This Privacy Policy is made to: (i) protect Personal Information as defined below, (ii) establish certain rules and procedures to protect Personal Information, and (iii) ensure that our employees observe and understand the importance of protecting Personal Information and taking the necessary measures to protect such Personal Information carefully, including by promoting such protection.

Article 1 (Personal Information)

“Personal Information” in this Privacy Policy means information which can identify a specific living individual by name, date of birth or other description contained in such information; or which includes a code that can identify a specific individual.

Article 2 (Acquisition and Use of Personal Information)

We may acquire from and use Personal Information of users of our services (the “Services”) (individually “User” or collectively “Users”) within the scope necessary for the following purposes. If we seek to use such Personal Information beyond the following purposes, we will obtain prior written consent of the User whose Personal Information is concerned:

  1. To perform the Services;
  2. To improve and refine the Services, or to develop new services;
  3. To notify Users of new functions or updated information of the Services, campaigns, and our other services (including via e-mails, flyers, and other direct mails);
  4. To inform Users of any maintenance of the Services or important news regarding the Services;
  5. To answer comments and questions from Users regarding the Services (including to confirm Users identification);
  6. To report to Users the situation regarding the use of the Services;
  7. To request Users to answer any questionnaires and questions regarding the Services or to attend events, or to report the answers of such questionnaires and questions or results of such events to such Users;
  8. To conduct research on and provide analysis of the history of the Services and to utilize the results of such research and analysis for the improvement and development of the Services and to deliver any promotional materials;
  9. Upon the approval or application by the Users, to provide Personal Information to third parties, including companies participating in an event that we hold; and
  10. To identify Users who have violated the Terms of Use or who intend to use the Services for unlawful or illegitimate purposes, and to block their use of Services.

Article 3 (Management and Protection of Personal Information)

We will carefully and closely manage Personal Information and will not disclose or provide such Personal Information to any third parties without the prior written consent of Users whose Personal Information is concerned, except in the following circumstances:

  1. if such disclosure of Personal Information is necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of such person;
  2. if such disclosure of Personal Information is necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person whose Personal Information is concerned;
  3. if such disclosure of Personal Information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by such state organ or local government in executing the affairs required by laws and regulations, and if obtaining the consent of the person whose Personal Information is concerned is likely to hinder the execution of such affairs;
  4. if we entrust the handling of Personal Information in whole or in part within the scope necessary to achieve our purposes as stipulated in Article 2, in order to implement our operations smoothly;
  5. if such Personal Information is obtained as a result of the succession of business in a merger or otherwise;
  6. if such Personal Information is used jointly between specific individuals or entities, and in such case if the scope, and purposes of such joint use, and the name of the individual or business operator responsible for the management of such Personal Information have been notified to the User(s) whose Personal Information is concerned in advance; and
  7. if it is permitted by laws and regulations to disclose or provide Personal Information.

We will, take preventive and corrective measures against risks resulting from any unlawful access to Personal Information, or any loss, destruction, falsification, or leakage of Personal Information.

Article 4 (Entrustment of Personal Information Handling)

We may entrust an individual or a business operator to handle Users’ personal data in whole or in part. In such case, we will examine their eligibility sufficiently, obligate such individual or business operator to maintain confidentiality obligations by contract, and will perform the necessary and appropriate supervision over such individual or business operator.

Article 5 (Joint Use)

We will not jointly use Personal Information of Users; however, we will de-identify such Personal Information and use the same anonymously and jointly with third party to the extent necessary for the following scope and purpose of use:

<Purpose of Joint Use>

<Scope of Personal Information for Joint Use>