PRIVACY POLICY

Handling of Personal Information

1.Name of Business Operator, Title, Department and Contact Information of Personal Information Protection Manager
Vernalossom Co., Ltd. (Hereinafter referred to as “VL”) Personal Information Protection Manager: Administrative personnel (in charge of compliance)
Contact: Omoide Bldg, 6-1-8, Sotokanda, Chiyoda-ku, Tokyo, Japan
Privacy mark promotion division.

2.Purposes of Use
Pursuant to Article 18, paragraph 1 of the Act on the Protection of Personal Information and JIS Q15001, VL (“Vernalossom”) publicly announces that it shall use personal information only to the extent necessary for the following purposes.

・Customer information shall be used to:
1)Explain about products and services handled by VL;
2) Sell VL’s products, provide its services and send its products;
3)Conduct questionnaire surveys with the aim of improving the quality of services handled by VL;
4) Verify the identity of users or identify individuals as needed, to sign in to services for members provided by VL or for other uses;
5)Provide services incidental to or associated with (1) through (4) above or contact customers regarding such services; or
6)Respond to enquiries and requests from customers.
7)Other purposes of use specified separately in our terms of use, etc.
・Information concerning business partners shall be used to:
1)Perform such business operations under a contract between VL and the relevant business partner;
2)Contact business partners concerning business operations;
3)Deliver or receive information or goods; or
4)Introduce personnel of a business partner to another business partner of DH (a third party).
・Inquirer Information
1)Respond to enquiries and requests
If a need to use personal information beyond the extent necessary for the purposes clearly indicated or publicly announced in advance, VL shall use such information with the consent of the person concerning the personal information.

3.Provision to Third Parties
VL shall not disclose or provide personal information of customers to any third parties, unless:
1)The customer has provided consent;
2)Such disclosure or provision is required by law;
3)Such disclosure or provision is necessary to protect the life, body or property of a person, and it is difficult to obtain the customer’s consent; or
4)VL hands over its business due to merger, divestiture, transfer of operations or any other causes.

4.Entrustment
VL may entrust the handling of personal information to an entity only to the extent necessary to achieve relevant purposes.In such case, VL shall sign a non-disclosure agreement as it shall designate as a standard, and shall ensure that personal information will be fully protected.

5.Disposal
Personal information held by VL will be disposed of or deleted in a safe and reliable manner as soon as the purpose of use is achieved, in accordance with our regulations.

6. Notice, disclosure, correction, addition or deletion, discontinuation, erasure, or right to refuse provision of the purpose of using personal information.
A person who has provided his or her personal information to VL may request VL to notify, disclose, correct, add or delete, discontinue the use of, erase, or discontinue the provision to a third party of, the purpose of using such personal information. Details of specified procedures shall be available at the contact point for complaints/consultation and enquiries about personal information described below in 12.
Such request shall only be made by the person himself or herself in principle. Any such request by a person under age may have to be made by his or her parent or guardian depending on the content of the personal information.

If any of the following a), b), or c) applies, information will be disclosed, if d) applies, use will be suspended, and if e) applies, provision to a third party will be suspended. However, in that case, we will notify the person without delay and try to explain the reason.
a)Harm the life, body, property, or other rights or interests of the person or a third party;
b)Impede the proper conduct of business operations by the business operator in a significant manner; or
c)Constitute a violation of laws or regulations.
d)When it costs a lot of money to suspend the use, etc. When it is difficult to suspend the use, etc., and when necessary alternative measures are taken to protect the rights and interests of the person.
e)When it costs a lot of money to stop providing information to a third party, when it is difficult to stop providing to other third parties, and it is necessary to protect the rights and interests of the person by undertaking appropriate measures.

7.Voluntary provision
Provision of personal information shall be on a voluntary basis, but if compulsory questions are left unanswered, VL may not be able to respond to enquiries or provide services.

8.Use of Cookies
Some Internet sites and other services operated and managed by VL (hereinafter referred to as “this site, etc.” uses cookies.
1)VL may use information obtained from cookies to analyze the use of its services and to ensure the proper provision of the services.
2)With regard to services for registered members, information obtained from cookies may be linked to other information that can identify individual customers, for the purpose of offering personalized services.

9.Matters to notify when personal information is obtained by methods other than directly from the person in writing.
Personal information handled within the boundaries of outsourced operations and obtained will only be used for the outsourced operations.

10.Indemnity
VL shall not be responsible for keeping personal information of customers safe on any website linked from the site of DH’s services, and customers shall check the security of such websites on their own. Customers shall also keep their passwords and registration information safe on their own responsibility, and shall handle information with sufficient care while connected to the Internet.

11. Revision
A revision shall be made to this page, “Handling of Personal Information,” from time to time in order to enhance the protection of personal information of customers or in the event of establishment or amendment of laws and regulations. VL recommends that customers shall check the most recently updated content on a regular basis.
VL may revise all or part of this page, “Handling of Personal Information.” Any material change shall be notified on this website.

12.Complaints/consultations and enquiries regarding personal information
Any person may contact the following contact point for enquiries regarding his or her personal information, or the protection of personal information in general.

Contact Point for Personal Information at Vernalossom Co., Ltd.
email : info@vernalossomprivacy.com
*The contact point above deals with complaints/consultations and enquiries regarding personal information concerning the
inquirer, and no other enquiries shall be accepted.

JIPDEC
Accredited Personal Information Protection
Organization Administrative Office
Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo, 106-0032
TEL
03-5860-7565 / 0120-700-779 ?*Only available in Japanese
Vernalsosom Co., Ltd.

Supplementary Provision 2020 April 1st Established and enforced by Vernalossom Co., Ltd.

These Privacy policy terms, etc. was originally prepared in Japanese and interpreted into English.
Please note that, the original Japanese version of the privacy policy will prevail over this English version,

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