We, DVERSE Inc. (“we”, “our”, or “us”), use commercially reasonable efforts to protect and handle information obtained from you (“User Information”) properly and make improvements in the quality of protecting and handling such User Information.
PLEASE READ POLICY CAREFULLY AND AGREE POLICY BEFORE USING SERVICES. YOU SHALL NOT USE SERVICES IF YOU DO NOT AGREE POLICY.
(Definition of User Information)
We will obtain User Information, including personal information as defined under Article 2, Paragraph 1 of the Act on the Protection of Personal Information (“Personal Information”) and the following information, through our Services
(1) Information you provide us:
Information collected from you may include, your name, birthday, age, occupation, family structure, gender, residence, telephone number, number or password of credit card, or information of account(email address and password) or any other information regarding to your payment of this Services; and
(2) Information collected by us:
・Information about devices
We may collect information regarding to your devices (including but not limited to device-specific IDs) for the purpose of operating, maintaining and improving Services and preventing unlawful acts, if you use your devices to use Services.
・Access log and history
We may collect information about your use of Services, including IP address, access logs, the date and time of your request, the number of usage, usage history, and other information regarding to your activities within Services, which are generated and stored automatically when you use Services, for the purpose of maintaining and improving Services and preventing unlawful acts.
・Cookies and anonymous IDs
・Information from external services
(Collecting User Information)
User Information we collect is appropriately obtained based only upon your use of Services and it is not obtained through any illegal means or deceptive acts by us. In addition, in the event we collect User Information from sources other than from the following meaning, we will inform you about the purpose of our use.
・input, register, or upload your User Information by yourself;
・provide your User Information by e-mail, postal services, or any other document by yourself; or
・collect your User Information such as usage history or status of usage by us, when you use Services.
(Insuring the Security of User Information)
1. For the purpose of preventing any leakage, loss or damage of User Information, we take necessary and appropriate measures to securely manage User Information by allowing only minimal and limited access to files containing personal information, and installing security software to prevent unlawful access.
2. We appoint our representative director as the person in charge to properly manage User Information by each our Services.
representative director: Shogo Numakura
(Purposes of Use)
・to provide notices about Services and provide information;
・to provide Services;
・to simplify the process of register User Information;
・to confirm application to Services of email distribution;
・to provide Services of email distribution;
・to confirm and deliver purchases related to Services;
・to confirm billing, payment related to Services;
・to improve the convenience of access to Services and to consider new services of us;
・to distribute advertisements;
・to make the content of Services and advertisements more appropriate for you;
・to analyze the environment and conditions of the use of Services and provide better services;
・to prevent fraud that interferes with the provision of Services.
2. We may revise the purposes of use provided for in the preceding paragraph to the extent that such revision is deemed to be reasonably related to the original purposes of use, upon which we will either notify you privately or make an announcement publicly to that effect through procedures separately established by us.
(Personal Information to Third Parties)
1. We will not provide Personal Information to any third parties without prior consent from you except under the following circumstances:
・When courts or government agencies require us to provide your Personal Information based on laws or regulations;
・When it is necessary to protect the life, body or property of an individual, and it is difficult to obtain your consent due to circumstances;
・When it is necessary for improving public health or ensuring the well-being of children, and it is difficult to obtain your consent due to circumstances; or
・When it is necessary for cooperating with government agencies, local public bodies, or any agents thereof, in executing the affairs prescribed by laws or regulations, and obtaining your consent is likely to impede the execution of the affairs concerned; or
・When the business is acquired by others due to mergers, splits, or transfers of business, and your Personal Information is included as part of the acquisition.
2. When we provided Personal Information to a third party, we will make and maintain a record of the following matters:
・The confirmation of your consent
・The identity or name of the third party and information sufficient to identify the third party
・The name of the person identified by Personal Information and other information sufficient to identify that person
・The details of Personal Information being provided to the third party
3. While we may provide Personal Information to third parties or make it available to the public after statistical analysis of age distribution, taste distribution and usage history, but these statistical information is not personally identifiable. It does not correspond to anonymized processing information under the Act on the Protection of Personal Information.
We may outsource the handling or management of Personal Information, in whole or in part, to one or more independent service provider, upon which we will in advance execute a confidentiality agreement with the terms and conditions that conform to the provisions of Policy with each of the respective companies, and conduct necessary and appropriate supervision to ensure proper and safe management of Personal Information.
(Sharing of Personal Information)
We have the right to share Personal Information with our trusted partners, but only to the extent necessary for them to enhance our Services, upon which we will notify you of or publicly announce in advance: types of information to be shared, the names of such partners, purpose of use, and names of persons in charge for managing such information.
(Information Gathering Modules)
Incorporated in Services are modules that enable us to gather and analyze information on service usage, Services themselves, and other services. Accordingly, we may provide User Information to module service providers. The information gathered by modules using Cookies and other technologies to collect User Information, but do not collect any information that identifies you personally. The information collected is managed in accordance with the privacy policies and other terms and conditions established by the respective providers.
(Behavioral Targeting Advertisements)
1. We may collect, store, or use the following information through the information gathering module as set forth in the preceding provisions in providing the Service or external services for the purpose of behavioral targeting advertising (an advertising method that distributes advertisements in accordance with the needs, interests, and interests of you) by us or a third party, such as the advertising distributor.
・Information of usage history and status of service usage (information which can be used to analyze customer needs or interests by storing it and which does not lead to the identification of a specific individual such as usage history).
・Information of your devices
2. We may provide the information stipulated in preceding paragraph to the providers of behavioral targeting advertisements (“Advertising Distributors”) for the purpose of delivering useful information to you by delivering optimal advertisements customized to meet your needs and interests.
1. We use commercially reasonable efforts to continuously review and improve our handling of User Information, and may revise Policy from time to time as necessary.
2. We will notify you of any revisions to Policy by announcing such revisions on our website or through other means that can be easily accessed and viewed. However, if we are required by applicable laws or regulations to obtain your consent in order for us to make certain revisions, then we will obtain your consent in a manner separately established by us.
1. We shall not assume any responsibility for any damage caused to you and third parties due to improper conduct by hackers.
2. You shall strictly manage the information to confirm the identity of you so that it is not lost, forgotten, or disclosed to a third party.
(Retrieval, Correction, Addition, and Deletion of Personal Information)
You may submit a request to retrieve, correct, add, and/or delete Personal Information you have previously provided us, by following the detail procedure prescribed in the PDF file “Guidance on Applications for Disclosure Personal Information”. Upon our verifying your identity pursuant to the preceding sentence, we will fulfill your request, to the extent deemed reasonable by us. However, there may be circumstances under which we may not be able to accommodate your request, such as when we are not required to fulfill your request under the Act on the Protection of Personal Information or other relevant laws or regulations, when you repeatedly make the same requests without justifiable grounds, or if such retrievals, corrections, additions or deletions require work by us that we deem to be excessively technical.
1. For any inquiries regarding Policy, please contact our Personal Information Help Desk.
2. A user residing in an EU member state and subject to the GDPR should contact us at the same address as (1.) to exercise their rights under the GDPR. If the inquiry is not handled appropriately, you may file a complaint with the supervisory authorities.
DVERSE Inc. Personal Information Help Desk
Address：4F, Nishisando K house, 3-45-2, Yoyogi, Shibuya-ku, Tokyo, 151-0053, Japan
The original language of Policy is Japanese and any translation, including this English translation, shall serve only as a guide to interpretation.
Effective March 29, 2018
Revised on May 24, 2018