Privacy Policy

TCROSS Co., Ltd. ("TCROSS Co., Ltd." or the "Company") and TCROSS Communication Co., Ltd. The following privacy policy (hereinafter referred to as the "Policy") shall apply to the handling of user information, including personal information, on the services provided by the Company (hereinafter referred to as the "Services"). The following privacy policy (hereinafter referred to as the "Policy") is set forth below.

1. User Information to be Collected and Collection Method

In this Policy, "User Information" means information pertaining to the identification of users, action history on communication services, and other information generated or stored by users or in relation to users' terminals, such as smartphones and PCs, and which is collected by the Company in accordance with this Policy. This means information that we collect under this Policy.

Information provided by the customer

All information provided by the customer to the Company, including name (including furigana), gender, date of birth, e-mail address, company/organization name, department name, work address, and other information related to contact and delivery addresses.

Information acquired in connection with the use of services

• Information related to transaction history linked to information that can identify the customer when the customer makes a reservation or purchase of publications provided by the Company or applies for other transactions.
• Information such as bank account numbers, credit card numbers, account information for electronic payments, etc., driver's license numbers, etc., entered by the customer for the purpose of payment of fees, etc., for this service and for identity verification
• Information related to subscriptions to e-mail newsletters, etc. from the Company
• Information regarding statements or descriptions in e-mails or other means of communication
• Information obtained mechanically when you access our website
• Browsing history of our website
• IP address used when the customer's computer connects to the Internet, and information related to the identification of the mobile terminal
• Information acquired when you access our website, such as the type and version of your browser, operating system, platform, etc., the pages (URL) you visit, the date and time of your visit, and the products you view or search for.
• In addition to the above, access information obtained through the use of cookies and web beacon technology.

2. Purpose of Use

• 2-1.
  User information will be used to provide the Service as specified in 2-2, and may also be used for other purposes as specified in 2-3.
• 2-2.
  The specific purposes of use of user information related to the provision of the Service are as follows.

  1. To accept registrations for the Service, to verify the identity of users, to provide the Service including the calculation of usage fees, to bill and pay for the Service, to maintain, protect, and improve the Service
  2. To provide information on the Service and to respond to inquiries, etc.
  3. To respond to any violations of the Company's terms, policies, etc. (hereinafter referred to as "Terms and Conditions, etc.") regarding the Service. To respond to violations of the Company's terms, policies, etc. (hereinafter referred to as the "Terms, etc.") regarding the Service
  4. To notify you of changes to the Terms of Service, etc.
  5. For purposes incidental to the above purposes of use.
• 2-3.
  Purposes of use other than 2-2 above are as follows

  1. To compile statistical data in relation to our services
  2. To distribute or display advertisements of the Company or third parties
  3. To respond to inquiries regarding our services, collect customer requests and opinions, send various materials, and conduct other marketing analysis
  4. To provide information regarding new products, events, and campaigns related to our business activities
  5. To send notices of billing for our services
  6. To provide information to third parties
  7. To provide the data of responses to our surveys to third parties. Members who wish to cooperate with our surveys are required to register as members in advance. The only way to do so is to register with the consent of the subject of the information (the person in question) in accordance with our Privacy Policy, which clearly states the purpose of use.

3. Method of Notification, Publication or Obtaining Consent, and Method of Requesting Cessation of Use

A member may request the discontinuation of use of all or part of the user information by making the prescribed settings for the Service, in which case the Company will promptly discontinue its use in accordance with the Company's stipulations. In addition, since the collection or use of certain items of user information is a prerequisite for the Service, the Company will stop collecting such information only when the member withdraws from the Service in accordance with the Company's prescribed method.

4. Management of User Information

The Company will keep user information accurate and up-to-date to the extent necessary to achieve the purpose of use, and will promptly dispose of or delete any personal information that is no longer necessary to be retained in light of the purpose of use.

5. Security Control Measures

The Company shall take the following safety control measures, including information security measures, to prevent unauthorized access to user information or the loss, destruction, alteration, or leakage of personal information, and to ensure the accuracy and safety of user information.
When improvements are required as a result of internal audits, security incidents, customer or internal requests, etc., we will promptly correct the situation.

1. We will establish the necessary security system to prevent unauthorized access to our computer system from outside.
2. User information shall not be removed from the designated office, storage location, etc., and unnecessary duplication, copying, etc., of user information is prohibited.
3. We may ask for your cooperation in ensuring that user information is accurate and up-to-date.
4. For security purposes, the Company uses SSL (Secure Sockets Layer) technology when entering user information to prevent such information from being intercepted, interfered with, or altered.

6. Supervision of Employees, etc.

When having employees handle user information, the Personal Information Handling Administrator shall exercise necessary and appropriate supervision over such employees to ensure the safe management of said user information, such as by making them aware of internal regulations, providing them with education and training, and conducting periodic audits.

7. Outsourcing of User Information Handling

We may outsource all or part of the handling of user information to a contractor or other party. In such cases, the Company shall exercise necessary and appropriate supervision over the contractor to ensure the safe management of the relevant user information.

