MELPOT Corporation(hereinafter “the Company”) shall enact this privacy policy as its basic policy to appropriately protect personal information by complying with the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter “the Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (Act No. 27 of 2013), the Guidelines Regarding the Protection of Personal Information in the Telecommunications Business and other relevant guidelines in relation to the handling of personal information when providing Services (including but not limited app, game, and other services) (hereinafter “the Services”).

1. Identification of the Purposes of Using Personal Information

The Company shall acquire and use personal information within the range necessary to achieve the purposes stipulated in the following items when providing the Services.

1. To open the accounts of users who will use the Services, to confirm the identity of those users and to register users

2. To respond to inquiries from users

3. To hold campaign lotteries and to send prizes/products

4. To perform the business of billing relating to the fees for paid currency used in the Services

5. To manage, improve and prevent the improper use of the Services

6. To analyze the usage situation relating to the Services and to create statistical data

7. To propose new projects relating to the Services and to advertise those projects

8. To conduct questionnaires/analysis relating to the Services and to conduct marketing investigations/analysis

9. For use incidental to the above purposes of use

10. For other purposes stipulated in the terms of use of the Company

2. Restrictions on the Use of Personal Information

The Company shall not handle personal information beyond the range necessary to achieve the purposes of use without obtaining the consent of the individual in question in advance. Even in the event the Company acquires personal information due to a merger or other reason, the Company shall not handle that information beyond the range of the purposes of use prior to the succession without obtaining the consent of the individual in question in advance. However, this shall not apply at the times stipulated in the following items.

1. When based on laws/ordinances

2. When it is necessary to protect the life, body or property of a person, and when it is difficult to obtain the consent of the individual in question

3. When it is especially necessary to improve public health or to promote the healthy development of children, and when it is difficult to obtain the consent of the individual in question

4. When it is necessary to cooperate with a national body, a local public body or a party commissioned by such a body executing matters stipulated in laws/ordinances, and when obtaining the consent of the individual in question risks hindering the execution of those matters

3. Appropriate Acquisition of Personal Information

The Company shall acquire personal information appropriately; it shall not acquire personal information by deception or other improper means. Moreover, the Company shall take care to not unnecessarily collect information relating to individuals from children under the age of 15 without the consent of the person exercising parental authority over them.

4. Notifications of the Purposes of Use When Acquiring Personal Information

The Company shall notify or announce to the individual in question the purposes of use in advance when acquiring personal information. However, this shall not apply at the times stipulated in the following items.

1. When notifying or announcing to the individual in question the purposes of use risks harming the life, body, property or other rights and interests of the individual in question or a third party

2. When notifying or announcing to the individual in question the purposes of use risks harming the rights or legitimate interests of the Company

3. When it is necessary to cooperate with a national body, or a local public body executing matters stipulated in laws/ordinances, and when notifying or announcing to the individual in question the purposes of use risks hindering the execution of those matters

4. When it is deemed that the purposes of use are clear from the acquisition situation

5. Storage Period

The Company shall establish a storage period for personal information within the range necessary for the purposes of use. The Company shall delete or discard the personal information in an appropriate method without delay after the expiration of the storage period or after the purposes of use have been achieved.

6. Changes to the Purposes of Using Personal Information

The Company shall not change the purposes of using personal information beyond the range reasonably recognized to have considerable relevance to the purposes of use before the change. In addition, the Company shall notify or announce to the individuals in question the changed purposes of use.

7. Safe Management of Personal Information and Supervision of Employees

The Company shall establish personal information protection rules and perform the necessary and appropriate supervision of employees to prevent the leakage, loss or damage of personal information and to otherwise safely manage personal information.

8. Supervision of Subcontractors

The Company may subcontract part or all of the handling of personal information to a subcontractor. In this case, the Company shall perform the necessary and appropriate supervision so that personal information is safely managed by the subcontractor (e.g., by entering into a contract that includes maintenance of confidentiality with the subcontractor).

9. Appointment of a Personal Information Protection Manager

The Company shall appoint a personal information protection manager. The personal information protection manager shall formulate internal rules to comply with this privacy policy, develop an audit structure and supervise the handling of personal data by the Company.

10. Restrictions on Provision to Third Parties

1. The Company shall not provide personal information to third parties without obtaining the consent of the individual in question in advance except at the times stipulated in the following items.

