Progummy Inc. (hereinafter referred to as "we", "our" or "us") will handle information including personal information provided by all users of the services we develop and administer (hereinafter referred to as "User" or "Users") in accordance with the following policy.
1. Content and method of collection of information we collect
We will automatically collect Users' usage history of Progummy, and in addition collect respective information entered by Users into the entry forms provided within Progummy, respective information provided by social network services which Users have authorized to be linked to Progummy, and respective information provided to us in connection with inquiries and so on about Progummy.
2. Purposes of use of collected information
We will use the information (including personal information) collected from Users within the scope of the following purposes and to the extent necessary for the performance of our business:
User identity verification;
Notification of matters necessary for the administration of Progummy;
Arrangement of service contents provided to the Users;
Promotional activities and other activities that contribute to the administration and penetration of services, after processing such information so that the relevant individual cannot be identified;
Production and use of statistical information to the extent that it is not possible to identify the relevant individual;
Analysis and marketing of data necessary for the improvement and new development of Progummy;
Exercise of rights or performance of obligations under agreements and laws, etc.;
Support for after-sales services and response to various inquiries;
Investigation or injunction of use in a manner contrary to the Terms of Use, etc.; and
Provision of advertising from Progummy to the Users.
3. Use of personal information
For the purpose of this Policy, personal information means information stipulated in Article 2, paragraph (1) of the Act on the Protection of Personal Information (hereinafter referred to as "Personal Information Protection Act"). We will use personal information of Users by lawful and fair means in accordance with the Personal Information Protection Act, etc.
4. Use of statistical data, etc.
If the information processed or produced pursuant to item 4 or 5 of Section 2 is anonymously processed information prescribed in the Personal Information Protection Act, we will use such information in accordance with the provisions of the said Act.
5. Third-party provision
Except as set forth below, we will not use or provide to a third party any personal information beyond the scope necessary for the achievement of the intended purposes without the prior consent of the User:
When it is permitted by laws and regulations;
When we outsource part of the operations of development, administration and provision of services of Progummy to a third party, and disclose the personal information to such third party to the extent necessary for the performance of the outsourced operations;
When the information is disclosed to a third party in the case where Progummy is provided in cooperation with such third party; or
When the personal information is disclosed to a person who succeeds to a business when the business is succeeded to due to a merger, business transfer or other event.
6. Management of personal information
We will manage personal information appropriately and carefully, prevent unauthorized access to personal information, and loss, destruction, falsification and leakage, etc. of personal information, and implement necessary and appropriate measures.
If we provide personal information to a third party pursuant to the provisions of the preceding paragraph, we shall impose the same obligations as those under this Privacy Policy on such third party.
7. Disclosure, correction, suspension of use and deletion of personal information
If you request disclosure, correction, suspension of use or deletion, etc. of your personal information, please contact the inquiry desk set out in Section 10 below. After verifying your identity, we will respond to your request to a reasonable extent.
8. Transfer of personal information
Personal information of individuals residing in EEA countries and subject to GDPR may be transferred outside of EEA countries and stored on servers in Japan. We will appropriately manage personal information collected and transferred in accordance with the provisions of GDPR.
9. Amendments
We may revise this Privacy Policy to take more appropriate measures. If such revision is made, we will inform you of such revision by displaying the same in the relevant application or by other appropriate means.
10. Inquiry desk
If you have any inquiries about this Privacy Policy, please contact us at info[at]progummy.com.
If you are residing in an EEA country and subject to GDPR, please also contact us at info[at]progummy.com to exercise your GDPR rights.
11. Date of enforcement and date of revision
Enforced on December 3, 2020
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