Privacy Policy

Our company (hereinafter “we”, “our” or “us”) shall handle information related to the Users (including the actual User such as a family member; hereinafter “User”) of the application provided by us (hereinafter “App”) in the following manner.

Article 1 (General Provisions)

We shall comply with the Act on the Protection of Personal Information (hereinafter “Personal Information Protection Act”), guidelines stipulated by the ministries and agencies, and other related laws and regulations, for the purpose of protection of the User information (this includes general information obtained from the Users).
This privacy policy (hereinafter “Privacy Policy”) applies to the use of this App (including the services related to this App, that are provided by us). Further, if we provide for the handling of User information in the privacy policy of the website operated by us or other privacy policies, or in the terms of use, etc., related to this App, such provisions shall also apply, and if such provisions and this Privacy Policy conflict, this Privacy Policy shall prevail.
The provisions of this Privacy Policy do not apply to the affiliated services provided by the partners that are stipulated in Article 7 and other services provided by entities other than us (hereinafter “External Service(s)”). For the handling of User information in External Services, please refer to the privacy policy, etc. provided by the entities providing such External Services.

Article 2 (Voluntariness of Providing Personal Information)
You may voluntarily provide your User information. However, if you do not input necessary information in this App, you may not be able to use this App.

Article 3 (Information Acquired by Us and Acquisition Method Thereof)

We will acquire User information including personal information (this means “personal information” as defined in Article 2, Paragraph (1) of the Personal Information Protection Act, and the same applies hereafter) in connection with this App, as defined below, and the following information is included:
(1) User’s name, nickname, photograph, address, date of birth, telephone number, e-mail address, and other information by which certain individual can be identified
(2) Terminal information (including individual identification information)
(3) Log information and behavior history information (including IP address, browsing history, operation history information)
(4) Location information, movement history information
(5) Cookie and anonymous ID
(6) Information related to payment
If the User uses a service in this App, we acquire information necessary for payment process. If a third-party payment provider processes the purchase by the User, we may in some cases acquire the billing information and payment information provided by the User to the payment provider.
(7) Information related to the individual’s attribute that is integral to the personal information
We shall acquire the User information properly, without using fraudulent or other illicit means. Further, when we acquire User information by other means than acquiring information through the User’s use of this App, we will give notice or announce the purpose of such use in advance.

Article 4 (Purpose of Use)

We will handle the User information acquired through the use of this App properly within the scope of purpose as listed below. We will not use information beyond the purpose of use, without obtaining the User’s consent.
(1) Administration of this App, guidance and communication about this App, response to inquiries regarding this App
(2) Correspondence to activities that infringes the terms of use or guidelines of this App
(3) Improvement and analysis of this App, or development of new services, etc.
(4) Notification and proposal regarding this App or regarding the products and services of the affiliated companies to the Users
(5) Filing an application with an External Service related to this App, etc.
(6) Shipping of prize of a campaign related to this App, etc.
(7) Identification verification of the User
(8) Provision of affiliated services, display of advertisement information, etc. that match the needs, interests and concerns, and analysis of the advertisement effect
(9) Operation of targeting advertisement, etc.
(10) Preparation of statistic data and provision of said data to a third party
(11) Use in connection with the purposes as listed in the above items
We may amend the purpose of use in the preceding paragraph within the scope that is reasonably deemed to have considerable relativeness with the purpose of use before the amendment, and if we amend it, we shall notify or announce the same to the Users by the means separately determined by us.

Article 5 (Provision to Third Party)

We shall not use personal information, among the User information, to any third party, except for the cases under the preceding Article and the cases as listed below:
(1) If we have obtained the User’s consent
(2) If required by the law or regulation
(3) If it is necessary for protecting human life, body or property and is difficult to obtain the interested person’s consent
(4) If it is particularly necessary for the improvement of public health or for the promotion of healthy cultivation of adolescents and is difficult to obtain the interested person’s consent
(5) If it is necessary to cooperate with the fulfillment of the work prescribed by the law by a governmental agency or local government, or a person or an entity who is entrusted by a governmental agency or local government, and is threatened to hinder the fulfillment of such work as a result of obtaining the interested person’s consent
(6) If our business is transferred, including the User’s personal information, for the reason such as merger, corporate split, business transfer or other reasons
We have the right to provide User information including personal information, duly by obtaining the User’s consent, to the entities who provide the services affiliated with this App (hereinafter “Affiliated Services”), for the purpose of providing the Affiliated Services to the Users.

