Privacy Policy - avatarin Inc.

avatarin Inc. （the “Company”）sets forth this Privacy Policy （this “Policy”）with respect to the handling of personal information that the Company acquires in connection with the Service （*1）. The meanings of the terms used in this Policy shall be in accordance with the Act on the Protection of Personal Information （the “APPI”）.

1.Items of Personal Information Acquired

The Company will acquire mainly the following types of personal information in connection with the Service.

Information of the Users of the Service
1. Registered information such as name, address, date of birth, email address, and telephone number
2. Information concerning online activity history such as the browsing history of websites and information such as the usage status of apps
3. Information concerning the usage status of the Services such as reservation information and purchasing information
4. Information such as images, video, audio and operating history （*4） that is collected from the Avatar （*2） and other devices when using the Open Service （*1）
5. Information concerning feedback from users such as review information and comments （*5）
6. Information collected in connection with inquiries and consultations
Information of Employees of and Persons Related to the Outside Service Provider （*3）
1. Information of the person in charge such as name, address, and telephone number
2. Information concerning online activity history such as the browsing history of websites and information such as the usage status of apps
3. Information concerning the cast such as guides for distributing interactive videos and persons in charge of customer service for product sales
4. Information such as images, video, audio and operating history （*4） that is collected from the Avatar and other devices when using the Open Service
5. Information collected in connection with inquiries and consultations
Information of Others
1. Information such as images, video, audio and operating history （*4） that is collected from the Avatar and other devices when using the Open Service
2. Information collected in connection with inquiries and consultations

2.Purpose of Use

The Company will use the acquired personal information to the extent of the purposes of use provided below.

Use for the provision of the Service
1. For accepting applications and registration of the Service
2. For managing information that is registered
3. For authenticating the Users, Etc. （*6） who will use the Service
4. For contacting the Users, Etc. in connection with the Service
5. For providing information on the services of the Outside Service Provider
6. For supporting the use of the services of the Outside Service Provider by the users
7. For supporting the provision of services by the Outside Service Provider
8. For supporting transactions between the Outside Service Provider and the users
9. For maintaining, managing, and improving the Service, etc.
Use for planning, development, research, etc.
1. For planning, research, development, etc. in connection with the products and services of the Company and other companies
2. For research and development concerning robots such as the Avatar and other relevant products, etc.
Use for marketing
1. For considering and implementing marketing policies for the products and services of the Company and other companies
2. For promoting, operating, and managing various events and campaigns regarding the products and services of the Company and other companies and providing various related information
3. For analyzing, etc. a user’s interests, concerns, etc. by using the user’s attribute information, usage status of the Service (including transaction history with the Outside Service Provider and information collected from the Avatar such as images, videos, audio and operation history), activities history information including website browsing history, and usage status of apps
4. For distributing, etc. advertisements concerning the products and services of the Company and other companies based on the analysis, etc. in ③ above
Use for responding to inquiries and consultations

When the Company uses personal information beyond the scope necessary for achieving the above purposes of use, the Company shall, unless otherwise permitted by the laws and regulations, obtain the data subject’s consent in advance.

3.Provision to Third Parties

The Company will not provide the personal information handled by the Company to third parties （*7） without obtaining the data subject’s consent in advance, except in the below cases:
1. If it is based on the laws and regulations;
2. If it is necessary for the protection of a person’s life, body or property and obtaining the data subject’s consent is difficult;
3. If it is particularly necessary for the improvement of public health or the promotion of the sound development of children, and obtaining the data subject’s consent is difficult;
4. If it is necessary to cooperate with the performance of business set forth in the laws and regulations by a government agency, local public agency or a person commissioned thereby, and there is the likelihood that obtaining the data subject’s consent will interfere with the performance of such business; or
5. Other than the above, if permitted by the laws and regulations.
Notwithstanding (1) above, there may be instances where the Company will provide the personal information of those who have consented to the Policy to third parties. The Company will conclude with such third party an agreement containing the prohibition of the disclosure or publicization of various data acquired by such third party unless otherwise permitted by the laws and regulations.
1. Provision to an Outside Service Provider （*3）
  If the users reserve, purchase, etc. the services of the Outside Service Provider, the Company will provide registered information such as the users’ name, etc., information concerning reservations, purchases, etc. and other information to such Outside Service Provider. There may also be instances where, in addition to the Users, Etc.’s (*6) usage status of the Service, website browsing history, and usage status of apps, the Company will provide the various data (including data such as images, videos, and audio filmed or recorded by the Avatar and data such as the operational history of the Avatar, and data obtained by analysis and analytics of such data) collected through the Avatar (*2) during the use of the Open Service (*1) to the Outside Service Provider. The Outside Service Provider will use the acquired information for purposes of providing information on the products and services of the Outside Service Provider to users and purposes of improving, planning, researching, developing, etc. the products and services of the Outside Service Provider, in addition to the purposes of providing the services reserved and purchased by the users.
2. Provision to the Company’s Joint Researchers
  There may be instances where the Company will provide the various data collected through the Avatar (*2) during the use of the Open Service (*1) upon performing proper processing that takes into consideration the privacy of the data subjects as necessary to the Company’s joint researchers. The various data that will be provided will contain data such as images, videos, and audio filmed or recorded by the Avatar and data such as the operational history of the Avatar, and data obtained by analysis and analytics of such data, but will not contain the registered information of the users such as their names. The joint researchers will use the acquired information for the purposes of joint research or development with the Company.