8. Response to Accidents

In the event that we become aware of the occurrence of an accident such as the leakage of user information, we will immediately take the necessary and appropriate measures.

9. Provision to a Third Party

• 9-1.
  We will provide personal information among user information to third parties without obtaining the prior consent of the user, when disclosure is permitted under the Personal Information Protection Law and other laws and regulations, and in the following cases.

  1. When we outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use
  2. When personal information is provided as a result of the succession of business due to a merger or other reasons
  3. When personal information is provided to information collection module providers
  4. When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the user's consent is likely to impede the execution of such affairs.
  5. Other cases permitted by the Personal Information Protection Law and other laws and regulations.
• 9-2.
  Except for cases in which the provision of personal information is suspended at the request of the user (the method of suspension shall be by written notification to the contact point described in 13 below), the Company shall not provide personal information to the user, including name (including furigana), gender, date of birth, e-mail address, company/organization name, department name, location of workplace, browsing history on the Company's website, e-mail or other means, or any other personal information that the user has provided to the Company. Personal information, such as name (including furigana), gender, date of birth, e-mail address, company name, organization, department name, work address, browsing history of the Company's website, information on statements made or contents of communications by e-mail or other means, will be used to respond to inquiries about the services provided, to collect customer requests and opinions, to send various materials, for other marketing analysis, and to provide information on new products, events, and campaigns related to our business activities. For the purpose of providing data to content providers for marketing analysis and surveys, and for other separately specified purposes, personal information may be provided to third parties by way of electronic or paper data transmission. However, this does not apply to personal information requiring special consideration.
• 9-3.
  In the case of 9-2 above, a request for cessation of provision to a third party shall be made in writing to the contact point specified in 13 below.

10. Joint Use

We will jointly use users' personal information as follows.

1. Items of personal information to be jointly used:
   Those stipulated in Article 1.
2. Scope of joint use:
   TCROSS Co., Ltd.
3. Purpose of use by persons with whom we jointly use the information:
   Those stipulated in Article 2
4. Name or title of the person responsible for the management of user information:
   NEOX Shinjuku Building 7F, 1-9-1 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan
   Contact for Personal Information Inquiries, TCROSS Co., Ltd.

1. Items of personal information to be shared:
   Items stipulated in Article 1
2. Scope of joint use:
   TCROSS Co., Ltd.
3. Purpose of use by persons with whom personal information is shared:
   Those stipulated in Article 2
4. Name or title of the person responsible for the management of user information:
   NEOX Shinjuku Building 7F, 1-9-1 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan
   Contact for Personal Information Inquiries, TCROSS Co., Ltd.

11. Disclosure of Personal Information

When a user requests disclosure of personal information in accordance with the provisions of the Personal Information Protection Law, we will disclose the information without delay after confirming that the request is made by the user himself/herself (if the relevant personal information does not exist, we will notify the user to that effect). (If such personal information does not exist, the Company will notify the user of such fact. However, this does not apply to cases in which we are not obligated to disclose the information under the Personal Information Protection Law or other laws and regulations. Please note that a separate fee will be charged for the disclosure of personal information.

12. Correction and Suspension of Use of Personal Information

• 12-1.
  If a user requests correction of personal information in accordance with the provisions of the Personal Information Protection Law because (1) the personal information is untrue, or (2) the personal information was collected for reasons beyond the scope of the purpose of use publicly announced in advance or by deception or other wrongful means, the Company shall correct the personal information in accordance with the provisions of the Personal Information Protection Law and suspend its use. If a user requests that the use of his/her personal information be discontinued in accordance with the provisions of the Personal Information Protection Law because (1) the information is used for purposes other than those previously disclosed, or (2) the information was collected through deception or other wrongful means, we will conduct the necessary investigation without delay after confirming that the request was made by the user himself/herself, and based on the results, we will correct or discontinue the use of the information and notify the user to that effect. If the Company decides not to correct or suspend the use of personal information based on reasonable grounds, the Company will notify the User to that effect.
• 12-2.
  If a user requests deletion of the user's personal information, and we deem it necessary to comply with the request, we will delete the personal information after confirming that the request is made by the user himself/herself, and notify the user to that effect.
• 12-3.
  The provisions of the preceding two paragraphs shall not apply in cases where the Company is not obligated to correct, etc. or suspend the use of personal information under the Personal Information Protection Law or other laws and regulations.

13. Contact for Inquiries

Please direct any comments, questions, complaints, or other inquiries regarding the handling of user information to the following contact point.

Name or title of the person responsible for the management of user information:
NEOX Shinjuku Building 7F, 1-9-1 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan
Contact for Personal Information Inquiries, TCROSS Co., Ltd.

14. Procedures for Changing the Privacy Policy

TCROSS will review the status of operation regarding the handling of user information from time to time and strive for continuous improvement, and may change this policy as necessary. In the event of any changes, we will notify users by posting the changes on our website or by other means. However, in the case of changes that require the consent of the user under laws and regulations, the Company shall obtain the consent of the user in a manner prescribed by the Company.