Personal Information

“Personal Information” shall mean “personal information” as defined in the Act on the Protection of Personal Information, and is information concerning a living individual and means information that can identify a specific individual by the name, address, telephone number, contact information and other descriptions contained in such information, and information that can identify a specific individual from any information by itself such as physical appearance, fingerprints, data regarding voice prints, and an insured’s number on a health insurance card (personal identification information).

Method for Collecting Personal Information

Synspective may ask for Personal Information such as the name, address, telephone number, email address and company name, when the user registers for use of the Services.

Purposes of Collection and Use of Personal Information

Synspective’s purposes of collection and use of the Personal Information are as follows:
(1) To provide and operate the Services;
(2) To respond to inquiries from the user (including to verify the identity of the user);
(3) To send emails regarding new functions, renewal information, campaigns and other information of the Services being used by the user and information regarding the other services provided by Synspective;
(4) To communicate regarding maintenance and important notices, as necessary;
(5) To identify users who have violated any terms of use and users who are trying to use the Services for unlawful or unfair purposes, and to refuse the use thereof; and
(6) Purposes incidental to the above purposes of use.

Amendment to Purpose of Use

1. Synspective shall amend the purposes of use of the Personal Information only if the purposes of use can be reasonably recognized to have relevance to those prior to such amendment.
2. If the purposes of use are amended, the user will be notified regarding the amended purposes by a method designated by Synspective or such amended purposes shall be announced on the Website.

Provision of Personal Information to Third Parties

1. Synspective will not provide the Personal Information to third parties without obtaining the user’s prior consent, except in the below instances; provided, however that this shall not apply to instances permitted under the Act on the Protection of Personal Information and other laws or regulations:
   (1) When there is a need to protect the life, body or property of a person and obtaining the consent of the individual is difficult;
   (2) When there is a particular need to improve public health or promote the healthy development of children and obtaining the consent of the individual is difficult;
   (3) When there is a need to cooperate with the execution of business set forth in the laws or regulations by a national agency or local government entity, or a person entrusted thereby, and there is the likelihood that obtaining the individual’s consent will interfere with such execution of business; and
   (4) When the below matters are notified or announced and Synspective notifies the Personal Information Protection Commission:
   (i) That the purpose of use includes the provision to third parties;
   (ii) The items of the data that are provided to third parties;
   (iii) The means or method of the provision to third parties;
   (iv) To cease the provision of the Personal Information to third parties as requested by the individual; and
   (v) The method to accept the request of the individual.
2. Notwithstanding the preceding clause, the recipient of such information shall not be considered a third party in the below instances:
   (1) If all or a part of the handling of the Personal Information is entrusted to the extent necessary for Synspective to achieve the purposes of use;
   (2) If the Personal Information is provided in relation to the succession of a business due to a merger or other events; or
   (3) If the Personal Information will be used jointly with a specific person, and the effect thereof and the items of the Personal Information that will be jointly used, the scope of the joint users, the purposes of use of the users, and the name or designations of the person responsible for the management of such Personal Information will be notified to the individual in advance or be placed in a condition that can be easily known by the individual.

Disclosure of Personal Information

1. When the disclosure of the Personal Information is requested by the individual, Synspective will disclose such information to the individual without delay; provided, however, that if any of the below applies due to the disclosure, all or a part thereof may not be disclosed, of if a decision is made not to disclose, the effect thereof will be notified without delay. Furthermore, a fee of JPY1,000 per case will be charged upon the disclosure of the Personal Information:
   (1) If there is the likelihood of harming the life, body, property or other rights or interests of the individual or a third party;
   (2) If there is the likelihood of causing significant harm to the proper execution of Synspective’s business; or
   (3) If it will otherwise violate the laws or regulations.
2. Notwithstanding the provisions of the preceding clause, information other than the Personal Information, such as historical information and characteristic information, in principle, will not be disclosed.

Correction and Deletion of Personal Information

1. If the user’s information that is in Synspective’s possession is incorrect information, the user may request Synspective for the correction, addition, or deletion of the Personal Information (the “Corrections”) by the procedures set forth by Synspective.
2. If Synspective receives a request in the preceding clause from the user and determines that there is a need to respond to such request, Synspective shall make the Corrections to such Personal Information without delay.
3. If Synspective makes the Corrections under the provisions of the preceding clause or decides to not make the Corrections, Synspective will notify that effect to the user without delay.

Suspension of Use of Personal Information

1. If Synspective is requested by the individual for the suspension of use or deletion of the Personal Information due to the reason that the Personal Information is being handled in a manner beyond the scope of the purposes of use or due to the reason that the Personal Information was acquired by fraudulent means (the “Suspension of Use”), Synspective will conduct necessary inspections without delay.
2. If Synspective determines that there is a need to respond to such request based on the inspection results of the preceding clause, Synspective will conduct the Suspension of Use of such Personal Information.
3. If Synspective conducts the Suspension of Use under the provisions of the preceding clause or determines not to conduct the Suspension of Use, Synspective will notify the user thereof without delay.
4. Notwithstanding the preceding two clauses, if significant expenses will be incurred for the Suspension of Use or conducting the Suspension of Use is otherwise determined to be difficult, and if a measure that is necessary to protect the rights and interests of the user and can be taken in place of the Suspension of Use, Synspective shall take such alternative measure.

Use of Cookies

1. Technology to identify the customer’s browser called “cookies” may be used on the Site for the purposes set forth below:
   (1) For the user to use the Website more conveniently when the user re-visits the Website; and
   (2) To measure and analyze the usage status of the Website.
2. If the user accesses contents that issue cookies, cookies will be recorded in the user’s computer; however, the recorded information will not contain information that can identify the individual user.
3. The acceptance of cookies can be rejected by the user by changing the settings of the browser; provided, however, that a part of the Website may no longer be used if the acceptance of cookies is rejected.
4. In addition to the above, Synspective analyzes the access by the user by using “Google Analytics,” which is provided by Google Inc., on the Website. Please review Google Inc.’s website with respect to “Google Analytics.”

Amendment to the Privacy Policy

1. Except for matters that are set forth in the laws or regulations or are otherwise set forth in this Policy, the contents of this Policy may be amended without notifying the user.

2. Unless otherwise set forth by Synspective, the amended Privacy Policy shall become effective from when it is published on the Website.

Contact for Inquiries

Please contact the following for inquiries regarding this Policy:
Address: 3-10-3 Miyoshi, Koto-ku, Tokyo
Company Name: Synspective Inc.
Department: PR Team
Email Address: hello@synspective.com