COCONE PRIVACY POLICY

1. 1. Preamble (Basic Policy)

   Cocone Corporation (hereinafter referred to as “Company,” “we,” or “us”) has established this privacy policy (hereinafter referred to as “Policy”) in recognition of the Company’s social responsibility regarding the personal information of customers, business partner personnel, shareholders, employees, and prospective hires (collectively, “Customer” or “Customers”) that the Company obtains, and will appropriately handle such personal information and protects the rights and interests of the individuals in accordance with the Policy and applicable laws and regulations relating to personal information.
   In addition, to realize the following policy, we declare our intent to make company-wide efforts towards its continuous improvement, recognizing at all times the latest trends in IT technology, changes in social demands, and fluctuations in the business climate.
   For services we operate (hereinafter referred to as “Services”), the privacy policy stipulated for each service (hereinafter referred to as “Service Policy”) shall prevail. Please refer to each Service Policy for details.

2. 2. Personal information

   1. 1) As a rule, the meaning of terms used in this Policy shall conform with the Act on the Protection of Personal Information (hereinafter referred to as “Personal Information Protection Act.” and the article numbers given in this Policy shall correspond to those as of April 1, 2022).

   2. 2) The term “personal information” as used in this Policy refers to that defined in Article 2, Clause 1 of the Personal Information Protection Act, and includes, for example, the following types of information:
      – Name, address, telephone number, gender, date of birth, and other details of the Customer.
      – Other information pertaining to the Customer (service usage history, salary amount, etc.)
      Information that by itself cannot identify a specific individual (e.g., gender, service usage history, salary, etc., and collectively, “Attribute Information”) is treated as personal information only when it can be combined with other information (e.g., name, employee number) to identify a specific individual.

3. 3. Acquisition and use of personal information

   1. 1) Purpose of acquisition and use of personal information

      We acquire and use the personal information of Customers in an adequate manner only within the scope of the purposes of use specified in advance in the “Personal Information Subject to Disclosure: 2. Purpose of Use” section below.
      Note that while the provision of personal information by Customers is voluntary, we may be unable to provide Services without the completion of the personal information fields required for such Services.

   2. 2) Provision of personal information to third parties

      We do not provide the personal information of Customers to any third party without obtaining the prior consent of the Customer in question, except in the cases specified in each item of Article 27, Clause 1 of the Personal Information Protection Act.
      The following parties are not considered “third parties” under Article 27, Clause 1 of the Personal Information Protection Act, and therefore, we reserve the right to provide personal information to them without obtaining the prior consent of the individual.

      ・Subcontractors (Article 27, Clause 5, Item 1 of the Personal Information Protection Act)
      We may outsource all or part of payroll calculation, social insurance procedures, customer service, etc., to external tax accountants, social insurance consultants, and other companies (collectively, “Subcontractor” or “Subcontractors”), and may also outsource the handling of the minimum necessary personal information for the performance of such outsourced services. In such cases, we will appropriately supervise the Subcontractor by, for example, concluding a contract with them regarding the handling of personal information.

      ・Group Companies (Article 27, Clause 5, Item 3 of the Personal Information Protection Act)
      To provide comprehensive services, we may share personal information with our group companies (wholly-owned subsidiaries and wholly-owned sub-subsidiaries located within Japan; applies similarly to the following sections).
      For details on this item, please refer to the “Personal Information Subject to Disclosure: 3. Joint use” section below.

   3. 3) Provision to third parties in foreign countries

      We may provide our Customers’ personal information to third parties in foreign countries (countries or regions outside Japan).
      For details on this item, please refer to the “Personal Information Subject to Disclosure: 4. Provision to third parties in foreign countries” section below. To select, and outsource work to an appropriate contractor as necessary, personal information may be provided to foreign contractors whose country of residence has not been identified at this time. In such cases, we may initiate a new outsourcing agreement with a new contractor without obtaining the consent of the individual.

   4. 4) Protection of personal information (safety control measures)

      In order to prevent unauthorized access to personal information, or leakage, loss, or damage of personal information, and to otherwise safely manage personal information, we will take necessary, appropriate, and reasonable security control measures and utilize management resources aligned with the actual conditions of our business, and continuously improve our personal information security system. In addition, we have established internal rules and regulations, including corrective actions for inappropriate matters, to protect personal information to the best of our ability.
      Please contact us via the details provided in “6. Inquiry desk” for information on the security control measures we take.

