Privacy Policy

of VPC Asia K.K.

This Privacy Policy is made to: (i) protect Personal Information as defined below, (ii) establish certain rules and procedures to protect Personal Information, and (iii) ensure that our employees observe and understand the importance of both protecting Personal Information and taking the necessary protection measures seriously.

Article 1 (Personal Information)

“Personal Information” in this Privacy Policy means “personal information” as stipulated in the Act on the Protection of Personal Information of Japan (Act No. 57 of May 30, 2003; “Personal Information Protection Act”); and therefore, means information which can identify a specific living individual by name, date of birth or other description contained in such information; or which includes a code that can identify a specific individual.

Article 2 (Acquisition and Use of Personal Information)

We may acquire and use Personal Information from Users (individually “User” or collectively “Users”) of our services (the “Services”) within the scope necessary for the following purposes.
(1)To perform the Services;
(2)To improve and refine the Services, or to develop new services;
(3)To notify Users of new functions or updated information about the Services, campaigns, and our other services (including via e-mails, flyers, and other direct mail);
(4)To inform Users of any maintenance of the Services or important news regarding the Services;
(5)To answer comments and questions from Users regarding the Services (including to confirm Users identification);
(6)To report to Users the situation regarding the use of the Services;
(7)To request Users answer any questionnaires and questions regarding the Services or to attend events, or to report the answers of such questionnaires and questions or results of such events to such Users;
(8)To conduct research on and provide analysis of the history of the Services and to utilize the results of such research and analysis for the improvement and development of the Services and to deliver any promotional materials;
(9)Upon the approval or application by the Users, to provide Personal Information to third parties, including companies participating in an event that we hold; and
(10)To identify Users who have violated the Terms of Use or who intend to use the Services for unlawful or illegitimate purposes, and to block their use of the Services.
If we seek to use such Personal Information beyond the above purposes, we will obtain prior written consent of the User whose Personal Information is concerned.

Article 3 (Management and Protection of Personal Information)

We will carefully and proactively manage Personal Information and will not disclose or provide such Personal Information to any third parties without the prior written consent of Users whose Personal Information is concerned, except in the following circumstances:
(1)where such disclosure of Personal Information is necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of such person;
(2)where such disclosure of Personal Information is necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person whose Personal Information is concerned;
(3)where such disclosure of Personal Information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by such state organ or local government in executing the affairs required by laws and regulations, and if obtaining the consent of the person whose Personal Information is concerned is likely to hinder the execution of such affairs;
(4)where we entrust the handling of Personal Information in whole or in part within the scope necessary to achieve our purposes as stipulated in Article 2, to implement our operations smoothly;
(5)where such Personal Information is obtained because of the succession of business in a merger or otherwise;
(6)where such Personal Information is used jointly between specific individuals or entities, and in such case if the scope, and purposes of such joint use, and the name of the individual or business operator responsible for the management of such Personal Information have been notified to the User(s) whose Personal Information is concerned in advance; and
(7)where it is permitted by laws and regulations to disclose or provide Personal Information.

We will take preventive and corrective measures against risks resulting from any unlawful access to Personal Information, or any loss, destruction, falsification, or leakage of Personal Information.

Article 4 (Entrustment of Personal Information Handling)

We may entrust an individual or a business operator to handle Users’ personal data in whole or in part. In such case, we will examine their eligibility sufficiently, obligate such individual or business operator to maintain confidentiality obligations by contract, and will perform the necessary and appropriate supervision over such individual or business operator.

Article 5 (Disclosure of Personal Information)

Upon a request of a User (only the person whose information is concerned; the same will be hereinafter applied), we will promptly disclose the Personal Information of such User. However, we may keep all or part of such Personal Information undisclosed, if such disclosure falls under any of the following categories; and in this case, we will promptly notify such User:
(1)where such disclosure is likely to harm the life, body, property, or other rights or interests of such User or any other third parties;
(2)where such disclosure is likely to hinder the proper execution of our business; and
(3)where such disclosure may result in violation of any laws and regulations.

