The Company is subject to the Act on the Protection of Personal Data (Act No. 57 of 2003. Hereinafter referred to as the ‘Personal Data Protection Act’). This Privacy Policy has been established to ensure the proper handling of personal data as an organization in accordance with the Act on the Protection of Personal Data (Act No. 57 of 2003).

１　Name, address and name of representative of the company

Vicc Ltd.
Fuji-Chuo building. 4F, 2-2-11 Shintomi, Chuo-ku, Tokyo, Japan 104-0041
Representative Director, Kenji Watanabe

２　Compliance with relevant laws, regulations and guidelines

The Company shall comply with the Personal Data Protection Act and other laws and regulations, as well as the guidelines of the Personal Data Protection Commission and other guidelines, and shall handle personal data (as defined in Article 16(3) of the Personal Data Protection Act) properly. The same applies hereinafter) will be handled properly.

３　Acquisition and use of personal information

When acquiring personal information, the Company shall publicly announce or notify the purpose of use (including public announcement through this Privacy Policy). In addition, when acquiring personal information directly from the person concerned in a contract or other document (including electromagnetic records), the purpose of use shall be clearly stated in advance and the information shall be acquired by lawful and fair means.
The Company will use personal information appropriately within the scope necessary to achieve the purpose of use.

４　Purpose of use of personal data

The Company uses personal data for the following purposes

（１）Personal data relating to the customer

【Purpose of use】

• Sending goods, invoices and prizes to winners for promotions in which the customer has participated.
• Response, confirmation and recording of customer enquiries, consultations, complaints, repairs and support.
• To improve and enhance our product development and other services.
• To improve and enhance the customer experience of digital services (websites, mobile apps, etc.) provided by the Company.
• To advertise and provide information on products, services, campaigns, etc. via letters, emails, etc. (*1 and *2)
• Distribution of behaviourally targeted advertising using ad-serving companies such as Google and Yahoo!
• Analysis of attribute information, behavioural history, etc. obtained by the Company in order to understand the interests and preferences of customers (*2)
• To provide customers with our products and services in a safe manner.
• To detect and notify users who are in breach of the Terms of Use and to investigate, detect and prevent fraudulent activities such as fraud and unauthorised access by abusing the services, etc., and to respond to such activities.

（※１）　Information such as website browsing history and purchase history obtained from customers is analysed to provide services and distribute advertisements.
（※２）　Information such as customer preferences and browsing history obtained from third parties other than the Company may be used in conjunction with customer personal data already held by the Company. In such cases, we will obtain prior consent from the customer and use the information within the scope of the purposes of use listed above.
The technology that records and manages the information of customers using the Company’s website on their computer or application software is called “cookies”. Our website uses cookies to make your use of our website more convenient.
Our website uses Google Analytics, a service provided by Google, to monitor your visits to our website. When you use Google Analytics on our website, Google collects, records and analyses your visits to our website based on the cookies we issue. The information collected, recorded and analysed by Google Analytics does not contain any personally identifiable information. Such information will be managed by Google in accordance with its privacy policy. You can also opt out of our use of Google Analytics to collect information about you by disabling Google Analytics in your browser’s add-on settings. You can disable Google Analytics by downloading and installing the Google Analytics Opt-out Add-on from Google’s opt-out add-on download page and changing your browser add-on settings. If you disable Google Analytics, Google Analytics will also be disabled on the other websites you visit, but you can re-enable Google Analytics by reconfiguring the add-on in your browser. For an explanation of the Google Analytics Terms of Use, please visit the Google Analytics website and for an explanation of Google’s privacy policy, please visit their website.
＜Google Analytics Terms of Use＞
http://www.google.com/analytics/terms/jp.html
＜Google’s privacy policy＞
http://www.google.com/intl/ja/policies/privacy/
＜Google Analytics opt-out add-on＞
https://tools.google.com/dlpage/gaoptout?hl=ja

（２）Personal information relating to business partners (or their officers and employees in the case of corporate customers)

【Purpose of use】

• Personal data relating to business partners (or their officers and employees in the case of corporations)
• For confirming and recording interests, enquiries, consultations, requests, etc.
• To contact, fulfill contracts and conduct business negotiations as necessary in the course of business.
• For the management of business partner information.
• For seasonal greetings, service information and other notices.

（３）Personal information relating to applicants for recruitment/recruitment activities

【Purpose of use】

• Contact and provision of information to applicants for recruitment and recruitment activities, and other uses necessary for recruitment and recruitment activities.

（４）Personal data relating to employees

【Purpose of use】

• Contact with employees./li>
• Payment of remuneration (wages, bonuses, benefits, etc.) to employees, performance of personnel and labor management and provision of welfare benefits./li>
• Health management of employees

５　Joint use of personal data

The Company will share the personal data it has obtained as follows

（１）Personal data items

Address, name, postcode, telephone number, fax number, email address, etc. of the individual acquired.

（２）Scope of co-users

Syntegrate Japan G.K. Business partner company

（３）Purpose of use

The information will be used jointly within the scope of the purposes of use of the “personal information obtained in 4 above”.

（４）Name, address and representative of the organization responsible for the management of personal data

The Company is responsible for the management of the shared personal data.
Contact for enquiries about sharing use.

【Contacts】
Syntegrate Japan G.K. General Affairs Department,
Fuji Chuo Building 9F, 2-1-7 Shintomi, Chuo-ku, Tokyo 104-0041
Tel : 050-5469-1534
Opening hours : Monday to Friday (except national holidays and year-end and New Year holidays)
10am-12pm and 1pm-5pm

６　Provision of personal data to third parties

The Company will not provide personal data to third parties except in any of the following cases

• When we have obtained the prior consent of the individual from whom the data was obtained.
• When the data is outsourced to the extent necessary to achieve the purpose of use.
• When the provision of personal data is required by law.
• When it is necessary for the protection of the life, body or property of a person and it is difficult to obtain the consent of the individual from whom the information was obtained.
• When it is particularly necessary for improving public health or promoting the sound development of children, it is difficult to obtain the consent of the individual who has provided the information.
• When it is necessary to cooperate with national or local authorities in the execution of their legally prescribed duties, obtaining the consent of the individual from whom the personal data was obtained is likely to impede the execution of those duties.
• When the information is provided to those listed in the scope of co-users in 5 above.

７　Matters relating to security control measures

The Company takes necessary and appropriate security control measures for the management of personal data, including the prevention of leakage, loss or damage. In addition, the Company shall exercise necessary and appropriate supervision over employees and contractors (including sub-contractors, etc.) who handle personal data. The Company will also provide necessary and appropriate supervision of employees and contractors (including sub-contractors, etc.) handling personal data. For more information on security control measures for personal data, please contact 9.

８　Requests for disclosure of retained personal data

The Company shall, upon receiving a request for disclosure, correction, addition, deletion, suspension of use, erasure, suspension of provision to a third party of retained personal data (as defined in Article 16.4 of the Personal Data Protection Act) If you have any questions or wish to exercise your rights in relation to this Privacy Policy, please contact us at 9. contact for enquiries in the following section.

９　Contact for enquiries

For inquiry about the handling of personal data, please contact below.

VICC Ltd. General Affairs Department
Address : Fuji Chuo Building Annex 4F, 2-2-11 Shintomi, Chuo-ku, Tokyo 104-0041
Tel : 050-5469-1534
Opening hours : Monday to Friday (except national holidays and year-end and New Year holidays)
10am-12pm and 1pm-5pm