アソビュー株式会社

Personal Information Protection Policy

Asoview, Inc. (the “Company”) recognizes the importance of properly processing personal information as an enterprise that contributes to society, sets forth this personal information protection policy, and ensures that its officers and employees comply with the policy, thereby making its endeavors to protect personal information and the rights and interests of individuals.

1. When collecting personal information, the Company shall specify the purpose of use as much as possible and collect personal information to the extent necessary to achieve such purpose.
2. In the event personal information is collected directly from the individual in writing, the Company name, personal information protection manager, contact information, purpose of use, etc., shall be notified and personal information shall be collected to the extent required.
3. The use of personal information shall be within the scope of the purpose of use for which the individual has given his or her consent. In addition, we will establish and implement procedures to take necessary measures to prevent use for purposes other than the intended purposes.
4. The retained personal information shall be appropriately managed and shall not be provided to any third party without the consent of the individual.
5. The retained personal information shall be managed accurately and in an up-to-date manner to the extent necessary for the purpose, and reasonable security measures shall be taken to prevent and correct any leakage, loss, or damage to the personal information.
6. In the event the Company subcontracts the processing of the personal information to a third party, the contractual obligation to not leak or provide personal information to a third party shall be imposed, and appropriate management shall be implemented with respect to the third party.
7. Complaints and inquiries regarding the personal information shall be handled by contacting Company’s inquiry counter.
8. The Company will comply with laws and regulations concerning the processing of personal information, guidelines, and other government’s standards.
9. The Company has established a management system for the protection of personal information, and will periodically review and continually improve the system.

Asoview, Inc.
Representative Director and President Tomohisa Yamano
Date of enactment: September 1, 2015
Date of final revision:September 25,2019

Please contact the following for any inquiries concerning the personal information protection policy:
Personal Information Inquiries Counter
Asoview, Inc.
3F, JIK Building, Jingu-mae 2-7-7, Shibuya-ku, Tokyo, Japan
Postal Code 150-0001
TEL: 050-2018-8080
Email: info@asoview.co.jp

Processing of Personal Information

In collecting personal information, the Company specifies the following:

(a)   Company Name: Asoview, Inc.
(b)   Title, affiliation, and Contact Information of the Administrator in Charge of Personal Information Protection
Personal Information Inquiries Counter
orporate Department
Asoview, Inc.
3F, JIK Building, Jingu-mae 2-7-7, Shibuya-ku, Tokyo, Japan
Postal Code 150-0001
TEL: 050-2018-8080
Email: info@asoview.co.jp

(c)   Purpose of Use

1. Collection in Writing Directly

a. Personal Information of Users of the Company’s services (the “Users”)

Personal information of Users includes name, address, date of birth, phone number, email address, gender, photographic data.

1. Answer or response to any questions, opinions, or inquiries about the Company or the Company’s services
2. Operation of systems for User management required for the use of the Company’s services, such as authentication of the User at the time of login and after login, display of User information on various screens, etc.
3. Communication concerning reservation for activity programs, ticket purchases, and inquiries from the User (transmission of reservation applications, ticket purchases, and inquiries to the Business Operator, transmission of responses from the Business Operator to the Users, confirmation of usage records, and other communications required for the provision of the Company’s services)
4. Delivery of gift vouchers and other items, confirmation of usage records related to gift vouchers, preparation of statistical and marketing materials related to use of gift vouchers and other items
5. Notice required for the operation of the Company’s services, such as maintenance information and important communications related to the Company’s services
6. Sending e-mail magazines or newsletters, displaying advertisements, and mailing direct mails that the Company considers helpful to Users
7. Campaigns, lotteries, prizes, etc., and delivery of prizes, etc., as well as communication related thereto to applicants
8. Conducting questionnaires related to the Company’s services
9. Analyzing data required to improve the Company’s services and develop new services
10. Promoting the use of the Company’s services, explaining and introducing the Company’s services, etc.

b.Personal Information of Business Operator Posting Activity Information or Ticket Information (the “Business Operator”)

1. Introduction of Business Operator and activity programs through the Company’s services
2. Answer or response to any questions, opinions, or inquiries about the Company or the Company’s services
3. System operation for managing Business Operator required for the use of the Company services, such as authentication at the time of log in to the reservation management system (satsuki), ticket management system (asoview! ticket management system) (collectively, the “Management System”), authentication after login, and display of Business Operator information on various screens.
4. Communication regarding reservation for activity programs, ticket purchases, and inquiries (transmission of reservation applications and inquiries to Business Operators, confirmation of usage records, and other communications required for provision of the Company’s services)
5. Notice required for the operation of the Company’s services, such as maintenance information and important communications related to the Company’s services
6. Sending e-mail magazines or newsletters that the Company considers helpful to Business Operators
7. Providing information related to new services, new features, campaigns, etc.
8. Conducting questionnaires related to the Company’s services
9. Analyzing data required to improve the Company’s services and develop new services
10. Promoting the use of the Company’s services, explaining and introducing the Company’s services, etc.

c. Personal Information of Customer

Responding to inquiries

d.Personal Information of Applicants for Job Posts

Managing recruitment selection and sending the results of the recruitment selection

e.Personal Information of the Company’s Employees.

Personnel and labor management and fringe benefits

f. Personal Information of Business Partners

Managing business partners and performing duty of the contracts with business partners

2.Collection through a Method Other Than Those Directly Collected in Writing

The Company may collect personal information of Users, such as name, address, date of birth, phone number, email address, gender, through third parties, including travel agencies, online travel agencies, alliance partners of the Service. The purpose of using personal information is same as stipulated in this section 1. a.

