Virtual Cast Co. Ltd. (hereinafter referred to as “Company”) shall handle personal information (hereinafter referred to as “Personal Information”, as defined under Clause 2(1) of the Japanese Act on the Protection of Personal Information,) collected by Company through and in connection with Company’s website, products and service (hereinafter referred to as “Services”) as follows:
- 1. In order to protect the user’s information, Company will comply with the Japanese Act on the Protection of Personal Information Act, Act No. 57 of May 30, 2003 (hereinafter referred to as the "Act on the Protection of Personal Information") and other related laws and regulations, and Company shall endeavor to appropriately handle and protect all the user’s information, including Personal Information.
Information to be Obtained and Method of for Information Acquisition
- 1. Company may acquire the following Personal Information in connection with the Services.
- (i) Information related to User
a User’s Information
Company may obtain, name, e-mail address, telephone number, selected basic language, date of birth, workplace name, division, position, and other information related to the organization (in the case that the user is a corporation or an entity), information on product’s ID and other license information provided by Company or its sales partners, information related to the participation in events organized by Company or its sales partners, historical information (including audio and text) related to communications between Company and users, access token provided for the certification related with the third party services through an application program interface (“API”) and other information designated by Company (hereinafter referred to as the "User Information")
- b Device Information
When the user uses the Services on any devices including mobile devices, Company may collect device information (the type of device, operating system, browser used on devices and ID information, etc. that can identify such devices) used by the user.
In addition, Company may collect information that is automatically generated and stored when using the Services, such as user’s IP address, request date and time from the user, user’s history accessing the Services, and user’s status on the Services (hereinafter referred to as "Log Information").
- c Cookie and Anonymized ID
The Services may use a technology called "Cookie", and "tracking pixel", " Web Beacon " or other similar technologies.
For the avoidance of doubt, a Cookie is an industry-standard technology by which a web server identifies a User's browser.
A Cookie can identify the browser used by the user but cannot individually identify such user. The function of a Cookie can be disabled by changing the settings on the device, however, by doing so, part or all of the Services may not be available.
- d Error Data
Company may gather and track the data on technical errors that may occur when the user uses Company’s applications.
- e Location Data
Company may acquire location information, GPS positioning information, and Wi-Fi positioning information pertaining to the base stations of the registered user when using the Services (hereinafter referred to as "Location Data”)
- a User’s Information
- (ii) Transmission Data and Linkage Data
Company may collect data, including but not limited to, Location Data of devices, history of use of the Services, uploaded files, written data and voices, search history, purchase history of goods from the VR space or other venues, any posting to the Services (hereinafter referred to as "Transmission Data") and other related data, including, but not limited to, login information, texts, images, videos, and other information being transmitted by user to the Services, and information obtained from other services in conjunction with the Services (hereinafter referred to "Linkage Data").
- (i) Information related to User
- 2. When acquiring Personal Information, Company shall properly acquire such personal information without falsification or other improper means. In addition, in the event Company collects any Personal Information in a method other than from the use of the Services by users, Company will notify or publish the purpose of use in advance
Purpose of Use
- 1. Company will appropriately handle Personal Information obtained through the use of the Services within the scope of the objectives set forth below. Company will not use the obtained Personal Information for any other purpose without the consent of the user.
Purpose of Use Description of Purpose of Use Use of Information To provide, maintain, and improve the Services For the application and provision of the Services
To verify the identity of the user and to prevent unauthorized use of the Services
To ensure smooth provision, maintenance, and improvement of the Services
To create and analyze marketing data for the purpose of understanding the characteristics of users.
For improving the Services or developing new services by analyzing information using machine learning and advanced analysis
For preventing and reducing fraud and software piracy
Cookie and Anonymized ID
To provide support and response to the user For the purpose of providing information and responding to inquiries relating to the Services
For the purpose of notifying user:
(i) any changes to this Policy or any terms and conditions of the Services,
(ii) suspension or cancellation of the Services, or
(iv) other important notices relating to the Services
User Information To provide information to third parties. In the event Company provides User Information to a third party, the third party who receives information prescribed in the right column shall use such information for the following purposes:
(i) for providing and improving the quality of the Services
(ii) for providing the Affiliated Services
(iii) for development study of new services
(iv) for commissioning research institute to conduct an investigation, research, and analysis
(v) for preventing or responding to fraud or software piracy
(vi) for defending any (cyber) attack brought against Company
Cookie and Anonymized ID
- 2. Company may revise the purpose of use provided for in the preceding paragraph to the extent that such revision is deemed to be reasonably related to the original purpose of use, upon which Company shall notify the user of such revision or announcing such revision on the website operated by Company in an easy to understand manner
- 3. In addition to the purpose of use prescribed in Article 3.1 above, Company may process Transmission Data, Linkage Data, and Personal Information, to the extent that the user cannot be identified, into; (i)anonymized information (hereinafter referred to as "Anonymized Data", as defined in Clause 2 (9) of the Act on the Protection of Personal Information) or (ii)statistical information; and Company shall have the right to use such information.
