Established: July 2019
Placing top priority on earning the trust of customers, UNDERCOVER Co., Ltd., and BBF, Inc., (hereinafter “Companies") strive to protect the vital personal information of customers (hereinafter, this includes personally identifying information) by keeping the following policy in mind at all times.
- 1.Compliance with laws and regulations
- In handling personal information, the Companies shall comply with the Act on the Protection of Personal Information (Personal Information Protection Act) and other laws and regulations regarding the protection of personal information, as well as this Policy.
- 2.Proper collection of personal information
- The Companies shall not collect personal information through fraud or other improper means.
- 3.Notification of purposes of use
- The Companies shall strive to obtain personal information only after first clearly identifying and announcing the purposes of use, scope of users, contact points for inquiries, and other necessary information and obtaining the consent of the individuals concerned.
- 4.Use within the scope of purposes of use
- Except when they have specified the purposes of use as clearly as possible and obtained the consent of the individual concerned in advance, or in exceptional cases as stipulated in laws and regulations, the Companies shall handle personal information solely within the scope of the purposes of use clearly indicated or published.
- 5.Personal information of minors
- When there is a possibility that personal information could be obtained from minors less than 15 years of age, the Companies shall employ special considerations with regard to the collection of personal information from minors, such as instructing that the consent of a parent or guardian be obtained before providing such information.
- 6.Security measures
- The Companies shall strive to ensure the accuracy and timeliness of personal information collected within the scope of the purposes of use, and shall implement the necessary and appropriate security measures to protect such information from threats, such as those of improper access, unauthorized alteration, leakage, or loss.
- 7.Supervision of subcontractors
- Within the scope of the purposes of use, the Companies may subcontract the handling of personal information collected to third parties. The Companies select such third parties after first confirming that they provide adequate security levels for personal information and implement the necessary and appropriate supervisory means, such as concluding contracts with them on the protection of personal information.
- 8.Provision to third parties
- The Companies shall not provide personal information to third parties other than the joint users of such information indicated clearly at the time of collecting such information. However, personal information may be disclosed to third parties in the following cases:
- ・When the individual concerned by such information has consented to the disclosure or sharing of the information
- ・When such disclosure has been demanded in accordance with legal procedures by a public agency such as a court of law or the police
- ・When it has been determined that the individual concerned by such information has caused disadvantages to a third party
- 9.Demands for disclosure, correction, or deletion
- When the individual concerned by such information has requested that the Companies implement measures for disclosing, correcting, ceasing use in the provision of products and services, or deleting personal information, they shall respond swiftly pursuant to the provisions of laws and regulations after first confirming the identity of the requester.
- 10.Responding to complaints
- The Companies shall maintain internal organizations to respond swiftly and appropriately to complaints from the individuals concerned concerning the personal information that they handle.
- 11.Continual improvements to internal structures
- To handle appropriately any personal information collected, the Companies shall strive continually to enhance and improve internal structures, including revising this Policy, through means that include the maintenance of internal structures as well as employee training and appropriate internal auditing.
- 12.Purposes of use of personal information collected
- The Companies shall use the names, addresses, telephone numbers, email addresses, and other personal information collected from customers solely for the purposes enumerated below.
- ・Advertising, publicity, and sales promotion activities (may include provision of information on products, services, exhibitions, and events by email, direct mail, or other means)
- ・Notification of information as necessary for operation of the Companies' websites (including notification by email, direct mail, or other means)
- ・Product packing and shipping operations
- ・Management of purchase and billing information and billing related to the purchase and use of products and services
- ・Customer support in areas such as responding to various inquiries and after-sales service
- ・Conducting surveys
- ・For use in customer satisfaction surveys, including those concerning states and environment of use of the Companies' products and services
- ・Exercise of rights and performance of obligations pursuant to contracts, laws, etc.
- 13.Collection and use of attribute information and behavior logs from which individuals cannot be identified
・The URLs of opt-out pages are provided below.
Google's opt-out page: http://www.google.co.jp/policies/privacy/ads/
The Network Advertising Initiative's opt-out page: http://www.networkadvertising.org/choices/#completed
Contact the contact point shown below if you wish to check or correct personal information.
We will respond to such requests swiftly, to a reasonable extent.
UNDERCOVER Co., Ltd.
Address any inquiries to: firstname.lastname@example.org