" COW "privacy policy

COW Inc.(Hereinafter referred to as "Company".), The platform application service service for carrying out the exhibition and purchase, such as a photo " COW (Hereinafter referred to as "User Information") on the users of the Service (hereinafter referred to as "the Service") as follows.

1. General provision

1. The Company, for the protection realization of user information, to comply with the laws and regulations of the Personal Information Protection Law and other relevant, and strive to appropriate handling and protection of user information, including personal information.

2. " COW "Privacy Policy (hereinafter referred to as the" Policy ".) Is applied relates to the use of the Service. In addition, the Company, the case prescribed for the handling of user information in the privacy policy or other personal information protection policies or terms and conditions relating to the services, etc. to be posted on the application to our operations, it is assumed that the provisions also apply, the If the provision conflicts with this policy, this policy shall prevail.

3. Service to partner with the Service (hereinafter referred to as the "tie-up service".) Operators to provide (hereinafter referred to as the "tie-up business.") Services provided by a person other than the tie-up services other company, which is provided by the ( Hereinafter referred to as "external service"), the provision of this policy does not apply. For the handling of user information in the tie-up service, please refer to the privacy policy, such as the operator providing the tie-up services separately determined.

2. Information acquired by the Company and its acquisition method

1. The Company acquires user information including personal information ("Personal Information" as defined in Article 2, Paragraph 1 of the Personal Information Protection Act, the same shall apply hereinafter) as provided below in this service To do.

1. Information to be provided to users (hereinafter referred to as "user-provided information")

We acquire the user's name, date of birth, gender, address, occupation, e-mail address, telephone number, information on SNS accounts such as Facebook and Twitter, credit card information and other information on users designated by us I will.

2. Information collected by the Company when using this service

A) A Terminal information

When the user uses this service on a terminal or a mobile terminal, we will store terminal information (ID information etc. that can identify the terminal etc.) used by the user in order to maintain and improve this service or to prevent fraudulent activity, You may collect.

B) Information on log information, action history and service usage status

In order to maintain and improve this service or to prevent fraud, IP address automatically generated and stored when using this service, date and time of request from the user, information on operation history in this service, We may collect information on user's service usage situation.

C) Cookie and anonymous ID

In this service, you may use technology called "cookie" and similar technology. Cookie is an industry standard technology that web server identifies user's computer. The cookie can identify the user's computer, but can not identify the individual user. Although you can disable cookie functions by changing settings on the electronic terminal, some or all of this service may not be available.

D) Location information

In order to provide a service using information such as the current location of the user, the Company collects position information transmitted from the user's smartphone terminal, tablet terminal or other information terminal, etc. within the range necessary for providing the service You may. You can stop sending position information by changing the settings on the information terminal, but you may not be able to use part of the service.

2. When acquiring user information, we will properly acquire user information regardless of fake or other illegal means. In addition, when we acquire user information by a method other than acquisition by the user using this service, we will notify or announce the purpose of use beforehand.

3. (purpose of use)

1. The Company, the acquired user information through the use of this service will handle properly within the scope of the following. It will not be used beyond the scope of the purpose of use without your consent.

Usage purpose / Usage purpose / Details Information to be used

Provision, Maintenance, Improvement of this service, etc. / Prevention of identification and prevention of unauthorized use in this service / For smooth provision, maintenance and improvement of this service. To provide this service, to apply. User provided information. Terminal information. Information on log information, action history and service usage status. Cookie and anonymous ID.

Notification, correspondence, etc. to users, etc. / In order to respond to guidance on this service, inquiries etc. / Terms of service regarding this service, change of this policy, suspension suspension of this service ยท cancellation of contract etc. Other important notice about this service etc. For guidance of other services provided by our company. / User provision information.

Third party provision / Third parties who received the information described on the right from the Company will use that information for the following purposes. In order to display advertising information etc. that matches user's needs, interests, interests. For analysis of advertisement effect. For market analysis, marketing. To provide other affiliated services. / Terminal information. Cookie and anonymous ID. Information on log information, action history and service usage status.

2. It may change within a range set forth in the preceding paragraph purposes, observed reasonably to have relevance and purpose of the pre-change, when changing the relative user notification or Services on Or posting on the website operated by the Company or other easy-to-understand methods.

4. (Third party provision)

1. In principle, we will not provide personal information to third parties without the consent of the individual. However, in the following cases, personal information may be provided without your consent, to the extent not contrary to the relevant laws and regulations.

