DELiGHTWORKS

1. Compliance with laws and ordinances

The Company recognizes the importance of personal information, and in order to thoroughly protect personal information, the Company complies with the Act on the Protection of Personal Information (the “Personal Information Protection Act”), cabinet orders and rules based on the same law, and related guidelines in relation to the collection, use, and other handling of personal information, in addition to reviewing the contents of personal information from time to time and striving to continually improve its handling of personal information.

2. Purposes of use

The Company uses personal information it collects for the purposes set out below.

• (1) Personal information of DELiGHTWORKS STORE users and users of other products or services of the Company

  (i)

  Identity verification for use of services and provision of other services

  (ii)

  Shipment, return or exchange, and payment or settlement of the cost of purchased products

  (iii)

  Communication, support, and distribution of notifications regarding the use of products or services

  (iv)

  Communication regarding and sending of surveys and the like to customers, collection of survey responses from customers who separately consent to that collection, and implementation of other survey-related operations

  (v)

  Communication regarding and implementation of campaigns, prize programs, and the like

  (vi)

  Distribution of email newsletters and other information

  (vii)

  Promotion and advertising of products and services

  (viii)

  Responding to opinions and inquiries regarding products and services

  (ix)

  Marketing data research, statistical compilation, and analysis

  (x)

  Any use incidental to any of the preceding items

• (2) Personal information collectd when inquiries are made to the Company

  (i)

  Responding to inquiries

  (ii)

  Distribution of email newsletters and other information

  (iii)

  Promotion and advertising of products and services

  (iv)

  Quality enhancement and improvement of products, services, handling of phone-based inquiries, and the like

  (v)

  Development of new products and services

• (3) Personal information of trading partners

  (i)

  Trading partner selection, business activities, contractual procedures, and performance and administration of transactions

  (ii)

  Provision of support and after-sale services

  (iii)

  Distribution of email newsletters and other information

  (iv)

  Promotion and advertising of products and services

  (v)

  Making or responding to inquiries

  (vi)

  Any operations incidental to any of the preceding items

• (4) Personal information of employees (including retired employees), officers (including retired officers), job applicants, and the like

  (i)

  Procedures related to the employment and resignation of employees and job applicants

  (ii)

  Procedures related to appointment and retirement of officers

  (iii)

  Administrative affairs regarding wages, bonuses, compensation, retirement allowances, corporate pensions, and the like

  (iv)

  Administrative affairs regarding safety, hygiene, and health management

  (v)

  Administrative affairs regarding social insurance, employment insurance, and the like

  (vi)

  Staff announcements and administrative communication

  (vii)

  Responding to inquiries

  (viii)

  Management of other personnel and labor matters

• (5) Personal information of shareholders

  (i)

  Shareholder management provided for under the Companies Act and other laws and ordinances

  (ii)

  Implementation of policies for shareholders

  (iii)

  Administrative communication with shareholders regarding shareholders meetings and the like

  (iv)

  Responding to inquiries

3. Restriction on use of personal information

The Company handles personal information within the scope necessary to achieve the purposes of use stated in “2.” above. If the Company handles personal information beyond the scope of those purposes of use, the Company will obtain your consent, except in each of the following cases:

• (1) if that handling is pursuant to laws and ordinances;
• (2) if that handling is necessary in order to protect the life, person, or property of an individual and it is difficult to obtain your consent;
• (3) if that handling is particularly necessary in order to improve public health or to promote the sound development of children and it is difficult to obtain your consent; and
• (4) if that handling is necessary to cooperate in the performance of business prescribed in law or ordinance by a national or local government body, or a person engaged by such a body, and obtaining your consent is likely to cause hindrance to the performance of such business.

4. Collection of personal information

The Company collects personal information by lawful and fair means and does not collect personal information by improper means that are contrary to your intentions. Please note that if you do not provide personal information required for use of the Company’s services, the Company might not be able to provide to you some of its services.

5. Notification, etc. of purposes of use

If the Company collects personal information, it will notify or publicly announce the purposes of use of that personal information in advance. If any of those purposes of use are altered, the Company (a) will notify you of or publicly announce the alteration and (b) will also obtain your consent, excluding in cases where the alteration falls within a reasonable scope.

6. Assurance about accuracy of personal data, security control measures, and supervision over employees

• (1) The Company strives to keep the contents of your personal data accurate and up-to-date within the scope necessary to achieve the purposes of use and to delete personal data without delay when use becomes unnecessary.
• (2) The Company takes necessary and appropriate measures to control the security of personal data, including preventing the leakage, loss, or damage of your personal data.
• (3) In having the Company’s employees handle personal data, the Company exercises necessary and appropriate supervision over those employees in order to control the security of personal data.

