Privacy Policy

Acquisition of personal information

The Company acquire personal information either by being provided by
customers or collecting it when customers use the services provided by the Company.

Purpose of Use of Personal Information

• Personal information about administrators and person in charge using the Company
  services (name, department, contact information, etc.)

• • For the execution of contract, customer management and business incidental
    thereto
  • To provide customer support
  • To provide information from the Company (including advertising information
    such as event information)
  • To respond when necessary to ensure the security of the Company services or
    when incidents (including illegal activities) or accidents occur
  • For the development of better services and the use for market and customer
    trend research and analysis for marketing, etc.
  • To produce statistical data on the Company services (data are processed so
    that individuals cannot be identified)
  • Responding to opinions, requests, inquiries, etc. concerning the Company
    services

• Personal information of those who contact the Company regarding the service
  provided (name, department, contact information, etc.)

• • For liaison and necessary administrative procedures concerning the Company
    services
  • To provide information from the Company (including advertising information
    such as event information)
  • For the development of better services and the use for market and customer
    trend research and analysis for marketing, etc.
  • To produce statistical data on the Company services (data are processed so
    that individuals cannot be identified)
  • Responding to opinions, requests, inquiries, etc. concerning the Company
    services

• Personal information (name, department, contact information, etc.) obtained at
  the time of receipt of inquiries, comments, etc., about matters other than the
  provision of the Company services

• • To respond to various inquiries

• Personal information of those who participated in events such as seminars (name,
  department, contact information, etc.)

• • For the operation and management of the event (including the provision of
    participant information to co-sponsors and supporting companies)
  • To provide information from the Company (including advertising information
    such as event information)
  • For the development of better services and the use for market and customer
    trend research and analysis for marketing, etc.
  • Responding to opinions, requests, inquiries, etc. concerning the Company
    services

• Personal information of shareholders and investors (name, contact information,
  etc.)

• • To conduct business in relation to the exercise of shareholders’ rights
    under the Companies Act and other laws and regulations
  • To grant shareholders various conveniences from the Company due to their
    position
  • To provide information from the Company (including advertising information
    such as event information)

• Personal information about business partners (name, department, contact
  information, etc.)

• • For liaison, negotiation, contract procedures, transaction management, etc.
    with business partners and execution of business incidental thereto
  • To provide information from the Company (including advertising information
    such as event information.)
  • For the development of better services and the use for market and customer
    trend research and analysis for marketing, etc.

• Personal information about people who wish to join the Company (name, contact
  information, personal history, etc.)

• • To use in recruitment screening (communication, examination and decision on
    acceptance, etc.)
  • To provide information from the Company (including advertising information
    such as event information)

• Personal information for employees, including retirees (name, contact
  information, personal history, etc.)

• • For various procedures such as employment management of employees,
    processing of personnel affairs, etc., and communication of other general
    affairs, etc.

• Personal information that the Company acquires through entrusted operations
  (personal information that is entrusted with some or all of the handling in
  connection with the provision of services to customers) (name, department,
  contact information, etc.)

• • A part or all of the handling of personal information is entrusted in
    connection with services provided by the Company for the purpose of
    conducting the following operations, etc.
    • Services such as account issuance for users who use the services
    • Responding to inquiries from customers or users regarding the use of
      the services
    • Management of ID associated with user information
    • Communication to users regarding how to use the services, updates,
      etc.

• Personal information of users who use our services (name, department, contact information, user ID, location information using the GPS function of the user’s device, camera images taken by the user and their acquisition times, etc.)

• • To provide services that combine location information, camera images, and drawings when providing our company’s services

  In addition to the purposes of use set forth above, the Company uses the obtained
  personal information to the extent necessary for the purposes for which the
  Company has notified the individual.

