1.Personal information protection policy

Our company conforms to laws and regulations as well as guidelines and standard practices concerning personal information, and we do our best to protect the personal information that we handle as part of our company activities.

2.Purposes for using personal information

(1) Usage purposes in cases where we directly acquire personal information on documents from the subject person (This includes documents and other media obtained via our webpage and email. Referred to below as “Documents.”)

Category	Usage Purpose
Customer information (including seminar participants and survey respondents)	Communications taking place as part of company operations (affiliate service administration, administration of various media and other related operations); distribution of email magazines; provision of information on new products, services and seminars; conducting of surveys; checking tasks for accounting audits; etc.
Information of entities with which we do business (including Agency)	Transaction reviews; order receipt/placement; invoice payment; operation communications; provision of information on new products, services and seminars; conducting of surveys; checking tasks for accounting audits; etc.
Job applicant information	Personnel recruiting activities (document reviews, interviews, evaluations, communications with applicants, etc.)
Employee information	Management of human resources, social insurance, and benefits, etc.

(2) Usage purposes in cases where we directly acquire personal information from the subject person by means other than Documents

Category	Usage Purpose
Customer information	Confirmation of order content (call records)
Entry/exit information and video/audio recordings	Management of company security for crime prevention, disaster prevention, etc.

(3) Personal information obtained in the providing of outsourcing services

Category	Usage Purpose
Customer information	Information processing services, member acquisition operations, campaign product delivery, etc., based on an outsourcing contract with the consigning company

3.Provision and consignment of personal information to a third party

Customer personal information may be provided or consigned to a third party only in the cases below.

• (1) When our company’s subcontractor is to provide information or services in place of our company using direct mail, email, or other means.
• (2) When it is necessary for our company’s subcontractor to provide individual services (after-sales services, etc.) in place of our company.
• (3) When for the purpose of providing statistical information, we aggregate or analyze the personal information of individuals, process the information into a form in which the individuals cannot be distinguished or identified, and then disclose the statistical data.
• (4) When we are required to disclose the information in accordance with a law, regulation, or lawful request from a court or other government body.
• (5) When we have obtained the consent of the customer for some other designated purpose.

When all or part of our company’s operations are consigned to a subcontractor, we strictly manage the personal information of the customer by carefully selecting the subcontractor using the criteria that a management system enabling suitable protection of the personal information be in place and operating and by concluding a non-disclosure agreement with the subcontractor.

4.Personal information usage-purpose notification, disclosure, correction/deletion and usage/provision refusal right

The term “personal information subject to disclosure” refers to personal information that comprises aggregations of systematically structured information and to which our company holds rights enabling us to comply with all of the following requests from the subject person: notification of usage purpose; disclosure; content correction, addition, or deletion; usage halt; information deletion; and halting of provision to third parties.

For details on requesting disclosure or other actions, please see the 【Contact information】 at the bottom of this page.

(1) Disclosure of personal information subject to disclosure

Upon receiving the subject person’s request to disclose the personal information subject to disclosure, our company will disclose the corresponding information to the subject person without delay. If personal information enabling the identification of that person does not exist, we will notify the person of that fact.However, in cases where the disclosure would result in any of the circumstances described in a) to c), we may be unable to disclose the information. At such time, we will notify the subject person of that fact and explain the reason.

• a) When there is a danger of harm to the life, body, property, or other rights or interests of the subject person or a third party.
• b) When there is a danger of a significant hindrance to the proper performance of the operations of the subject business operator.
• c) When it would result in the violation of laws or regulations.

(2) Correction, addition, or deletion of personal information subject to disclosure

When our company is requested to correct, add, or delete content of individual data fields of the personal information subject to disclosure for the reason that it was found to be not factual as a result of disclosure, we will without delay perform the necessary investigation, and based on the results of that investigation we will carry out the correction or other action with respect to the information subject to disclosure and then notify the subject person of the action taken (content correction, etc.) without delay.

(3) Right to refuse the usage or provision of the personal information subject to disclosure

When our company receives a request from the subject person to halt the usage of the personal information subject to disclosure or to delete or halt the provision to a third party of that information, we will comply with that request. When action has been taken, we will notify the subject person of the action without delay. However, in instances where the exception cases described in (1) a) to c) above apply, we will be unable to comply with the request. At such time, we will notify the subject person of that fact and explain the reason.