   5. 5) Disclosure requests

      We retain and use the personal information of Customers to the extent and for the period necessary to comply with applicable laws and regulations or to achieve the stated purpose of use.
      However, Customers or their representatives may request (i) notification of the purpose of use, (ii) disclosure of personal information or records of provision to third parties, (iii) correction, addition, or deletion of or to content, or (iv) suspension of use or provision to third parties, by following the procedures we set forth.
      For specific request procedures, please refer to the “Personal Information Subject to Disclosure: 5. Procedures for requesting disclosure, etc.” section below.

4. 4. Acquisition and use of Attribute Information

   1. 1) To provide appropriate services to Customers, our website and Services may use cookies, advertising identifiers (Advertising Identifier (iOS), Google Advertising ID (Android OS)), and other similar tracking or analysis technologies to obtain Attribute Information (e.g., browsing history, service usage history, location information, IP address, device type, OS, browser type, device unique ID, etc.).
      You may choose to reject the use of cookies and advertising identifiers in the settings of your browser or smartphone application. However, please note that if you reject the use of cookies, the provision of all or part of our Services may be restricted.

   2. 2) Google Analytics
      We may use Google Analytics to analyze access to our website and our Services.
      Data collected through the use of Google Analytics is handled in accordance with Google’s Privacy Policy. Please refer to Google’s official pages below.

      – Google Analytics Terms of Use

      – Use by Google of information collected from sites and applications that use Google services

   3. 3) When providing Attribute Information to a third party, if said information is likely to be acquired as personal information by the third party, we will confirm in advance the matters listed in Article 31, Clause 1 of the Personal Information Protection Act with the third party.

5. 5. Special provisions for Customers residing in foreign countries

   1. (1) We handle the information of Customers who are subject to the EU General Data Protection Regulation (hereinafter referred to as “GDPR”) in accordance with the provisions of the GDPR.
      Please refer to the COCONE Privacy Notice (GDPR privacy policy) for the provisions of GDPR.

   2. (2) We handle the information of Customers who are subject to the California Consumer Privacy Act (hereinafter referred to as “CCPA”) in accordance with the provisions of CCPA.
      Please refer to the COCONE Privacy Notice (CCPA privacy policy) for the provisions of CCPA.

6. 6. Inquiry desk

   We have established internal rules for responding to inquiries, complaints, and consultations regarding the handling of personal information (collectively, “Inquiries”) and will respond to such Inquiries promptly and in good faith.
   Please send your Inquiries to the address below.

   Name: Cocone Corporation Personal Information Inquiry Representative
   Address: 3-1-18 Wakabayashi, Setagaya-ku, Tokyo
   Email: info@cocone.co.jp
   (Business hours: 9:00 AM to 6:00 PM, excludes weekends and holidays)

7. 7. Revisions

   We may revise this Policy to better protect the personal information of Customers and comply with changes in applicable laws and regulations. In such cases, we shall notify Customers of the revisions in advance and make changes to the content after a grace period.

■Personal Information Subject to Disclosure

• 1. Name of the business operator handling personal information

  Cocone Corporation
  3-1-18 Wakabayashi, Setagaya-ku, Tokyo
  Representative Director and CEO: Shintaro Takaya

• 2. Purpose of use

  We acquire and use the personal information of Customers within the scope of the following purposes of use.

