Cosmo Shoji Inc. (hereinafter called the “Company”) herein sets forth a privacy policy (hereinafter called the “Policy”) concerning handling user’s information including personal information.

１． Collection of User’s Information
In the Policy, the “personal information” shall mean the information relating to an individual and containing data such as name, date of birth and other descriptions which makes a certain individual identifiable (the information which can be easily verified with other information and makes a certain individual identifiable).
“User’s information” shall mean the information including personal information related to the identification of a client company and an individual customer (hereinafter collectively called “Customer”), user’s behavioral history on communication service and other data generated or accumulated on user’s devices such as smartphone and personal computer in association with user or user’s device and the user’s information may be collected by the Company under the Policy.
The user’s information collected by the Company to operate the business, is categorized by the collection method and listed as follows:
（１） Information provided by Customers
・ Address
・ Name
・ Telephone Number
・ E-mail Address
・ Date of Birth
・ Credit Card Information
・ Bank Account Information
・ Other information to be provided by Customers in the form indicated by the Company
（２） Information provided by other service providers which a Customer permits the Company to cooperate with when the Customer uses the services provided by the Company.
If a Customer permits the Company to cooperate with external service providers such as social network service when the Customer uses the services provided by the Company, the Company may collect the following information from such external service providers based on what the Customer agreed:

・ ID used by the Customer in such external service
・ Other information which the Customer permitted to disclose in the privacy settings on such external service
（３） Information collected by the Company when Customers use the services provided by the Company
The Company may collect information related to status of access to the services provided by the Company and how to use the service. Such information includes the following items:
・ Device Information
・ Logging Information
・ Cookie and Unidentifiable ID

２．Purpose of Use
２−１
User’s information may be used for the provision of services as specified in 2-2 and for other purposes specified in 2-3.
To prevent user’s information being used beyond the purpose of use, the Company sets forth the internal rules on handling user’s information, familiarize all board members, employees and contract employees (hereinafter collectively called “Employees”) with the rules and conducts the handling in accordance with the rules.
２−２
Specific purposes to use user’s information to provide the services are listed as follows:
（１） Provision, maintenance and protection of the services such as acceptance of registration in connection with the services provided by the Company, identity verification and usage fee calculation
（２） Notification on the services provided by the Company and response to inquiries
（３） Handling a violation of the terms of service and policy, etc. (hereinafter called the “Terms”)
（４） Notification on change, etc. of the Terms

（５） Other purposes related to the purposes specified in the preceding items.
２−３
Purposes to use other than those above are listed as follows:
（１）Creation of statistics in connection with the services provided by the Company by processing user’s information into a form which makes a certain individual unidentifiable
・Device Information
・Logging Information
・Cookie and Unidentifiable ID
（２）Distribution or display of advertisements of the Company or third parties
・Device Information
・Logging Information
・Cookie and Unidentifiable ID
（３）Other use for marketing
・Name
・E-mail Address
・Date of Birth
・Other information to be provided by Customers in the form indicated by the Company

３．How to Request Termination of Use
Customers may request the Company to terminate the use of all or part of user’s information in the manner specified in the services provided by the Company or by contacting the Company. In such cases, the Company shall terminate the use without delay in accordance with the provisions specified by the Company.

４．Provision to Third Parties
The Company shall not provide the personal information in user’s information to third parties without obtaining consent of Customers except in the case where the disclosure is permitted under the Act on the Protection of Personal Information and other laws and regulations.
Provided, however, that this shall not apply in the following cases:
（１）If the Company entrusts the handling of personal information, the Company shall choose a company satisfying the personal information protection standard and shall enter into an entrustment agreement on the protection of personal information as well as strictly supervise and manage such company.
（２） When all or part of the handling of personal information is entrusted to a third party within a range required for attaining the Company’s purpose of service
（３） When the personal information is provided due to business succession by merger or other events
（４）When the Company’s cooperation is required by a state organization, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and obtaining consent from Customers is likely to impede the execution of the affairs concerned
（５）When permitted by the Act on the Protection of Personal Information and other laws and regulations

５．Disclosure of Personal Information
When the Company is requested by a Customer to disclose personal information under the Act on the Protection of Personal Information, the Company shall disclose it without delay after confirming the identity of Customer.
(If such personal information does not exist, the Company shall notify the Customer of that effect.)
Provided, however, that this shall not apply if the Company is not responsible for the disclosure under the Act on the Protection of Personal Information and other laws and regulations.

６．Modification and Discontinuance of Utilization of Personal Information
６−１
(1) If a Customer claims that the contents of personal information are untrue and asks the Company to modify the contents under the Act on the Protection of Personal Information, and
(2) if a Customer claims that the personal information has been handled beyond the officially announced purpose of use or was collected in a dishonest or illegal manner and asks the Company to discontinue the use under the Act on the Protection of Personal Information,
the Company shall confirm the identity of Customer and conduct necessary researches without delay. Based on the result, the Company shall modify the contents of personal information or discontinue the use and then notify the Customer of that effect.
Also, if the Company made a decision not to modify or discontinue the use on reasonable grounds, the Company shall notify the Customer of that effect.
６−２
If a Customer asks the Company to delete the personal information of Customer and the Company judges that such deletion is necessary, the Company shall delete such personal information after confirming the identity of Customer and notify the Customer of that effect. ６−３ The provision of the preceding paragraph shall not apply if the Company is not responsible for the modification and discontinuance of utilization under the Act on the Protection of Personal Information and other laws and regulations.

７．Contact Information
Should you have any questions, comments, complaints or other matters related to the Company’s handling of user’s information, please contact the Company:
Address: Seikoshinko Bldg. 1-5-9 Kotobuki, Taito Ward, Tokyo, 111-0042
Company Name: Cosmo Shoji Inc.
E-mail：info@cosmoshoji.com

８．Procedure to Modify Privacy Policy
The Company shall timely review the operation status on the handling of user’s information and strive to improve it on a constant basis and may modify the Policy as needed. The Company shall notify Customers on this website or by e-mail if the Policy has been modified.
However, the Company shall obtain consent from Customers in the manner specified by the Company if the modification requires consent from Customers by the laws.

Established on August 31, 2018