POKELABO

Basic Policy regarding the Protection of Personal Information

EnglishJapanese

1. Basic Policy

i. Protection of personal information

Pokelabo, Inc. (“the “Company””) recognizes the importance of personal information, views the complete protection of personal information as its social responsibility, and promises to comply with the Act on the Protection of Personal Information, other relevant laws and regulations, guidelines, and the like, and to properly handle the personal information collected from the customers who use the Company’s services and the Company App in accordance with this Policy.

ii. Scope

This Policy will apply to all of the Company’s services provided by the Company. The personal information that will be collected and the purpose of use of such information will be specifically provided for each of the Company’s services in the individual privacy policy for the Company’s service.

2. Handling of Personal Information

i. Collection

The Company will clearly state the purpose of use in the privacy policy and collect the personal information required for providing the Company’s services through lawful and fair means.

ii. Purpose of use

The Company will only use the collected personal information for improving the quality of the Company’s services, delivering ads, or for any other purpose of use set forth in the privacy policy, and the Company will not use such information for any other purpose without the customer’s consent or in the absence of any law or regulation to the contrary.

3. Administration System

i. Appointment of administrator and creation of internal rules

The Company has appointed a personal information protection administrator as the person responsible for the administration of the personal information. The Company has also created internal rules regarding the protection of personal information and is ensuring the proper handling of personal information.

ii. Information security measures

The Company restricts access to personal information for the purpose of preventing personal information from being leaked, destroyed, or damaged or for any other safety management purpose. The Company also provides training regarding the handling of personal information for its officers and employees who handle personal information.

iii. Destruction of information

When the Company reasonably determines that the collected personal information is unnecessary for the business operation of the Company’s services or upon the expiration of the individually specified retention period, the Company will dispose the personal information in its possession.

4. Provision to Third Parties

i. Disclosure to third parties

In the following cases, the Company may disclose personal information to third parties:

  • The Company outsources work to a third party to the extent necessary to achieve the purpose of use
  • The Company performs a merger, corporate spin-off, transfer of business, or disposes all or some of the Company’s business, assets, or stock (including cases where it is performed in connection with bankruptcy or similar proceedings)
  • The Company requests the customer’s consent for the disclosure and the customer gives such consent

However, with regard to any information that has been statistically processed so that individual customers cannot be identified, the Company may use such information for purposes other than those listed above.

ii. Disclosure at the request of a government body, local government, public agency, or the like

In the following cases, the Company may disclose personal information to a public agency or the like:

  • Pursuant to laws and regulations (including any laws and regulations outside of the country of residence of the party that will be providing the information)
  • Disclosure is necessary to protect a person’s life, body, or property, and it is difficult to obtain the consent of the customer
  • It is particularly necessary to improve public health or to promote the healthy development of children, and it is difficult to obtain the consent of the customer
  • There is a need to cooperate with the performance of administrative work provided for by law or regulation by a national government body, local government, or a contractor for such body, and obtaining the customer’s consent may interfere with the performance of such administrative work

5. Personal Information Inquiry Desk

i Request for disclosure, correction, addition, deletion, suspension of use, etc.

If you or your agent makes a request to disclose, correct, delete, or suspend the use of your personal information, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. With regard to such requests, please contact the “Wright Flyer Studios Customer Information Disclosure and Inquiry Desk” set forth below. Please note, however, that if any personal information required to provide the Company’s services is corrected, deleted, or suspended from use, there may be cases where you will not be able to use all or part of the Company’s services.

ii Contact information

If you wish to make an inquiry, to discuss, or to file a complaint with regard to the handling of personal information in connection with the Company’s services, please contact the “Pokelabo Customer Information Disclosure and Inquiry Desk” set forth below:

Customer Information Disclosure and Inquiry Desk
info.appli@pokelabo.co.jp
Established on July 29, 2014
Pokelabo, Inc.