soeasy, Inc. (hereinafter referred to as the “Company”) hereby stipulates as follows a privacy policy (hereinafter referred to as the “Policy”) concerning the handling of private information that includes the personal information of users (refer to all users who use the Service and include users before beginning use who want to use the Service; hereinafter the same) for the service (hereinafter referred to as the “Service”) provided by the Company.

Of private information, “personal information” refers to the information defined in the Act on the Protection of Personal Information. Of private information, “history information and characteristic information” refers to information other than the personal information stipulated above, and it indicates the services that were used, products that were purchased, the history of pages and advertisements that were accessed, search keywords for which the user conducted searches, dates and times of use, methods of use, use environment, postal code, gender, occupation, age, the user’s IP address, cookie information, position information, and the terminal’s individual identification information.

When a user registers to use or requests materials from the Company, the Company may request personal information that includes the user’s name, date of birth, address, telephone number, e-mail address, bank account number, credit card number, and driver’s license number. In addition, transaction records that include the user’s personal information for transactions between the user and a business partner and information related to settlements may be collected from the Company’s business partners (including parties that provide information, advertisers, and parties to which advertisements are delivered; hereinafter referred to as the “Business Partners”).
When the user uses a service of the Company or a Business Partner or accesses a page, the Company will collect history and characteristic information about the user, such as services and software that were used, products that were purchased, the history of pages and advertisements that were accessed, search keywords for which searches were conducted, dates and times of use, methods of use, use environment (including the state of correspondence on the relevant terminal in the case of use via a mobile terminal, and information about various settings for use), IP address, cookie information, position information, and the terminal’s individual identification information.

The purposes for which the Company will collect and use personal information are as stated below.
(1) For provision of the Service
(2) For handling contact and inquiries related to the Service
(3) For providing information about the Company’s other products or services
(4) For handling actions that violate the Company’s regulations related to the Service
(5) For giving notification about changes of terms
(6) For utilization for improvement of the Service or development of new services
(7) For changing information into statistical data in relation to the Service
(8) For other purposes that are incidental to the aforementioned purposes of use

Except for cases that are permitted based on the Act on the Protection of Personal Information or another law or ordinance, the Company will not, without obtaining agreement from the user, handle personal information beyond the scope that is necessary in order to accomplish the purposes of use. Provided, however, that this will not apply in the cases below.
(1) A case based on a law or ordinance
(2) In the event that it is necessary in order to protect a person’s life, body, or property, when it is difficult to obtain agreement from the user
(3) In the event that it is particularly necessary in order to improve public health or promote the sound upbringing of children, when it is difficult to obtain agreement from the user
(4) In the event that it is necessary to cooperate with the performance of clerical work that is stipulated in a law or ordinance and that will be conducted by a national government organization, a local government, or a party that received consignment from a national government organization or a local government, when there is a possibility that obtaining agreement from the user will cause a hindrance to the performance of that clerical work

Except in cases where disclosure is allowed based on the Act on the Protection of Personal Information or another law or ordinance, the Company will not provide personal information to a third party without obtaining agreement from the user in advance. Provided, however, that the cases stated below will not fall under the provision to third parties stipulated above.
(1) A case in which the Company will consign all or a portion of handling personal information within the scope that is necessary in order to accomplish the purposes of use
(2) A case in which personal information will be provided in association with succession of business due to a merger or another reason
(3) A case in which joint use will be conducted based on the stipulations of the Act on the Protection of Personal Information

Our service transmits the following information externally:

(1) Customer Information to be transmitted:
Cookies (randomly generated identification ID) or unique ID specific to the app,
System log information of the device,
Information entered by the customer.

(2) Purpose of the transmission:
To provide the inherent functionalities of the app/service,
To analyze usage of the app/service, and to improve and enhance quality.

(3) Recipients:
Google, Inc.
Amazon.com, Inc.
Salesforce, Inc.
Sendbird, Inc.
Twilio, Inc.
Zebrafish Labs, Inc.
One More Cloud, Inc. (only for the 'user information sent from third-party modules')
Rollbar, Inc. (only for the 'user information sent from third-party modules')
New Relic, Inc. (only for the 'user information sent from third-party modules')
Talend, Inc. (only for the 'user information sent from third-party modules')

1. In the event that the user asked the Company to disclose personal information, the Company will confirm that it is a request made by the user and then disclose the personal information to the relevant user without delay. Provided, however, that in a case that will fall under one of the items below as a result of disclosure, we may not disclose all or a portion of the personal information, and in the event that we decided not to disclose the information, we will give notification of that fact without delay. Please understand in advance that we may collect a service charge for disclosure of personal information.
(1) A case in which there is a possibility of harming the life, body, property, or other rights or interests of the relevant person or a third party
(2) A case in which there is a possibility of causing a significant hindrance to proper implementation of the Company’s work
(3) Another case that would be a violation of a law or ordinance
2. Irrespective of the provisions of Article 6.1, in principle, we will not disclose information other than personal information, such as history and characteristic information.

1. In the event that the user’s own personal information that is possessed by the Company is erroneous, the user can conduct the Company’s stipulated procedures and thereby ask the Company to correct or delete the personal information.
2. In the event that the Company received a request of Article 7.1 from the user and judged that it is necessary to handle that request, it will correct or delete the relevant personal information without delay and then notify the user of that correction or deletion.

In the event that the user asked the Company to suspend the use of or delete (hereinafter referred to as the “Suspension of Use”) personal information based on the reason that the relevant personal information is being used beyond the scope of its purposes of use or based on the reason that it was obtained by unjustifiable means, the Company will conduct the necessary investigation without delay and then, based on those results, conduct the Suspension of Use of personal information and notify the relevant person of that fact. Provided, however, that in the event that the Suspension of Use of personal information will require a large amount of expenses, or in another case in which it is difficult to suspend the use, if it is possible to implement measures that should be substituted and that are necessary in order to protect the relevant person’s rights and interests, those substitute measures will be implemented.

The content of the Policy can be changed without notifying users. Except in cases where the Company stipulates separately, the privacy policy after a change will become valid at the time it was posted on the Company’s website.

We will take reasonable safety measures and preventive and corrective measures against risks such as leakage, loss or damage of personal information so that users can use this service with peace of mind.
（1）Systematic security control measures
　　The person in charge confirms that personal information is handled according to the established handling method.
（2）Personnel security control measures
　　We provide regular training to employees regarding points to note regarding the handling of personal information.
（3）physical security measures
　　We have implemented measures to prevent anyone other than the employee who can handle personal information and the person himself/herself from easily viewing personal information.
（4）Technical safety control measures
　　We will clarify the equipment that can handle personal information and the employees who handle such equipment, and prevent unnecessary access to personal information.
（5）Understanding the external environment
　　When handling personal information in a foreign country, we will take the necessary and appropriate measures for the safe management of personal information after understanding the system for the protection of personal information in that country.

If you would like to make an inquiry related to the Policy, please use the form stated below.

#2F P208 Axle ochanomizu
3-28-5 Kandaogawamachi,
Chiyoda-ku, Tokyo-to 101-0052
Japan

soeasy, Inc.
CEO Keisuke Iio

【soeasy Co., Ltd.】inquiry email

enactment 4/11/2018
revision 6/12/2023