1. SCOPE

This Privacy Policy shall apply to all personal information you provide to us via our websites, phone, email, or in writing, etc., in connection with all of our services. If provisions differing with this Privacy Policy are specified when providing personal information, such provisions shall apply preferentially. Additionally, our Privacy Policy does not apply to personal information obtained separately by advertisers that place advertisements on our websites.

2. THE INFORMATION WE COLLECT

To achieve the purposes of use prescribed in “3. Use and Retention of Your Information”, we shall collect from you the personal information prescribed below. We take efforts to collect the minimum personal information necessary.

2.1 INFORMATION PROVIDED BY YOU

• Your personal information such as your name, mailing address, telephone number, your company name, email address, etc.
• Login information such as account name (user ID) and password
• Information regarding payment methods such as credit cards, bank accounts, electronic money, etc.
• Information for identity verification such as copies of drivers licenses, health insurance cards, etc.

2.2 INFORMATION ACQUIRED VIA COOKIES

When you visit our websites, we may place a small text file called a “cookie” on your device. You can disable cookies by changing their browser’s settings, but this may result in being unable to use some features provided by the website.

• IP address
• Referring URL (address of the webpage linked from)
• Device information (browser type and version, time zone settings, operating system, etc.)
• Information on products and services displayed or searched

The websites we manage and operate use Google Analytics to keep track of usage. Google Analytics uses cookies to collect user information. User information is collected anonymously and does not identify an individual. Information collected through the use of Google Analytics is managed in accordance with Google's policies. Click here to learn more about how to prevent your information from being used by Google Analytics.

3. USE AND RETENTION OF YOUR INFORMATION

We use your information for the purposes specified below. We shall not use it for any other purposes than below.

• To enable logging in to your account, forums, message boards, etc.
• To ship our products or gift and to provide our services such as downloads, etc.
• To bill fees for providing our services
• To refund when service cancellation
• To transfer collected fee on behalf of contractor of our service
• To reply appropriately to your inquiries about our service
• To send you information and advertisements such as direct mailings or email newsletters, etc.
• To notify you of updates, changes, or discontinuation, etc., of our services.
• To improve existing services and conduct R&D for the development of new services
• To utilize information for services such as analysis, marketing, and information dissemination, etc., as statistical data in which individuals or corporations are anonymized
• To perform identity verification
• To prevent, investigate, and identify fraud, cyber-attacks, and other illegal activities or violations of our services’ terms of use, and to protect our legal rights
• To utilize information for personnel recruitment

We may retain information about you for as long as it is necessary to fulfill the purposes described above. In order to secure your information, we take all the security measures described in “6. Security”

4. SHARING AND PROVISION OF YOUR INFORMATION

We shall not sell or rent your personal information to third parties. However, we may share your information with our partners or provide it to a third party in the following circumstances.

• When you have provided consent in advance
• When necessary for our partners to perform outsourced duties (transmitting email, processing payments, etc.)
• When necessary to provide statistical data in which individuals or corporations are anonymized
• When necessary to sell our business in whole or in part
• When required by law
• Cases of urgent necessity in which there is imminent danger to the life, body, or property of an individual, and in which it is difficult to obtain the consent of the person
• Cases of cooperation with legal demands by public institutions such as judiciary agencies or the police, etc.
• Cases in which there is reasonable suspicion that the individual has violated the law or our terms of use in connection with the use of our services, and it has been recognized as necessary to protect our or third party’s rights, assets, or services, etc.

5. YOUR RIGHTS

When we receive your request of disclosure, correction, amendment, deletion, erasing, suspension of use, or notification of the purposes of use of your information, we shall take care of it promptly within a reasonable scope. Under the GDPR (General Data Protection Regulation), those residing in the European Economic Area (EEA) countries have the rights to revoke consent to provide personal information, to raise objections regarding the handling of personal information, and to file complaints with the competent supervisory authorities.

6. SECURITY

To prevent unauthorized access or leaking of your personal information, and maintain the accuracy of information and dispose of it properly, we shall comply with all applicable laws, and make efforts to handle personal information with high level of security. In order to protect your privacy and ensure security, your information shall be protected by passwords. Additionally, we shall use industry standard SSL encryption to protect data transmissions when necessary. When we outsource duties to a third party for the purpose of providing services to you, a contract will be signed to ensure proper management of the outsourcer. We shall conduct regular reviews to confirm that these activities are being properly performed and at a suitable level.

