Corporate Privacy Policy (Ver.1.0)

avatarin Inc. (hereinafter referred to as "the Company") has established the following Corporate Privacy Policy (hereinafter referred to as "this Policy") regarding the Company's handling of personal information.The avatarin Service Privacy Policy, which is separately established by the Company, shall apply to personal information that the Company collects in connection with the avatarin service.

Article 1. Purpose of use of personal information

The Company shall acquire and use personal information within the scope necessary to achieve the following purposes of use and the purposes set forth in Article 3. below. The Company shall not use personal information in a manner that may encourage or induce illegal or unjust acts, even within the scope of the purposes.

  1. Purposes of use of personal information concerning business partners, etc.

    1. To contact you regarding negotiations, preparation, and execution of business transactions.
    2. To provide information and guidance regarding the Company’s products and services.
    3. To plan and operate exhibitions, seminars, and other events held or participated in by the Company, and to provide information regarding such events.
    4. To conduct marketing research and analysis regarding the Company’s products and services.
    5. To respond to inquiries.
  2. Purposes of use of personal information concerning applicants and candidates for recruiting employment.

    1. For recruitment selection.
    2. To contact applicants, recommenders, etc. in connection with recruitment selection.
    3. To plan and operate recruitment-related events held or participated in by the Company and to provide information regarding such events.
    4. To contact applicants regarding various procedures for entering the Company.
    5. To conduct surveys and analysis regarding trends in recruitment applications.
    6. To respond to inquiries.

Article 2. Provision of personal information to third parties

The Company shall not provide personal information to third parties except in the following cases.

  1. When the individual concerned has given consent.
  2. When required by law.
  3. When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the person in question.
  4. When providing personal information in connection with entrustment of the handling of personal information.
  5. When providing personal information in connection with the succession of business due to merger, company split, business transfer, or other reasons.
  6. When providing personal information to a joint user in accordance with the provisions of the following article.
  7. In addition to the preceding items, when the provision of personal information is permitted under the Personal Information Protection Law.

Article 3. Joint use with group companies

The Company may share personal information with group companies as follows.

Scope of joint use ANA Group Companies
For details, please click here.
Purpose of use
  1. To provide air transportation services, travel services such as tours and hotels, and other products and services handled by the Company or companies with which it shares information.
  2. To send direct mail, to provide information on products and services, and to conduct questionnaires, etc., by the Company or companies with which it shares information.
  3. To analyze sales and conduct other surveys and research, and to develop new products and services by the Company or companies with which it shares information.
  4. To communicate and hand over to a company in charge in the event of a customer inquiry, application for use, or other request regarding products or services provided by the Company or companies with which it shares information.
  5. To ensure the appropriate and smooth performance of transactions with customers by the Company or companies with which it shares information.
  6. For management and internal administration of the ANA Group
Items of personal information to be shared Name, date of birth, address, telephone number, e-mail address, place of employment, gender, transaction details, etc.
Name, address and representative name of the person responsible for the management of personal information ANA Holdings, Inc.
Shiodome City Center, 1-5-2, Higashi-Shinbashi, Minato-ku, Tokyo 105-7140, Japan
President and CEO
Koji Shibata

Article 4. Outsourcing the handling of personal information

The Company may outsource the handling of personal information within the scope necessary to achieve the purposes specified in Article 1. above. In such cases, the Company shall evaluate and select the outsourcing company in advance based on separately specified standards before outsourcing, and the Company shall also appropriately supervise the outsourcing company.

Article 5. Management of personal information

The Company manage personal information appropriately and take the utmost care to prevent leakage, loss, or damage of personal information. The Company provides in-house training to its directors and employees regarding the protection and appropriate handling of personal information.

Article 6. Request for disclosure, etc.

In accordance with the provisions of the Personal Information Protection Law, the Company shall respond to requests for disclosure, etc., from the person in question as follows.

  1. Notification of Purpose of Use or Disclosure of Personal Information, etc.
    If the person wishes to request the Company to notify the person of the purpose of use or to disclose its personal information or records related to the exchange of personal information, the person may do so in accordance with the Company’s prescribed procedures and within the scope of the law. Please note that when such notification or disclosure is requested, a disclosure fee may be charged in accordance with procedures separately prescribed by the Company.
  2. Correction, addition, and deletion
    If the person believe that the content of its personal information is untrue, the person may request correction, addition, or deletion of its personal information in accordance with the Company's prescribed procedures. In such a case, the Company shall investigate without delay to the extent necessary to achieve the purpose of use, and correct, add, or delete the relevant personal information based on the results of such investigation.
  3. Cessation of Use or Cessation of Provision to Third Parties
    In cases where the Company believes that the use or provision of personal information by the Company is in violation of laws or regulations, or for other reasons stipulated by the Personal Information Protection Law, the person may request that the Company cease using or providing the personal information to a third party in accordance with the Company's prescribed procedures. Upon receiving such a request, the Company shall respond appropriately in accordance with the Personal Information Protection Law.

Article 7. Handling of cookies

The Company’s website uses cookies. A cookie is a small text file containing arbitrary characters that is exchanged between a web server and a visitor's Internet browsing software (browser) and stored on the visitor's device when visiting a website. The Company use cookies to improve its website, analyze usage, deliver advertisements, and conduct marketing. As an example, the Company use Google Analytics to understand how its website is used. Google Analytics uses cookies to collect information about its visitors. For more information, please see this explanation page from Google (external site). Please note that if a visitor chooses not to use cookies, this may limit the functionality available on the Company’s website.

Article 8. Contact for inquiries

Please direct any comments, questions, complaints, or other inquiries regarding the handling of personal information to the following contact.

Address: 5F Nihonbashi IT Building, 3-3-9 Nihonbashi Muromachi, Chuo-ku, Tokyo
Company name: avatarin Inc.
Department in charge: Corporate Department
e-mail: info@avatarin.com

Article 9. Changes to this policy

This policy may be revised from time to time, and the latest version of this policy is always posted on this page. Any significant changes shall be notified in advance by posting a notice on the Company’s website or by other appropriate means.

The English version of this Privacy Policy is a translation from the Japanese original.

Ver. 1.0 enacted on June 13, 2023

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