Privacy Policy

Article 1 (General Provisions)

1 EgoDiva Inc. (“EgoDiva”) complies with the Personal Information Protection Law, government guidelines, and other related laws and regulations to protect personal information.

Article 2 (Information to be Acquired)

1 EgoDiva will acquire individuals’ information including personal information (defined as “personal information” in accordance with Article 2(1) of the Act on the Protection of Personal Information; hereinafter the same will be applied.), as set forth below.

(1) Information provided directly by an individual

EgoDiva may request the following information from and individual, and EgoDiva will acquire such information.

I Basic Information

Username, email address, password and other information necessary to verify your identity when logging into your user account

II Other Registration Information

Name, address, telephone number, date of birth, profile (profile picture, username or nickname in the service, sex, background and any other information a user lists as part of his/her profile, and his/her ID)

III Information for Payment

Information necessary for payment processing, such as a user’s bank account information (including billing and payment information provided by the user to a third-party payment service company in the case of using such company)

IV Other Information Provided by the Individual

Any and all information provided by the individual (including information about business partners, information about candidates and applicants for employment, and employee information).

(2) Information EgoDiva Collects

I Terminal Information

EgoDiva may acquire information specific to the information terminal used by a user (including OS type, individual identification information of the terminal, computer name, advertising ID) and link the advertising ID to an internal identifier assigned to the user by EgoDiva.

II Location Information

To the extent necessary to provide our services, EgoDiva may acquire location information transmitted from the information terminal used by a user.

III Log Information and Action History Information

During the use of EgoDiva’s services, EgoDiva may acquire IP address, type of browser used by a user, information automatically generated and saved such as browser language preference, or the date and time of the request from the user, and the operation history within the services.

IV Information Using Cookies

In EgoDiva’s services, EgoDiva may use the technology called “Cookie” and similar technology, including “Google Analytics” as stipulated in Article 8. Cookie is an industry-standard technology that allows a web server to identify a user’s computer. Cookie can identify the user’s computer, but cannot identify the user himself or herself. Any user can disable Cookie function through the settings on an information terminal, but the user might not be able to use all or part of EgoDiva’s services.

(3) Information Collected in Connection with the Use of EgoDiva’s services

EgoDiva may collect (i) information on purchases and sales of products and services and their history, participation in campaigns, responses to questionnaires, evaluations of services, and other transaction and usage history, (ii) information on the status of communications regarding EgoDiva’s services, mail magazines, and direct mails, (iii) information on interactions with EgoDiva for support via telephone and e-mail, and (iv) information on procedures for requesting disclosure or correction of personal information and on submitted materials.

(4) Communication Information and Contents Information

If a user communicates with another user of EgoDiva’s services or shares communication or contents information (including text, photos, images, sounds, videos, applications, and other information) by uploading contents, EgoDiva may collect such information. The information EgoDiva collects includes messages sent and received between users using the messaging function. Users agree that EgoDiva reviews and uses this information.

(5) Information Acquired through Collaboration with External Services

EgoDiva may collaborate with external services including Facebook and Twitter or perform authentication using the external services. In such cases, EgoDiva may acquire ID used by the users on the external services and other information that the users authorize to be disclosed to the collaborators according to the privacy settings of the external services. In these cases, EgoDiva may obtain the ID used by the person in the external service and other information that the person has authorized the linked party to disclose according to the privacy settings of the external service.

2 To acquire personal information, EgoDiva will not use any wrongful means, including deception, but will use appropriate methods.

Article 3 (Purpose of Use)

1 EgoDiva will properly handle acquired personal information within the scope of the following purposes. EgoDiva will not use the information beyond the scope of the purpose of use without the consent of the person concerned.

