PRIVACY POLICY

This document is an English translation of our Privacy Policy to be used for reference purposes only. The Japanese version of the Privacy Policy is the only official and complete document by NET DREAMERS Co., Ltd. This English translation has no legally binding power as the original Japanese Privacy Policy and shall not influence or be used as reference for the interpretation of said Privacy Policy. NET DREAMERS., Ltd. makes no warranties and bears no responsibility or liability whatsoever for the contents of these Terms of Use.

Basic Policy for the Protection of Personal Information

The Company has committed to protecting customers’ personal information.Now we have more opportunities than before to handle personal information of customers in our online media business, smartphone gaming business and software/cloud business.

We have established a management system in line with the Act on the Protection of Personal Information and related guidelines as well as with the Japanese Industrial Standards（JIS）. Through continuing operation and improvement of this system, the Company will work diligently to prevent any leakage, destruction, alteration or other incidents to the personal information the customers provide to us and to ensure security for customers.

Established on July 1, 2004
Revised on April 1, 2022

1. Establishment and Continuing Improvement of a Personal Information Protection Management System

The Company ensures that all our employees understand the importance of the protection of personal information and establishes, implements, maintains, and improves on an ongoing basis a personal information protection management system（including this Policy, the Regulations for the Protection of Personal Information, and other applicable regulations and rules）in order to ensure that personal information is protected properly.

2. Compliance with the Regulations for the Protection of Personal Information

The Company collects, uses, and provides personal information in a proper manner by establishing an appropriate management system for the protection of personal information according to the business and size of each department in accordance with our Regulations for the Protection of Personal Information and other applicable regulations and rules. We will use personal information only for prescribed purposes and have appropriate procedures in place for data subjects, such as the disclosure and correction of personal information.

3. Ensuring the Accuracy and Security of Personal Information and Handling of Complaints and Inquiries

The Company endeavors to keep your personal information accurate and up-to-date in order to ensure its accuracy and security. The Company also endeavors to prevent any personal information risks, such as unauthorized access, loss, destruction, alteration and leakage, by taking reasonable security measures and corrective measures for any security incidents in terms of both the information and communication technology and the organizational management system. The Company will establish a system in case customers have complaints and inquiries regarding personal information we manage.

Customer help desk regarding the handling of personal information
Customer Center for the Protection of Personal Information
privacy@netdreamers.co.jp
From 10 a.m. to 6 p.m. on weekdays（JST）

4. Compliance with Laws and Regulations on the Protection of Personal Information and Other Standards

The Company complies with the provisions of laws and regulations on the protection of personal information as well as with specified standards and guidelines established by administrative organs and other similar organizations and guidelines, etc. established by the government.

5. Education and Training

The Company will raise awareness among its officers and employees of the importance of the protection of personal information and provide them with education and training on the management system for the protection of personal information.

NET DREAMERS Co., Ltd.
President and CEO
Toshikazu Mukae

Handling of Personal Information

１. Matters Regarding the Disclosure of Purposes of Use of Personal Information

NET DREAMERS Co., Ltd.（hereinafter, the “Company”）will handle personal information for purposes listed in the table below.Personal information marked by an asterisk（*）is treated as personal data retained by the Company, or “retained personal data.” For retained personal data, you may make a request to the Company for the following purposes; notification of purposes of use, disclosure, correction, addition or deletion, suspension of use, erasure, and suspension of provision to third parties.

