Last modified: [April 1, 2018]
1. With respect to the handling of the personal information handled by any of our businesses, including employee information, we will comply with applicable laws and regulations, national guidelines, and other rules concerning the handling of personal information. In addition, we will create a personal information protection management system that conforms to the “Personal information protection management systems-Requirements” (JIS Q15001) act of the Japanese Industrial Standards, in order to protect personal information.
2. With respect to obtaining and using personal information, we will specify the purpose of use of such information and will not use the personal information beyond the extent of which is necessary for the achievement of such purposes (referred to as “unintended use”). In order to prevent unintended use, we will take appropriate management measures.
4. If we receive any complaints or inquiries concerning the handling of personal information, we will promptly carry out a factual investigation and take measures in good faith within a reasonable period.
5. In order to appropriately manage the obtained personal information, we will take security measures through organizational, personnel, material, and technical means and prevent or remedy leaks and losses/damage to such personal information.
6. In accordance with changes to the social conditions and environment, we will improve the measures for the protection of personal information by continuously updating the personal information protection management system.
Start Today Technologies, Inc.
Tatsuya Kubota (Chief Executive Officer)
Handling of the User’s Information
Article 1. Information to be Obtained and Manners of Obtaining
1. In order to achieve the purpose of use set forth in Article 2, the Company may, by using its technologies, automatically obtain the following User’s Information concerning the User’s use of WEAR when the User downloads, accesses, and uses WEAR:
(1) The device’s configuration information and device information such as the Device ID numbers can be obtained by the Company. This information is retrieved from the devices the User used to access WEAR, such as computers and smartphones (Such information may include the User’s IP address and browser type, including the identifiers). The hardware model, OS version, crash information, mobile network information, location information and information on accessed webpages may be obtained.
(2) Log data which can be obtained by the Company in relation to the User’s use of WEAR. Such information includes the User’s IP address, information of the webpage the User visited before accessing WEAR, browser type/configuration, and date/time or record of access. For the purpose of obtaining log data, the Company may send cookies to WEAR User’s computer or smartphone in order to record its log data and collect such cookie information. There are two types of cookie information; session cookies that remain active until the web browser is closed, and persistent cookies that are preserved in the web browser even after the web browser is closed. In order to delete the persistent cookies upon closing the web browser, the deleting must be performed through the configuration of the web browser. However, such cookie information shall not include information that identifies or specifies individual Users.
(3) Do Not Track is a privacy preference that User’s can set in their web browsers. When a User’s turn on the Do Not Track signal, the browser sends a message to websites requesting them not to track the User’s. For information about Do Not Track, visit https://allaboutdnt.com/. At this time, Company does not respond to Do Not Track browser settings or signals. In addition, Company may use other technology that is standard to the Internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to WEAR or one of the affiliated pages hosted at the Company domain. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.
2. In order to achieve the purpose of use set forth in Article 2, the Company may, through the User’s own action, obtain the following User’s Information concerning the User’s use of WEAR when the User downloads, accesses, and uses WEAR:
(1) The User’s name or nickname, User ID, sex, date of birth, height, password, e-mail address, country/region of residence, postal address, telephone number, social security number, personal photograph, clothing sizes, personal biography (self-introduction), URL of websites and blogs, Twitter account, Facebook account, and ANY OTHER INFORMATION THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“personal information”) provided to the Company while the User downloads, register with or use WEAR;
(2) The Post Contents that the User posted or shared with the other Users through WEAR’s posting function (including photographs, comments, and messages exchanged on WEAR between the User and another User) and other relating information; and
(3) If the User enters WEAR using an ID or account of a service provided by a third party (including but not limited to, Facebook and Twitter, other Social Network Services, and E-commerce websites, which shall be collectively referred to as “Third Party Websites”), then the information on such Third Party Websites that the User accepts can be obtained by the Company. This includes, for example, information of friends on Facebook, the contents the User's “likes” on Facebook, friends on Twitter, and other related information.
3. User’s Information the Company may ask the User to provide includes:
•Information that the User provides by filling in forms in WEAR. This includes information provided at the time of registering to use WEAR, subscribing to the Company’s service, posting material, and requesting further services. The Company may also ask the User for information when the User enters a contest or promotion sponsored by the Company, and when the User reports a problem with WEAR.
•Records and copies of the User correspondence (including email addresses and phone numbers), if the User contacts the Company.
•The User’s responses to surveys that the Company might ask the User to complete for research purposes.
•Details of transactions the User carries out through WEAR and of the fulfillment of the User’s orders. The User may be required to provide financial information before placing an order through WEAR.
•The User’s search queries on WEAR.
4. The Post Contents are posted and transmitted to others at each User’s own risk. Although the User may set certain privacy settings for such information by logging into his or her account profile, the User should be aware that no security measures are perfect or impenetrable. Additionally, the Company cannot control the actions of third parties with whom the User may choose to share the Post Contents. Therefore, the Company cannot and do not guarantee that the User’s Post Contents will not be viewed by unauthorized persons.