(1) To smoothly provide, maintain and improve EgoDiva’s services

(2) For payment processing, including calculating, billing, paying, or remitting of fees and rewards

(3) For identity verification and authentication services

(4) To conduct campaigns and questionnaires

(5) To contact communication and notification of EgoDiva’s services, and to make of important notices such as changes to EgoDiva’s rules, terms and conditions, or policies, or suspension or discontinuation of services provided by EgoDiva

(6) For development, provision, maintenance, and improvement of the services, contents, or advertisements provided by EgoDiva

(7) For providing technical support and information on services, and to respond to inquiries from users

(8) To send messages users as part of the EgoDiva’s marketing activities

(9) For marketing research, statistics and analysis

(10) Recruitment selection and communication

(11) Contact with suppliers, performance of contracts, and claims for performance

(12) Employment management, including of human resources and general affairs

(13) To prevent, investigate, or take countermeasures against, illegal acts, fraudulent acts, and acts that are or might be in violation of EgoDiva’s terms of use

(14) For other purposes specified in EgoDiva’s services

2 EgoDiva may change the purpose of use as stipulated in the preceding paragraph within the scope reasonably deemed to have reasonable relevance with the purpose of use before such change. In the event of such change, EgoDiva will notify users, or make a public announcement, of such change in a manner separately determined by EgoDiva.

Article 4 (Provision to Third Parties)

1 EgoDiva may provide users’ personal information to third parties in the following cases.

(1) When disclosing necessary information such as the name, user name, address, telephone number, and e-mail address of a user to another user in the event of a transaction between the two users of EgoDiva’s services or in the event of a problem related to such transaction.

(2) If the consent of the person in question has been separately obtained.

(3) If required by law.

(4) If a user commits, or attempts to commit, an act that harms the interests of others, offends public policy and morals, or otherwise violates the terms of use of services provided by EgoDiva in connection with the use of EgoDiva’ services, and EgoDiva takes necessary measures against such act.

(5) If it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the person whose personal information is concerned.

(6) If it is particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person concerned.

(7) If it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the person whose personal information is concerned is likely to impede such execution of affairs.

(8) In case of business succession involving transfer of personal information, due to grounds including a merger, company split, and business transfer.

2 EgoDiva may provide personal information to the operators of external services, including Facebook and Twitter, and other collaborating companies to the extent necessary for collaboration with such external services, authentication with such external services or for EgoDiva’ business.

Article 5 (Outsourcing of Handling of Personal Information)

EgoDiva may outsource the handling of all or part of personal information obtained from users to a third party (i.e., outsourcing the management of information, including personal information, to a business operator). In such case, EgoDiva will execute a confidentiality agreement equivalent to this privacy policy with such outsourcee in advance, and will provide necessary and appropriate supervision to ensure that such outsourcee manages the information in an appropriate and secure manner.

Article 6 (Provision to Third Parties Located in Foreign Country)

Outsourcees to which EgoDiva outsources all or part of its handling of personal information include third parties located in a foreign country as defined in the Personal Information Protection Law.

The name of the country in which such third party is located and the relevant system including of personal information protection are as follows.

[Country name]

-United States of America

[Personal Information Protection System of the Foreign Country]

Please refer to the following Personal Information Protection Committee Web site.

https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku

[Personal Information Protection Measures Taken by the Foreign Business Operator]

Each of the business operators handles personal information in accordance with its own privacy policy.

salesforce.com, Inc. https://www.salesforce.com/ap/company/privacy/full_privacy/

Article 7 (Joint Use)

EgoDiva may jointly use acquired information, including user’s personal information, with its alliance partner and other third parties to the extent necessary to provide alliance services. In this case, EgoDiva will make public in advance the names of alliance partner, the purpose of joint use, the type of information to be jointly used, and the address of the person responsible for managing the personal data to be jointly used, as well as the name of the representative of the company if the alliance partner is a company.

Article 8 (Information Collection Module)

EgoDiva’s services, measurement of the EgoDiva’s services site is conducted through the use of Google Analytics by Google, Inc. in order to analyze information including the usage situation of EgoDiva’s services and the effectiveness of advertisements related to services or products of EgoDiva. Analysis through “Cookie” produced concurrently with the above is conducted in some cases. In such cases, some of users’ personal information such as IP address and browsing history might be collected by Google, Inc. EgoDiva receives the results of such analysis from Google, Inc. and uses such analysis solely for the purpose of analyzing site usage situation, compiling reports for site operators, and providing other services. By using this site, users will be deemed to grant Google permission to process such data in the manner and for the purposes described above. If any of users wishes to stop the collection of information through Google Analytics or to review relevant rules including the privacy policy of Google Analytics, please refer to the following.

