Privacy Policy

Compliance with Laws and Regulations

In the acquisition, usage and all other handling of stakeholder personal information, GMO Internet Group, Inc. complies with the laws, the guidelines and this Privacy Policy.

Declaration of Specific Usage Purposes

GMO Internet Group, Inc. determines and declares in advance the purpose of use of personal information obtained, to the extent possible. When personal data is obtained directly as a result of details provided by a stakeholder in a contract or other documents, the purpose of use shall be explicitly stated in advance. Please refer to the usage purposes in section 2 of each service provider.

Use within the Scope of Usage Purposes

GMO Internet Group, Inc. uses stakeholder personal information only to the extent necessary to achieve previously determined and declared usage purposes. However, we may use stakeholder personal information outside the scope of usage purposes where provided for in Article 18, paragraph 3 of the law and in Article 5, paragraph 3 of the guidelines.

Period of Retention

Except where otherwise prescribed by law, GMO Internet Group, Inc. determines the length of time it is necessary to retain stakeholder personal information to achieve the objectives of pre-disclosed usage purposes. At the expiry of this period or when the objectives of the usage purposes are achieved, stakeholder personal information is promptly destroyed. However this limitation does not apply in cases specified in Article 10, paragraph 1 of "the guidelines".

Secure Information Management

GMO Internet Group, Inc. strives to maintain current and accurate records of stakeholder personal information, and take necessary and appropriate measures to ensure secure management in order to safeguard against unauthorized access, falsification and damage. If stakeholder wish to request disclosure of details, GMO Internet Group, Inc. will promptly respond to the stakeholder request. Please contact the inquiry desk indicated in the Contact Information for specified section 9. Claims and Inquiries.

Employee Supervision

GMO Internet Group, Inc. conducts necessary and appropriate supervision of employees to ensure secure management of stakeholder personal information. In addition we conduct training to ensure employees handle personal information appropriately.

Subcontractor Supervision

GMO Internet Group, Inc. may entrust some or all of the handling of stakeholder personal information to a third party within the scope of usage purposes. When selecting subcontractors, we verify that personal information is handled suitably and demand that stakeholder personal information be handled appropriately. In addition GMO Internet Group, Inc. conducts necessary and appropriate supervision of the subcontractor through measures such as the inclusion in contracts of provisions relating to the auditing of personal information.

Provision of Information to Third Parties and Shared Usage

GMO Internet Group, Inc. will not disclose stakeholder personal information to third parties without consent, except where provided for under Article 27, paragraph 1 of the law and Article 15, paragraph 1 of the guidelines or where otherwise allowed by all other regulations. In addition, records pertaining to the provision of such information to the third party and records pertaining to the confirmation of the receipt of such information from the third party (hereinafter collectively referred to as "Records of provisions to a third party") shall be kept. If stakeholder wish to request disclosure of your personal information, please make your request in accordance with our prescribed procedures as described in section 5. Disclosure of Personal Information.
However, disclosure is not limited to cases that fall under Article 9 of the law.

Where certain personal information is supplied to a third party as allowed for under Article 27, paragraph 1 of the law and Article 15 paragraph 10 of the guidelines, GMO Internet Group, Inc. is not required to treat that party as a third party and may entrust the handling of stakeholder personal information, provide or share the use of stakeholder personal information with specified individuals without obtaining prior consent from the stakeholders. The scope of shared use is confined mainly to the GMO Internet Group, Inc. However, information may also be shared with other specified parties. Details of shared stakeholder personal information, usage purposes and the relevant privacy officer are listed below in section 3. Provision of Information to Third Parties and Shared Usage.

Requests for Disclosure etc.

Stakeholders wishing to be informed of the usage purposes of personal information, or who seek disclosure, correction, addition or removal of details, or who wish to prevent GMO Internet Group, Inc. or a third party using personal information should apply in accordance with our procedures. Please refer below to the procedures for requesting disclosure of personal information in section 9. Claims and Inquiries.

Management of Claims

GMO Internet Group, Inc. deals promptly and appropriately with claims and other inquiries from stakeholders regarding the handling of personal information. Please find contact details at the end of this document.

Handling of Leakages

In occurrences such as the leakage of personal information, relevant facts will be promptly provided to stakeholders. and the leakage will be quickly and appropriately handled.

Ongoing Improvement

GMO Internet Group, Inc. strives to continually improve internal handling of personal information through the improvement of internal regulations regarding the protection of personal information and through continued employee training and internal auditing.

Ⅱ）Usage Purposes of Personal Information

Each company in the GMO Internet Group, Inc. has defined usage Purposes of personal information. Information shared among group companies shall be used in accordance with the relevant usage purposes.

Ⅲ）Shared Personal Details

Name, address, email address, telephone number, contract details, and other information within the limits of the above usages purposes.

Ⅳ）

When the stakeholder personal information is shared outside the group special measures are required.

Ⅴ）

Stakeholder personal information may be supplied to third parties in the provision of this service only after consent is obtained in advance from the stakeholder.

Ⅵ）

In some cases the handling of personal information is entrusted to a company outside the group. However, in these cases GMO Internet Group, Inc. only selects companies that have higher personal information protection management standards than our own. Required measures are taken in regard to a duty of confidentiality agreement. At the same time GMO Internet Group, Inc. ensures appropriate management and supervision of the concerned company.