1. When based on laws/ordinances.

2. When it is necessary to protect the life, body or property of a person, and when it is difficult to obtain the consent of the individual in question.

3. When it is necessary to cooperate with a national body, a local public body or a party commissioned by such a body executing matters stipulated in laws/ordinances, and when obtaining the consent of the individual in question risks hindering the execution of those matters.

4. When the following items have been notified or announced in advance according to the provisions in the Personal Information Protection Act.

• The fact provision to third parties is included in the purposes of use

• The items of data to be provided to the third parties

• The means or methods of provision to third parties

• The fact the provision to third parties of personal information shall be stopped at the request of the individual in question

2. Notwithstanding the provisions in the preceding paragraph, the times stipulated in the following items shall not be applicable to the third parties stipulated above.

1. When part or all of the handling of personal information is subcontracted within the range necessary to achieve the purposes of use by the Company

2. When personal information is provided due to the succession of business because of a merger or other reason

3. When personal information is used jointly with a specific party, and when a statement to that effect, the items of personal information to be used jointly, the range of the party that will jointly use the personal information, the purposes of use of the party that will use the personal information and the name of the party with responsibility in regards to the management of the personal information have been notified to the individual in question in advance or have been placed in a state that allows the individual in question to easily learn of them

11. Disclosure of Personal Information

In the event a personal information disclosure request has been received from an individual, the Company shall disclose that personal information without delay upon confirming that the individual making the request is the individual in question. However, in the event the disclosure is applicable to any of the following items, the Company may not disclose part or all of that information. In the event the Company determines it shall not disclose that information, the Company shall notify the individual making the request to that effect without delay.

1. When there is a risk of harm to the life, body, property or other rights and interests of the individual in question or a third party

2. When there is a risk of significantly interfering with the appropriate implementation of business by the Company

3. When disclosing that personal information would violate laws/ordinances (excluding the Personal Information Protection Act, and its enforcement orders and enforcement rules)

12. Correction etc. of Personal Information

In the event the correction, addition to or deletion (hereinafter “Correction etc.”) of content is requested by an individual because the personal information of that individual is not true, the Company shall conduct the necessary investigation without delay within the range necessary to achieve the purposes of use except when specific procedures are stipulated by the provisions of laws/ordinances (excluding the Personal Information Protection Act, and its enforcement orders and enforcement rules). The Company shall then perform the Correction etc. of the content of the personal information based on those results and notify the individual in question to that effect.

13. Stoppage of the Use etc. of Personal Information

In the event a request has been received from an individual to stop using or delete (hereinafter “Stoppage of Use etc.”) his/her personal information because it is being handled.
beyond the range of the purposes of use announced in advance or because it was acquired by deception or other improper means, the Company shall conduct the necessary investigation without delay upon confirming that the individual making the request is the individual in question. When the reason to perform the Stoppage of Use etc. has been ascertained, the Company shall perform the Stoppage of Use etc. of the Personal Information and notify the individual in question to that effect. However, in the event performing the Stoppage of Use etc. of Personal Information shall cost a lot of money or it shall otherwise be difficult to perform that Stoppage of Use etc., and in the event it is possible for the Company to take alternative measures necessary to protect the rights and interests of the individual in question, the Company may take those alternative measures.

14. Acquisition and Use of Information Not Applicable to Personal Information

The Company may acquire and use information obtained by processing personal information so that it cannot identify individuals and other information not applicable to personal information within the range stipulated in the Personal Information Protection Act and other laws/ordinances to develop new apps and to improve services.

15. Disclaimers

The Company shall not accept any responsibility whatsoever at the following times.

1. When an individual has personally revealed his/her own personal information to a third party using the functions of the Services of the Company or by other means

2. When it has become possible for a third party to identify an individual with information disclosed or provided by that individual in the Services of the Company

16. Inquiries

Inquiries about the disclosure or Correction etc. of personal information acquired from customers by the Company and reports of grievances relating to the handling of that personal information from the individuals in question should be addressed to the following.

MELPOT Corporation Inquiries Desk
E-mail address : support [ at ] melpot.co.jp

17. Revisions

The Company may revise part or all of this privacy policy. The Company shall announce any important changes on its website.

Enacted on June 1st , 2021