Article 6 (Subcontracting of handling of Personal Information)
We may subcontract all or a part of the handling of personal information obtained from the Users to a third party (this means a case where we subcontract administration of information including personal information, for example). In this case, we shall conclude a non-disclosure agreement whose content is substantially equivalent to this Privacy Policy with the subcontractor in advance and perform necessary and proper supervision so that proper safety management of information should be done by such subcontractor.

Article 7 (Shared Use)
We may use the personal information obtained from the Users with our partners and other third parties in a shared manner, within the scope necessary for the provision of Affiliated Services. In this case, we shall announce in advance the name of the third party, the purpose of use and the type of information that is shared to be used.

Article 8 (Cookie; Information Collection Module)

We may use the technology called “Cookie” or other similar technology in this App. Cookie is the standard industrial technology for identifying the computer of the User by the web server. Cookie can identify the computer of a User, but cannot identify the individual User. You can invalidate the function of Cookie by changing the setting on the electronic terminal, but by doing so, you may not use all or a part of this App.
An information collection module selected by us is incorporated in this App, for the purpose of analyzing the information, including the utilization status of this App and the effect of advertisement about the service or product including this App. In connection with this, we may provide the User information with the following information collection module provider. These information collection modules collect User information without including information with which an individual can be identified, and the collected information will be administered based on the provision of the privacy policy provided by each information collection module provider.

Article 9 (Safety Measures Regarding Personal Information)
We establish regulations and strive to take safety measures for preventing and correcting unauthorized access to personal information, leakage, loss or damage of personal information. We take the following measures to attain the above-mentioned purposes.
(1) Formulation of basic policy for performing each measure stipulated in the laws, regulations and guidelines for the purpose of proper handling of personal information
(2) Formulation of various regulations that provide each measures including acquisition, use, storage, provision, deletion, disposal, etc., and the responsible person and his/her role thereof
(3) Nomination of the responsible person, clear nomination of the employees who handle the personal information and the scope of handling of the personal information, consolidation of the system of reporting/communication to the responsible person in case where a violation of the laws and regulations or a sign of such status is found
(4) Taking human security control measures, such as publishing the matters regarding the confidentiality obligation about personal information in the rules of employment and implementing training regarding the matters to be taken into consideration in connection with the handling of personal information
(5) Taking physical safety control measures including the system of employee access management, restriction on devices to be taken in, and restriction, control, etc. of taking out of electronic media and documents involved in handling personal information for preventing theft or loss
(6) Technical safety control measures including introduction of a system that protects the information system handling personal information from being accessed in an unauthorized manner or from an unauthorized software

Article 10 (Corrective Measures)
We strive to correspond properly to the change of social environment regarding the handling of personal information. Further, regarding this Privacy Policy and other related regulations, we strive to improve the status by amending, modifying or adding as it becomes necessary.

Article 11 (Response to Disclosure Request)
If you think that we do not comply this Privacy Policy, or if you would like to request disclosure, correction, addition, deletion or discontinuation of use of your personal information (including discontinuation of provision to third parties), or if you would like to request disclosure of record of provision to third parties, please contact us to the contact detail described in Article 14. We will correspond to such request within a reasonable period (principally two weeks, but if we need longer time to deal with such request, for example, if we receive many request or a complexed request, we estimate it to be within thirty days) and reasonable scope, in accordance with our internal regulations.

Article 12 (Process of Complaints)
As for the complaints regarding the handling of personal information (including claim of complaints from the demandant to the measure taken by us regarding the disclosure, and other complaints regarding the handling), please contact us to the contact detail described in Article 14. We will strive to properly and promptly process such complaints.

Article 13 (Amendment to This Policy)

We may from time to time revise the operating status of the handling of User information and strive to improve it continuously, and may amend this Privacy Policy as it becomes necessary.
We will announce the Privacy Policy after amendment in a comprehensible form, including posting on this App or on the website operated by us. If we amend the content of this Privacy Policy in a manner that the User’s consent should be obtained, we will obtain the User’s consent in a manner separately determined by us.

Article 14 (Contact)
If you have any opinion, inquiry, complaint regarding our handling of User information, and other inquiry regarding the handling of User information, please contact the following:

Address: 東京都港区愛宕二丁目５番１号
Contact: info@enjiniya.co.jp
Reception hours: 9:00 – 17:00
Established on 20 11, 2022