NTT Advertising, Inc. reveals our personal information as well as personal number and the specific personal information (hereinafter referred to as “specific personal information, etc.”) and policies on the protection of such specific personal, etc. because we aware that it is an important responsibility to ensure the trust of customers and society for business activities to properly deal with, to protect the individual’s rights and interests, including our customers, our company.
- We will set up a system within our organization to promote the protection of personal information, by clearly defining the role and responsibility of any and all of our employees who handle personal information.
- We will comply with any and all laws, regulations and principles relevant to the protection of personal information.
- We will not obtain or use any personal information for any purposes other than those for which they are to be used as notified to the relevant individual.
- We will not disclose any personal information to any third party without consent of the relevant individual.
- We will operate an information security management system (ISMS) in order to maintain the confidentiality, completeness and usability of personal information.
- When we employ a third party to handle personal information, we will select those who can handle personal information properly and supervise them to the extent necessary and appropriate.
- We will regularly conduct educational activities on the protection of personal information for our employees and others in order to assure the compliance with the relevant laws, regulations and principles and to promote the awareness of protection of personal information.
- Whenever we are required notice, disclosure of purpose to use, correction, addition, deletion, suspension of use, erasure or suspension of delivery to a third party of personal information we hold, we will quickly respond.
- When we receive a complaint on our way to handle personal information, we will respond properly and quickly.
- We will regularly check our own activities on protection of personal information and will do our continuous efforts to improve.
- Acquisition of User Information and Usage Purpose
- Acquisition Using the Information Collection Module
- Provision of User Information to Third Parties
- Consent to Acquisition, Storage, and Utilization of User Information
- Suspension, Etc. of Acquisition of User Information
- Contact for Inquiries About Handling of User Information
- Transfers Outside the EEA
- Security Management of Personal Data
- Retention Period
1. Acquisition of User Information and Usage Purpose
(1) User information acquired by the Company through the application (hereinafter referred to as the “User Information”) consists of the following items. The Company automatically acquires the User Information through the application and also acquires the User Information registered through manual input by the Customer.
|User Information acquired||Usage Purpose||Acquisition method||Remarks|
|Notification token for the application (this is the authentication key required to implement push notification and is acquired by the device from Apple Inc. or Google Inc.)||Identify the Customer in provision of the Services and provide recommendations of content that responds to the Customer’s preferences and current location via push notification, etc.||Automatic acquisition through the application (This will be sent when push notifications are turned on.)|
|Language selected on the application by the Customer and date of birth, gender, nationality, and other information input by the Customer||Identify the Customer in provision of the Services and provide recommendations of content that responds to the Customer’s preferences and current location via push notification, etc.||Acquisition through manual input by the Customer|
|Access history to each content of each site on the Customer device (information related to access date and number of accesses)||Analysis of usage details for the Services, analysis for implementation of various measures by the Services, measurement of subject measure effects, improvement of service quality, and other analysis and surveys related to the Services||Automatic acquisition through the application||This does not identify individuals.|
|Customer device information (model, OS, etc.)|
|Information on actions within the app (screen transitions, screen viewing time, number of activations, etc.)|
|iOS Advertising Identifier or Android Advertising ID|
|Location information of the Customer device (latitude/longitude acquired by GPS, etc.)||Provide recommendation of content for the Customer’s location information via push notification, etc.||Automatic acquisition through the application (transmitted when acquisition of location information has been allowed)||The following points cover handling of location information.
・User of location information: Company or Company business partner
・Type of location information: GPS location information
・Acquisition frequency: Acquisition frequency varies by OS, but is generally once per minute
・Whether it is provided to third parties or not and the third parties: As stipulated in Article 3
・Other utilized User Information that is tied to location information: Date of birth, gender, language, content access history, device information, information on actions within app
・Framework of user involvement: As stipulated in Article 4 and Article 5
2. Acquisition Using the Information Collection Module
The Company acquires User Information described in the preceding article via the following information collection modules built into the application. The information collection module is a program supplied by a third party with functions to acquire and analyze user information. The Company combines the User Information acquired by the information collection module with the ID that identifies individual Customers and may add the Customer’s attribute information and other information and use it.
