1. Definitions

For the purposes of this privacy policy, “personal information” refers to any and all information than is entrusted to us by users of one or more of our services that can be used to determine the identity of said user, including gender, birth date, address, telephone number, e-mail address, etc.

2. Regarding the handling and usage or personal information

When collecting personal information from users, the purpose, usage, and scope of said usage will be displayed and made known in advance to the user on a service-by-service basis, either on a web site or within an application where such personal information is collected.

3. Purpose of using personal information

We will not use personal information collected from users in a way that goes beyond the stated scope and purpose of usage of each service without first obtaining the user’s consent.
Note that there are times when information that has been collected from users is shared with third parties, such as information that has been processed for statistical analysis including gender distribution summaries, preference distribution summaries, usage history patterns, etc. This information cannot be used to personally identify users.

4. Acquisition, provision, and disclosure of personal information

Personal information will be acquired properly without the use of deception or other fraudulent means. Except in the following cases, personal information will not be supplied to third parties without prior consent of the user. There are cases where personal information may be transmitted to our subcontractors or affiliates as necessary by the nature of the service, of which the user will be aware of by accepting the respective Terms of Use or other such agreements before beginning utilization of said service. In such cases, we take necessary measures to protect the personal information of our users through the signing of confidentiality agreements between us and our partners, so as not to allow our partners to use the personal information they may obtain in a way that violates the personal information usage purpose presented to our users upon the start of each service. Please also note that we will cooperate with law enforcement officials in the event that personal information is requested in accordance with the laws and regulations of Japan.

5. Secure management of personal information

Regarding the handling of our users’ personal information, we will take all possible precautions to safeguard against the leakage, loss, damage, falsification, and unauthorized access of personal information obtained from our users. In addition, we will continue to strive to keep the personal information of our users as current and as accurate as possible. Additional oversight is allocated towards limiting the number of employees with access to the personal information of our users, on a “needs-to-know” basis.

6. Personal information of those under 15 years of age

We will take all possible care in protecting the personal information of minors under the age of 15. For those under the age of 15, consent of a parent of legal guardian is required to register for the services we provide.

7. Requests for the use, correction, deletion, or disclosure of personal information

When users wish to make a request involving the suspension, correction, deletion, or disclosure of personal information that we hold, inquires should be submitted to the predetermined Contact support terminal for the service in question. Except in cases where special procedures have been prescribed by law, we will verify the identification of the user making such a request and disclose, stop usage, or delete the personal information related to said user within a reasonable timeframe. However, in cases where the suspension of usage, deletion, or correction of personal data would result in a significant cost to us, possibly from the additional resources required to protect the rights and interests of the person in question or resulting from disruption of service, an extra fee may be imposed. Depending on the the method of disclosure, scale of disclosure, etc. there are times when it will be required to pay a separate fee for such support.

8. Compliance with laws and regulations

When dealing with personal information collected from our users, we will comply with all relevant laws and regulations relating to the protection of personal information in Japan, along with various other internal rules and regulations.

Enacted: July 1, 2009
Revised: July 12, 2010

UpSwell, Inc.

Please note that in the event of any differences in meaning or interpretation between the original Japanese version of this Privacy Policy and a translation, the original Japanese version takes precedence.