Privacy Policy Privacy Policy
Win Techno Inc. (the “Company” or “we”) sets forth this Privacy Policy (this “Policy”) regarding treatment of information of our customers (our “Customers”) for whom we provide our several services (the “Services”) including personal information as follows.
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1. Compliance
We understand strict observance of security management of information is important social responsibility: therefore, we comply with laws, regulations and guidelines regarding personal information protection as well as this Policy upon treatment of Customer Information (as defined below) including personal information. For performing this responsibility, we keep reviewing and improving our information security measures and educating our officers and employees.
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2. Scope of Customer Information and Collection Method
Under this Policy, “Customer Information” shall mean information regarding identification of our Customers, action history in the course of communication services, and other information created or accumulated in relation to our Customers or their devices (including smartphone, tablet, personal computer etc.) that are collected by the Company in accordance with this Policy. Depending on collection method, Customer Information collected by the Company through the Service includes the following information.
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2.1 Information provided directly by our Customers
Upon use of the Services, information provided directly by our Customers is as follows.
- Profile information such as name, occupation, entity to which our Customers belong ant its name, address, and telephone number etc.
- Contact information such as email address, telephone number, address etc.
- Account information of Amazon Web Service (“AWS”) and other cloud platform.
- Information regarding payment method such as credit card, bank account, and virtual currency etc.
- Other information to be inputted by our Customers to input form which is prescribed by the Company.
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2.2 Information provided by other services based on our Customers’ permission to associate with such other services upon use of the Services
Upon use of the Services, when our Customers permit association with external services such as AWS, other cloud platform, repository services (GitHub etc.), cloud security services, and supervision tools etc., information provided by such external services is as follows.
- Account Information for such external services such as ID.
- Other information of which our Customers permit disclosure to associated services in the setting of such external services.
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2.3 Information collected by the Company upon our Customers’ use of the Services
The Company may collect information regarding access status to the Services and the method of usage. Such information includes the following information.
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2.3.1 Device Information
When our Customers use the Services by using their device such as smartphone, tablet, personal computer etc., the Company may collect our Customers’ device information (such as ID information through which each device is able to be identified) for the purposes of maintaining and improving the Services and avoiding misuse or unlawful use of the Services.
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2.3.2 Operation log information
The Company may collect IP address automatically created and stored upon use of the Services, date of our Customers’ request, operation log in the Services, our Customers’ usage status of the Services etc. for the purposes of maintaining and improving the Services and avoiding misuse or unlawful use of the Services.
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2.3.3 Cookie and similar technology thereto
The Company may use technology called “Cookie” and similar technology thereto in the Services. Cookie is industry standard technology for web server to identify our Customers’ device. Cookie may identify our Customers’ device, however, it may not identify our Customers themselves. Our Customers may invalidate Cookie’s function by changing the setting in their device, however, it may lead to unavailability of all or part of the Services.
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3. Purpose of Utilization
Our specific purposes of utilizing Customer Information are as follows. The Company may change the following purposes of utilizing to the extent the purposes after change are reasonably deemed as duly related to the purposes before change. In this case, the Company will notify our Customers of the change or publicize the change on our website or by other means.
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3.1 Providing, Maintaining, and Improving the Services
The Company may use technology called “Cookie” and similar technology thereto in the Services. Cookie is industry standard technology for web server to identify our Customers’ device. Cookie may identify our Customers’ device, however, it may not identify our Customers themselves. Our Customers may invalidate Cookie’s function by changing the setting in their device, however, it may lead to unavailability of all or part of the Services.
- For application and registration receipt regarding the Services and external services associated with the Company, identification, calculation of service fees, payment and settlement within the Services, and other provision, maintenance, protection, improvement, avoidance of misuse and unlawful use of the Services and external services associated with the Company.
- For operation of system necessary for administration of our Customers which is required for use of the Services and external services associated with the Company, such as identification upon log-in and change of display information.
- For provision of function for facilitating our Customers’ use, such as recommendation by using log information in the Services.
- For creation of statistical data in form where each individual is unable to be identified in relation to the Services.
- For development of the Services by the Company.
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3.2 Notice to and communication etc. with our Customers
- For notice regarding the Services and external services associated with the Company, communication and response to inquiry etc.
- For notice regarding the change of the terms and conditions regarding the Services and this Policy, suspension, cease, termination of the Services, and other important matters regarding the Services.
- For dealing with activities breaching the terms and conditions regarding the Services and this Policy etc.
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3.3 Other Purpose
- For analysis, marketing research and activities regarding advertisement’s effect of products and services of the Company and external services providers associated with the Company.
- For display of advertisement information etc. matching our Customers’ needs, preference and interest.
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4. Provision to Third Party
The Company will not provide Customer Information which falls under personal information for third party (including third party outside of Japan) without obtaining prior consent of our Customers except for the following cases.
