Kurashi Study Privacy Policy

“Kurashi Study” (hereinafter referred to as the “Service”) is an application and web service provided and operated by SUN Co., Ltd. (hereinafter referred to as the “Company”). The Company recognizes the importance of protecting customers’ personal information, and will comply with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act") and strive for appropriate handling and protection in accordance with the following privacy policy (hereinafter referred to as the "Policy").

1. Information to be acquired and method of acquisition

The personal information that the Company may acquire, by each method of acquisition, is as follows.

1. Information acquired directly from the user
   The Company may acquire the following information from the user in the course of the member registration and use of the Service.

   • Name, nickname, and the user’s name
   • Age
   • E-mail address
   • Area of residence (city, ward, town or village)
   • Usage history of services
   • Other information specified in the application and the website as information to be acquired by the Company
   • History of ticket purchase and subscription usage

2. Technical information
   When the user accesses the Service with a terminal or mobile device, the Company may acquire the following technical information.

   • Terminal type
   • Terminal identifier
   • Browser type
   • Referrer
   • IP address
   • Cookie
   • Any information that the user has agreed to provide on the terminal, such as name, phone number, nationality, user name, etc. associated with the terminal.
   • Other advertising identifiers

3. Information acquired based on the user's individual consent
   The Company acquires the following information when the user agrees to provide it on the terminal.

   • Location information

4. Information acquired through collaboration with external services
   In the event that the user permits the linkage with external services in the use of the Service, the Company will acquire the following information from such external services.

   • ID used by the user for the external service
   • Other information that the user has permitted to be disclosed to the linked party according to the privacy settings of the external service

2. Purpose of use

The Company will use the acquired User’s information for the purposes specified below. Specific examples of utilization are described in each item.

1. To enable the user to use the Service smoothly;

• Personal authentication and identification of users, etc.
• Ticket issuance, calculation, and administration of the ticketing system
• Billing and payment of fees
• Management of in-app events

2. To conduct various surveys and analyses necessary for each purpose of use

• Conducting questionnaires regarding this service and new services to users
• Analysis of survey results
• Analysis of the frequency and duration of use of the Service and other usage conditions

3. To respond to inquiries, opinions, and other communications from users

• Identification of the user who made the inquiry
• Responses to user opinions and inquiries
• Improvement of quality in response to user inquiries

4. To plan new projects, advertise services, and conduct marketing for future services

• Analysis of the frequency and duration of use of the Service and other usage conditions of the Users
• Improvement of the Service and development of new services based on the results of analysis of user usage, survey results, user inquiries, etc.
• Analysis of users' preferences and interests and promotion, advertisement, and marketing using such analysis

5. To prevent fraud, and to amend the terms of use

• Investigation of violations of the Terms of Use, prohibited acts, registration of false information, fraud, unauthorized access, and other illegal acts
• Changes to the Terms of Use

6. To contact the user as necessary, such as for other important notices regarding the Service

3. Disclosure of personal information to a third party

The Company shall not provide any personal information among the user’s information to any third party without obtaining the prior consent of the user. However, in the following cases, the Company may provide the user’s information to a third party (including a third party located outside of Japan).

1. When providing personal information to an external service operator in order to link with the external service or authenticate the user using the external service (In such cases, we shall conduct necessary and appropriate supervision to ensure the security of the personal information provided.)
2. When it is necessary for the Company to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining the consent of the user would interfere with the performance of the said affairs.
3. Other cases permitted by law
4. When there is a need to protect a human life, body, or property, and it is difficult to obtain the customer's consent
5. When the Service entrusts all or a part of the handling of personal information to the extent necessary to achieve the purpose of use
6. When personal information is provided in connection with the succession of business due to a merger or other reasons

4. Access analysis tools

1. The Service may use cookies and similar technologies. These technologies are useful in understanding the usage of the Service, etc. and contribute to the improvement of the Service. The user who wishes to disable cookies is able to do so by changing the settings of the web browser. However, if cookies are disabled, some functions of the Service may not be available.
2. The Service uses Google Analytics to help analyze and improve the site. Your web browser will automatically send certain information to Google (for example, the web address of the page you are visiting and your IP address). Google may set a cookie on your browser or read an existing cookie in order to collect data. By using the Service, the user shall be deemed to have given permission for such data processing to be carried out by Google in the manner and for the purposes described above.
3. The Service may contain advertisements distributed by third parties. In that case, the third party may acquire the cookie information, etc. of the user who visited the Service. The acquired cookie information, etc. will be handled in accordance with the privacy policy of the relevant third party. The use of cookie information, etc. for the distribution of advertisements can be stopped. Cookies will not be used to identify the user or invade the privacy of the user.

5. Disclosure of Personal Information

1. When the Company is requested by a user to disclose, correct, delete, or discontinue the use of personal information or records provided to third parties (hereinafter referred to as "disclosure, etc.") in accordance with the provisions of the Personal Information Protection Act, the Company shall make the disclosure, etc. the information to the user without delay after confirming that the request is made by the user himself/herself. However, this does not apply in cases where the Company is not obligated to disclose such information under the Personal Information Protection Act or other laws and regulations.