A) Based on laws and ordinances

B) When it is necessary for the protection of human life, body or property, and it is difficult to obtain consent of the person himself / herself

C) When it is particularly necessary for improving public health or promoting the sound development of children and it is difficult to obtain consent of the person himself / herself

D) In cases where it is necessary for a national agency or a local public entity or a person receiving consignment to cooperate in carrying out the affairs prescribed by laws and regulations, by obtaining the consent of the principal, When there is a risk of interfering with

E) In the event that the business including the user's personal information is succeeded due to merger, corporate division, business transfer or other reasons

2. If we provide Personal Data ("Personal Data" as defined in Article 2, Paragraph 6 of the Personal Information Protection Act, the same shall apply hereinafter) based on the consent of the user to the third party, the following We will create and keep a record of matters of

A) You have prior consent from the user

B) Name or name of the third party and matters sufficient to identify the third party concerned

C) the name of the person identified by the personal data and other information sufficient to identify that person

D) Items of the personal data

3. Notwithstanding the provisions of paragraph 1, when we notify the Personal Information Protection Committee, we will notify the third party of the information of the third party provided by the third party in the table You can provide personal data included in the item by e-mail or other means. However, if the user does not wish to offer his / her own personal data to a third party, we will stop offering it to third parties if we tell us according to Article 10.

4. 4 In accordance with the provisions of the preceding paragraph, if we provide personal data to a third party, we will prepare and keep records of the following matters.

A) Date when the relevant personal data was provided

B) Name or name of the third party and matters sufficient to identify the third party concerned

C) the name of the person identified by the personal data and other information sufficient to identify that person

D) Items of the personal data

5. (Consignment of handling of personal information)

The Company may entrust the handling of all or part of the personal information acquired from the user to a third party within the range necessary for achieving the purpose of use. In this case, the Company preliminarily concludes a confidentiality agreement etc. in accordance with this policy with the subcontractor, and also conduct necessary and appropriate supervision so that the outsourcer can properly manage the information I will do.

6. (Information gathering module)

This service may incorporate the following information collection module selected by the Company in order to analyze information on the usage of this service and advertisement effect on services including this service. Along with this, we may provide user information to the provider of the following information collection module. These information collection modules collect user information without including information that identifies individuals, and the collected information is managed based on the privacy policy and other provisions determined by each information collection module provider.

Name: Google Analytics

Provider: Google Inc.

Privacy Policy: http://www.google.com/intl/ja/policies/privacy/

7. (Behavioral targeting advertisement)

1. Our company, targeting advertising by third parties such as the Company or ad delivery business (user needs or interests, says the advertising methods to deliver ads to match the interest.) For the implementation of, this service or affiliated service upon the providing, by utilizing the information collection module is provided for in Article, collect the following information may be stored or utilized.

A) Action history and service usage information (usage history of the service such as the user's needs and interests by storing it, the information that can be subjected to analysis of interest, which do not lead to identify specific individuals It is called.

B) Terminal information

2. The Company, the information collected on the basis of the preceding paragraph, the needs or interests of users, by delivering the best ads that are customized to suit the interest, for the purpose of delivering useful information to the user, a behavioral targeting advertising operators to deliver (hereinafter referred to as "ad delivery business.") to offer.

3. Regarding the handling of each information by the advertisement distribution provider, it is subject to the privacy policy and other conditions specified by the advertisement distribution provider.

8. (Safety management system)

1. The Company, leakage of user information, for the protection of loss or damage prevention and other user information of, of restricting access to personal information file implementation, limited the minimum necessary level of access rights holders, also illegally from outside of the introduction of security software for access prevention, we take necessary and appropriate measures to maintain the security of user information.

2. The Company, the user information management officer a representative director, will conduct the proper management and continuous improvement of user information.

9. (Right to Disclosure / Correction of User concerning Personal Information)

(Hereinafter referred to as the "disclosure, etc.".) Disclosure, correction, deletion or suspension of use of personal information on this service for the measures, etc., refer to the "Guide for the disclosure, such as application for Personal Information" (PDF) Please give me. However, if the Company does not undertake these obligations under the Personal Information Protection Law or other laws, if the same contents are repeated several times without justifiable reasons, or if excessive technical work is required, these procedures You may not be able to do.

10. (Change of this policy)

1. We reviewed the operational situation on the handling of user information as appropriate, and shall endeavor to continuous improvement, if necessary, may be changed at any time this policy.

2. For this policy after the change, and announcements by other easy-to-understand method posted on the web site operated by the service or on the Company. However, when making changes to contents that require legal consent from users, we will obtain the consent of the user separately according to the method specified by the Company.

11. (Contact Us)

Please contact us from the following inquiry form if you have any comments about our company's handling of user information, inquiries concerning the handling of user information, comments on complaints, questions.

COW Inc.

Email: info@cow.tokyo

[July 5, 2017 Temporary translation]