- When personal information is provided upon succession of business due to merger and other causes.
- When personal information is provided for access analysis tools’ and information collection module’ services providers (such as Ad Network).
- When personal information is provided for our parent company holding majority of voting rights of the Company.
- When personal information is provided for external services providers associated with the Company upon provision of the Services.
- When provision of personal information is permitted under Act on the Protection of Personal Information and other laws and regulations.
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5. Disclaimer regarding Provision to Third Party
The Company shall not be liable for any damages and responsibility regarding third party’s collection of our Customers’ personal information in the following cases.
- When our Customers publicize personal information to third party by using the function etc. of the Services.
- When third party other than our Customers obtains identification information necessary for use of the Services (such as email address, ID, password) by any means not attributable to the Company.
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6. Entrustment of Treatment of Personal Information
The Company may entrust all or part of treatment of personal information collected from our Customers to third party to the extent necessary for accomplishing the purposes of utilization. In this case, the Company will make and enter into non-disclosure agreement etc. equivalent to this Policy with such third party, and will implement necessary and appropriate supervision to ensure appropriate security management of information on the side of such third party.
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7. Joint Use
The Company may jointly use personal information collected from our Customers with our parent company and affiliated companies, external services providers associated with the Company and other third parties upon provision of the Services. In this case, the Company will publicize items of personal information used jointly, name of entity with which the Company uses personal information jointly and its purposes of utilization, name of person or entity responsible for administration of such personal information in advance.
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8. Disclosure of Personal Information
The Company discloses personal information to our Customers without delay (or notifies such Customer of non-existence of requested personal information) when such Customers request disclosure of personal information in accordance with the provisions of Act on the Protection of Personal Information and the Company confirms such Customers have requested disclosure of her/his own personal information. Provided, however, that this disclosure obligation shall not apply when the Company is not obligated to disclose in accordance with Act on the Protection of Personal Information and other laws and regulations. Please refer to “Guidance of Application for Disclosure etc.
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9. Correction and Suspension etc. of Personal Information
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9.1 Correction and Suspension of Personal Information
The Company corrects or suspends utilizing personal information and notifies our Customers of such correction or suspension based on the results of necessary research: (a) when such Customers request correction of personal information in accordance with the provisions of Act on the Protection of Personal Information (such as incorrectness of personal information); or (b) when such Customers request suspension of utilization of personal information for the reason the personal information is being utilized beyond the purposes of utilization publicized in advance or for the reason the personal information was collected by fraud or other unlawful means in accordance with the provisions of Act on the Protection of Personal Information; and (c) when the Company confirms such Customers have requested correction of or suspension of utilization of her/his own personal information. When the Company determines not to correct or suspend utilizing personal information based on the reasonable reasons, the Company notifies our Customers of such decision. Provided, however, that this correction or suspension obligation shall not apply when the Company is not obligated to correct or suspend in accordance with Act on the Protection of Personal Information and other laws and regulations.
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9.2 Deletion of Personal Information
The Company deletes personal information and notifies our Customers of such deletion: (a) when such Customers request deletion of personal information, (b) when the Company confirms such Customers have requested deletion of her/his own personal information, and (c) when the Company determines acceptance of such request is necessary. Provided, however, that this deletion obligation shall not apply when the Company is not obligated to delete in accordance with Act on the Protection of Personal Information and other laws and regulations.
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10. Use of Access Analysis Tools and Targeting Advertisement
The Company uses and plans to use the access analysis tools and targeting advertisement services provided by the following external services providers for the purposes of grasping our Customers’ trends and distributing appropriate advertisement. Please refer to webpages publicized by each of the service providers for the services’ terms and conditions and policies etc.
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10.1 Google LLC
- Google Analytics Terms of Service https://marketingplatform.google.com/about/analytics/terms/jp/
- Google AdSense Online Terms of Service https://www.google.com/adsense/new/localized-terms?hl=ja
- Google Ads policies https://support.google.com/adspolicy/answer/6008942?visit_id=637029923606506714-3979934184&rd=1
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10.2 MIXPANEL, INC.
- Terms of Use https://mixpanel.com/legal/terms-of-use/
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11. Amendment to this Policy
The Company continuingly reviews this Policy for improvement and may amend this Policy if necessary. When the Company amends this Policy, the Company notifies our Customers of the amendment or publicizes the amended Policy on our website or by other means.
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12. Contact Information regarding Inquiry, Complaint, Request for Disclosure etc.
Win Techno, Inc.
Roppongi Hills North Tower 17F, 6-2-31 Roppongi, Minato-ku, Tokyo 106-6135, JapanAttention: Personal Information Protection Management Contact
[Inquiry Method] Please contact to support@win-techno.com. After confirmation of the content inquired, the Company sends email for communication and makes its efforts to implement appropriate measures if necessary.
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Amended as of September 1, 2019