Pocket Change

The protection of personal information is recognized as being of great importance to Pocket Change Inc. (“our Company” and “we”). With respect to the services provided by us on kiosk terminals (information terminals) installed at airports and facilities, etc. and Pocket Pay Money issued by our Company, we pay close attention to the collection and handling of personal information of individuals and corporations (the “Users”) who use the services provided or managed by our Company (the “Services”), in accordance with the Act on the Protection of Personal Information (the “Personal Information Protection Act”) ,other applicable laws and regulations, the guidelines established by the Personal Information Protection Commission etc. and the following privacy policy of our Company ( “this Privacy Policy”).

Except when the definitions are specifically stipulated in this Privacy Policy, the definitions of the terms herein are based on the Personal Information Protection Act and applicable laws and regulations.

What is Personal Information?


In the Services, “Personal Information” means information that identifies a living individual User, such as name, address, telephone number, email address, credit card number and bank account number (including information that can be easily combined with other information and thereby enables one to identify a specific individual).

Collection and Use of Personal Information


In the Services, in using the Services the User may be required to register Personal Information. The Personal Information that the User registers is used for the purpose of use specified in the Terms of Use or for the following purposes, and the information shall be strictly managed.

1. To provide, manage and operate the Services;
2. To make necessary contact with the User for him/her to use the Services;
3. To aggregate and analyze the attributes of the User, and to collect, create and send statistical data processed so that individuals cannot be identified and specified in order to manage the Services or develop new services, etc.;
4. To provide telephone verification services for the purpose of improving reliability;
5. To use the registered information on external services such as SNS in the Services or to provide information to such external service if the User consents to connect such external services with the Services upon use;
6. To provide information and advertising related to the Services and such services provided by our Company’s business partners, by email or other means;
7. To reply to inquiries;
8. To conduct media coverage of the Users;
9. To troubleshoot Service operations;
10. To prepare and perform any contracts if the User and our Company become parties to a contract on the Services;
11. To comply with legal obligations that our Company should comply with in regards to the Services;
12. To protect important interests of the User’s life, health and property, etc.;
13. To respond to the exercise of the authority with regard to the Services which is granted to third parties by laws and regulations, or to protect public interest;
14. For other purposes for which the User’s consent has been obtained; and
15. In addition to the preceding items, for the purposes permitted by the Act on the Protection of Personal Information.

If it is necessary to use the information for purposes that are not set out above, we will contact you to that effect beforehand.

Provision of Personal Information to Third Parties


Our Company will not provide Personal Information to third parties without obtaining the advance consent of the User, except under laws and regulations or as provided below.

1. It is necessary for the protection of any person’s life, body or property and in which it is difficult to obtain the consent of the person;
2. It is specially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person;
3. It is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned;
4. If the content, usage history and profile information are displayed on the Services based on the conditions stipulated by our Company;
5. If providing Personal Information to a person succeeding the business as a result of business succession due to merger, company split, business transfer or other reason;
6. If the User is a minor and a request for disclosure is made by a parent or legal representative, or if the User is an adult ward and a guardian of the adult has requested disclosure;
7. If our Company determines that disclosure is necessary to resolve trouble with the Users or third parties;
8. If using for the improvement of the quality of the Services, and for consideration, investigation, research and analysis of new services; or
9. For other necessary purposes to properly operate the Services.

Entrustment regarding Personal Information


We may entrust the handling of Personal Information of the User to a company, within the range necessary for achieving purpose of use, to facilitate operations and provide good service to our customers. In such case, in addition to thoroughly examining the eligibility as a trustee, and at the time of entrusting, we will create a system to properly manage information in which matters concerning confidentiality obligations are specified.

Joint Use of Personal Data


We may jointly use the Personal Information provided by the User with our Company’s group companies, affiliated stores, our Company’s platform users and service users in accordance with the following:

1. Personal Information to be used jointly: Name, address, telephone number, email address, age and purchase history;
2. Purpose of use of our Company’s group companies, affiliated stores, and our Company’s platform users and service users: As described in “Collection and Use of Personal Information” and
3. Name of person responsible for the management of Personal Information: Pocket Change Inc.

Disclaimer relating to Third Parties Obtaining Personal Information


Our Company is not responsible with respect to obtainment of Personal Information by a third party in the following cases:

1. If the User reveals Personal Information to a third party using the functions of the Services or by other means;
2. If Personal Information is provided by a User when using an external site linked to the Services; and
3. If a person other than the User obtains information (ID, password, etc.) that can identify the User as an individual.

Use of Statistically Processed Data


Based on Personal Information received, our Company may create statistical data processed so as to not identify individuals. Our Company shall be able to use without any restrictions such statistical data that cannot identify individuals.

Management of Personal Information


1. Our Company endeavors to accurately process the data of the provided Personal Information. However, the User is responsible for the fact that the content of the provided Personal Information is accurate and up to date.
2. Our Company will take necessary and appropriate measures for the prevention of any leakage, loss or damage of the provided Personal Information and other security management.
3. Our Company shall conduct appropriate training to employees on the proper handling of Personal Information, and conduct necessary and appropriate supervision in handling the provided Personal Information.
4. When we entrust the handling of Personal Information, our Company shall select as a trustee a company that is taking appropriate security control measures, and we shall perform necessary and appropriate oversight of the contractors.

Receiving Requests for Correction, etc. of Personal Information


1. If there is a request by a User for the correction, addition or deletion of Personal Information (the “Correction, etc.”), after verifying that the request is from the User himself or herself, our Company shall investigate without delay to the extent necessary for achieving the purpose of use, and will take appropriate measures based on the results. However, if the Company does not have the obligation of the Correction, etc. under the Act on the Protection of Personal Information and other laws and regulations, this shall not be the case.
2. If there is a request by a User for the suspension or deletion of use of Personal Information (the “Suspension of Use, etc.”), after verifying that the request is from the User himself or herself, our Company shall take appropriate measures if it turns out that there is a reason in compliance. However, if the Company does not have the obligation of the Suspension of Use, etc. under the Act on the Protection of Personal Information and other laws and regulations, this shall not be the case.
3. In the case of making requests of the two preceding paragraphs, please contact the person in “Inquiries” below.

Information on Minors


If a User is a minor and shall enter Personal Information, it is necessary that parents, legal guardian or guardian consent to the contents of this Privacy Policy and the Terms of Use, etc., and give consent comprehensively that the User will use the Services pursuant to this Privacy Policy and the Terms of Use, etc.

Cookies


1. It is not possible to identify a specific individual with cookie information alone. In the case where cookies are used together with Personal Information, then it shall be regarded as Personal Information.
2. Our Company automatically receives information on the User’s cookies, advertising and pages that were viewed, and the usage environment, etc. of the User from the User’s browser, and records it on servers to use for the login management of the Services, investigation of traffic and to improve the Services.

Logs


In the Services, the operation information and access information of the User are recorded as a log. The recorded information includes the operation log, the IP address of the person who gained access, OS and other information of the terminal used, access dates and times; however, it is not used for the purpose of identifying individuals. The operation logs and access logs are used to manage and analyze the usage of the Services.

Changes to this Privacy Policy


We will review the operational status regarding the handling of Personal Information as appropriate, and we may change this Privacy Policy from time to time for continuous improvement of our Services.

Inquiries


For any inquiries regarding this Privacy Policy, please contact our staff below.

To: Person in Charge of Personal Information Protection, Pocket Change Inc.
First Okada Bldg. 3F 4-3-5 Shiba, Minato-ku, Tokyo, 108-0014

Date of Last Revision: July 31, 2019.

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