1, Basic Policy of Personal information Protection
We will comply with all applicable laws, state-specified policies, and other rules regarding the protection of personal information.
We will clearly specify the purpose for which we use the personal information, and will obtain, use, and provide the personal information in an appropriate manner. Unless otherwise specified by law, we will only use the personal information we collect for the specified purpose, and will also take and maintain necessary measures to prevent the use of such information for other purposes.
In order to prevent leakage, loss or damage of the personal information, we will employ appropriate organizational, physical, personal, and technical countermeasures and implement security management measures.
We will give notification of the purpose for which we use personal information as required by law, and will handle any complaints, comments or enquiries in an appropriate manner.
Personally identifiable information may be collected from Users in the United States and elsewhere outside of Japan and transmitted to Japan for storage and for use consistent with this policy.
(1) Information We Collect and Manage
Information on our applications downloaded
(Names of applications; version information; application-specific IDs (i.e., IDs issued at the time of installing the applications, which are uniquely assigned to each device and each application))
Advertising Identifier (IDFA)
(An ID for advertising distribution which is issued to each device, etc., in an environment where Cookies are not available (such as mobile applications),including obtaining such information in the background for the purpose of providing O2O services)
Information on telecommunications carriers.
(Telecommunications carriers connected to by your mobile device)
(Information on carriers; type and version of operating system; and device model information)
(Location data of your mobile device which is automatically collected by our applications)
Information on mobile networks or services, and information on usage environment
(Connection status, including connection availability; and network type)
Search information entered when you use our application, as well as your browsing history
(Search words entered; and times and dates of browsing)
If you permit our services to link to other services, such other services may obtain the information listed above and transmit it to our servers.
- Information on our applications downloaded
(2) Use of Information We Collect
We may aggregate, analyze and otherwise use the Collected Data for various purposes. The purposes for which we use the Collected Data are included in those set forth below:
- Provision of services of the relevant application;
- Our business operations, including operation of or improvement of functions of our applications;
For improvement of functions and performance of applications;
Research on service demands
For enabling applications to provide valuable information more easily;
Research on business demands
For reflecting such information into our products or services or to use such information in marketing research, in a form that does not contain any personal information;
Distribution of advertising
For delivery and display of advertisements regarding our or other companies’ products or services, etc.;
Big-data analysis services
For sale or disclosure of integrated and analyzed information (including disclosure by persons to whom the Company have sold such information) to other companies in a form that does not contain any personal information;
- Prevention of unauthorized use;
For fulfillment of our disclosure obligations which are imposed by law, contract, or otherwise
(3) Provision of Collected Data to Third Parties
We may provide or disclose information which integrates the Collected Data (including disclosure by third parties to whom we have provided such information), to other business enterprises or public institutions, in a form that does not contain users’ personally identifiable information as below;. Upon provision, Agoop strictly prohibits the third parties to which information is provided from connecting such information to personal information, etc.
- to communication carriers as reference information for improvement of the communication environment (in such case, advertisement identifiers are excluded);
- to third parties as various commercial products and services provided by Agoop (including disclosure by the third party to which the information is sold); and
- to any third party for the purpose of the previous section 2 (2), in addition to the purposes provided for in the previous two (2) items.
In addition, we may provide the Collected Data to third parties, including investigative authorities or in response to discovery requests, subpoenas, warrants or court orders, if it is deemed appropriate for:
- Protecting our assets, services, and legal rights;
- Protecting the life, limb or property of an individual;
- Preventing wrongful acts against us or any third party;
- Supporting auditing, compliance or corporate governance functions;
- Complying with orders or requests by public institutions including investigative authorities, regulatory authorities, or courts; or
- Complying with applicable laws.
(4) Suspension of Provision of Location Data by Users
If you disable location-based services on your mobile device, your location data will not be transmitted to our server. The disabling process may differ depending on the model of the device; so please refer to the operation manual of your mobile device.
Some of the main functions of our applications may not be available if you disable the location-based services.
(5) Third Party Advertisements
3, “Do Not Track” Signals.
Some Internet browsers include the ability to transmit “Do Not3Track” signals. We do not process or respond to “Do Not Track” signals.
4, Third Party Data Collection.
Third parties are not permitted to collect personally identifiable Collected Data about Users’ online activities over time or across different websites or online services.