Provision of acquired personal information to third parties

1. The Company will not provide personal information acquired from customers to third parties without prior consent, except in the following cases:
   1. When necessary for the protection of a person’s life, body or property, and when it is determined that it is difficult to obtain the consent of customer;
   2. When particularly necessary for the improvement of public health or the promotion of the sound development of children, and when it is determined that it is difficult to obtain the consent of customer;
   3. When it is necessary to cooperate with a national agency or a local government, or a person entrusted by the same, in the execution of affairs prescribed by laws and regulations, and when it is determined that obtaining the consent of customer is likely to hinder the execution of said affairs;
   4. Other cases permitted by laws and regulations.
2. The Company will not provide personal information handled by the Company to third parties located in foreign countries without prior consent, except in the following cases:
   1. When personal data is provided to a third party located in a foreign country who has implemented measures in accordance with the provisions of Chapter 4, Section 2 of the Personal Information Protection Act in an appropriate and reasonable manner with regard to the handling of personal information, and whose implementation has been verified by the Company;
   2. Cases that fall under any of items (1) through (4) of the preceding paragraph;
   3. Other cases permitted by laws and regulations.

Management of subcontractors

The Company may outsource all or part of the handling of personal information to the extent necessary for achieving the purpose of use. In such a case, the Company shall select a subcontractor who is deemed to properly handle personal information and shall provide appropriate supervision.

Joint use

The Company may use the personal data listed below jointly with our Group companies (*) within the scope of the purpose of use set forth below. The person responsible for the management of the joint use of personal information shall be as set forth in “9. Person in charge of personal information management.”

*Subsidiaries as defined in Article 8, Paragraph 3 of the Regulation on Terminology, Forms and Preparation Methods of Financial Statements, etc., and affiliated companies as defined in Article 8, Paragraph 5 of these Regulations.

1. Personal information about administrators and person in charge using the Company services
   • Items of personal data: Name, department, contact information, and others
   • Purpose of use: As set forth in “2. Purpose of Use of Personal Information”
2. Personal information of those who contact the Company regarding the service provided
   • Items of personal data: Name, department, contact information, and others
   • Purpose of use: As set forth in “2. Purpose of Use of Personal Information”
3. Personal information obtained at the time of receipt of inquiries, comments, etc., about matters other than the provision of the Company services
   • Items of personal data: Name, department, contact information, and others
   • Purpose of use: As set forth in “2. Purpose of Use of Personal Information”
4. Personal information of those who participated in events such as seminars
   • Items of personal data: Name, department, contact information, and others
   • Purpose of use: As set forth in “2. Purpose of Use of Personal Information”
5. Personal information about business partners
   • Items of personal data: Name, department, contact information, and others
   • Purpose of use: As set forth in “2. Purpose of Use of Personal Information”
6. Personal information about people who wish to join the Company
   • Items of personal data: Name, contact information, personal history, and others
   • Purpose of use: As set forth in “2. Purpose of Use of Personal Information”
7. （1）Personal information for employees, including retirees
   • Items of personal data: Name, contact information, personal history, and others
   • Purpose of use: As set forth in “2. Purpose of Use of Personal Information”

Provision and Entrustment of Acquired Personal Information to Third
Parties

The Company shall not provide personal information obtained from customers
to third parties except in the following cases:

1. When required by laws and regulations;
2. When it is necessary for the protection of the life, body or property of a person
   and when it is determined that it is difficult to obtain the consent of the person;
3. When it is particularly necessary for the improvement of public health or the
   promotion of the sound upbringing of children and when it is judged to be difficult
   to obtain the consent of the person; or
4. When it is necessary to cooperate in the execution of affairs prescribed by laws and
   regulations by a national organ, a local government, or a person entrusted thereby,
   and when it is judged that obtaining the consent of the person is likely to hinder
   the execution of said affairs.

The Company may entrust all or part of the handling of personal
information to the extent necessary to achieve the purpose of use. In such cases, the
Company shall select outsourcing contractor that is deemed to handle personal
information appropriately and perform appropriate supervision.

Cookie usage status

1. Cookies

   Cookies are functions that enable the device customers use to store information
   about the visit to websites on the computer, tablet PC, mobile phone, or other
   device (the “Device”). Cookies enable to retrieve information on the Device, such as
   the number of website visits and pages visited.

