Privacy Policy

Ligareus Ltd. (hereinafter referred to as "the Company") has established this Privacy Policy (hereinafter referred to as "this Policy") to recognize the protection of personal information as a crucial social responsibility. We declare that all officers and employees will comply with legal standards related to personal information protection and will acquire, manage, and use personal information in a necessary and appropriate manner.

Article 1 (Personal Information)

In this Policy, "personal information" refers to "personal information" as defined in the Personal Information Protection Act, which means information about a living individual that can identify a specific person through details such as name, date of birth, address, phone number, contact information, and other descriptions, as well as data related to appearance, fingerprints, voiceprints, and health insurance card numbers that can identify a specific person from such information alone (personal identification information). Terms such as "personal data," "retained personal data," and "personal-related information" shall be as stipulated in the Personal Information Protection Act.

Article 2 (Methods of Collecting Personal Information)

The Company may collect personal information such as names, dates of birth, addresses, phone numbers, email addresses, bank account numbers, credit card numbers, driver's license numbers, passport numbers, and other personal information through the websites and applications provided by the Company (hereinafter referred to as "the Company’s Websites, etc.") and various services offered by the Company. Additionally, the Company may collect transaction records and payment-related information containing user personal information from partners (including information providers, advertisers, and advertising distributors).

Article 3 (Purposes of Collecting and Using Personal Information)

The purposes for which the Company collects and uses personal information are as follows:

1. To provide and operate the various services offered by the Company
2. To respond to inquiries from users (including identity verification)
3. To send emails regarding new features, updates, campaigns, and other service announcements related to the services currently being used by users, as well as other services offered by the Company
4. To contact users as necessary for maintenance, important notices, etc.
5. To identify and refuse service to those who violate the terms of contracts or other service regulations with the Company or those who attempt to use the services for illegal or inappropriate purposes
6. To allow users to view, change, or delete their registration information and view their usage status
7. To bill users for usage fees in paid services
8. For purposes incidental to the above purposes

Article 4 (Changes to Purposes of Use)

1. The Company will only change the purposes of use of personal information if such changes are reasonably deemed related to the purposes before the change.
2. If the purposes of use are changed, the Company will notify users of the new purposes by a method prescribed by the Company or publish them on the Company’s website.

Article 5 (Provision of Personal Information to Third Parties)

1. The Company will not provide personal information to third parties without obtaining prior consent from the user, except in the following cases or as permitted by the Personal Information Protection Act or other laws:
   1. When it is necessary to protect human life, body, or property, and it is difficult to obtain the individual's consent
   2. When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the individual's consent
   3. When cooperation is required for a national or local government agency or a person entrusted by such an agency in performing duties prescribed by law, and obtaining the individual's consent may hinder the performance of those duties
   4. When the following matters have been disclosed or published in advance, and the Company has reported to the Personal Information Protection Commission:
      1. That the purpose of use includes provision to third parties
      2. The items of data provided to third parties
      3. The means or methods of providing data to third parties
      4. That the provision of personal information to third parties will be stopped upon request by the individual
      5. The method for accepting requests from individuals
2. Notwithstanding the above, the following cases are not considered as provision of personal information to third parties:
   1. When the Company entrusts the handling of personal information to another party within the scope of the handling of personal information
   2. When personal information is provided due to business succession caused by mergers or other reasons
   3. When personal information is used jointly with specific parties, and prior notification or placement in a state easily known by the individual is made regarding the fact of joint use, the items of personal information used jointly, the scope of parties using it jointly, the purposes of use by the parties, and the name or title of the party responsible for managing the personal information

Article 6 (Outsourcing of Personal Information)

The Company may outsource all or part of the handling of personal information. In such cases, the Company will conduct necessary and appropriate supervision of the outsourced party to ensure the safety management of personal information.

Article 7 (Disclosure of Personal Information)

1. When the Company receives a request for disclosure of personal information from the individual, it will disclose it without delay. However, if disclosure would fall under any of the following categories, the Company may not disclose all or part of the information, and if a decision is made not to disclose, it will notify the individual without delay. A fee of 1,000 yen per request will be charged for the disclosure of personal information.
   1. When there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party
   2. When there is a risk of significantly hindering the proper implementation of the Company’s operations
   3. When disclosure would violate other laws
2. Notwithstanding the above, in principle, information other than personal information such as browsing history and attribute information will not be disclosed.

Article 8 (Correction and Deletion of Personal Information)

1. Users may request the correction, addition, or deletion (hereinafter referred to as "correction, etc.") of their personal information held by the Company if it is inaccurate, according to the procedures established by the Company.
2. If the Company determines that it is necessary to respond to a request for correction, etc., it will promptly make the necessary corrections.
3. The Company will notify the user without delay when corrections are made based on the above provisions or when a decision is made not to make corrections.

Article 9 (Suspension of Use, etc. of Personal Information)

1. If an individual requests the suspension of use or deletion (hereinafter referred to as "suspension of use, etc.") of their personal information for any of the following reasons, the Company will promptly conduct necessary investigations. However, this does not apply if there are exceptions as listed in Article 5, Paragraph 1 (1) to (4):
   ① If the personal information is being handled beyond the scope of the purpose of use
   ② If the personal information was obtained by fraudulent means
   ③ If the personal information is no longer needed
   ④ If a significant leak has occurred regarding the personal data that requires reporting to the Personal Information Protection Commission
   ⑤ If there is a risk of harm to the individual’s rights or legitimate interests
2. Based on the results of the investigation in the previous paragraph, if it is determined that it is necessary to respond to the request, the Company will promptly suspend the use of the personal information, etc.
3. When the Company suspends the use of personal information, etc., or makes a decision not to suspend, it will notify the user without delay.
4. Notwithstanding the above two paragraphs, if the suspension of use, etc. involves significant costs or is otherwise difficult, and if alternative measures that adequately protect the user’s rights and interests can be taken, such alternative measures will be implemented.

Article 10 (Changes to Privacy Policy)

1. The contents of this Policy may be changed without notice to users, except as otherwise provided by laws and regulations or specific provisions in this Policy.
2. Except as otherwise provided by the Company, the revised Privacy Policy will take effect when it is posted on the Company’s website.

Article 11 (Measures for Security Management of Retained Personal Data)

The Company takes the following measures to ensure the security management of retained personal data:
① Designation and appointment of a person responsible for handling personal information
② Formulation of personal information handling regulations
③ Restriction of access to personal information and prohibition of removal of records
④ Conducting training for officers and employees on personal information protection
⑤ Inclusion of confidentiality clauses related to personal information protection in contracts with officers and employees, as well as in employment rules

Article 12 (Use of Cookies, etc.)

The Company may link browsing history and personal information collected through cookies (Cookie), web beacons, etc. (hereinafter referred to as "Cookies, etc.") on the Company’s website to analyze visitor behavior, deliver advertisements tailored to user interests, or measure the effectiveness of advertisements.
Please refer to the Company's separately established Cookie Policy for details on the use of Cookies, etc.

Article 13 (Contact Information)

For inquiries regarding this Policy, please contact the following:

Daiwa Shibuya Square 6F, 16-28 Nanpeidai-cho, Shibuya-ku, Tokyo

Ligareus Ltd., Representative Director, Tatsuya Hirose
Personal Information Protection Manager and Inquiry Contact: Tatsuya Hirose

E-mail: hirose@ligareus.com
Reception: Monday to Friday, excluding public holidays, from 9:00 AM to 6:00 PM (Japan Time)

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