Article 2. Purpose of Use
(1) To operate WEAR, and to provide the Users with WEAR and its contents, and any other information, products or services that the User requests from the Company.
(2) To fulfill any other purpose for which the User provides it.
(3) To research, analyze, and prepare statistical data for the improvement and the development of new functions in WEAR.
(4) To conduct various campaigns, prize giveaways, and surveys relating to WEAR.
(5) To take measures towards various inquiries received from Users and after-sales services.
(6) To deliver updated information and newsletters regarding WEAR, and to deliver various information regarding other related services that are provided by the Company.
(7) To give notice of information that is necessary for the operation of WEAR.
(8) To inform of services and projects to be implemented by the Company or its related companies (including but not limited to, subsidiaries and equity method affiliates).
(9) To authenticate the User and to automatically display the registered information of the authenticated User on various screens.
(10) To practice rights or perform obligations in accordance with contracts, laws, and regulations.
The Company may also use the User’s Information to contact the User about the Company’s own and third parties' goods and services that may be of interest to the User. If the User does not want the Company to use his or her information in this way, the User should adjust his or her user preferences in the account profile. For more information, see Article 8.
The Company may use the information it collects to display advertisements to the Company’s advertisers' target audiences. Even though the Company does not disclose the User’s personal information for these purposes without the User’s consent, if the User clicks on or otherwise interact with an advertisement, the advertiser may assume that the User meets its target criteria.
Article 3. Consent
Article 4. Amendments
Article 5. Third-Party Information Collection
When the User uses WEAR or its content, certain third parties may use automatic information collection technologies to collect information about the User or his or her device. These third parties may include:
•Advertisers, ad networks, and ad servers.
•The User’s mobile device manufacturer.
•The User’s mobile service provider.
These third parties may use tracking technologies to collect information about the User when he or she uses WEAR. The information they collect may be associated with the User’s personal information or they may collect information, including personal information, about the User’s online activities over time and across different websites, apps, and other online services websites. They may use this information to provide the User with interest-based (behavioral) advertising or other targeted content.
The Company does not control these third parties' tracking technologies or how they may be used. If the User has any questions about an advertisement or other targeted content, he or she should contact the responsible provider directly.
Article 6. Consignment of the User’s Information
To the extent of which the Company clearly specified as necessary to achieve the purpose of use, the Company may consign the User’s Information obtained from the Users to a third party that has executed applicable contracts with the Company, concerning the management and retaining of the User’s Information with the Company.
Article 7. Providing the User’s Information to a Third Party
1. The Company shall not provide or disclose the User’s Information obtained from the Users unless:
(1) It is in accordance with laws and regulations.
(2) It is to fulfill the purpose for which the User provides it.
(3) It is for any other purpose disclosed by the Company when the User provides the information.
(4) The User has provided prior consent.
(5) When the Company believes disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, its customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
(6) The business is succeeded by way of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about WEAR Users is among the assets transferred..
(7) The User’s Information is to be shared between the Company and its related companies (including but not limited to, subsidiaries and equity method affiliates).
(8) The User’s Information is consigned in accordance with Article 5.
(9) It is to third parties to market their products or services to the User if the User has not opted out of these disclosures. The Company contractually requires these third parties to keep personal information confidential and use it only for the purposes for which the Company discloses it to them. For more information, see Article 8.
(10) To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
2. The Company may compile several Users' Information and directly use or share them with a third party for marketing and promoting activities, provided that the possibility to identify individual Users from such compiled Information is eliminated.
Article 8. Voluntary Nature of Providing Personal Information and Results to Arise if such Information is Not Provided
The Company strives to provide the User with choices regarding the personal information the User provides to the Company. This Article 7 describes mechanisms the Company provides for the User to control certain uses and disclosures of over the Users’ Information.
(2) Location Information. The User can choose whether or not to allow WEAR to collect and use real-time information about the User’s device's location through the device's privacy settings. If the User blocks the use of location information, some parts of WEAR may then be inaccessible or not function properly.
(3) Promotion by the Company. If the User does not want the Company to use the User’s email address to promote the Company’s own or third parties' products or services, the User can opt-out by adjusting his or her user preferences in the User’s account profile. The User can also always opt-out by sending the Company an email stating his or her request from https://wear.net/contact/.
(4) Targeted Advertising by the Company. If the User does not want the Company to use information that the Company collects or that the User provides to the Company to deliver advertisements according to the Company’s advertisers' target-audience preferences, the User can opt-out by adjusting his or her user advertising preferences in his or her account profile by checking or unchecking the relevant boxes or by sending the Company an email stating his or her request from https://wear.net/contact/.
