1. Handling of Personal Information and User Information

1. IIn this Policy, "personal information" means personal information as defined in Article 2, Paragraph 1, of the Personal Information Protection Law. In addition, in accordance with our policy of "placing importance on the protection of user privacy," we define information that does not strictly fall under the category of personal information, but which we nevertheless handle in a manner similar to that of personal information to the extent practicable, and refer to this information together with personal information as "user information”. This Policy defines the Company's policy regarding the handling of user information in addition to the user's personal information.
2. While placing importance on protecting the privacy of our users, we endeavor to provide our users with an unprecedented experience through our Service using user information. Accordingly, we will be transparent in the collection of user information from the users, and will specify as much as possible in this Policy, so that the users will know in advance, what kind of user information we will collect and for what purpose.
3. This Policy forms an integral part of the user agreement for our Service. Users of the Service should read this Policy carefully, and if they do not agree with its contents, they should not use the Service.
4. The Company may provide third parties, such as our business partner companies, with aggregated data, such as statistical data generated from user information, that excludes any connection with specific individuals. The provision of personal information to third parties shall be conducted in accordance with Section 5 “Provision of User Information to Third Parties” of this Policy.
5. The Company provides an opt-out procedure to prevent the provision of user information obtained by the Company through our Service to third parties. For details of the opt-out procedure, please refer to the relevant section of Article 9 "Requesting Suspension of Use and Removal and Opting-Out". Please note that since our Service is provided using user information, if you opt out, you may not be able to use important features of the Service.

2. User Information to be Collected and Collection Method

1. The "user information" that we obtain in our Service is information related to user identification, behavior history on communication services, user's means of transportation (the "means of transportation"), status and motion of the means of transportation, and other information collected, generated, and stored with respect to the user or the user’s terminals such as smartphones (the “terminals”) or devices that are provided by the Company or the Company’s partner companies (the “partner companies”) and installed on the user’s means of transportation for purposes of using the Service (the “devices”).
2. The Company uses Google Analytics and other tools to obtain statistical information about the users of our Service for the purpose of delivering advertisements that uses user information and studying user trends. For more information about Google Analytics, please refer to: http://www.google.com/intl/ja/analytics/

3. Purpose of Use of User Information

The Company uses collected user information within the scope of the following purposes of use (the "Purpose of Use").

1. To provide, maintain, protect, improve, and expand our Service, including the acceptance of registration, user identification, and calculation of usage fees related to the Service.
2. To provide information about the Service and to respond to inquiries.
3. To respond to acts in violation of the Company's terms and policies (the "Terms") related to the Service.
4. To notify users of the changes to the Terms regarding the Service.
5. To compile aggregated data and statistical data based on user information that excludes any connection with specific individuals.
6. To combine information collected from other services provided by the Company and other information to create new data.
7. For employment selection and communication.
8. To conduct questionnaires.
9. To provide information that may be useful to the users such as advertisements or promotions of the Company’s products or those of third parties (including sending direct mails and emails).
10. To conduct research, statistics, and analysis of marketing data.
11. For purposes of use incidental to the above purposes of use.

4. Behavioral Targeting Advertising

1. The Company may, by itself or through its partner companies, provide behavioral targeting advertising that delivers advertisements that are deemed to be beneficial to each user based on the user's interests.
2. Behavioral targeting advertising provided by the Company uses access information obtained through cookies and information regarding the user’s means of transportation, and based on this historical information, delivers advertisements that are deemed to be beneficial to the users through advertising delivery systems provided by the Company.
3. Behavioral targeting advertising provided by the partner companies uses user information that cannot identify specific individuals, such as access information obtained through cookies and information regarding the user’s means of transportation, which is provided to partner companies after prohibiting the identification of specific individuals by linking such information with other information. Advertisements that are considered to be beneficial to users are then delivered through the advertising delivery systems provided by the partner companies.
4. Those who wish to stop the behavioral targeting advertising provided by the Company may opt out in accordance with the procedures set forth in Section 9 " Requesting Suspension of Use and Removal and Opting-Out.” By opting out, the user may not be able to use parts of the Service provided by the Company, for which the user agrees not to make any objections.
5. If you wish to stop the behavioral targeting advertisements provided by the partner companies, please opt out from their websites in accordance with the procedures set" forth in Article 9 “Requesting Suspension of Use and Removal and Opting-Out.”

