Astool Inc. (hereinafter referred to as the “Company”) recognizes the importance of Personal Information and User activity data in this modern society. We thereby enact our privacy policy (hereinafter referred to as the“Policy”) and strive to ensure privacy within the various services (hereinafter referred to as the “Service”) we provide.
Definition of Terms
Personal Information
- “Personal Information” in the Policy means that information relating to a living individual which falls under any of each of the following items:
- those containing a name, date of birth, or other descriptions etc. (meaning any and all matters (excluding an individual identification code (an “Individual Identification Code”) as defined in the Act on the Protection of Personal Information (hereinafter referred to as the “Act”)) stated, recorded or otherwise expressed using voice, movement or other methods in a document, drawing or electromagnetic record whereby a specific individual can be identified (including those which can be readily collated with other information and thereby identify a specific individual); and,
- those containing an Individual Identification Code
User activity data
- “User activity data” is defined in this Policy as accumulated data which do not identify a specific individual and is used for the purpose of analysis of the user’s services, advertising history, history of activities within this service, and interests/preferences. “User activity data” is stored, collected, and analyzed by the Company in a form that is anonymous and is used for the purposes of improving the functionality of the service, developing the service, and providing statistical reports.
- However, when incorporated properly with other information, it may distinguish certain individuals, and thus, User activity data will be considered and handled as the Personal Information for the purpose of this Policy.
Acquisition of Personal Information
The Company will obtain information through lawful and fair means and save the data on the server securely.
Use of Personal Information
The Company will only utilize Personal Information for the following business purposes.
- To resolve technical problems
- To respond to customer inquiries about the Service
- To deliver the most optimal information for each individual user
- To carry out surveys regarding the Service
- To inform the users about the Company’s new campaigns and products
- For other purposes related to the criteria mentioned above
Management of Personal Information
- The Company maintains the accuracy and safety of Personal Information.
- The Company will take proper security measures in order to prevent loss, destruction, manipulation or breach of Personal Information.
- The Company thoroughly educates the employees and maintains the operating system to manage Personal Information appropriately. Additionally, the Company will take any precautions to prevent loss, destruction, manipulation or breach of Personal Information.
- When a user’s account has been terminated for whatever reason, Personal Information will be completely deleted from the database.
- When a user terminates the Service, all Personal Information will be deleted.
Claims to Utilize, Disclose, Correct and Suspend Personal Information
When a user requests to disclose, correct, add, delete, or suspend the relay to third parties of Personal Information, the Company will first confirm the identity of the user and then immediately take measures in accordance with the regulations of the Act. However, if the request does not meet the requirements of the Act or other laws and regulations, the Company will be blocked from following through with the request. Additionally, there are no fees for making such requests to the Company. Nevertheless, the Company is not responsible for the telephone charges, transportation costs, and the expenses for the preparation of certain documents and data. Therefore, the user must bear all the above expenses.
Entrustment of Personal Information to Third Parties
With the exceptions permitted by law, the Company will not relay Personal Information to any third party without the consensus of the user. The Company may access users’ Personal Information and disclose it to third parties for the following cases.
- When there is a consent from the user
- When the law, judicial court, or administrative agencies require the disclosure of Personal Information for regulatory reasons
- When it is reasonably necessary to protect, and defend the Company’s rights or property
- When it is required to protect the lives and property of the Company, users, and other common people and obtaining the approval of the users is problematic
- When the Company needs to cooperate with local government and agencies to promote positive externalities specified by the law, such as public health and child education, and acquiring the consent of the user is difficult
- When Information, such as statistical data, that cannot be used to identify individuals are disclosed
Entrustment of Personal Information to Third Parties
With the exceptions permitted by law, the Company will not relay Personal Information to any third party without the consensus of the user. The Company may access users’ Personal Information and disclose it to third parties for the following cases.
- When there is a consent from the user
- When the Law, judicial court, or administrative agencies require the disclosure of personal information for regulatory reasons
- When it is reasonably necessary to protect, and defend the Company’s rights or property
- When it is required to protect the lives and property of the Company, users, and other common people and obtaining the approval of the users is problematic
- When the Company needs to cooperate with local government and agencies to promote positive externalities specified by the law, such as public health and child education, and acquiring the consent of the user is difficult
Usage of User activity data
The company shall use User activity data only for the following purposes, as necessary for the execution of business duties.
- Analysis of user characteristics and activity
- Displaying content, etc., relevant to the user’s characteristics and activity
- Measuring the effectiveness of the company’s service/features
- Development of the company’s service/features
- Providing the results of analysis to third parties
Provision of User activity data to third parties
The Company may relay User activity data to third parties. In such cases, the Company shall require that the third party agree to a contract including a non-disclosure agreement or to a protocol established by the company and shall practice necessary and appropriate oversight.
At present, the third parties receiving User activity data from this company are as follows.
About Cookies
The Service and some portion of the Company’s advertisement system utilizes Cookies. Cookies are a technology that stores information exchanged between the browser and the server on the user’s device. The user may choose to disable Cookies on the browser but it may affect the service of each website.
Disclosure of Information Regarding Premium Members
Users who have registered as premium members and use paid services in relation to the Service consent to the disclosure of Personal Information to credit card companies or other service providers provided that it is deemed necessary by the Company for the purpose of determining, collecting and securing the payment of debt owed to it by the users. Such users further consent to a consignee who is cosigned services by the Company managing credit card information and other payment related information for the purpose of issuing invoices for paid service fees.
Revision of the Privacy Policy
The Company constantly reviews the status of Personal Information management and always strives to improve it. The Policy may be modified, if necessary, and the updated Privacy Policy will be frequently updated on the Company’s website.
Contact
Please contact info@smoozapp.com for inquiries concerning the handling of Personal Information.
February 2nd, 2020
Astool Inc.