Types of personal information	Purposes of use
Information of applicants*	To make employment decisions about human resources we require To send gifts to campaign prize winners under respective services of the Company To send notices of our campaigns
Information of employees*	To handle human resource management affairs and make staff announcements
Information of retirees*	To handle statutory human resource management affairs regarding retirees and send notices as needed about gatherings and other necessary matters
Information registered with our services*	To provide services
Personal information obtained through services outsourced to the Company	To perform outsourced services
Personal information obtained through services outsourced to other companies	To perform accounting and management work
Information related to inquiries*	To handle inquiries

2. Matters to Be Notified Regarding Retained Personal Data

The Company discloses the following information in relation to its handling of retained personal data:

（１）Name of the Company

NET DREAMERS., Ltd.（Shibuya Scramble Square 36F, 2-24-12 Shibuya, Shibuya-ku, Tokyo）
Toshikazu Mukae, President and CEO

（２）Personal Information Protection Manager

Tetsuo Kojima

（３）Purposes of Use of All Retained Personal Data

Please see Section 1: Matters Regarding the Disclosure of Purposes of Use of Personal Information.

（４）Help Desk for Inquiries and Complaints Regarding the Handling of Retained Personal Data

Please see Section 3: Procedures for Handling Requests for Disclosure of Personal Information.

（５）Measures Taken for Ensuring Security Control of Retained Personal Data

-Established a basic policy for inquiries, complaints, etc. in order to ensure proper handling of personal information
-Established regulations on the handling of personal information
-Appointed a personal information protection manager and established a reporting structure for actual or potential violations of the Act on the Protection of Personal Information or the regulations on the handling of personal information
-Provide employees with periodic training on the handling of personal information
-Conduct access control of employees in areas in which personal information is handled and have measures in place to prevent access to personal information by unauthorized employees
-Conduct access control through an information system and limit the scope of personal information handled and employees in charge

（６）The Accredited Personal Information Protection Organization to Which the Company Belongs and Help Desk for Resolving Complaints

[Name of the Accredited Personal Information Protection Organization]
JIPDEC
[Help Desk for Resolving Complaints]
Help Desk for the Protection of Personal Information
Address: Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
Phone: 0120-700-779
[This number is not for inquiries about our products or services.]

3. Procedures for Handling Requests for Disclosure of Personal Information

By performing our prescribed procedures, you may make a request to the Company for the following purposes with respect to your own personal information held by the Company; notification of purposes of use, disclosure, correction, addition or deletion, suspension of use, erasure, and suspension of provision to third parties. In case you wish to make a complaint or inquiry about your personal information, you can do so through the same prescribed procedures.
If you wish to go through these procedures, please contact our Customer Center for the Protection of Personal Information below.

Customer help desk regarding the handling of personal information
Customer Center for the Protection of Personal Information
privacy@netdreamers.co.jp
From 10 a.m. to 6 p.m. on weekdays（JST）
*Please note that if you request “disclosure” or “notification of purposes of use,” you will be charged 1,000 yen（tax included）as handling fees.
If you wish to make a request through your agent, please contact our personal information protection personnel.
Only the following types of agents can make a request:
A statutory agent of a minor or of an adult ward; or An agent appointed by the data subject himself/herself in order to request disclosure, etc.

If the Company receives any of the aforementioned requests, the Company will reply in writing or through electronic records（such as emails）within 10 days after conducting necessary investigations.
You can choose the means of our reply.
If you choose to receive a reply in writing, we will use a restricted mail-delivery service in which only the addressee can receive the mail, in order to prevent leakage of personal information by identity theft.
Please note that, for replies by e-mail or other electronic records, we will verify the identity of the data subject by other methods.

End

Privacy Policy for Our Website and Applications

Introduction

NET DREAMERS., Ltd.（hereinafter, “NET DREAMERS”）takes the protection of personal information in an advanced information and telecommunications society seriously and considers it our important social responsibility to manage personal information in a proper manner. Therefore, we have established the following privacy policy for this website and the applications we operate（hereinafter, the “Services”）based on our personal information protection policy. We will handle customers’ personal information in accordance with this Privacy Policy and strive to operate and manage the Services so that the customers can use the Services with a sense of security.

If you provide your personal information to us through the Services, we will handle it in accordance with this Privacy Policy.

However, if there are any rules stated on a certain webpage on which you provide your personal information that are different from the provisions of this Privacy Policy, such different rules will take precedence over this Privacy Policy.