  1. 1) Personal data of customers of our Services

     Personal information we acquire	Purpose of use
     Name	1. To deliver prizes for campaigns and contests 2. To contact customers as necessary when conducting questionnaires, interviews, etc. 3. To notify customers of matters necessary for the operation of our Services and to respond to various inquiries 4. To prevent and respond to fraudulent acts, etc.
     Date of birth	1. To obtain age-based analysis results when conducting questionnaires, interviews, etc., with customers 2. To provide, solicit, advertise, or otherwise market the Company’s or a third party’s products and services through the Company’s or the third party’s media in accordance with the interests of customers based on gender analysis 3. To determine the legality of the Customer’s actions, such as determining whether or not the consent of a person with parental authority is needed when billing for our Services, entering a campaign or contests, etc.
     Gender	1. To provide appropriate and effective after-sales service for our Services 2. To obtain gender-based analysis results when conducting questionnaires, interviews, etc., with customers 3. To provide, solicit, advertise, or otherwise market the Company’s or a third party’s products and services through the Company’s or a third party’s media in accordance with the interests of customers based on gender analysis
     E-mail address	1. For user administration of our Services (e.g., to transfer customer service data between different devices, such as when changing device models) 2. To deliver prizes for campaigns and contests 3. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries
     Address and postal code	1. To deliver products purchased through our Services and prizes for campaigns and contests, and to provide after-sales services related to such products and prizes 2. To obtain analysis results based on the place of residence (country of residence, etc.) when conducting questionnaires, interviews, etc., with customers 3. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries
     Telephone number	1. To deliver products purchased through our Services and prizes for campaigns and contests, and to provide after-sales services related to such products and prizes 2. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries
     Bank account information, wallet address	To process necessary transactions (e.g., payments, revenue processing)
     Credit card data	To use as payment information for customers who chose “credit card payment” as their payment method for our Services
     In-service user name	1. To manage (identify) users of our Services 2. To notify customers of matters necessary for the operation of our Services and to respond to various other inquiries 3. To prevent and respond to fraudulent acts, etc.
     Cookie data (e.g., service usage history, browsing history, location information, IP address, device type, OS, browser type, device UID, etc.)	1. To manage users of our Services 2. For maintenance and administration of our Services (e.g., to maintain stable web sessions) 3. To simplify customer information entry when using our Services, such as saving user settings 4. To process payments for customers who are paying for our Services for the first time or who purchase products through our Services for the first time 5. To improve and enhance our services, and to plan, research, and develop new services 6. To research and analyze marketing data and to consider and implement marketing measures 7. To provide, solicit, advertise, or otherwise market the Company’s or a third party’s products and services through the Company’s or a third party’s media in accordance with the interests of Customers based on browsing history analysis 8. To prevent and respond to fraudulent acts, etc.
     Advertising identifier (Advertising Identifier (iOS), Google Advertising ID (Android OS))	1. To determine whether or not our Services are being used on the customer’s device and to obtain the results of analysis of usage of our Services, etc. 2. To improve and enhance our Services and to plan, research, and develop new services 3. To research and analyze marketing data and to consider and implement marketing measures 4. To provide, solicit, advertise, or otherwise market the Company’s or a third party’s products and services through the Company’s or a third party’s media in accordance with the interests of customers based on browsing history analysis
     Other (e.g., the information provided by customers when making inquiries, contacting us, etc.)	To respond to inquiries and contact customers

  2. 2) Personal information of business partner representatives

     Personal information we acquire	Purpose of use
     Name	1. To contact representatives regarding business matters 2. To process necessary transactions. (e.g., payments, income processing)
     E-mail address
     Address and postal code
     Bank account information
     Telephone number
     My Number (personal identification number)

  3. 3) Personal information of shareholders

     Personal information we acquire	Purpose of use
     Name	1. To prepare records (shareholder registry, etc.) and manage shareholders in accordance with various applicable laws and regulations 2. To send materials, etc., related to the General Meeting of Shareholders 3. To exercise rights and perform obligations under the Companies Act
     E-mail address
     Address and postal code

  4. 4) Personal information of employees, etc. (including their dependents)

     Personal information we acquire	Purpose of use
     Name	1. To perform necessary procedures, including those related to hiring new employees, arrangement of social insurance, provision of benefits, business communications, various procedures required by law, and other procedures required for employment management 2. To contact and perform procedures in the event of a celebration or untimely event, such as marriage and death, and to perform other procedures necessary in connection with personal changes to employees, etc. 3. To perform duties related to wages, bonuses, retirement benefits, corporate pensions, etc. 4. To ensure appropriate health management and safety management, and secure a proper working environment, or to take appropriate measures to enable the Company to fulfill its duty of care for safety and ensure that employees conduct appropriate health management 5. To perform procedures necessary for work-related communication and business activities 6. To perform the following other administrative tasks – Employment insurance notifications, etc. – Health insurance and welfare pension notifications, etc. – Category 3 national pension filings – Preparation and submission of withholding tax certificates and other withholding tax-related matters – Administrative tasks related to each of the above items
     Date of birth
     Gender
     E-mail address
     Address and postal code
     Telephone number
     Current and past affiliations
     Employment history and occupation
     Personnel evaluations and self-assessments
     Education and qualifications
     Family Information
     Bank account information
     Salary Information (e.g., base salary, bonuses, benefits, work status, income tax, resident tax, withholding tax)
     Social insurance information (e.g., health insurance, welfare pension, worker’s accident insurance, employment insurance)
     Health information (e.g., information on medical examination results, health information related to leaves of absence, etc.)
     My Number (personal identification number)

  5. 5) Personal information of prospective hires

     Information obtained	Purpose of use
     Name	1. For employment selection 2. To contact and provide information to prospective employees
     Date of birth
     Gender
     E-mail address
     Address and postal code
     Telephone number
     Employment history and occupation
     Education and qualifications
     Family Information
     Salary Information (e.g., base salary, bonuses, benefits, work status, income tax, resident tax, withholding tax)