Provision to Third Parties
1. Except for the outsourcing prescribed in Article 5 of this Policy, in principle, Company will not provide
Personal Information to any third parties without prior consent from the user.
However, in the following circumstances, Personal Information may be provided to a third party without the user’s consent to the extent that such provision does not violate any applicable laws and regulations.
- (i) When it is based on laws and regulations
- (ii) When it is necessary to protect the life, body or property of an individual and consent from the user is difficult to obtain.
- (iii) When it is necessary for improving public health or ensuring the well-being of children and consent form the user is difficult to obtain.
- (iv) When it is necessary to cooperate with government agencies, local public bodies, or any agents thereof, in executing the affairs prescribed by laws and regulations, and obtaining the user’s consent is likely to impede the execution of the affairs concerned.
- (v) When Personal Information is succeeded due to Company being merged, spilled, transferred or any other similar business transaction.
- 2. In the event Company provides personal data (hereinafter referred to as "Personal Data", as defined in
Clause 2(6) of the Act on the Protection of Personal Information) to a third party with the consent of
the user, the Company shall prepare and retain records relating to the following matters:
- (i) that prior consent from the user has been obtained.
- (ii) the name or any other information sufficient to identify such third party
- (iii) Sufficient Information for identifying the individual, such as the name of the individual identified by the Personal Data
- (iv) Details of the Personal Data
Outsourcing of Handling Personal Information
Company may outsource the handling or management of Personal Information, in whole or in part, to third parties to the extent necessary for the purpose prescribed in Article 3. In this case,Company will in advance execute a confidentiality agreement with each of the consignee, of the terms and conditions that conform to the provisions of this Policy and conduct necessary and appropriate supervision to ensure proper and safe management of the Personal Information by the consignee.
Jointly Use of Personal Information
Company may, for the purpose set forth in Article 3, share Personal Information acquired pursuant to the provisions of Article 2 with Dwango Co., Ltd., Infinite Loop Co. Ltd., companies that provide Affiliated Services and Company’s subsidiaries or affiliate, in which case Company is a responsible person.
Information Gathering Module
The Services may incorporate information gathering module applications that enable Company to
gather and analyze information on the usage and the advertising effect on the Services or other services.
Accordingly, Company may provide the User Information to information gathering module providers.
The information gathering modules providers collect the User Information but do not collect any information that identifies the user personally. The information collected is managed in accordance with the privacy policies and other terms and conditions established by the respective providers. The followings are the details of the information gathering module application and its provider used in the Services.
Name of Module: Google Analytics
Provider: Google Inc.
Linking through API
- 1. Company uses user’s access token for linking with YouTube through API. In addition to the manner
prescribed in Article 11, the information stored can be deleted through the following URL.
- 2. For inquiry regarding the preceding paragraph, please contact Company according to the manner prescribed in Article13.
Handling of Location Data
- 1. The accuracy of the user’s Location Data that Company obtains depends on the user’s operating system and Company, from time to time, collects user’s Location Data as long as the setting for the acquiring of the user’s Location Data is turned on.
- 2. Location Data obtained by Company will be stored and kept by Company as long as it is necessary to provide the Services or the Affiliated Services to the user.
- 3. Company utilizes Location Data in connection with the ID of the Services.
Security Management System
- 1. In order to protect the User Information from leakage, loss, or damage, Company will take necessary and appropriate measures of security safeguards, such as implementing restrictions to access Personal Information files and Anonymized Data files, limiting the minimum necessity of persons who hold access rights, and to install security software for preventing unauthorized access.
- 2. Company will appoint its Representative Director as the person in charge to properly manage the User Information and to continuously make improvement in the quality of such management.
Right of Disclosure, Correction, etc.
Please refer to Company’s Inquiry Form under the Article 12 to submit a request for disclosure,
correction, deletion, or discontinuation to use of Personal Information that previously provided by the user
However, Company may not be able to accommodate the user’s request if: (i) Company have no such obligation to do so under the Act on the Protection of Personal Information or other laws or regulations, (ii) the request has been repeatedly made without justifiable reason; or (iii) excessive technical work is required for accommodating the request.
- 1. Company will use commercially reasonable efforts to continuously review and improve handling of the User Information and may revise this Policy from time to time as it deems necessary.
2. Company will notify the user of any revisions to this Policy by announcing such revisions on the Services
or the website operated by Company or through other means that can be easily accessed and viewed.
However, if Company is required by applicable laws or regulations to obtain the consent of the user in order to make certain revisions, then, Company will obtain the user's consent in a manner separately specified by Company.
For any inquiries regarding the handling of the User Information, including any suggestions, questions,
complaints or comments, please contact Company using the following inquiry form:
Virtual Cast Co., Ltd.
The reception time shall be from 10:00 p.m. to 17:00 p.m. Japan time on weekdays.