Privacy policy

TOKiON (“we”, “us”, “our website”) recognizes the importance of protecting your personal information and, in addition to complying with the Act on the Protection of Personal Information (“APPI”), we will endeavor to handle and protect your personal information in an appropriate manner in accordance with the following privacy policy ("Privacy Policy").

1. Definition of personal information

In this Privacy Policy, “personal information” means the “personal information” defined in Article 2(1) of the APPI, namely information about a living individual which can identify the specific individual by name, date of birth, or other description contained in such information (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual) or information containing an individual identification code.

2. Purposes for which personal information is used

(1) We will use your personal information for the following purposes:

① To provide content-distribution services (including official Twitter, official Instagram, and other social networking services operated by third parties) (including authentication if we ask you to register or if you sign on via third-party services).

② In addition to the preceding tem, to inform you of information including recommended articles using desktop notifications or push notification functions.

③ To distribute email newsletters (to provide information on services provided by us or to provide information on goods and services sold on our website).

④ To distribute advertising relating to our website (including by means of third party websites or social networking services) and to use data in advertising distribution services in a form that does notpermit the identification of a specific individual.

⑤ To respond to customer inquiries, etc.

⑥ To respond to acts that breach our terms of use or policies concerning the services provided by us (“Terms).

⑦ To inform you of changes to the Terms concerning the services provided by us.

⑧ To improve the services provided by us and to promote the development of new services, etc.

⑨ To generate statistical data which is processed into a form that does not permit the identification of a specific individual in relation to services provided by us for the purpose of ⑧ or for marketing purposes.

⑩ To provide services such as the purchase or delivery of goods and services.

(11) To contact advertisers following customer inquiries.

(12) To conduct events and offer prizes (including in relation to contacting winners, delivering prizes, or other procedures).

(13) To conduct monitoring, surveys, and questionnaires.

(14) For other purposes incidental to those listed above.

(2) Our services use cookies and other similar technologies (“Cookies, etc.”). These technologies help us to understand how our services are being used so as to improve them, and are used for the purposes set out in (1) ④, ⑧, and ⑨. Email addresses and other customer data (this may include date of birth, gender, prefecture, etc.) or data processed into a form that does not permit the identification of a specific individual may be shared with providers of third party analytical modules associated with Cookies, etc. provided that this is within the scope of these purposes.

Users wishing to turn off cookies can do so by changing their browser settings. However, turning off cookies may mean that users are no longer able to use some of our services. Users wishing to turn off cookies should refer to the following cookie policy.

Providers of third party analytical modules

Google https://support.google.com/ads/answer/2662922?hl=ja

Chartbeat https://static.chartbeat.com/opt-out.html

Facebook https://www.facebook.com/legal/terms

Instagram https://www.instagram.com/about/legal/privacy/

Twitter https://support.twitter.com/articles/20171553-

Treasure Data https://www.treasuredata.com/privacy

New Relic https://newrelic.co.jp/termsandconditions/cookie-policy

Zendesk https://www.zendesk.co.jp/company/policies-procedures/cookie-policy/

SendGrid https://sendgrid.kke.co.jp/privacypolicy/

Disqus https://help.disqus.com/en/articles/1717155-use-of-cookies

Auth0 https://auth0.com/privacy

Shopify https://www.shopify.com/legal/cookies

Wordpress https://ja.wordpress.org/about/privacy/cookies/

Spotify https://www.spotify.com/jp/legal/cookies-policy/

3. Changing the purpose for which personal information is used

We may use your personal information for a different purpose if this is related to the original purpose and it is reasonable to do so. In the case of a change of purpose, we will notify you or publish an announcement.

4. Restrictions on the use of personal information

We will not handle your personal information beyond the scope required to achieve the usage purposes without your consent, unless this is permitted under the APPI or other laws and ordinances. This does not, however, apply in the following cases:

① Where there is a legal basis.

② Where it is necessary to protect life or limb or to prevent damage to property, and it is difficult to obtain your consent.

③ Where there is a particular need to advance public health or to promote the healthy development of children, and it is difficult to obtain your consent.

④ Where it is necessary to cooperate with government agencies, local government bodies, or their agent in the execution of their duties set out in laws and ordinances and there is a risk that obtaining your consent could interfere with the execution of those duties.

5. Reasonable collection of personal information

We will acquire your personal information in a reasonable manner and will not use deception or other wrongful means.

6. Security of personal information

We will put in place appropriate measures to ensure the security of your personal information with the aim of protecting against risks such as the loss, destruction, alteration, or leak of personal information. We will also monitor our employees as well as any processors contracted to handle your personal information in part or whole, and will do this in an appropriate manner as required for the security of personal information.

7. Third-party provision

We will not provide your personal information to a third party without your prior consent unless it is for third-party authentication, to publish a comment where a user provides information in an icon, nickname, or in a comment on content that could identify the user, for the purpose set out in paragraph (2) in ‘2. Purposes for which personal information is used’, or where it is permitted under the APPI or other laws and ordinances. The third-party provision set out above, however, does not include the following cases:

(1) Where we provide the information when subcontracting the handling of personal information in part or whole to the extent required to achieve the usage purposes.

(2) Where personal information is provided following a merger or the transfer of operations for other reasons.

(3) Where joint use is based on the provisions of the APPI.

8. Disclosure of personal information

If we receive a request from you pursuant to the APPI to disclose personal information, we will first verify that the request came from you, and then disclose the information to you without delay (or, if the requested personal information does not exist, inform you to this effect). This does not apply, however, if we are not under an obligation to disclose the information under the APPI or other laws and ordinances.

9. Correction of personal information

If we receive a request from you pursuant to the APPI to correct, add to, or delete (“Correct”) some of your personal information because the personal information is not factual, we will first verify that the request came from you, and then conduct the necessary investigations without delay to the extent required to achieve the usage purposes, and, based on the findings, Correct the personal information and notify you to this effect (or, if we decide not to Correct it, inform you to this effect). This does not apply, however, if we are not under an obligation to Correct the information under the APPI or other laws and ordinances.

10. Ceasing use of personal information

If we receive a request from you pursuant to the APPI to cease use or erase your personal information because your personal information has not been handled within the extent of the purposes previously published or because it has been collected using deception or other wrongful means, or if we have been requested to cease provision of your personal information because it was provided to a third party without your prior consent (collectively, “Cease Use”), and it is clear that there is a reason for the request, we will first verify that the request came from you, and then Cease Use of the personal information without delay and notify you to this effect. This does not apply, however, if we are not under obligation to Cease Use of the information under the APPI or other laws and ordinances.

11. Contact details

If you would like to contact us concerning the handling of your personal information, such as to make a disclosure or other request, to provide a comment or ask a question, or to file a complaint, please contact us using the contact details shown below, or by using the contact form on our website.

Contact details:

President and Administrator for Protection of Personal Information

Masahiro Shinozaki

7-20-6 Roppongi, Minato-ku, Tokyo, Japan 106-0032

policy@tokion.jp

13. Ongoing improvements

We will revise how we handle personal information from time to time and endeavor to make ongoing improvements, and it may therefore be necessary to update this Privacy Policy.