Revised on April 1, 2022

Handling of Personal Information

[Definition of Personal Information]

The term “personal information” as used in this Privacy Policy means information provided by a customer to NET DREAMERS via the Internet under the Services that can identify the customer himself/herself or is specific to the customer himself/herself, such as name, address, phone number, and e-mail address.

[Collection of Personal Information]

When we ask you to provide us with your personal information, we will specify its purposes of use in advance.
We will use the personal information you provide to us within the intended purposes of use and will not use it outside such intended purposes without your consent.
If you do not wish to provide your personal information, you can refuse to do so at your discretion.
Please note that, in such a case, you may not be able to use services under the Services.

[Provision of Personal Information to Third Parties]

We will not disclose personal information you have provided to us to third parties, except when:

1. you have provided your consent to the disclosure of your personal information;
2. we outsource the handling of personal information to our partners, affiliates and service providers with whom we have entered into a non-disclosure agreement for personal information, within the scope necessary for achieving the purposes of use specified to you（such as when we ask a carrier to ship competition prizes or when we make inquiries with a credit company at the time of settling a payment）;
3. your personal information is processed into statistical data that cannot identify you（such as when we disclose data on website usage by age）; or
4. we are required to provide your personal information under laws and regulations, etc.

[Security Control of Personal Information]

When we ask you to provide us with your personal information, we will specify, in advance, the manager of such personal information on a certain webpage on which you provide your personal information. The manager will strictly store and manage your personal information and take reasonable security measures, such as setting up a firewall and taking anti-virus measures, in order to prevent any leakage, unauthorized use, alteration, etc. resulting from unauthorized access to personal information by a third party. When you send your personal information at our request, we ensure security by encrypting your personal information using the secure sockets layer（SSL）technology or equivalent security technology in order to prevent any unauthorized access by a third party on the communication route.

[Inquiries about and Correction and Deletion of Personal Information]

If you wish to make an inquiry about or request the correction, deletion, etc. of the content of the personal information you provided, please contact the relevant manager. After matching the identity of the requester with the identity of the data subject, we will disclose, correct, or delete personal information or perform other procedures as requested within a reasonable period of time.

[Personal Information of a Child]

If you are 15 years of age or younger, you must obtain the consent of your guardian before providing your personal information.

Cookies

In order to enhance customer experience when a customer re-visits us to use the Services and/or for other similar reasons, we may send and store in the customer’s hard disk, data called cookies to identify the customer’s computer.

Cookies do not identify individual customers.
If you wish to disable the cookies we use, you can delete cookies stored on your hard disk.

Advertisers will use cookies in accordance with their privacy policies.

[Third-Party Tracking System]

In order to research usage trends and/or to show optimized advertisements, this website collects statistical information on website usage by using cookies, image files（web beacons）, etc. of third-party companies（*1）. Sometimes third-party companies collect information directly from those cookies and web beacons. Such cookie information will not be provided or disclosed to us but will be managed in accordance with the privacy policies of those third-party companies.
*1: For the privacy policies and cookie statements of the third-party companies or how to disable those cookies, please refer to the following websites of the third-party companies or the DDAI（Data Driven Advertising Initiative）:
DDAI
aboutads.infochoices
Google AdSense
Google Analytics　（including via Google signals）
Google Ad Manager
GENIEE
Yahoo!

Protection of Personal Information on Linked Websites

NET DREAMERS is not responsible for the security of personal information on the websites linked from the Services. For the measures to protect personal information on those linked websites, please confirm their respective privacy policies, etc.

Inquiry Desk

If you have any questions about the handling of personal information you have provided, please contact us through the inquiry desk specified on a certain webpage on which you have provided your personal information.
For any inquiries about this Privacy Policy, please contact us at the e-mail address below. Please note that some of the inquiries a customer sends to the following e-mail address about their personal information may take some time to respond to.

For inquiries:

E-mail：privacy@netdreamers.co.jp