Privacy Policy

Techro Inc. (hereinafter referred to as the “Company”) hereby establishes this Privacy Policy (hereinafter referred to as the “Policy”) regarding the handling of User Information, including personal information, pertaining to users (including those who use the Service and those who browse the Company’s website related to the Service; hereinafter referred to as “Users”) of the email newsletter distribution service and related services provided by the Company (hereinafter collectively referred to as the “Service”).

Article 1 (General Provisions)

1. The Company shall comply with the Act on the Protection of Personal Information (hereinafter referred to as the “APPI”), guidelines of relevant ministries and agencies, and other applicable laws and regulations to realize the protection of User Information.
2. This Policy applies to the use of the Service. Furthermore, if the Company stipulates provisions regarding the handling of User Information in a privacy policy posted on a website operated by the Company, other personal information protection policies, or the terms of use related to the Service, such provisions shall also apply. In the event of any conflict between such provisions and this Policy, this Policy shall prevail.
3. The provisions of this Policy shall not apply to affiliated services provided by alliance partners or other services provided by third parties other than the Company (hereinafter referred to as “External Services”). Please refer to the privacy policies established by the providers of such External Services regarding the handling of User Information in those services.

Article 2 (User Information to be Collected)

1. Within User Information, “Personal Information” refers to “personal information” as defined in the APPI, and means information regarding a living individual that can identify a specific individual by name, date of birth, address, telephone number, contact information, or other descriptions contained in such information.
2. Within User Information, “Historical Information and Attribute Information” refers to information other than “Personal Information,” including services used, date and time of use, method of use, usage environment, postal code, gender, educational background, employment history, occupation, age, cookie information, and individual identification information of the terminal.

Article 3 (Method of Collection of User Information)

1. The Company may ask for Personal Information such as name, date of birth, address, telephone number, and email address when a User uses the Service. In addition, the Company may collect information regarding transaction records containing the User’s Personal Information made between the User and business partners, etc., from the Company’s business partners (including information providers, advertisers, advertisement distributors, etc.; hereinafter referred to as “Partners”).
2. The Company collects Historical Information and Attribute Information—such as services used, date and time of use, method of use, usage environment (including the communication status of the terminal if used via a mobile terminal, and various setting information at the time of use), cookie information, and individual identification information of the terminal—when a User uses the Service or browses pages.

Article 4 (Purpose of Use)

The Company uses User Information for the purposes specified in the following items:

• To use information necessary for the provision of the Service;
• To use contact information such as names and addresses to send notices or contact Users via email, or to contact Users as necessary;
• To use information such as names, dates of birth, addresses, and telephone numbers to verify the identity of Users;
• To display information recorded by the Company on input screens or to transfer such information to other services, etc. (including those provided by Partners) based on User instructions to allow Users to enter data easily;
• To use information identifying individuals, such as usage patterns, names, and addresses, to refuse the use of the Service by Users who violate the Terms of Use of the Service—such as by causing damage to third parties—or Users who attempt to use the Service for fraudulent or unjust purposes;
• To use information necessary for the Company to provide services to Users, such as information regarding the content of inquiries, as well as User service usage status and contact information, in order to respond to inquiries from Users;
• To respond to acts that violate the Terms of Use, this Policy, etc., regarding the Service;
• To notify Users of changes, etc., to the Terms of Use, this Policy, etc., regarding the Service;
• To help improve the Service; and
• For purposes incidental to the above purposes of use.

In addition to the preceding paragraph, the Company uses User Information for the purposes specified below:

1. Purpose of Use: To create statistical data processed into a format that cannot identify individuals in relation to the Company’s Service

   Corresponding Items of User Information: Device information, Log information, Cookie information

2. Purpose of Use: For the distribution or display of advertisements for the Company or third parties

   Corresponding Items of User Information: Device information, Log information, Cookie information

3. Purpose of Use: To use for questionnaire surveys and other marketing purposes

   Corresponding Items of User Information: Name, Email address, Date of birth, Gender, Other information entered by the User in input forms prescribed by the Company

Article 5 (Disablement of Behavioral Targeting Ads; Existence of Information Collection Modules)

1. Within the Service, “Behavioral Targeting Advertising” utilizing User behavioral history information is distributed by the business operators described in this Article. In such Behavioral Targeting Advertising, each business operator uses cookies to collect User behavioral history information. Please follow the procedures on each business operator’s website to disable (opt-out of) Behavioral Targeting Advertising by each business operator.
2. Please note that while the distribution of Behavioral Targeting Advertising to the User will basically cease after opting out (advertisements other than Behavioral Targeting Advertising will still be distributed), the opt-out may not function effectively due to changes in browsers, deletion of cookies, changes to new terminals, or other circumstances, and it may be necessary to perform the opt-out procedure again. Please also note that opting out may render some services within the Service unusable.

