OOOOOOOOOO Inc. recognises that “personal information” means information about a living individual as defined in the Act on the Protection of Personal Information (name, date of birth and other information that can identify a specific individual), together with email addresses, membership numbers, passwords, credit card details and similar information used in connection with a specific individual, as well as attribute information such as interests, family composition and age when combined with personal information.

OOOOOOOOOO Inc. specifies the purpose of use of personal information as far as practicable when handling it.

OOOOOOOOOO Inc. does not handle personal information beyond the scope necessary to achieve the purpose of use without obtaining prior consent. This also applies to personal information acquired through a merger or other reason. The following cases are exceptions:

1. Where required by law
2. Where necessary to protect a person’s life, body or property and it is difficult to obtain consent
3. Where specially necessary to improve public health or promote the sound growth of children and it is difficult to obtain consent
4. Where cooperation with a national or local government body performing statutory duties is required and obtaining consent could impede those duties

OOOOOOOOOO Inc. acquires personal information properly and never through deception or other wrongful means.

OOOOOOOOOO Inc. publishes the purpose of use in advance when acquiring personal information, except in the following cases:

1. Where notifying or publishing the purpose could harm the life, body, property or other rights of the person or a third party
2. Where notifying or publishing the purpose could harm the rights or legitimate interests of ETB RIGHTS Inc.
3. Where cooperation with a national or local government body performing statutory duties is required and notification could impede those duties
4. Where the purpose is clear from the circumstances of acquisition

When changing the purpose of use, OOOOOOOOOO Inc. does so only within a scope reasonably deemed to be duly related to the previous purpose, and notifies or publishes the changed purpose.

OOOOOOOOOO Inc. establishes personal information protection rules and exercises necessary and appropriate supervision over employees so that leakage, loss or damage of personal information is prevented.

Where OOOOOOOOOO Inc. outsources all or part of the handling of personal information, it concludes a contract including confidentiality obligations, or requires agreement to the terms set by ETB RIGHTS Inc., and exercises necessary and appropriate supervision over the contractor.

OOOOOOOOOO Inc. does not provide personal information to third parties without prior consent, except in the following cases:

1. Where required by law
2. Where necessary to protect a person’s life, body or property and it is difficult to obtain consent
3. Where specially necessary to improve public health or promote the sound growth of children and it is difficult to obtain consent
4. Where cooperation with a national or local government body performing statutory duties is required and obtaining consent could impede those duties
5. Where the following matters have been announced or published in advance
   1. That provision to third parties is included in the purpose of use
   2. The items of data provided to third parties
   3. The means or method of provision to third parties
   4. That provision to third parties will stop at the request of the person

The following are not treated as third parties:

1. Where OOOOOOOOOO Inc. outsources all or part of the handling of personal information within the scope necessary to achieve the purpose of use
2. Where personal information is provided as a result of a business succession due to a merger or other reason
3. Where personal information is used jointly with specific parties and the relevant matters have been notified in advance or made readily available to the person

OOOOOOOOOO Inc. keeps the following matters available to the person and responds without delay upon request:

1. The purpose of use of personal information (excluding matters for which there is no obligation under the Act; if we decide not to respond, we notify the person without delay)
2. The contact point for enquiries regarding personal information

OOOOOOOOOO Inc. discloses personal information without delay upon request from the person. However, we may withhold all or part of it in the following cases, and will notify the person without delay if we decide not to disclose:

1. Where disclosure could harm the life, body, property or other rights of the person or a third party
2. Where disclosure could significantly impede the proper operation of ETB RIGHTS Inc.
3. Where disclosure would violate other laws

As a rule, information other than personal information, such as access logs, is not disclosed.

Where the person requests correction, addition or deletion of personal information on the grounds that it is untrue, OOOOOOOOOO Inc. conducts the necessary investigation without delay within the scope necessary to achieve the purpose of use, makes the correction based on the results, and notifies the person accordingly, except where special procedures are stipulated by other laws.

Where the person requests suspension of use or erasure on the grounds that their personal information is being handled beyond the published purpose of use, or was acquired by deception or other wrongful means, OOOOOOOOOO Inc. conducts the necessary investigation without delay, suspends use based on the results, and notifies the person accordingly. Where suspension would involve substantial cost or is otherwise difficult, and alternative measures sufficient to protect the person’s rights can be taken, we take those alternative measures.

Where, despite a request from the person, OOOOOOOOOO Inc. decides:

(1) not to notify the purpose of use
(2) not to disclose all or part of the personal information
(3) not to suspend the use of personal information
(4) not to stop providing personal information to third parties

we endeavour to explain the reason when notifying the person of that decision.