(d) Provision of Personal Information to a Third Party

• Items of Personal Information

Communication regarding reservations for activity programs, ticket purchases, and inquiries (transmission of reservation applications, ticket purchases, and inquiries to the third parties stipulated in (4) below, transmission of messages and responses concerning activity program or ticket from the Business Operator to the Users, confirmation of usage records, and other communications required for the provision of the Company’s services)
Publication of the Company services or activity programs in media managed, operated, published, broadcasted, or distributed by the Company or a third party, confirmation of advertising effectiveness

• Items of Personal Information
  User registration information, information regarding reservation for activity program, ticket purchase information, or photo data
• Means or Methods
  Management System, email, or posting on web pages
• Type and Attributes of Organization to Which Information is Provided
  Business Operators, travel agencies using the Service or having a business partnership with Company, tourism associations, and companies providing accommodation services, transportation services, or internet media services and other media services

(e)Subcontracting of the Processing of Personal Information

The Company may subcontract the processing of all or part of the collected personal information.

(f)Request for Disclosure, etc. of Personal Information

1. In the event the data subject requested the Company to notify the purpose of use, disclose, correct, add or delete the contents, discontinue, erase, or discontinue provision to a third party (“Disclosure, etc.”), the Company will conduct a survey on the personal information and will respond without undue delay; provided, however, depending on the details of the request, the data subject may not be able to request Disclosure, etc.. In such a case, the Company will notify the data subject of the reason.
2. If the data subject requests a Disclosure, etc., the data subject shall send the request by mail according to the procedures below. The request may not be accepted if there are any deficiencies in the contents of the request. Note, however, that the data subject shall pay 1,000 yen per request for disclosure of personal information or notification of the purpose of use via wire transfer.(the remittance fee shall be borne by the data subject).
3. Personal information provided for Disclosure, etc. shall be used in response to inquiries and shall not be used for any other purpose.

※Please contact the following for any inquiries regarding the Disclosure, etc.:

Personal Information Inquiries Counter
Administrator in Charge of Personal Information Protection
Corporate Department
ASOVIEW Inc.
3F JIK Building, Jingu-mae 2-7-7, Shibuya-ku, Tokyo, Japan
Postal Code 150-0001　TEL: 050-2018-8080
Email: info@asoview.co.jp

※Data subject may request a settlement of a complaint in relation to processing of his/her personal information with JIPDEC (the authorized personal information protection organization set out in Japanese Personal Information Protection Act).
Contact information is the following:
Inquiry Counter for Settlement of a Complaint
JIPDEC
Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo, Japan
Postal Code 106-0032
TEL: 03-5860-7565 / 0120-700-779
*Please note that the contact above is not the inquiry counter for the Company’s products and services

(g) Voluntary Provision of Personal Information
The provision of personal information is optional. If the data subject does not provide his/her personal information, the Company will not be able to provide all or part of the services, which requires such personal information.

(h)Collection of Website Usage Data by Cookie
The Company uses cookie and collects website usage data to authenticate individuals, improve the services, distribute advertisements, analyze accesses, and obtain statistical data. In connection with these, the Company may use the following third party services. Cookie and website usage data collected by such third party shall be handled in accordance with the privacy policy of such third party. Users can access the opt-out pages located on the third party’s website and opt-out the use of cookie and website usage data by the third party. Users agree that, if Users opt-out the use of cookie information, all or part of the services may become unavailable

These special provisions shall apply to processing of personal data of Users in the EEA in accordance with the General Data Protection Regulation (GEPR).

1. Legal Bases for Processing

The Company processes personal data of Users based on the following legal bases:

• When processing is required for the performance of contractual obligations to provide services to Users;
• When processing is required for the pursuit of legitimate interest (such legitimate interests will include where Company improves its services, promotes the use of its services, or provide the personal data with third parties set forth in (d) above);
• When processing is required for compliance with legal obligations (including where the Company is required to retain business records for fixed periods of time to comply with legal requirements);
• When Users’ express consent is obtained in advance.

Each User has the right to withdraw his/her consent at any time by notifying aforementioned Personal Information Inquiries Counter designated by the Company.

The company does not conduct any solely data-based, automated decision-making that produces any legal or similar material effect on Users.

2. Transfer of Personal Data from the EEA to Third Countries

The Company will transfer the personal data from the EEA to Japan on the basis of the adequacy decision.

3. Retention Period for Personal Data

The Company will retain the personal data for as long as necessary to fulfill the aforementioned purposes for processing the personal data. Specific retention periods are decided based on the following considerations: the purpose of processing the personal data; the nature of the personal data; and the necessity of retaining the personal data for legal or business reasons.

4. Users’ Rights

Users have the following rights regarding the personal data processed by the Company:

• Obtaining information regarding processing of data
• Access to personal data;
• Rectification or erasure of personal data;
• Restriction on processing of personal data;
• Objection to processing of personal data;
• Data portability of personal data;
• Not to be subject to automated decision-making.

If Users intend to exercise any of the aforementioned rights, please contact aforementioned Personal Information Inquiries Counter designated by the Company.

Users may lodge a complaint in relation to processing of the personal data with the Data Protection Supervisory Authority of the Member State of users’ habitual residence, place of work or place of the alleged infringement.