3. The following Information Collection Modules are incorporated into the Service. In accordance with this, User Information will be provided to the Information Collection Module providers (including those located outside of Japan) as follows:

   (1) Name of Information Collection Module

   Google Analytics

   (2) Provider of Information Collection Module

   Google LLC

   (3) Items of User Information Provided

   HTTP Cookies, IP address, browser environment variables, IDFA, UUID, OS used

   (4) Purpose of Use

   Improvement of the Service, analysis of usage status

   (5) URL of the Provider’s Privacy Policy

   https://policies.google.com/privacy?hl=en

Article 6 (Provision of User Information to Third Parties)

1. The Company shall not provide User Information to third parties without obtaining the User’s consent in advance, except in cases permitted by the APPI or other laws and regulations. However, the following cases do not fall under the provision to third parties specified above:
   • When the Company entrusts all or part of the handling of Personal Information within the scope necessary to achieve the purpose of use of the Service;
   • When Personal Information is provided in connection with the succession of business due to merger or other reasons; or
   • When Personal Information is used jointly based on the provisions of the APPI.
2. Notwithstanding the preceding paragraph, the Company may provide User Information to third parties in the following cases:
   • When based on laws and regulations;
   • When necessary for the protection of human life, body, or property, and it is difficult to obtain the User’s consent;
   • When strictly necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the User’s consent; or
   • When it is necessary to cooperate with a national government agency, a local government, or a person entrusted thereby in executing the affairs prescribed by laws and regulations, and obtaining the User’s consent is likely to impede the execution of such affairs.

Article 7 (Security Control Measures)

The Company shall implement appropriate security control measures for Personal Information to prevent unauthorized access, leakage, falsification, loss, etc. Although specific details regarding security control measures are stipulated separately in internal regulations, the main contents are as follows:

1. Organizational Security Control Measures: The Company appoints a person responsible for the handling of Personal Information and confirms the status of Personal Information handling by employees as appropriate. The person responsible for the handling of Personal Information periodically confirms and reviews the status of Personal Information handling.
2. Personnel Security Control Measures: Under the leadership of the person responsible for the handling of Personal Information, the Company conducts education and awareness-raising activities for all officers, employees, and related parties to ensure the appropriate handling of Personal Information.
3. Physical Security Control Measures: The Company takes measures to ensure that persons other than the person responsible for handling Personal Information and the individual concerned cannot easily view Personal Information. The Company takes necessary measures to prevent theft or loss of equipment, electronic media, documents, etc., that handle Personal Information in management areas and handling areas. When employees carry electronic media recording Personal Information or documents containing Personal Information, the Company takes safe measures to prevent loss, theft, etc., such as setting passwords or transporting them in envelopes inside bags. When deleting Personal Information or disposing of equipment, electronic media, etc., on which Personal Information is recorded, the Company has the person responsible for handling Personal Information confirm such action.
4. Technical Security Control Measures: To prevent unauthorized access to Personal Information, the Company clarifies the equipment that can handle Personal Information and the employees who handle such equipment. The Company identifies and authenticates employees who use information systems handling Personal Information through user control functions (user account control) equipped on devices capable of handling Personal Information. The Company takes necessary measures to protect information systems from unauthorized external access or unauthorized software.
5. Understanding of the External Environment: When storing Personal Information in a foreign country, the Company implements security control measures after understanding the systems regarding the protection of personal information in that country.

Article 8 (Disclosure of Personal Information)

1. When requested by the User to disclose Personal Information, the Company shall disclose such information to the User without delay. However, if disclosure is not required by the APPI or other laws and regulations, the Company may decide not to disclose all or part of the information. If a decision is made not to disclose the information, the Company shall notify the User to that effect without delay. Please note that a fee (1,000 yen per case) will be charged for the disclosure of Personal Information.
2. Notwithstanding the provisions of the preceding paragraph, information other than Personal Information, such as Historical Information and Attribute Information, shall not be disclosed in principle.

Article 9 (Correction and Suspension of Use of Personal Information)

1. If a User requests the suspension of use of their Personal Information based on the provisions of the APPI, the Company shall conduct the necessary investigation without delay after confirming that the request is from the User. Based on the results, the Company shall correct the content of or suspend the use of the Personal Information and notify the User to that effect. If a decision is made not to correct or suspend the use based on reasonable grounds, the Company shall notify the User to that effect.
2. If a User requests the deletion of their Personal Information and the Company determines that it is necessary to respond to such request, the Company shall delete the Personal Information after confirming that the request is from the User and notify the User to that effect.
3. The provisions of the preceding two paragraphs shall not apply if the Company is not obligated to correct, etc., or suspend use, etc., under the APPI or other laws and regulations.

Article 10 (Contact for Inquiries)

For inquiries regarding this Policy, please contact the inquiry window below.

Article 11 (Changes to Privacy Policy)

The Company shall review the operational status regarding the handling of User Information as appropriate and strive for continuous improvement, and may change this Policy as necessary. In the event of a change, the Company shall notify Users by displaying the change on the Service. However, in the case of changes to the content that require the consent of Users under laws and regulations, the Company shall obtain the consent of Users by the method prescribed by the Company.

Enacted: January 30, 2021
Revised: August 10, 2023