Naia Inc. (hereinafter referred to as the “Company”) sets forth this Privacy Policy (hereinafter referred to as this “Policy”) with regard to the acquisition and use of personal information in the course of the services and applications which are provided by the Company (hereinafter referred to as the “Services”) and complies with Act on the Protection of Personal Information, guidelines of ministries and agencies and other relevant laws and regulations to realize protection of User Information.

Article 1 (Definition of the User Information)

User Information in this Policy means personal information (which means “Personal Information defined in Article 2, Paragraph 1 of Act on the Protection of Personal Information, the same applies to follows), history of actions in communication service and other information which is created or accumulated in devices of the Users and information collected by companies which affiliate with the Company (hereinafter referred to as “Business Partners”) through the provision of Cooperative Services concerning Users which are collected by the Company pursuant to this Policy.

Article 2 (User Information to be collected in the Services)

The Company collects information regarding access circumstances and way of use of the Services of Users in the course of the Services. The Information includes as follows:

1. Basic Information
   The Company may be provided name of User, date of birth, address, telephone number, e-mail address and other information regarding profile and contact by Users for provision of the Services and response to inquiries from Users;
2. Payment Information
   The Company may be provided credit card information, bank account information, e-money information and other information regarding payment method by Users for provision of charged service and its settlement;
3. Device Information
   The Company may collect device unique information (device unique ID and other individual identification information etc.) for maintenance and improvement of the Service or preventing illicit actions;
4. Logs and History of Actions Information
   The Company may collect IP address, time of request by Users, history of operation in the Services which are created and saved automatically through the use of the Services for maintenance and improvement of the Services or prevention of illicit actions;
5. Location Information
   The Company may collect location information which is transmitted from smartphone, tablet and other information devices for provision of service which uses information such as Users’ present point to the extent necessary therefore. Also, transmission of location information may be suspended by changing setting of information devices, but a part of the Services may become unable to use by such setting; and
6. Cookie
   The Services may use technology called “Cookie” and other similar technology. Cookie is the industry standard technology which the web server identifies User’s device (including but not limited to desktop PC, Laptop PC, smartphone and other hardware that Users use for using the Services, the same applies as follows.). Cookie can identify User’s computer but cannot identify each individual User. Also, the function of Cookie may be disabled by changing setting of information devices, but all or a part of the Services may become unable to use by such setting.

Article 3 (Purpose of Use)

• The Company may not use User Information which is collected through the use of the Services beyond the scope of the purpose of use without consent of the User. User Information which is collected by the Company shall be treated properly within the scope of purpose of use as follows:

Purpose of Use	Details of Purpose of Use	Information to be used
Operation, provision, Maintenance, and Improvement of the Services	・Provision of the Services; ・Provision of charged service and its settlement in the Services; and ・Identity verification and prevention of illicit actions in the Services	・Device Information; ・Logs and History of Actions Information; ・Location Information; ・Basic Information; and ・Payment Information
Notice and Response to Users	・Guidance and response to inquiries relating to the Services; ・Notice and Provision of new service relating to the Services; and ・Notice of such as amendment of Terms of Use of the Services or this Policy or suspension, discontinuation, cancellation and other important information relating to the Services	・Basic Information; and ・Device Information
Provision to Third Parties	Third parties which are provided information listed in the right-side column use such information for the purpose as follows: ・Provision of Cooperative Services; ・Expression of advertisement information which is suitable for needs and interest of Users; ・Analysis of effect of advertisement; and ・Marketing and analysis of a market	・Device Information; ・Logs and History of Actions Information; and ・Cookie
Creation and Provision to Third Parties of Statistical Data	The Company may use information listed in the right-side column for the purpose as follows: ・Creation of Statistical Data which is processed as unable to identify individual through analysis of information listed in the right-side column Third parties which are provided Statistical Data relating to information listed in the right-side column may use such information for the purpose as follows: ・Expression of advertisement information which is suitable for needs and interest of Users; ・Analysis of effect of advertisement; and ・Marketing and analysis of a market	・Device Information; ・Logs and History of Actions Information; ・Location Information; and ・Cookie

• The Company may, obtaining prior consent of Users, provide Business Partners and other third party with User Information including Personal Information each other to the extent necessary for the achievement of the purpose sets forth in the preceding paragraph.

Article 4 (Change of the Purpose of Use)

The Company may change the purpose of use sets forth in the preceding Article to the extent that the purpose of use after the change is deemed to be reasonably relevant to the purpose of use before the change and in the case the Company changes the purpose of use, the Company shall notify Users of or publish such change pursuant to the procedure as separately designated by the Company.

Article 5 (Collection of User Information)

• The Company shall collect User Information properly without collecting in a fraudulent or otherwise illicit manner.
• If the Company collect User Information by a method other than collection through the use of the Services by Users, the Company shall notify Users of or publish such method in advance.

Article 6 (Security Control)

• The Company shall take measures that are necessary and proper for prevention of divulgence, lose or damage of User Information and other security control of User Information.
• If the Company authorizes third party to handle User Information, the Company shall conclude a non-disclosure agreement which content is equivalent hereto with such third party and supervise necessarily and properly to achieve security control of User Information at such third party.