4.Management of Personal Information

The Company will properly manage the personal information and will take security control measures necessary for the prevention of the leakage, loss, damage, etc. of personal information. The Company will conduct company training for the officers and employees regarding the protection and proper handling of personal information. In addition, unless there are other specific grounds, personal information that is no longer used will be deleted within a reasonable period.
If the data subject would like to know about the security control measures taken by the Company, he/she should contact us using the contact information set forth in "8. Contact for Inquiries".

5.Outsourcing

There may be instances where the Company will outsource the services concerning the handling of personal information to the extent necessary to achieve the purpose of use set forth in 2. above. In such instances, the Company will perform the outsourcing upon evaluating and selecting the outsourcing service provider in advance, based on standards that are separately set forth, and properly supervise the outsourcing service provider.

6.Requests for Disclosure, etc.

The Company will respond to requests for the disclosure, etc. from the data subject as follows, in accordance with the APPI:

Notification of purpose of use or disclosure of personal information, etc.
If the data subject requests the Company for a notification of the purpose of use or the disclosure of personal information or records of providing or receiving personal information, the data subject may make a request to the extent of the laws and regulations in accordance with the method designated by the Company.
If such notification or disclosure is requested, there may be instances where disclosure fees will be incurred pursuant to the procedures separately set forth by the Company.
Revision, addition, and deletion
If the data subject believes that the contents of the personal information are not true, the data subject may request the revision, addition, or deletion of personal information in accordance with the method designated by the Company. In such instance, the Company will conduct an investigation without delay to the extent necessary for achieving the purpose of use, and will make revisions, additions or deletions to such personal information based on the results thereof.
Suspension of use or suspension of third party provision
If there is a reason stipulated by the APPI such as the use or provision of the personal information by the Company violates the laws and regulations, the data subject may request the suspension of use or suspension of provision to third parties of the personal information in accordance with the method designated by the Company. If there is a request, the Company will properly respond in accordance with the APPI.

7.Handling of Cookies

Cookies
The Company’s website uses cookies. Cookies mean small text files on which words are written voluntarily, and are exchanged between the web server and the viewer’s web-browsing software （browser） and saved on the viewer’s device when browsing the website. In addition to using cookies for providing functions necessary for the Service, such as the users’ log-in management, the Company will use cookies for improving and analyzing the website and app, implementing the marketing described in 2. above, etc. As an example, the Company uses Google Analytics for understanding the usage status of the website, and Google Analytics collects information of viewers by using cookies. Please take a look at Google’s website for details.

Google site（external site）

If the viewer’s settings do not use cookies, please understand that there is a possibility that the functions that can be used on the website may be restricted.
Information gathering module
There may be instances where the Company is using information gathering modules such as SDKs provided by other companies to optimally use the Service when using the App. In addition to using the information gathering module for providing functions necessary for the service, the Company will use the information gathering module for improving and analyzing the website and app, implementing the marketing described in 2. above, etc.

8.Contact for Inquiries

Please send your opinions, questions, complains and other inquiries concerning the handling of personal information to the below:

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

9.Changes to this Policy

This Policy may be revised from time to time, and the latest Policy will always be posted on this page. Announcements will be made by an appropriate method, such as by advance notifications within the Service, when material changes will be made.

【End Notes】

The “Service” is the service using the Avatar (*2) that is provided by the Company with the name “avatarin.” Other than on the avatarin website（https://avatarin.com）operated by the Company, the Service will be provided through various apps, etc. Users can use the services such as interactive video service provided by the Outside Service Provider (*3) in the Service. The Service contains the following two types of services:

Open Service	Users can use the services that the Outside Service Provider provides to the general public.
Closed Service	Only users who have been authorized to participate in advance by the Outside Service Provider can use the services of such Outside Service Provider.

“Avatar” means the remote-controlled robot “Avatar” used in the Service, and, in addition to “newme,” includes robots that will be sold in the future.
The “Outside Service Provider” means a business provider other than the Company that provides services such as interactive video service in the Service.
During the use of the Closed Service （*1）, the Company will not acquire such information without separately obtaining the data subject’s consent.
Please be advised that review information, comments, etc. that the users write in the Service will be made available to the public. Such information will continue to be made public even after the termination of the use of the Service by the users.
The “Users, Etc.” means, in addition to the users of the Service, the employees of and persons related to the Outside Service Provider.
The provision of personal information to joint users and outsourcing service providers pursuant to the APPI, or the provision of personal information in connection with a business succession is not considered a provision of personal information to third parties.

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

Ver1.1.1 enacted on 15th July 2021.
Ver.1.2.1 enacted on 25th November 2022.