2. Using Cookies

   The Company uses cookies to analyze customers’ website usage to improve website
   performance and the services provided to customers. The Company uses tools such as
   Google Analytics and Pardot for analysis.
   Cookie information obtained on this website does not include information that can
   identify the customers personally.
   Customers can stop the use of cookies by disabling them on their own from the
   settings of the web browser.

3. Cookie Management Settings

   Customers can enable, disable, or delete cookies in the settings of their web
   browser. Cookie management settings vary by web browser, and available settings and
   features may be changed by the developer at any time.
   The following links provide detailed information on cookie management settings for
   each of the major web browsers.
   Microsoft Edge
   Google Chrome
   Safari

Disclosure, Correction and Suspension of Use of Retained Personal
Data

• If the Company receives a request for disclosure of retained personal data (this
  shall mean notification of the purpose of use of retained personal data, disclosure
  of retained personal data, correction, addition or deletion of content, suspension
  of use, deletion or suspension of provision to third parties, or disclosure of
  records provided to third parties) from a user in accordance with the provisions of
  the Act on the Personal Information Protection, the Company shall respond without
  delay after confirming that the request is from the user. The Company shall notify
  the user if the subject personal data does not exist or if it decides not to
  disclose it for a justifiable reason under the provisions of the Act on the Personal
  Information Protection.
• Requests for disclosure, etc. shall be in accordance with the format prescribed by
  the Company, and requests in any other format shall not be accepted. For information
  on the Company standard format, please use this inquiry form.
  
  Please note that there is a fee of 1,000 yen per case, which is prescribed by the
  Company, for notifying the purpose of use and disclosing the retained personal data.

Security management measures

1. Organizational security management measures

   • In order to ensure the proper handling of personal information held by the
     Company, basic matters concerning the handling of personal information have
     been stipulated in regulations, and operations are conducted in accordance
     with the regulations.
   • Under the supervision of the representative director, who is in charge of
     handling personal information, the Company has appointed a person in charge
     of personal information management and a personal information management
     office to establish a personal information management system.
   • The Company has prepared a response manual and response system in
     preparation for accidents such as leakage of personal information.

2. Human security management measures

   • Internal education on the protection of personal information is provided to
     officers and employees of divisions in charge, and efforts are made to make
     them understand and comply with relevant laws and regulations as well as
     internal rules and detailed regulations.
   • In cases where the handling of personal information is outsourced to an
     outside company, a contract stipulating matters concerning confidentiality
     is concluded with the outsourcing contractor.

3. Physical security control measures

   • For the protection and management of personal information, the Company
     designates areas where entry or access is prohibited for persons other than
     those authorized to access the personal information, and manages information
     on entry and exit in the restricted areas and access records in the
     restricted areas.
   • The Company has implemented anti-theft measures such as locking devices and
     electronic media in which personal information is stored.
   • When devices and electronic media in which personal information is stored
     become unnecessary, the stored personal information is deleted and
     physically disposed of.

4. Technical safety control measures

   • The system that handles personal information uses an ID and password or a
     biometric user authentication function.
   • In cases where the authority to access personal information is granted, it
     shall be limited to officers and employees who needs access in the course of
     business, and the access authority granted to such officers and employees
     shall be the minimum necessary.
   • The access rights of officers and employees handling personal information
     are modified in accordance with the changes, and are cancelled when the
     employment, contract or agreement is terminated.
   • When personal information is sent, only encrypted communication paths are
     used.

Person in charge of personal information management

The following personnel shall be responsible for managing the personal
information received.

Kenji Ito, Head of Personal Information at SpiderPlus & Co.

Links to websites other than the Company’s websites

The Company’s website provides links to websites of the Company’s
affiliates and third parties for customers’ convenience. Please note that the Company is
not involved in the content of the linked websites and is not responsible for the
handling of personal information.

Contact for personal information inquiries and complaints

Spider Plus & Co.
Address: 105-0001
Sumitomo Fudosan Toranomon Tower 27th Floor, 2-2-1 Toranomon, Minato-ku, Tokyo

For inquiries,please use the inquiry
form.

Revision

The Company shall promptly post any revisions to this Privacy Policy on
the Company’s website in response to revisions to the protection of personal information
and changes in the surrounding environment in order to further protect personal
information.