Privacy Policy

This English translation is provided for reference purposes only. In the event of any discrepancy, the Japanese version shall prevail.

Notice

We are pleased to announce a partial revision to our Privacy Policy, effective April 1, 2022.
This revision reflects our response to the amended Act on the Protection of Personal Information, which takes effect on April 1, and also restates our policy on the handling of personal information in a way that is easier for our customers to understand.
Customers who have already registered personal information with us or with our services are not required to take any new action as a result of this revision.
The main points of the revision and additions are as follows.

Definitions
We have removed definitions that were previously based on the wording of the pre-amendment provisions, in order to make clear that this policy sets out our approach to the handling of personal information as required by law.

Regarding Acquisition
We have clarified that personal information is acquired "within the scope necessary to achieve the purpose of use."

Cookies and IP Addresses
In addition to cookies and IP addresses, we have newly added advertising identifiers (such as IDFA) as personally referable information.

Other minor changes to wording and formatting.

SIROK Inc. (hereinafter, "SIROK") complies with the Act on the Protection of Personal Information and related cabinet orders, ministerial ordinances, guidelines, and other rules (hereinafter, the "Laws and Regulations"), and appropriately manages and uses personal information as set out below.
This Privacy Policy applies cumulatively together with the privacy policies, terms of use, guidelines, and other rules of each individual service (hereinafter, the "Service Rules"). In the event of any conflict between the content of this Privacy Policy and the Service Rules, the Service Rules shall take precedence.

1. Acquisition of Personal Information

SIROK acquires personal information, by proper and lawful means, within the scope necessary to achieve the purpose of use notified or announced in advance.

2. Cookies, Advertising Identifiers, and IP Address Information

Cookies, advertising identifiers (including but not limited to the Identifier for Advertisers (IDFA) and the Google Advertising Identifier (AAID)), and IP address information (hereinafter collectively, "Cookies, etc.") cannot, by themselves, identify a specific individual; however, where such information is used together with personal information, SIROK treats it as personal information as well. On the media operated by SIROK, even where a specific individual cannot be identified, SIROK will disclose the purpose and method whenever Cookies, etc. are used. In addition, cookies and advertising identifiers can be disabled through browser or device (OS) settings. Where such settings prevent use of SIROK's services, SIROK will also announce that fact.

The privacy policies and opt-out pages of the cookie and advertising delivery companies are as follows.

[Privacy Policies of Advertising Delivery Companies]

・Yahoo Japan Corporation
・Google G.K.
・LINE Corporation
・Facebook, Inc.
・Google Analytics
・Dynalyst (CyberAgent, Inc.)

[Opting Out of Targeted Advertising Delivery]

・Yahoo Japan Corporation
・Google G.K.
・LINE Corporation
・Facebook, Inc.
・Dynalyst (CyberAgent, Inc.)

3. Specification of the Purpose of Use of Personal Information

In handling personal information, SIROK specifies the purpose of use to the greatest extent possible, and gives clear and specific notice to the individual concerned (hereinafter, the "Data Subject"), or makes a public announcement thereof.

4. Restrictions on the Use of Personal Information

SIROK will not handle personal information beyond the scope necessary to achieve the purpose of use without first obtaining the Data Subject's consent. Even where SIROK acquires personal information as a result of a merger or other reason, SIROK will not handle such information beyond the scope of the purpose of use that applied prior to the succession, without first obtaining the Data Subject's consent. However, this shall not apply in the following cases:

(1) Where required by law
(2) Where necessary to protect the life, body, or property of a person, and it is difficult to obtain the consent of the Data Subject
(3) Where particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the Data Subject
(4) Where it is necessary to cooperate with a national or local government body, or a party entrusted by such body, in carrying out affairs prescribed by law, and obtaining the consent of the Data Subject would impede the execution of such affairs

5. Proper Acquisition of Personal Information

SIROK properly acquires personal information and will not acquire it by deception or other wrongful means. SIROK also takes care not to indiscriminately collect information about individuals from children under the age of 15 without the consent of a legal representative (such as a person with parental authority).