Article 6 (Correction and Deletion of Personal Information)

1.If any Personal Information retained by us includes false information, we will, upon the request of the User whose Personal Information is concerned, correct or delete such false information in accordance with our internal procedures.
2.Based on the request of such User whose Personal Information is concerned, as referred to in paragraph 1 of this Article 6, we will promptly notify such User once such correction or deletion of the Personal Information has been completed.

Article 7 (Discontinuation of Personal Information Use)

If we receive any request from a User to discontinue using or to delete his or her Personal Information (“Discontinuation”) on any of the grounds below, we will promptly conduct the necessary research and, based on the result of such research, implement the Discontinuation and notify such User to that effect:
(1)Where Personal Information is handled beyond the defined use purpose;
(2)Where Personal Information is acquired through unlawful means;
(3)Where Personal Information is used in a manner that may promote or cause illegal or unlawful acts;
(4)Where we no longer need to use such Personal Information;
(5)Where Personal Information that includes certain Personal Information requiring special care is divulged, lost, or damaged (“Divulgence”) or there is an indication that Divulgence has occurred.
(6)Where Divulgence of Personal Information that might be unlawfully used and cause proprietary damage has occurred or there is an indication that such Divulgence has occurred.
(7)Where someone caused Divulgence of Personal Information with an indication of unlawful intent, or there is an indication that such Divulgence has occurred.
(8)Where Divulgence occurred concerning over one thousand (1,000) persons whose Personal Information is concerned, or there is an indication that such Divulgence has occurred.
(9)Where Users’ rights or lawful interests are likely damaged by handling their Personal Information.
However, if such Discontinuation is unduly expensive or is otherwise difficult to implement, we will, if possible, take the necessary alternative measures to protect the rights and interests of such User.

Article 8 (Procedures for Amending Privacy Policy)

We will review the content of this Privacy Policy appropriately and endeavor to improve this Privacy Policy. The content of this Privacy Policy can be amended unless otherwise stipulated in laws, regulations, and this Privacy Policy. The amended Privacy Policy will be valid when all Users are notified or uploaded on our website in accordance with our procedures.

Article 9 (Compliance with Laws, Regulations and Norms)

We will comply with the laws and regulations in Japan and other rules that are applicable to the use of Personal Information we retain.

Article 10 (Response to Complaints and Consultations)

We will respond to any complaints from Users and will provide consultation to any User whose Personal Information is concerned as to the handling of his or her Personal Information. We will respond properly and promptly to any request for disclosure, correction, addition, deletion, refusal of use, or provision regarding Personal Information.

Article 11 (Security Control Measures)

We will take organizational, physical, personnel, and technical measures, such as restricting access to Personal Information files, recording access logs, and implementing security measures to prevent unauthorized access from outside the company to prevent unauthorized access to Personal Information, loss, destruction, alteration, or leakage of Personal Information. In the unlikely event of an incident involving the leakage of users’ Personal Information, we will promptly report the incident to the regulatory authorities in accordance with the Personal Information Protection Act and related guidelines, and take necessary measures to prevent similar incidents from occurring or recurring.

Article 12 (Company’s Address, Name of Representative, and Personal Information Protection Manager)

The address and the names of the representative and the personal information protection administrator are as follows:
Address: Fukoku Seimei Bldg. 2-2-2 Uchisaiwai-cho, Chiyoda-ku, 100-0011 Tokyo
Representative: Dominik Steiner
Personal Information Protection Manager: Dominik Steiner

Article 13 (Customer Desk)

For inquiries concerning our policy of handling of Personal Information, please contact us as below at:
VPC Asia K.K.
Fukoku Seimei Bldg. 2-2-2 Uchisaiwai-cho, Chiyoda-ku, 100-0011 Tokyo
TEL: 050 5809 8800

Established on and valid from 1st December 2022.