7. CHANGES TO THIS PRIVACY POLICY

We may revise our Privacy Policy in whole or in part. In the event of revisions, they shall apply automatically at the point in time they are posted on our websites or when we notify you of them.

8. CONTACT US

If you have any questions or concerns regarding the contents of this Privacy Policy or other aspects of how your personal information is handled, please contact us below.

KOMODO Co., Ltd -  / Personal information protection manager
PHONE: +81-50-6861-0240
e-mail: personalinfo@komodo.jp
Reception hours: 10:00am to 5:00pm, Monday to Friday (except Japan’s public holidays, the Year-End and New Year holidays)

Personal Information Protection Policy

KOMODO Co., Ltd. (hereinafter referred to as “The Company") is committed to protecting the privacy of the personal information of its customers. “The Company" may ask you to provide personal information in order to provide our services such as e-commerce site operation, digital content sales, and overseas promotional support to our customers. “The Company" is deeply aware of the importance of protecting the personal information of our customers, and we want our customers to feel secure in their relationships with us by handling their personal information appropriately. For this reason, we hereby disclose our privacy policy.

Article 1: Respect of the Individual with respect to Personal Information

Personal information shall be collected only after clarifying the purpose and obtaining the consent of the individual, and shall be used only to the extent necessary to achieve the purpose. We shall also take measures to ensure that the information is not used for purposes other than those stated. If we need to provide personal information to a third party, we will obtain the consent of the individual and provide the information only to the extent necessary to achieve the purpose. In the event that a customer requests a disclosure or correction of personal information, we will respond to such requests within a reasonable period of time.

Article 2: Personal Information Protection System

In implementing this policy, an internal system with clearly defined roles and responsibilities will be established under the supervision of a personal information protection manager appointed by a representative of “The Company". In addition, we will conduct regular audits of the handling of personal information and constantly strive to spiral up our internal system.

Article 3: Security Control of Personal Information

All personal information shall be properly managed to prevent loss, destruction, falsification, or leakage due to unauthorized access, theft, or removal, and preventive and corrective measures shall be taken as necessary. In the event that personal information is outsourced, a confidentiality agreement shall be put in place, and “The Company" shall manage and supervise the outsourcing of personal information to ensure that it is properly managed.

Article 4: Compliance with Japanese Laws, Regulations, Guidelines, and Other Standards Concerning Personal Information

“The Company" shall comply with the "Act on the Protection of Personal Information," the Japan Industrial Standard "Personal Information Protection Management System - Requirements," and other laws, national guidelines, and other norms related to the protection of personal information.

Article 5 Contact for Complaints and Consultations Concerning Personal Information

“The Company" will not use personal information obtained for any purpose other than those described in the Privacy Policy "3. Use and Retention of your Information". Based on the above, when we receive a consultation, complaint, or request for disclosure of personal information from the person concerned, we will respond to the request as soon as reasonably possible after we confirm the identity of the person concerned by filling in the prescribed form and by using identification documents.

For requests concerning "information about the purpose of personal information subject to disclosure" and "disclosure of personal information subject to disclosure," an administration fee of 1,000 yen per request will be charged.

<Inquiries regarding personal information>
Personal Information Inquiry Contact:
KOMODO Co., Ltd.
Personal Information Protection Manager

Phone number: 050-6861-6861 (email: personalinfo@komodo.jp)
(10:00 a.m. to 5:00 p.m. Monday through Friday, excluding national holidays and year-end and New Year holidays)

Article 6 Continuous Improvement of Personal Information Protection Management System

We will continuously review and improve the "Personal Information Protection Management System" in response to changes in our business activities, as well as changes in the legal, social, and IT environments surrounding our business.

Established: April 1, 2021
Last revised: April 26, 2022

KOMODO Corporation
Representative Director Ricky Uy
(External Communication of Personal Information Protection Policy)
This policy shall be communicated to all employees and published on “The Company"'s website.