7. Supervision over entrusted parties

The Company may entrust all or part of the handling of personal data it collects. In this case, the Company will exercise necessary and appropriate supervision over the entrusted parties in order to control the security of the personal data whose handling has been entrusted.

8. Restriction on providing personal information to third parties

• (1) In principle, the Company does not provide any of your personal data to a third party without obtaining your consent. In exceptional cases, the Company will provide your personal data to a third party but only if your consent is obtained. However, that consent is not required in each of the following cases:

  (i)

  if that provision is pursuant to laws and ordinances;

  (ii)

  if that provision is necessary in order to protect the life, person, or property of an individual and it is difficult to obtain your consent;

  (iii)

  if that provision is particularly necessary in order to improve public health or to promote the sound development of children and it is difficult to obtain your consent; and

  (iv)

  if that provision is necessary to cooperate in the performance of business prescribed in law or ordinance by a national or local government body, or a person engaged by such a body, and obtaining your consent is likely to cause hindrance to the performance of such business.

• (2) In each of the following cases, the person to whom the personal data is provided will not constitute “a third party” as prescribed above:

  (i)

  if personal data is provided by the Company as a result of entrustment of all or part of the handling of personal data within the scope necessary to achieve the purposes of use;

  (ii)

  if personal data is provided as a result of the Company’s business being succeeded to by another party due to a merger or other similar event; or

  (iii)

  if personal data is provided to a specified person who jointly utilizes the personal data, and if you have been notified in advance or are in a situation where you are readily able to know of the joint utilization of the personal data, the categories of the personal data subject to joint utilization, the person who jointly uses the personal data, the purposes of joint utilization, and the name or appellation of the person responsible for controlling the personal data.

9. Procedures for requesting disclosure, etc. of retained personal data

If the Company receives a request from you for disclosure of retained personal data, notification of purposes of use of retained personal data, correction, etc. of retained personal data in the case that the contents of the personal information subject to disclosure conflict with fact or the like, or suspension of utilization or provision to any third party of retained personal data (“Disclosure, etc.”), then under the provisions of the Personal Information Protection Act, the Company will comply with the request for Disclosure, etc. to you without delay after confirming that it is you making the request, unless the Company does not bear an obligation of Disclosure, etc. pursuant to the Personal Information Protection Act or any other law or ordinance.
Please contact the Company through the contact form stated in “10.” Below to make requests for Disclosure, etc.
Please note that, in connection with requests for Disclosure, etc., the Company may charge fees within a reasonable extent, taking into consideration actual costs.

10. Inquiries

Please contact the Company through the contact form to make complaints or inquiries regarding personal information and this privacy policy.

11. Use of Cookies, etc.

If you use the Company’s services and enable cookies, etc. (including tracking technologies, such as Flash cookies and web beacons; hereinafter referred to as “Cookies, etc.”), the Company might automatically collect information regarding your PC, mobile phone device, tablet, and other information communication devices you use, and other information from Cookies, etc. When the Company collects such information, it handles the information as personal information.
If you do not wish Cookies, etc. to be used, you can disable them by changing the settings on your web browser. However, if you do so, you might become unable to use some of the features of the Company’s services.

12. Collection, etc. of information through the use of service tools provided by third parties

Google Analytics
For services the Company provides on the website, the Company may use Google Analytics to collect statistical use information for the purpose of researching the status of use by customers and for other purposes.
By using Google Analytics, the Company collects user information that does not include information that identifies individuals through the use of Cookies, etc. Please refer to the following websites for details on the use of collected user information and the like.

Google Analytics Terms of Service:
http://www.google.com/analytics/terms/
Google Privacy Policy:
https://policies.google.com/technologies/partner-sites?hl=en

The Google Analytics advertising function the Company uses is as follows:
- Google Analytics’ Demographics and Interests reports

The Company and third-party vendors, including Google, combine first-party cookies, such as the cookies of Google Analytics (or another first-party ID), with third-party cookies, such as the advertising cookies of Google (or another third-party ID), and use them to analyze customers’ demographics, interests, and concerns.
Please refer to the following webpage for information on how to opt out of Google Analytics’ advertising functions:
https://adssettings.google.com/authenticated

13. Alteration of this privacy policy

The Company may alter the contents of this privacy policy pursuant to any revision to a law, changes in business activities, or requests from customers. In this case, the Company will notify you in advance and alter the contents of this privacy policy after a certain period of time for the introduction of the altered contents.