Google Analytics Privacy Policy (https://policies.google.com/privacy?hl=ja)

Opt-out (https://tools.google.com/dlpage/gaoptout/)

Any user may choose to stop the collection of information through Google Analytics by operating the user’s browser; provided, however, that, in this case, some of the functions of this site might become unavailable.

Article 9 (Security Management System)

1 To prevent leakage, loss, or damage of personal information and otherwise protect personal information, EgoDiva takes necessary and appropriate measures for the secure management of personal information, such as restricting access to personal information files and recording access logs.

2 EgoDiva appoints its representative director the person responsible for the management of personal information, and the Company will implement appropriate management of personal information and continuous improvement.

Article 10 (Request for Disclosure and Correction of Information)

1 Any user may request disclosure of his/her personal information that such user provides to EgoDiva, in accordance with the procedures set forth below.

(1) Please submit your request by filling in the required information in the prescribed form on the EgoDiva’s website.

(2) If the identity of the user making the request under the preceding item is verified, EgoDiva will disclose the personal information to a reasonable extent; provided, however, that this will not apply in cases where the Company is not obligated to make such disclosure under the Personal Information Protection Law or other laws and regulations, including cases where there is a risk of harm to the life, body, property, or other rights or interests of the person concerned or a third party, where there is a risk of significant hindrance to the proper conduct of EgoDiva’s business, or where such disclosure would be in violation of other laws or regulations.

(3) The results of the decision on whether to disclose or not in accordance with the preceding item will be notified to the person concerned without delay.

2 If the content of personal information held by EgoDiva about the individual is false, the individual may request correction, addition, or deletion of such personal information in accordance with the procedures set forth below.

(1) Please submit your request by filling in the required information in the prescribed form on the Company's website.

(2) If the identity of the person making the request in accordance with the preceding item is verified, EgoDiva will conduct checking without delay to the extent necessary to achieve the purpose of use, and based on the results, correct, add, or delete the personal information (“Correction”); provided, however, that this will not apply to cases in which the Company is not obligated to implement Correction under the Information Protection Law or other laws and regulations, including cases in which Correction is not necessary in light of the purpose of use or the claim that the content is false is incorrect.

(3) The results of the decision on whether to conduct correction, addition, or deletion or not in accordance with the preceding item will be notified to the person concerned without delay.

Article 11 (Suspension of Use of Personal Information)

If permitted under the Personal Information Protection Law (in the event of violation of Article 18, 19, or 20 of the Personal Information Protection Law, or in the event that the use of personal information is no longer necessary), any user may request the suspension of use or deletion (“Suspension”) in accordance with the procedures set forth below.

(1) Please submit your request by filling in the required information in the prescribed form on the EgoDiva’s website.

(2) If the identity of the person making the request in accordance with the preceding item is verified, EgoDiva will conduct checking without delay, and based on the results, implement Suspension of the personal information; provided, however, that this will not apply to cases in which the Company will not implement Suspension in accordance with the Information Protection Law or other laws and regulations, including cases in which it is difficult to implement Suspension, such as due to excessive cost for Suspension, and it is necessary to take measures alternative to Suspension for protecting rights and interests of the person concerned or it is likely that rights or legitimate interests of such person will be damaged.

(3) The result of the decision on whether or not to suspend the use in accordance with the preceding item will be notified to the person concerned without delay.

Article 12 (Revision of this Policy)

1 The Company will review from time to time amendments to laws, regulations, and guidelines regarding the handling of personal information and the status of their application, and will strive for continuous improvement, and may revise this policy as necessary.

2 The revised policy will notified to users in a manner easy for users to notice, including posting on this site or EgoDiva website and the revised policy will be applied from the time it is clearly stated in the notice.

3 Notwithstanding the preceding paragraph, if any changes that would legally require the consent of the person concerned is to be made to the content of this privacy policy, such consent will be obtained in a manner separately determined by EgoDiva.

Article 13 (Inquiries)

For any inquiries including opinions, questions, complaints, or offers regarding the handling of personal information, please contact EgoDiva at the address below.

EgoDiva Inc.: info@egodiva.jp

Article 14 (Address and Representative)

The address and the name of representative of EgoDiva are as follows.

Address: 10th floor, 2-8-3 Shinjuku, Shinjuku-ku, Tokyo

Representative: Ginji Usuki

Establishment : April 22, 2022

Date of Revision: May 16, 2022