JANKEN Privacy Policy

This privacy policy (hereinafter referred to as the "Policy") outlines how JANKEN (hereinafter referred to as "the Site") handles user information, including personal information, when providing services (hereinafter referred to as "the Service").

Collected User Information and Collection Methods

In this Policy, "User Information" refers to information that identifies users, activity history within the Service, and other information generated or stored on the user’s device that is collected by the Site according to this Policy. The user information collected by the Site through the Service is as follows:

Information Provided Directly by Users

Information that users provide when using the Service or through the Service includes the following:

• Profile information such as name, date of birth, and gender
• Payment information such as credit card details, bank account information, or electronic money details
• Information for creditworthiness assessment, including income, debt, repayment status of other loans, occupation, employer, family composition, living situation, and purpose of transactions
• Information submitted via input forms or other methods designated by the Site

Information Provided Through External Services Linked by Users

If users permit linking with external services (such as social networking services) when using the Service, the following information may be collected based on the consent granted during linkage:

• Profile information such as name, date of birth, and gender
• Contact details including email address, phone number, and address
• Creditworthiness assessment information as described above
• IDs used on the external service
• Usage information of the external service
• Any other information disclosed by the user through privacy settings on the external service

Information Automatically Collected During Service Use

The Site may collect information regarding access and usage patterns of the Service, including:

• Referrer URLs
• IP address
• Server access logs
• Identifiers such as cookies, ADID, or IDFA

Purpose of Use

• For registration, identity verification, user authentication, management of user settings, payment processing, and providing, maintaining, protecting, and improving the Service
• For developing new products, features, or services related to the Site’s business and conducting market research
• To analyze transaction and activity history, including information obtained from external services, and offer personalized services
• To analyze user data to deliver relevant advertising from the Site or third-party advertisers
• To respond to inquiries and provide notifications related to the Service
• To take appropriate action for violations of the Site’s terms and conditions
• To notify users of changes to the Site’s policies or terms
• For other purposes related to the above

The Site does not collect or use sensitive personal information unless required by law.

How to Request Suspension of Use

Users can request to stop the collection or use of all or part of their user information through the designated settings within the Service. Upon receiving such a request, the Site will promptly suspend the use of the information as specified. However, in some cases where collection or use is necessary for the Service, suspension will occur only upon withdrawal from the Service following the Site’s procedures.

Provision to Third Parties

The Site will not provide user information, including personal information as defined by Japan’s Personal Information Protection Law, to third parties (including those outside Japan) without the user's prior consent. However, exceptions include cases where provision is necessary:

• When delegating the handling of personal information to third parties within the scope necessary for achieving the purpose of use
• When transferring information due to mergers or other business succession
• When cooperation with national or local government authorities is required by law, and obtaining consent could hinder the execution of relevant duties
• When otherwise permitted by the Personal Information Protection Law or other applicable laws

Disclosure of Personal Information

In accordance with the Personal Information Protection Law, the Site will disclose personal information upon request from the user, after confirming that the request is made by the individual concerned. The disclosure will be provided without delay (if the personal information does not exist, the Site will notify the user accordingly). However, if the Site is not legally obligated to disclose such information under applicable laws and regulations, this obligation does not apply. Please note that the Site may charge a fee for processing such disclosure requests in accordance with the procedures separately established by the Site.

Correction and Suspension of Use of Personal Information

• If a user requests (1) correction of their personal information on the grounds that it is inaccurate under the Personal Information Protection Law, or (2) suspension of use on the grounds that the information is being used beyond the originally disclosed purpose or was obtained through improper means, the Site will verify the request from the user and promptly investigate. Based on the results, necessary actions such as correcting or suspending the use of the information will be taken, and the user will be notified accordingly. If the Site decides not to correct or suspend the information, the user will also be notified.
• If a user requests the deletion of their personal information, and the Site determines that it is necessary to comply, the Site will verify the request and promptly delete the information. The user will be notified upon deletion.
• If the Site is not obligated to correct, delete, or suspend usage under the Personal Information Protection Law or other applicable regulations, the provisions above do not apply.

Shared Use of Personal Information

The Site will share personal information in accordance with Article 27, Paragraph 5, Item 3 of the Personal Information Protection Law. However, if the law prohibits or restricts such shared use, the Site will comply accordingly.

Items of Personal Information for Shared Use

• Name
• Address
• Date of birth
• Contact details (email address, phone number, etc.)
• Credit assessment information such as income, debt, repayment status, occupation, and employer
• Transaction information related to the Site (including user identifiers)
• Other information related to credit assessment and risk management

Purpose of Shared Use

• Development of new products, features, and services for joint users' businesses (including creating new credit models) and conducting market research
• Analyzing user transaction history and behavioral patterns to provide customized services (including developing new credit scores)
• Analyzing user data to deliver targeted advertising from the joint users or third-party advertisers
• Responding to inquiries related to shared services
• Other related business activities of the shared users

Management of Shared Personal Information

JANKEN Personal Information Contact (info@janken-hokkaido.com)

Outsourcing

The Site may outsource the handling of personal information in relation to various business operations, including sales, customer support, equipment maintenance, billing, and marketing. The Site will thoroughly assess the eligibility of third-party contractors. Contracts will specify terms regarding data security, confidentiality, subcontracting conditions, and proper handling of personal information. The Site will also monitor contractors regularly to ensure proper handling of personal information.

Security Management of Personal Information

• The Site takes various safety measures to ensure the accuracy and currency of personal information.
• To prevent unauthorized access, the Site restricts access to personal information to the minimum necessary and implements appropriate security measures.
• The Site strengthens data storage procedures and systems to prevent leakage, tampering, loss, or damage of personal information through proper security measures against unauthorized access and computer viruses.
• The Site limits access rights to departments handling personal information and enforces strict monitoring to ensure third-party contractors follow equivalent security measures.
• Personal information is stored in data centers located in Japan and may also be processed using external cloud services or SaaS platforms located in Japan and the United States. In cases where data is handled outside Japan, the Site takes appropriate safety measures according to local regulations.

Disclaimer

The Site implements the highest level of security measures to protect user data from external threats and attacks. However, personal information is always exposed to potential external threats. The Site does not guarantee complete protection from unauthorized access or other external threats and assumes no responsibility for damages caused by incidents beyond the Site’s control.

Contact Information

For inquiries, feedback, complaints, or questions regarding the handling of user information, please contact:

JANKEN Personal Information Contact (info@janken-hokkaido.com)

Policy Revision Procedure

The Site may update this Policy as necessary. However, any changes requiring user consent under applicable laws will only apply to users who have agreed to the revised Policy through the Site’s designated process. When changes are made, the Site will notify users of the effective date and content of the revised Policy through appropriate means, such as announcements on the website or direct notifications.

Relationship with Other Terms and Conditions

If there is any inconsistency between this Policy and the Site’s other terms and conditions concerning the Service (agreed upon by the user), the terms and conditions of the Service will prevail.

Established: June 1, 2023