individual identified by the Personal Data; or
(iv) Details of such Personal Data.
Article 5 (Outsourcing)
The Company may outsource the handling or management of Personal Information, in whole or in part, to one or more independent services provider company, upon which the Company will in advance execute a confidentiality agreement with each of the respective companies, of the terms and conditions that conform to the provisions of this Policy and conduct necessary and appropriate supervision to ensure proper and safe management of the Personal Information.
Article 6 (Sharing)
The Company may share Personal Information acquired pursuant to Article 2 herein with the Company’s subsidiaries and affiliated in accordance with the purposes of use set forth in Article 3 of this Policy.
In addition to the provision of the preceding paragraph, the Company may share Personal Information obtained from User to the extent necessary for the provision of tie-up services with its affiliated companies and other third parties. In this circumstance, the Company will publicize in advance; (i) the itemization of the information to be shared, (ii) the scope of the use, (iii) the purpose of use, and (iv) the name of the person responsible for the management of such information.
Article 7 (Safety Management System)）
In order to protect User Information from leakage, loss, or damage, the Company will take necessary and appropriate measures of security safeguards, such as implementing restrictions to access Personal Information and Anonymized Information, limiting the minimum necessity of persons who hold access rights, and to install security software in preventing unauthorized access.
The Company will appoint an administrator as the person in charge to properly manage User Information and to continuously make improvement in the quality of such management.
Article 8 (Rights of User to Disclose, Correct, etc. of Personal Information)
User have the discretion and right to withdraw the consent in relation to the provision of User Information by the Company at any time. For further information on User’s right to disclosure, correct, delete or discontinue any Personal Information on the Service, please refer to the Information on Application for Disclosure, etc. of Personal Informationa (PDF version) (“Rules”). However, that in the event, (i) the Company is not liable for obligations detailed in the Rule as prescribed under the Protection of Personal Information Act or other laws or ordinances, or (ii) the request for obligations detail in the Rule have been repeated many times without due reason, or (iii) excessive technical work is required, such obligation detailed in the Rule may not be carried out by the Company.
Article 9 (Revisions)
The Company will use commercially reasonable efforts to continuously review and improve handling of User Information and may revise this Policy from time to time as it deems necessary.
The Company will notify User of any revisions to this Policy by announcing such revisions on website operated by the Company or through other means that can be easily accessed and viewed. However, if the Company is required by applicable laws or regulations to obtain User’s consent in order to make certain revisions, then the Company will obtain User’s consent in a manner separately established by the Company
Article 10 (Inquiry)
For any inquiries regarding our handling of User Information, including any suggestions, questions, complaints or comments, please contact following address
HIKE ON STARWAY Co., Ltd. / Email: email@example.com
(The reception time shall be from 10:00 p.m. to 17:00 p.m. on weekdays.)
(Established on 00th day of 1st of September, 2018, 2018)