Ⅶ）

GMO Internet Group, Inc. may disclose personal information when ordered to do so by the government or a court order.

1）

GMO Internet Group, Inc. acquires personal information only as necessary and through appropriate measures.

2）

GMO Internet Group, Inc. may set cookies on client computers for certain reasons. We use personal information (IP address and the account names, passwords and IDs required to use some services) contained in cookies. This information is only used for the purposes listed in the usage purposes stated by GMO Internet Group, Inc.

3）

Some emails sent to customers advertising GMO Internet Group, Inc. services direct the customer to a URL with parameters (personal URL) that contains encrypted information identifying the customer. Information about customer browsing activity that is collected from these personal URLs may be used by our services, however information is only used for the purposes listed in the usage purposes stated by GMO Internet Group, Inc.

1）

When an individual seeks disclosure, amendment, deletion or notification of usage purposes in regard to their own personal information (excluding information acquired from stockholders), GMO Internet Group, Inc. shall respond within a reasonable time in accordance with the Act on the Protection of Personal Information Articles 37 following the process determined by GMO Internet Group, Inc. and laid out below. Where no such data exists, the individual shall be informed immediately. (In regard to requests about personal information acquired from stockholders such as transfers and bank accounts to which dividends are paid, it is necessary to inquire to the company's stockholder register administrator, Sumitomo Mitsui Trust Bank, Limited. Please see section 9. Complain and Inquiries for details regarding stockholder inquiries.)

2）

Requests for disclosure etc. shall be dealt with in the following manner. Please be aware that we will not accept requests by telephone, fax, email, verbally or by any method other than that laid out below.

（6）

In regard to requests for notification of purpose of usage, disclosure of personal data, amendment of personal data, disclosure of records of provisions to a third party, after verifying the identity of the sender of the documents, GMO Internet Group, Inc. will send out an invoice for handling fees. Please submit payment by bank transfer to the account listed on the invoice. Any bank transfer costs should be paid by the customer. Handling fees are charged for each service for which information is disclosed.

In regard to requests other than notification of purpose of usage and disclosure of personal data, amendment of personal data, disclosure of records of provisions to a third party we will proceed as soon as verification is complete

（7）

In regard to requests for notification of usage purposes and disclosure of personal data, amendment of personal data, disclosure of records of provisions to a third party after confirming receipt of payment, GMO Internet Group, Inc. will send a response by certified mail.
* If you have any queries regarding the response please inquire at the relevant point of contact listed below section 9. Complain and Inquiries.

1）Creation of Anonymous Processed Information

1. (1) We process the information appropriately in accordance with the standards set forth in laws and regulations.
2. (2) We will take security control measures to prevent the leakage of deleted information and information regarding the method of processing in accordance with the standards set forth in laws and regulations.
3. (3) We will disclose the items of information contained in the Anonymous Processed Information we have created as follows if we have.
4. (4) We will not collate the information with other information in order to identify the individual whose personal information was the source of creation.

2) Providing Anonymous Processed Information to third parties

1. (1) We will publicly announce in advance the items of information concerning individuals included in the Anonymous Processed Information to be provided and the method of provision as follows if we have.
2. (2) We will clearly indicate to the third party to whom the information is to be provided that the information is Anonymous Processed Information.

1) Creation Pseudonymized Information

1. (1) We will create the information after appropriate processing in accordance with the standards set forth in laws and regulations.
2. (2) We will create information that has been deleted during the creation process or information regarding the method of processing (hereinafter collectively referred to as "Deleted Information, etc.") in accordance with the standards set forth in laws and regulations. We will take security control measures to prevent the leakage of information that has been deleted during the creation process or information regarding the method of processing (hereinafter collectively referred to as "Deleted Information, etc.") in accordance with the standards prescribed by law.

2) Obtaining Pseudonymized Information and Deleted Information, etc.

1. (1) We will take security control measures to prevent the leakage of Deleted Information, etc., in accordance with the standards set forth in laws and regulations.
2. (2) When we have acquired personal information, especially processed Pseudonymized Information, we will promptly disclose the purpose of use of such information in Section 2. Purpose of Use of Personal Information unless otherwise publicly announced in advance.

3) Handling processed Pseudonymized Information as a database

1. (1) We will take necessary and appropriate security control measures to protect against unauthorized access, falsification, leakage, loss, or damage.
2. (2) We will not collate personal information with other information in order to identify the individual whose information was used to create the information.
3. (3) We will not use the contact or other information contained in such pseudonymized information to make telephone calls, send postal or letter mail, send telegrams, transmit by facsimile machine or electromagnetic means, or visit a residence.
4. (4) Other handling of information, except for cases exempted under Article 41, Paragraph 9 of the law, shall be in accordance with the policy on the handling of personal information in Section 1. Privacy Policy

1) Cases in which Personally Relevant Information is provided by a third party from whom the information is provided and acquired as personal data

2) Providing Personal Related Information to a third party as a database

1. (1) We will provide Personal Related Information to the third party to whom we disclose the information below if we have. The third party may match the Personal Related Information provided with the Personal Information in its possession, resulting in personal data that identifies the individual. The recipients of the information and the items of personally identifiable information to be provided will be described below if we have.
2. (2) The purpose of use of Personal Related Information at the recipient after it is provided and acquired as personal data will be notified or announced at the recipient.