■ Information collection module: Firebase GoogleAnalytics/GoogleAnalytics
・Provider of the information collection module: Google, Inc. and its wholly owned subsidiary
・User information acquired: Customer device model information (model, OS, etc.), information on actions within the app (screen transitions, screen viewing time, number of activations, etc.), app instance identifier, and iOS Advertising identifier or Android Advertising ID
・Utilization of the User Information by the information collection module provider: A server system managed by Google stores the User Information. Google utilizes the User Information within the scope of the usage purpose stipulated by Google.
Refer to ＜https://www.google.com/privacy.html＞ for details on Firebase GoogleAnalytics/GoogleAnalytics and the usage purpose defined by Google.
3. Provision of User Information to Third Parties
(1) The Company utilizes the following information from the User Information for provision, improvement, etc. of the Services. Additionally, ① the Company may process collected information into statistical data, etc. for use in provision of products and services related to demographic analysis, marketing analysis, and other analysis for government ministries and agencies, public organizations, general companies, and other customers and ② the Company may provide collected information to a partner of the Company without having processed it into statistical data, etc. in order to supply the partner business with necessary information for the purpose of the partner processing collected information into statistical data, etc. for use in provision of products and services related to demographic analysis, marketing analysis, and other analysis for the Company’s customers (there is an obligation to process collected information into statistical data, etc. for use in provision of subject products and services).
■ User Information provided
① Profile information selected by the Customer on the application (language and date of birth, gender, nationality, and other information input by the customer)
② Location information (latitude/longitude acquired by GPS, etc.)
③ OS type
④ Information on actions within the app (screen transitions, screen viewing time, number of activations, etc.)
■ Usage purpose
Processing the User Information into statistical data, etc. and provision of products and services related to marketing analysis by the partner
(2) The User Information may not be transmitted or provided to a third party other than in cases indicated in the preceding items and the following cases.
① In cases of transmission to the provider of the information collection module stipulated in Article 2
② In cases of having overtly obtained approval in a contract with the Company
③ In cases of provision to a third party that does not require the individual’s consent under the Act on the Protection of Personal Information, including provision based on laws and provision to an outsourcing firm as part of business consignment.
4. Consent to Acquisition, Storage, and Utilization of User Information
5. Suspension, Etc. of Acquisition of User Information
(1) Through changes to the settings stipulated on the Customer device in use of the application, the Customer may stop acquisition, use, and third-party provision of User Information such as location information, halt reception of recommendation information, and delete information input into the application by the customer. By changing the location information setting to “Not allowed” and changing information input by the customer to “Not selected” or “Unselected,” the Customer may halt third-party provision of all User Information based on Article 3 (1).
(2) You have the following rights with respect to the Personal Data.
To make a request regarding the various rights of the Personal Data, please contact us through the inquiry desk in Article 6.
・The right to request access (disclosure of purpose, type, recipient, retention period, source, etc.).
・The right to request correction.
・The right to request erasure.
・The right to limit the handling.
・The right to object to the handling of personal information.
・The right to request the transfer or portability of personal information so that it can be used by other services.
・The right to withdraw your consent at any time.
・The right to lodge a complaint at any time with the supervisory authority of any country in the EEA.
6. Contact for Inquiries About Handling of User Information
Please contact the following inquiry desk if you have any opinions or requests about the handling of User Information by the application or the Services.
8. Transfer Outside the EEA
(1) (1) We may transfer the personal data we handle to countries outside the EEA. These transfers may include cloud service vendors, our partners, and other third parties (data processors). We will supervise these third parties that handle personal data to ensure that they take appropriate and adequate measures to protect the data in accordance with the GDPR and the circumstances of the transfer.
(2) The Company assumes that by using the Company's services the Customer has agreed to the following.
・The Personal Data protection laws and regulations may not be sufficient in countries outside the EEA, and the same level of protection as that provided by the GDPR cannot always be guaranteed.
・In order to achieve the usage purpose, the Personal Data may be transferred to third parties (those who process data), including cloud service vendors located in countries outside the EEA, our partners, and other contractors.
9. Security Management of Personal Data
(1) We will take safety control measures to handle the Personal Data appropriately and thoroughly “prevent leakage, destruction, damage, loss, falsification, unauthorized access, etc.”
(2) We will provide sufficient guidance to employees so that they are fully aware of and understand the importance of the Personal Data and the risks associated with violations of handling rules, and can manage and handle such data.
10. Retention Period
Personal data will be processed within the scope specified in the usage purpose, and will be stored appropriately under secure management. Personal data that is no longer needed will be promptly deleted.