1. Definition of Personal Data
- "Personal Data" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
2. Contact Information of Data Controller
Name: TOHO Co., Ltd
Address: 1-2-2 Yurakucho,Chiyoda-ku Tokyo 100-8415,Japan
Notes: If Users send an inquiry to the E-mail address above, E-Guardian Inc., a Japanese company, will collect and process the User's E-mail address and the content of the inquiry based on an entrustment by the Company for the purpose of responding to the inquiry.
3. Personal Data Processed
- The Company may process the following Personal Data through our Application:
> Information the Company collects when the User accesses our Application
The Company may collect information regarding the User's access and usage of our Application. This includes the following information:
- Device manufacturer, model and operating system;
- Device properties related to screen size, screen orientation, audio volume and battery, device memory usage;
- Operating system;
- Name and properties of mobile application through which a consumer interacts with the Services;
- Country, time zone and locale settings (country and preferred language);
- Network connection type and speed;
- IP Address;
- Internet browser user-agent used to access the Services;
- Identifier for advertisers (IDFA);
- Device ID;
- Location information; and
- Name, phone number, e-mail address stored in directories on the device.
4. Purpose of Processing Personal Data
Personal Data may be used only for the following purposes, not for any other purpose.
(1) To provide the Users of our Application with the most optimal information
Legal Basis: The Company process the Personal Data based on the legitimate interests pursued by the Company (providing the Users of our Application with the most optimal information).
(2) For surveying and analyzing usage on our Application
Legal Basis: The Company process the Personal Data based on the legitimate interests pursued by the Company (improving our Application).
(3) For improving the Application, developing new services, etc.
Legal Basis: The Company process the Personal Data based on the legitimate interests pursued by the Company (improving our Application and developing new services, etc.)
(4) For placement of behavioral targeted ads
Legal Basis: The Company process the Personal Data based on a consent from Users.
Behavioral targeted ads refer to user-optimized ads that are distributed by using behavioral history such as a User's browsing history of our Application and viewing history of ads placed on the Application.
(5) For usage related to the above purposes
5. About Cookies
Cookies refer to small data files sent from a website to the User's browser.
By using cookies, browsed internet sites and servers can identify the site's User's individual browser from other internet browsers with different cookies. Using a unique cookie ID, they can recognize and identify a specific Internet browser.
If a User does not wish for their cookie information to be collected, they may disable the feature within their internet browser's settings at any time ("opt-out"). However, please be advised that by disabling the cookies feature the user will lose access to some of our services. In addition, by changing browsers, deleting cookies, or changing to a new device, etc., the opt-out feature will be disabled, so please note that the user may need to repeat the process if the user wishes to opt-out again.
6. Providing Information to Third-Party
7. Necessity of Providing Personal Data
- The Personal Data that Users are to provide is not necessary in order for the User to access the Application. However, without the Personal Data, there may be cases where the Company will not be able to provide the services to Users, in whole or in part.
8. International Transfers of Personal Data
- The Personal Data may be transferred to entities in countries or jurisdictions outside the European Economic Area (the "EEA"), if required for the purposes as described above. Please note that such countries or jurisdictions may not have the same data protection laws as the EEA and that they may not afford many of the rights conferred upon the user in the EEA. The Company will ensure that any such international transfers are made subject to appropriate and suitable safeguards as required by the applicable privacy law. When doing so, the Company will comply with applicable privacy law and take appropriate safeguards to ensure the security and integrity of the Personal Data.
9. User Rights
Under the applicable privacy law, the User of this Application has following rights. If the User would like to request to access, correct, delete, or restrict the use or object to the processing of their Personal Data that the User have previously provided to the Company, or if the User would like to receive an electronic copy of the User's Personal Data for purposes of transmitting it to another company (to the extent these rights are provided to the User by law), please contact the Company at the Contact Information of Data Controller.
(1) The right to withdraw consent regarding Personal Data;
(2) The right to demand access to Personal Data;
(3) The right to demand corrections to Personal Data;
(4) The right to demand Personal Data be deleted;
(5) The right to object to the Company's processing of Personal Data;
(6) The right to demand a restriction of processing of personal information;
(7) The right to complain to a supervisory authority that is located in the User's address, place of work, or a violation is alleged to have occurred. However, the Company ask that the User please contact the Company before making a complaint with the supervisory authority so that the Company can take care of any complaints; and
(8) The right to request to disclose the following;
However, we may deny the user's request specified in (1) through (8) above if retaining the information is necessary for us to:
- The categories of personal information it has collected about that consumer;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom the business shares personal information; and
- The specific pieces of personal information it has collected about that consumer.
(1) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
(2) Debug products to identify and repair errors that impair existing intended functionality.
(3) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
(4) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
(5) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if the user previously provided informed consent.
(6) Comply with a legal obligation.
(7) Make other internal and lawful uses of that information that are compatible with the context in which the user provided it.
10. Personal Data from Children
- Our Application are not intended to provide with children under the age of 13 and we do not knowingly collect any Personal Data from such children. In the event that we learn that we have inadvertently gathered Personal Data from children under the age of 13 without verification of parental consent, we will take reasonable measures to promptly erase such information from our records.
- Under California Law, we will not discriminate against California residents for exercising any of their rights under the California Consumer Privacy Act (CCPA). Unless permitted by the CCPA, we will not:
However, we may offer the user certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the user personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires the user's prior opt in consent, which the user may revoke at any time.
- Deny the user goods or services.
- Charge the user different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide the user a different level or quality of goods or services.
- Suggest that the user may receive a different price or rate for goods or services or a different level or quality of goods or services.
12. Safety Control Measure
- The company has taken adequate technical and organizational safety control measures regarding the protection of Personal Data. If the User of this Application is concerned about the specific method of data transfer etc., we will take sufficient alternative measures.
13. Storing of Personal Data
- The Company does not store Personal Data beyond the limit necessary for the purpose of usage, and Personal Data will be promptly and securely deleted after the end of the statutory retention period unless it is necessary for the purposes of processing.
14. General Clause
Date of Last Revision: March 25, 2021