Article 7 (Joint Use)

The Company may jointly use Personal Information of Users with Business Partners to the extent necessary for the provision of Cooperative Services. In such case, the Company shall publish name of Business Partner, purpose of joint use and items of information used jointly in advance.

Article 8 (Information Collection Modules)

Information collection modules are incorporated into the Services for analysis of User Information. Thus, the Company provide User Information for the providers of such information collection modules. These information collection modules collect User Information without including individual specification information using Cookie etc. and collected information shall be managed pursuant to the provision of the privacy policy etc. of the providers of such information collection modules (for more information, please refer to the privacy policy etc. of each provider of such information collection module).

Article 9 (Outside Services and Link)

The Company may provide services by associating with Facebook, Twitter and other outside services (hereinafter referred to as “Outside Services”). If a user uses the Services which is associated with Outside Services at user’s request, the Company may provide User Information for the provider of such Outside Services.

Article 10 (Disclosure and Share of User Information)

Except when the Company is entitled to disclose Personal information contained in User Information pursuant to Act on the Protection of Personal Information and other laws and regulations, the Company shall not disclose or share such information any third party without prior consent of Users; provided, however, that this shall not apply to the following cases:

1. The Company authorizes third party to handle Personal Information in whole or in part to the extent necessary to accomplish the purpose of the use;
2. The Company deposit Personal Information of Users to settlement system companies, credit card companies or banks for claiming payment of the fees of the Services;
3. Personal Information is provided to the provider of an information collection module or the provider of Outside Services pursuant to the preceding two Articles;
4. The Company take necessary measures when Users conduct or try to conduct that cause damage to others or public order and good morals;
5. In case of emergency that there is an imminent danger to human lives and property etc.;
6. Personal Information is provided through a business transfer by way of merger or other similar transactions;
7. The Company is requested by Court, Police and other public organization to disclose Personal Information pursuant to the laws and regulations.

Article 11 (Targeting Advertisement)

• The Company may collect, accumulate or use following information at provision of the Services or Cooperative Services through information collection modules for implement of targeting advertisement (which means advertising method that distribute advertisement suitable for needs and interest of Users) by the Company, Advertisement Distributer or other third party.
  1. History of Actions Information (Information that is permissible for analysis of needs and interest of Users through accumulating of it and that is not resulting in identification of individual such as history of use of the Services); and
  2. Device Information.
• The Company may provide business operators who distribute action targeting advertisement (hereinafter referred to as “Advertisement Distributer”) with collected information pursuant to the preceding paragraph for delivery of beneficial information to Users through distribution of the customized and optimal advertisement suitable for needs and interest of Users.
• The Company shall preserve History of Actions Information etc. collected from Users within the period necessary for legally and justly in the course of business.
• If the Company provide Advertisement Distributer with History of Actions Information etc., the Company shall endeavor to take following measures for prevention of divulgence, lose or damage of User Information and other security control of User Information:
  1. Not publishing system such as algorism for encrypting History of Actions Information etc.;
  2. Providing Advertisement Distributor with History of Actions Information etc. under condition of that Advertisement Distributer shall use History of Actions Information etc. within the scope of purpose of use set forth in the paragraph 2; and
  3. If Advertisement Distributer provide other third party with History of Actions Information etc., the Company shall impose on Advertisement Distributor that Advertisement Distributor shall attach the equivalent condition set forth in the preceding item to provision for such other third party
• If you do not wish delivery etc. of action targeting advertisement through data of the Services, please take following opt-out procedures according to OS of using smartphone:
  1. for iOS applications
  2. for Android applications

Article 12 (Disclosure or Correction etc. of User Information)

• If Users request, in writing, disclosure, correction, addition or delete of Personal Information provided by Users, please request by submitting an application by post enclosing identity confirmation documents (in case of an application by an agent, document necessary for confirmation of properness of the agent). In case of disclosure request or notification request of purpose of use in writing, please note that you shall pay 500 JPY (tax included. Actual cost of answering by simple registered mail) per application.
• In case of there is application pursuant to the preceding paragraph and User is identified, the Company shall disclosure etc. to the reasonable extent; provided, however, that this does not apply if the Company does not have the duty to disclose etc. pursuant to Act on the Protection of Personal Information and other laws and regulations.

Article 13 (Inquiries)

Any suggestions, questions, complaints, or other matters on the handling of the User Information must be submitted to follows: Naia, Inc. E-mail：info@naia.co.jp

Article 14 (Organization and System)

The Company designates Takuto Nishioka as the manager and manage properly of User Information and improve continuously.

Article 15 (Indemnification)

The Company shall not be liable for the case that:

1. User disclose User Information to a third party through the function of the Services or other method him/herself; or
2. User is able to be identified by information which is entered into the Services by him/herself.

Article 16 (Amendment of this Policy)

The Company shall review operating circumstances of the handling of User Information appropriately and take endeavor to improve continuously and may amend this Policy as necessary without prior consent of Users. Unless otherwise provided by the Company, this Policy after the amendment become effective immediately after posting on Website; provided, however, that the Company shall obtain User’s consent in a manner specified by the Company for the amendment that requires such consent under the laws and regulations.

Article 17 (Other Precautions)

The Services provided by the Company may include a link to services otherwise the Company manages, the Company shall not be liable for the content of and the protection of User Information at such Outside Services.