5. Provision of User Information to Third Parties

1. The Company will not provide any personal information contained in the user information to any third party without the prior consent of the user, except in cases where disclosure is permitted under this Policy, the Personal Information Protection Law, or other laws and regulations. However, this does not apply to the following cases:
   1. When the Company entrusts all or part of the handling of personal information within the scope necessary to achieve the Purpose of Use.
   2. When personal information is provided in connection with the succession of business due to a merger or other reasons.
   3. When it is necessary to cooperate with a national agency, a local public body, or a person or organization entrusted by either of the foregoing in executing affairs prescribed by the laws and regulations, and obtaining the user's consent is likely to impede the execution of such affairs.
   4. Other cases permitted under the Personal Information Protection Law and other laws and regulations.
2. The Company shall handle the provision to third parties of user information from which terminal-specific IDs have been removed to prevent identification of specific users, in accordance with Section 5-1 of this Policy. The provision of user information provided to third parties for the purpose of advertising can be stopped in accordance with Section 9 "Requesting Suspension of Use and Removal and Opting-Out”.
3. The Company may disclose to the public or provide to the partner companies aggregated data, statistical data, and other data generated from user information that is aggregated and excludes any connection with specific individuals.
4. To the extent necessary to achieve the Purpose of Use, we will share user information with our group companies (meaning subsidiaries and affiliates as defined in the "Regulation on Terminology, Forms, and Preparation Methods of Financial Statements", including foreign subsidiaries and affiliates) as follows:
   1. Items of personal information to be used jointly:
      The same as the items listed in Section 2 "User Information to be Collected and Collection Method" above.
   2. Purpose of joint use:
      The same as those described in Section 3 "Purposes of Use of User Information" above (provided that, for the purposes of joint use, "the Company" shall be read as "the Company Group" and "the Service" shall be read as "the services provided by the Company Group”).
   3. Person responsible for management of joint use:
      The Company (For specific inquiries, please refer to Section 10 “Contact Information”.)
5. When a user uses a service linked with the service of a partner company, the Company may provide such partner company with the minimum necessary information for the partner company to identify the user. In such cases, the Company will provide only the minimum necessary information (internal identifiers, part of the device information (advertising ID, language settings), and attribute information) to the relevant partner, and will confirm the user's intention before providing the user’s name, address, and telephone number.
6. If a user uses a service provided by a partner company that is linked to our service via API, and if the user approves the acquisition of user information by such partner company in their contract with such partner company, we may provide user information obtained by us to the partner company via API on behalf of the user in accordance with such contract.

６. Use of Anonymously Processed Information

Our company will obtain, use, manage, and provide anonymously processed information by creating it or obtaining it by transfer in compliance with the laws and regulations. For the items of information included in the anonymously processed information to be created by the Company and the items of information to be included in the anonymously processed information provided to third parties and the method of such provision, please see here.

７. Supervision of Entrusted Party

The Company may entrust all or part of our business operation to a third party to the extent necessary to achieve the Purpose of Use. In this case, the Company will require the entrusted party to handle the user information provided by the Company in an appropriate manner, and supervise the entrusted party appropriately.

８. Disclosure of Personal Information

When the Company is requested by a user to disclose their personal information in accordance with the provisions of the Personal Information Protection Law, the Company will disclose such information to the user without delay after confirming that the request is made by the user themselves. However, this does not apply to cases where the Company is not obligated to disclose the personal information under the Personal Information Protection Law or other laws and regulations. Please note that a handling fee of 1,000 yen per request will be charged for the disclosure of personal information and notification of its purpose of use. The purpose of use of personal information subject to disclosure is as follows, and please see Section 10 “Contact Information” to make requests for disclosure and notification of the purpose of use.

９. Requesting Suspension of Use and Removal and Opting-Out

1. The user may request the suspension of use or removal of all or part of the user information obtained by the Company (however, excluding the anonymously processed information described in Section 6 “Anonymously Process Information” above; the same shall apply throughout this section). In such a case, the Company shall promptly confirm that the request is made by the user themselves and suspend the use of and remove the relevant personal information in accordance with the procedures set forth by the Company.
2. The user may request that the user information obtained through the device or terminal used by the user not be provided to third parties ("opt-out"). The opt-out must be set for each device, and if it is set for a device, the same setting will be applied to the user information obtained through the device. After opting out, the user information obtained through the relevant device will not be provided to third parties. However, if this setting is disabled due to a change in the device or other reasons, the collection, use, and provision to third parties of user information of the user may restart.
3. If you wish to request an opt-out, please see Section 10 “Contact Information”.
4. If you wish to disable the use of cookies by third parties, including our partner companies, please follow the necessary procedures on such third parties’ websites.

10. Contact Information

If you have any opinions, questions, complaints, or other inquiries regarding the handling of user information, please contact us at:

11. Procedures for Changing the Privacy Policy

The Company will review the operation of handling of user information from time to time, shall strive to make continuous improvement, and may change this Policy as necessary. Any changes will be posted in our Service or on the Company's website. In the case of a change in the contents that will require the consent of the users under the laws, the user's consent shall be obtained in a manner prescribed by the Company.