5. Obtaining information via methods that the relevant individual does not easily recognizes

At FAN Communications Global, Inc., ads delivered by the following companies or third parties may be displayed, and in relation to these ads, the third party may acquire and use cookies and other information from users visiting the websites run by FAN Communications Global, Inc.

Yahoo! JAPAN, Google, Criteo, Facebook
The cookie information acquired by this third party is handled in compliance with the third party’s privacy policy.

A user may access the opt-out page on the third party’s Web site and stop the third party from using cookies and other information for the purpose of displaying ads.
Cookies and mobile phone identification numbers (fixed identification numbers) are used to provide a more convenient browsing experience next time the relevant customer visits the company’s site. They do not infringe upon the customer’s privacy in any way, and will have no negative impact on the customer’s computer.

Sections of the company’s website that require customers to enter personal information use measures such as SSL (Secure Sockets Layer) data encryption system to ensure security. The company also has a strict policy of protecting information within the website, using measures such as firewalls. Please be aware however that, due to the nature of online communications, it is not possible to completely guarantee security.

6. Security of personal information

In order to prevent the loss, destruction, falsification, damage, leakage, etc. of personal information, we will introduce appropriate and reasonable level of security measures to protect personal information. When outsourcing the handling of personal information, we strongly urge you to comply with applicable personal information protection laws and work to maintain the confidentiality of information.

We always make every effort to protect your personal information, but we do not guarantee or represent that your information is fully protected.

7. Rights of users under GDPR or the equivalents

If you are under GDPR or the equivalents, you have the following rights regarding the processing of personal data:
When you exercise the following rights, you can send a request to the contacts listed in the "Contacts" section.
We may ask you to provide certain information in order to identify and correct your data.

Right to withdraw consent
You have the right to withdraw your consent at any time in accordance with Article 7(3), paragraph 3 of the GDPR.
If you wish to withdraw your consent, please contact us at the address specified in this policy to withdraw your consent. The withdrawal of this consent cannot affect the legality of the treatment based on the consent before the withdrawal.
If you withdraw your consent, you will not be able to continue using the applications and services.

Right of access and rectification
You have the right to receive confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data in accordance with Article 15 of the GDPR.
You also have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you in accordance with Article 16 of the GDPR.

Right of erasure and restriction of processing
In accordance with Article 17 of the GDPR, you shall have the right to obtain from us the erasure of personal data concerning you without undue delay.
You also have the right to restrict the handling of personal data in accordance with Article 18 of the GDPR.
However, if your personal data is legitimately used to provide our services and for other purposes, we may reject your request or ask you to postpone the response.

Right to data portability
In accordance with Article 20 of the GDPR, you shall have the right to receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us to which the personal data have been provided.
And you have the right to have the personal data transmitted directly from us to another, where technically feasible.

Right to object
in accordance with Article 21 of the GDPR, you shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you.

Right to lodge a complaint with a supervisory authority
In accordance with Article 77 of the GDPR, without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringment if you considers that the processing of personal data relating to you infringes this Regulation.

Transferring of your personal data
We may transfer and process your personal data from your country or region of residence to Japan and other countries around the world. We may share your information with international organizations as partner. Please note that these countries and jurisdictions may not have the same data protection laws as your country.

8. Data retention period

We will retain your information for as long as necessary to provide the service, unless required by law or unless we accept your request to delete the information.
We will retain and use your information for as long as we need it to comply with our legal obligations.

9. Children's Personal Information Policy

This application and service are not available to users under 16 years of age.
However, we cannot determine if the personal information sent is for persons under 16 years of age. We do not knowingly collect personal information from anyone under the age of 16.

10. The voluntary nature of the provision of personal information

The decision on whether to provide personal information to our company is left up to the discretion of the customer. However, if we do not receive the necessary data fields, there are cases where we cannot provide certain services in an appropriate manner.

Personal information protection administrator
Tetsuya Endo

【Contact information】
Inquiries concerning personal information are handled by the contact point specified below.

1-1-8 Shibuya, Shibuya-ku, Tokyo Japan
FAN Communications Global, Inc.
Privacy Policy Consulting Service
(email: contact@fancsglobal.com)

11. Change of Privacy Policy

We may update this Privacy Policy from time to time as necessary.