2. If the person in question requests disclosure, etc., of his/her personal information, the Company will disclose, etc. it to him/her without delay. However, the Company may decide not to disclose, etc. all or a part of the information if disclosure, etc. would cause any of the following to occur, and if the Company decides not to disclose, etc. the information, it will notify the person without delay.

   1. When there is a threat of harm to the life, body, property, or other rights or interests of the customer or a third party
   2. When there is a threat of significant hindrance to the proper execution of the Company's business
   3. When it would violate laws and regulations
   4. When the Company is unable to confirm that the request for disclosure has been made by the customer him/herself

3. Contact for requests for disclosure, etc.

   Requests for disclosure, etc. shall be directed to the personal information inquiry section below.

4. Procedures for requesting disclosure, etc.

   1. After receiving your inquiry, the Company will mail you the prescribed request form "Request Form for Disclosure of Retained Personal Data"
   2. Please send the completed request form, documents proving that the person is a representative if the request is made by the representative, and a postal money order for the charge (only for request for notification of purpose of use, and for request for disclosure) to the personal information inquiry section above.
   3. After receiving the above request form, in order to confirm your identity, the Company will inquire about two items of personal information registered with the Company that can be used to confirm your identity (e.g., telephone number and date of birth).
   4. In principle, the response will be made in writing (by mail in a sealed envelope) to the person in question.

5. If the request is made by a representative, a document verifying the representative's identity If the person requesting disclosure, etc. is a representative, please enclose documents proving that the person is a representative and documents proving the representative's identity. The registered domicile information included in each document should be limited to the prefecture, and information after that should be blacked out. Send documents that do not contain your individual number, or please black out all digits.

   Documentation proving that you are a representative

   1. In the case of an authorized representative of the person making the request for disclosure, etc.;

      1. A power of attorney from the principal (original)

   2. In the case that the representative is a legal representative of a minor;

      A copy of either of the following;

      1. Certified copy of family register
      2. Certificate of residence (with the family relationship listed)
      3. Other official documents that can confirm the right of legal representation

   Documents proving the representative's identity;

   3. Driver’s license
   4. Passport
   5. Health insurance card
   6. Certificate of residence
   7. Charges for requesting notification of purpose of use or requesting disclosure

6. 1,000 yen per request.
   (Please enclose a postal money order with the request form you send)

7. Documents sent to us will be disposed of as soon as the purpose for which they were sent is achieved. Please note that the documents will not be returned for any reason.

6. Management of personal information

IIn order to prevent risks such as leakage, loss, and damage of personal information, the Company will take reasonable safety measures, invest management resources that match the actual situation of the business, and continuously improve the personal information security system. In addition, the Company will promptly take corrective measures when it is determined that there is a security problem. Specific security control measures are as follows.

1. Formulation of Personal Information Protection Guidelines

To ensure the proper handling of personal data, we have formulated these guidelines (Privacy Policy).

2. Establishment of Rules for Handling Personal Data

Basic handling methods for acquisition, use, storage, etc. of personal data are in place.

3. Organizational Safety Control Measures

We clarify the employees who handle personal data and the scope of personal data handled by such employees, and have in place a system for reporting and communicating with the person in charge in the event that we become aware of facts or signs of violation of the Personal Information Protection Law or internal regulations on the handling of personal data.

4. Personnel Safety Control Measures

Regular training is provided to employees concerning points to keep in mind when handling personal data.

5. Physical security control measures

In the areas where personal data is handled, the Company implements access control for employees, restricts the equipment and other items they may bring in, and implements measures to prevent unauthorized persons from accessing personal data.
In addition, measures are taken to prevent theft or loss of equipment, electronic media, and documents that handle personal data, and measures are taken to prevent personal data from being easily discovered when such equipment, electronic media, etc. are carried, including during transportation within the office.

6. Technical safety control measures

Access controls are implemented to limit the scope of persons in charge and the personal information databases, etc. handled.
A system is in place to protect information systems that handle personal data from unauthorized external access or unauthorized software.

7. Correction, deletion, etc. of personal information by "Delete account" from this application

If a user "Delete account" from this application, the user's personal information will be individually deleted during scheduled maintenance on the server where the personal information is stored, at the closest point in time to the time of the scheduled maintenance after the user's deleting account. Even if the user deletes (uninstalls) this application from the device used, the personal information will not be deleted unless the user follows the "Delete account" procedure described above.

8. Revision of Privacy Policy

The Service complies with Japanese laws and regulations applicable to personal information, and will review and strive to improve the contents of the Policy as necessary. The revised and updated privacy policy will always be disclosed on this page.

 

9. Contact for inquiries

Please contact the following section if you have any opinions, questions, complaints, or other inquiries regarding the handling of the user’s information.

Address: Noax Bld 3F, 1-16-4 Nishi-shimbashi, Minato-ku, Tokyo
SUN Co., Ltd.

Contact Address: support-team@kurashi-study.net

 

Enactment: 03 03, 2021

Revision: 04 01, 2022