CommentScreen K.K. (hereinafter referred to as the "Company") shall set forth the following privacy policy (hereinafter referred to as the "Policy") with respect to the handling of personal information in the services that the Company provide (hereinafter referred to as the "Service").

Article 1 (Personal Information)

The term "Personal Information" as used in this Policy shall mean "Personal Information" as set forth in the Act on the Protection of Personal Information and passwords related to the use of the Service.

Article 2 (Method of Collecting Personal Information)

The Company may acquire the following pieces of information from users in the Service:

1. User authentication information, information acquired at the time of the user's registration of the Service or change of the registered data, and information acquired through inquiries or communications from the users. Including, but not limited to, name, email address, company name, telephone number, and content of inquiries to our support team.

2. Information automatically acquired through the user's use of the Service or browsing the Company’s Site. Pieces of information, includes but not limited to, the usage of the Service, the access time log to the Service, the OS of the device used for the Service, the type and version information of the application and browser used, the pages viewed (including the third-party websites that the User used prior to using the Service), the information of the device used to access the Service, the model of hardware, IP address, MAC address, and other unique identifiers, selected languages, advertising identifiers, serial numbers, operational information of the device and its mobile network information, Posted Data sent to the Company while using the Service, etc.

3. The Company may obtain user information if a user allowed the Company through third-party operated services to obtain it. In such cases, the Company may adopt the information obtained in such a manner to the information independently obtained from the user to improve the Service or provide advertisements that are of interest to the user.

Article 3 (Purpose of Collecting and Using Personal Information)

The Company may collect and use Personal Information for the following reasons:

1. For the provision and operation of the Service

2. To answer inquiries from users (including identity verification)

3. For sending e-mails of new features, updates, campaigns, and other services the Company offers

4. For communications necessary in case of maintenance, important notices, etc.

5. To identify and refuse to use the Service against users who have violated the Terms of Use or who intend to use the Service for unauthorized or improper purposes

6. To enable users to view, change, or delete their registered information and usage status

7. For billing purposes on the Registered Users on a paid plan

8. To collect and analyze data containing personal information to maintain and improve the convenience and quality of the Company’s Websites, products, and/or Service

9. To distribute and display advertisements and content based on personal attributes, terminal information, geoinformation, behavior history, etc.

10. For improvement of the Company’s Website, products, or Services, as well as development and marketing of new products or Service

11. Purpose incidental to the above-mentioned purpose of use

Article 4 (Change of Purpose of Use)

1. The Company shall change the purpose of use of Personal Information only if it is reasonably recognized to be relevant to that before the change.

2. Any change in the purpose of use shall be notified to the user or made public on this website in the manner prescribed by the Company with respect to the purpose changed.

Article 5 (Provision of Personal Information to a Third Party)

1. The Company will not provide Personal Information to any third party without obtaining the prior consent of the user except in the following cases: (Provided, however, that this shall not apply to cases where it is permitted by the Personal Information Protection Law or other relevant laws and regulations)
   1. When it is necessary for the protection of the life, body, or property of a person and yet it is difficult to obtain the consent of the person
   2. Cases in which it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children and in which it is difficult to obtain the consent of the person
   3. Cases in which it is necessary to cooperate with a national agency or local public entity, or a person commissioned thereby in executing the affairs prescribed by laws and regulations, and in which obtaining the consent of the person in question is likely to hinder the execution of the affairs
   4. In the event the Company notifies or publicly announces the following matters in advance and the Company notifies the Personal Information Protection Committee:
      1. Including provision to a third party for the purpose of use
      2. Items of data to be provided to third parties
      3. Suspension of the provision of Personal Information to a third party in response to a request by the third party by means or method of provision to a third party
      4. Methods of accepting requests from the person in question
   5. Notwithstanding the provisions of the preceding clause, in the following cases, the recipient of said information shall not fall under the category of a third party:
      1. In the event the Company entrusts all or part of the handling of Personal Information to the extent necessary for the achievement of the purpose of use
      2. Cases where Personal Information is provided upon the succession of business due to a corporate merger, or etc.
      3. Cases where Personal Information is used jointly with a specific person and where the Personal Information is either notified to or put in a readily accessible condition for the person in advance regarding the items of Personal Information to be used jointly, the scope of persons to be used jointly, the purpose of use of the person, and the name or nickname of the person responsible for the management of the Personal Information

Article 6 (Disclosure of Personal Information)

1. The Company will disclose Personal Information to him/herself without delay when requested by a person to disclose such his/her own Personal Information. Provided, however, that the Company may refuse to disclose all or part of the information in the event of disclosure that falls under any of the following, and in the event the Company decides not to disclose the information, the Company shall notify the person of such decision without delay. A fee of ¥1,000 per case will be charged for the disclosure of Personal Information in this manner:
   1. Cases where there is a risk of harm to the life, body, property, or other rights and interests of the person or a third party
   2. Cases in which the proper execution of our business is likely to be seriously hindered
   3. In the event of any other violation of laws and regulations

2. Notwithstanding the provisions of the preceding clause, information other than Personal Information, such as activity log and characteristic information, shall not be disclosed in principle.

Article 7 (Correction and Deletion of Personal Information)

1. In the event the Personal Information in the possession of the Company is incorrect, the User may request that the Company correct, add, or delete the Personal Information (hereinafter referred to as the "Correction, etc.") in accordance with the procedures set forth by the Company.

2. In the event the Company determines that it is necessary to comply with the request as set forth in the preceding clause upon receipt of a request from the User, the Company shall correct such Personal Information without delay.

3. The Company will notify the user of any correction or decision not to make such correction in accordance with the provisions of the preceding clause without delay.

Article 8 (Suspension of Use of Personal Information, etc.)

1. In the event the Company is requested by an individual to suspend or delete the use of the Personal Information (hereinafter referred to as "Suspension of Use") due to reason that the Personal Information is believed to be handled beyond the scope of the purpose of use or is obtained through fraudulent means, the Company will conduct necessary investigations without delay.

2. In the event it is deemed necessary to comply with the request based on the results of the investigation as set forth in the preceding clause, the Company shall suspend the use of such Personal Information without delay.

3. The Company will notify the user of any suspension of use or decision not to suspend use in accordance with the provisions of the preceding clause without delay.

4. Notwithstanding the provisions of the preceding two clauses, in the event the Company has a large number of expenses for the Suspension of Use, etc., or in the event it is difficult to implement Suspension of Use, etc., the Company shall take alternative measures necessary to protect the rights and interests of the subject Users.

Article 9 (Change of Privacy Policy)

1. The content of this Policy may be changed without notice to the user, except for matters otherwise provided by laws or ordinances or in this Policy.

2. Except in cases separately stipulated by the Company, the revised Policy shall become effective upon its publication on this Website.

Article 10 (Contact Information)

For inquiries regarding this Policy, please contact the following:

Address: 2-A, Hoshiya Building, 21-3, Amakubo 3-chome, Tsukuba-shi, Ibaraki 305-0005

Company Name: CommentScreen K.K.

Department: Support Team

E-mail address:support@commentscreen.com