6. Notification of the Purpose of Use upon Acquisition of Personal Information

When acquiring personal information, SIROK announces its purpose of use in advance. However, this shall not apply in the following cases:

(1) Where notifying the Data Subject of, or publicly announcing, the purpose of use would harm the life, body, property, or other rights or interests of the Data Subject or a third party
(2) Where notifying the Data Subject of, or publicly announcing, the purpose of use would harm SIROK's rights or legitimate interests
(3) Where it is necessary to cooperate with a national or local government body in carrying out affairs prescribed by law, and notifying the Data Subject of, or publicly announcing, the purpose of use would impede the execution of such affairs
(4) Where the purpose of use is clear from the circumstances of acquisition

7. Change of the Purpose of Use of Personal Information

When changing the purpose of use of personal information, SIROK will not do so beyond a scope reasonably considered to be relevant to the purpose of use prior to the change, and will notify the Data Subject of, or publicly announce, the changed purpose of use.

8. Security Control of Personal Information and Supervision of Employees

SIROK establishes personal information protection regulations and provides necessary and appropriate supervision of its employees, so as to ensure the security control of personal information, including the prevention of leakage, loss, or damage.

9. Supervision of Contractors

Where SIROK entrusts all or part of the handling of personal information to a third party, SIROK enters into a contract with the contractor that includes confidentiality obligations, or requires the contractor's agreement to terms prescribed by SIROK, and provides necessary and appropriate supervision to ensure that the contractor maintains the security control of personal information.

10. Restrictions on Provision to Third Parties

SIROK will not provide personal information to third parties without first obtaining the consent of the Data Subject, except in the following cases:

(1) Where required by law
(2) Where necessary to protect the life, body, or property of a person, and it is difficult to obtain the consent of the Data Subject
(3) Where particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the Data Subject
(4) Where it is necessary to cooperate with a national or local government body, or a party entrusted by such body, in carrying out affairs prescribed by law, and obtaining the consent of the Data Subject would impede the execution of such affairs

11. Disclosure of Personal Information

Where the Data Subject requests disclosure of personal information, SIROK will disclose it to the Data Subject without delay. However, SIROK may decline to disclose all or part of the information where disclosure would fall under any of the following, and where SIROK decides not to disclose the information, it will notify the Data Subject of that fact without delay.

(1) Where disclosure would harm the life, body, property, or other rights or interests of the Data Subject or a third party
(2) Where disclosure would significantly impede the proper conduct of SIROK's business
(3) Where disclosure would violate other laws and regulations. In principle, information other than personal information, such as access logs, will not be disclosed.

12. Correction, etc. of Personal Information

Where the Data Subject requests correction, addition, or deletion (hereinafter, "Correction, etc.") of personal information on the grounds that it is not accurate, SIROK will, except where a special procedure is prescribed under other laws and regulations, conduct the necessary investigation without delay within the scope necessary to achieve the purpose of use, and, based on the results, make the Correction, etc. to the content of the personal information and notify the Data Subject accordingly.

13. Suspension of Use, etc. of Personal Information

Where the Data Subject requests the suspension of use or deletion (hereinafter, "Suspension of Use, etc.") of the Data Subject's personal information on the grounds that it has been handled beyond the scope of the publicly announced purpose of use, or that it was acquired through deception or other wrongful means, SIROK will conduct the necessary investigation without delay and, based on the results, carry out the Suspension of Use, etc. of the personal information and notify the Data Subject accordingly. However, where the Suspension of Use, etc. would require substantial expense or is otherwise difficult to carry out, and alternative measures can be taken in its place to protect the rights and interests of the Data Subject, SIROK will take such alternative measures.

14. Explanation of Reasons

Notwithstanding a request from the Data Subject, where SIROK decides:

(1) Not to notify the purpose of use
(2) Not to disclose all or part of the personal information
(3) Not to carry out the Suspension of Use, etc. of personal information
(4) Not to stop providing personal information to third parties

SIROK will endeavor to explain the reasons when notifying the Data Subject of any such decision.

15. Contact Information

For inquiries regarding SIROK's Privacy Policy, please contact us at the following.

150-0042
Abema Towers, 40-1 Udagawa-cho, Shibuya-ku, Tokyo, Japan

SIROK Inc.
Privacy Policy Administration Officer
Personal Information Protection Management Officer: Naoyuki Kataoka

Contact for Inquiries Regarding the Privacy Policy
inquiry@sirok.co.jp

Revised April 1, 2022