(5) Disclosure of the User’s Information for Third-Party Advertising and Marketing. If the User does not want the Company to share his or her personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, the User can opt-out by adjusting his or her user preferences in his or her account profile by checking or unchecking the relevant boxes or by sending the Company an email stating his or her request from https://wear.net/contact/.
The Company does not control third parties' collection or use of the User’s Information to serve interest-based advertising. However these third parties may provide the User with ways to choose not to have his or her information collected or used in this way. The User can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
All of the User’s Information the Company obtains shall be provided at the User’s own discretion. It must be noted that if all or part of the information the Company obtains in relation to WEAR is not provided from a User, the Company may not accept such User to use WEAR.
Article 9. Publication of the Information
1. The User ID of the Users shall be displayed on the website provided to WEAR, and shall be publicized to all of the Users. The Post Contents shall also be publicized in the same manner if it is set to be public.
2. If the User (i) exchanges messages or otherwise communicates with other Users by using WEAR, or (ii) uses the function that shares the Post Contents or its related information, the texts, pictures, videos, sounds, URLs of linked websites, or other information included in such messages and contents may be notified or publicized to the other Users.
3. If the User links to WEAR a website operated by a third party by using WEAR’s functions, all or part of the information publicized on WEAR shall be publicized on such Third Party Website as well.
4. The Company shall not assume any liability for the damages and losses, if any, incurred by the Users due to the publication of information through using WEAR.
Article 10. Obtaining Information of Those Under the Age of 13
1. Those under the age of 13 are not allowed to become a User of WEAR. The Company shall not collect the User’s Information of those under the age of 13 and shall not accept the registration of such Users.
Article 11. Procedures for the Disclosure of the User’s Information
1. The Company accepts the User’s request to disclose his or her own personal information subject to the disclosure, notify the purpose of use, amend the personal information subject to disclosure if it does not comply with the facts, suspend the use of personal information, or suspend the provision of such information to a third party (collectively referred to as “Disclosures”).
(1) Place to request Disclosures:
(i) For requesting by e-mail, please contact the Company at the [E-mail Address for Inquiries Concerning the User’s Information] which is inserted in Article 14;
(ii) For requesting by mail, please mail the prescribed requesting form to the following address with the required documents attached. START TODAY CO.,LTD.
WEAR Customer Support Center
World Business Garden Marive West 16F
2-6-1 Nakase, Mihama-ku, Chiba City, Chiba Prefecture
(2) Documents to be Submitted:
(i) Request for the Notification of the Purpose of Use and Disclosure of Personal Information.
(ii) Request for the Amendment of Personal Information.
(iii) Request for the Suspension of Using Personal Information.
(iv) Documents for identification (driver’s license, passports, etc.).
(v) Statutory agents shall submit a document that certifies the authority of statutory representation in addition to (iv).
Please note that among the above mentioned requests, the User shall be charged a certain amount prescribed by the Company for requests for disclosures and requests for notification of the purpose of use.
For other specific procedures for the requests of disclosures, please inquire via the inquiry desk set forth in Article 14.
Article 12. Termination of Services and the Handling of Information
1. If the User completes registration cancelling procedures on WEAR, or the Company cancels the User’s registration on WEAR, the Company shall promptly suspend the publication of such User’s Information on WEAR. However, the messages that have already been exchanged between other Users and information already provided through the sharing function when such suspension is performed may continue to be publicized after account cancellation.
2. The Company may, in accordance with related applicable laws and regulations, and in a manner that is reasonably secure from the Company’s technological aspect, continue to retain the archives of the User’s Information limited to those minimum necessary for a legitimate business purpose.
Article 13. Data Security
The Company has implemented measures designed to secure the User’s personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information the User provides to the Company is stored on its secure servers behind firewalls. Any payment transactions and OTHER INFORMATION will be encrypted using SSL technology.
The safety and security of the User’s information also depends on each User. Where the Company has given the User (or where the User has chosen) a password for access to certain parts of WEAR, the User is responsible for keeping this password confidential. The Company asks the User not to share his or her password with anyone. The Company urges the User to be careful about giving out information in public areas of WEAR like message boards. The information the User shares in public areas may be viewed by any User of WEAR.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although the Company does its best to protect the User personal information, the Company cannot guarantee the security of the User personal information transmitted through WEAR. Any transmission of personal information is at the User’s own risk. The Company is not responsible for circumvention of any privacy settings or security measures the Company provides.
Article 14. Inquiry Desk
The Company accepts inquiries concerning the handling of the User’s Information on WEAR at the following desk.
START TODAY CO.,LTD. WEAR Customer Support Center
*In order to improve the quality of its supporting services and to collect information correctly, the Company may record and retain the contents of the conversation between the Company and the User.
[Manager of the Protection of Personal Information]
(START TODAY CO.,LTD. Executive Officer)