The terms of this policy are subject to change and notice of any material change to this policy will be provided on our website. Please visit our website periodically to keep yourself updated.
In addition to publicizing this policy through distribution to all officers and employees, we make this policy available to all stakeholders via our website (https://www.agoop.co.jp/en/) or through brochures.
6, Contact Point for Complaints, Comments, or Enquiries regarding Handling of Personal information and User Information
If you would like to review Collected Data that pertains to you, and to request corrections or deletions of same, please send your request in writing to:
- Personal Information Protection Manager:
- Director, Information Operations Div.,
- AGOOP Corp.
- Personal Information Protection Auditor:
- Director, Management Administration Div.,
- AGOOP Corp.
Established on: April 1, 2009
Amended on and effective as of: February 7, 2017
Amended on and effective as of: August 1, 2017
Amended on and effective as of: April 1, 2018 Kazuhisa Shibayama, President & CEO
1, Types of Personal Data
2, Collection, Use and Disclosure of Personal Data
(1) Purposes of Use of Personal Data
We collect, process and provide your Personal Data in order to achieve the purposes set forth below.
To integrate the Personal Data of the users of “AroundMe” with the Personal Data of the users of applications operated by Flying Code, and conduct data analysis thereof.
To provide the “floating population data,” which is a type of big data generated from location information acquired from “AroundMe,” to third parties for the following purposes:
a) Urban planning
c) Tourism policy planning
d) Trade area analysis
e) Store opening planning
f) Other research and analysis related to population and movement of people
Please see the description page (https://www.agoop.co.jp/en/floating-population/) for more details on the “floating population data.”
(2) Legal Grounds for Processing Personal Data
We may process the Personal Data based on the following legal grounds:
- To perform your instructions or fulfil the obligations under other contracts with you;
- Your consent expressly given to us to process the Personal Data in such manner. You may withdraw the consent to this processing at any time; however, this will not affect the lawfulness of any processing activity carried out by us before such withdrawal of the consent ; and
- To comply with legal and regulatory obligations
(3) Additional Processing
In the case of processing the Personal Data for purposes other than the foregoing, we will notify you in advance of such purposes of use and other matters as required by applicable laws.
(4) Retention Period
We will retain your Personal Data as long as such data is necessary to achieve the purposes of use specified above.
(5) Transfer of Personal Data
We may provide your Personal Data to third parties such as telecommunications companies, mobile application developers and operators, cloud service vendors, contractors for monitoring, operation and maintenance of cloud servers, and sub-contractors for data analysis, etc., and your Personal Data will be processed by such third parties in order to carry out the purposes of use specified above.
We may provide the “floating population data” to third parties such as administrative organs, universities and other research institutions, local governments, consulting companies, GIS (geographic information system) vendors, destination management companies, shopping centers, franchise headquarters, restaurants, advertising businesses and other categories of companies which use the “floating population data” for the purpose of public policy, marketing and/or commercial purposes.
The Personal Data may be transferred to entities in countries or jurisdictions outside the EEA, such as Japan and the U.S., if required for the purposes as described above. Please note that such countries or jurisdictions may not have the same data protection laws as the EEA and that they may not afford many of the rights conferred upon you in the EEA. We will ensure that any such international transfers are made subject to appropriate and suitable safeguards as required by the GDPR or other relevant laws. When doing so, we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of the Personal Data.
- To integrate the Personal Data of the users of “AroundMe” with the Personal Data of the users of applications operated by Flying Code, and conduct data analysis thereof. To provide the “floating population data,” which is a type of big data generated from location information acquired from “AroundMe,” to third parties for the following purposes:
3, Data subject’s rights
You may make a request to us for access to, correction or erasure of, or restriction of processing of your Personal Data, and may make a request for data portability with regard to your Personal Data retained by us. When we receive a request based on the right specified above, we will conduct any necessary investigation without undue delay and provide you or a nominated third party with the Personal Data or respond to such rights without undue delay
Please note that you may raise an objection to the data protection authorities having jurisdiction over us or the location of your domicile with regard to the processing of your Personal Data.
[Address] 3-35-8 Jingumae, Shibuya-ku, Tokyo 150-0001 Japan
[Contact details of Data Protection Officer] firstname.lastname@example.org, +81-3-6682-9349
Effective date: January 9,2019