• 3. Joint use

  1. 1) Items of personal information to be shared

     The information listed in “2. Purpose of use”

  2. 2) Purpose of use of personal information to be shared

     The purpose listed in “2. Purpose of use”

  3. 3) Scope of joint users

     Our group companies

  4. 4) Party responsible for management of joint use

     Cocone Corporation (3-1-18 Wakabayashi, Setagaya-ku, Tokyo, Shintaro Takaya, Representative Director and CEO)

• 4. Provision to third parties in foreign countries

  We may, for example, provide personal information of Customers to third parties in the following foreign countries within the scope specified in “2. Purpose of use.” The country-specific information to be used as a reference at this time is as follows:

  ・United States of America

  ・United Arab Emirates (DHC)

  ・Singapore

  ・South Korea

  ・Taiwan

  ・Hong Kong

  “Foreign countries” as used herein does not include the following countries, which are deemed “foreign countries, etc. that have systems for the protection of personal information that are recognized as being equivalent to those in Japan for protecting the rights and interests of individuals.”

  – United Kingdom

  – Estonia

• 5. Procedures for requesting disclosure, etc.

  We respond to requests for disclosure, etc. (refers to requests for (i) notification of purpose of use; (ii) disclosure of personal information or records of provision to a third party; (iii) correction, addition, or deletion of or to content; and (iv) suspension of use or provision to a third party) as specified below.

  1. 1) (i) Notification of purpose of use; (ii) Disclosure of personal information or records of provision to a third party

     Customers may request that we notify them of the purpose of use, or request disclosure of personal information or records of provision to third parties within the scope permitted by the Personal Information Protection Act, in accordance with the procedures set forth in “4) Procedures” below. However, we may decline to disclose it if any of the following items apply.

     – If there is a risk that disclosure may harm the life, body, property, or other rights or interests of the person concerned, or of a third party

     – If there is a risk that disclosure may significantly impair the proper execution of our business

     – If disclosure would violate other laws or regulations

     – If we are unable to confirm that the request for disclosure is made by the individual in question

  2. 2) (iii) Correction, addition or deletion of or to content

     Customers may request the correction, addition or deletion of or to personal information in accordance with the procedures set forth in “4) Procedures” below. In the said case, we will investigate the matter without delay to the extent necessary to achieve the stated purpose of use, and based on the results of our findings, we will correct, add, or delete the relevant personal information to the extent permitted under the Personal Information Protection Act.

  3. 3) (iv) Suspension of use or provision to a third party

     Customers may request the correction, suspension of use of personal information, or suspension of provision to third parties in accordance with the procedures set forth in “4) Procedures” below. In such cases, we will respond appropriately in accordance with the Personal Information Protection Act.

  4. 4) Procedures

     To make a request for disclosure, complete the requisite items on the form prescribed by the Company (item A below), enclose identification documents (item B below), and mail them to the mailing address designated (item C below).

     • A. Request forms

       Request forms can be downloaded via the links below.

       – Request form for notification of purposes of use

       – Request form for disclosure of retained personal data

       – Request form for disclosure of personal data provided to third parties

       – Request form for correction, etc. of retained personal data

       – Request form for suspension of use of retained personal data

     • B. Identity verification documents

       1: Requests by the Customer themselves

       – A copy of the Customer’s personal identification document (one of the following)

       ◯Driver’s license

       ◯Employment insurance card

       ◯Passport

       ◯My Number identification card

       ◯Basic resident register card

       ◯Certificate of alien registration (residence card (zairyu card), special permanent resident certificate)

       2: Requests by a legal representative

       If the person making the request for disclosure, etc. is a legal representative of a minor or an adult ward, please enclose the following documents (two in total) in addition to the identification documents in A above.

       – A copy of the legal representative’s personal identification document (one of the following)

       ◯Driver’s license

       ◯Employment insurance card

       ◯Passport

       ◯My Number identification card

       ◯Basic resident register card

       ◯Certificate of alien registration (residence card (zairyu card), special permanent resident certificate)

       – Documents demonstrating the identity of the legal representative (one of the following)

       ◯Copy of family register

       ◯Official copy of segment of family register

       ◯Certificate of registration of adult guardianship

       3: Request by a voluntarily appointed representative

       If the person making the request for disclosure, etc. is a proxy (voluntary representative) authorized by the individual to whom the information pertains, please enclose the following documents (3 items in total) in addition to the identification documents in A above.

       – A copy of the representative’s personal identification document (one of the following)

       ◯Driver’s license

       ◯Employment insurance card

       ◯Passport

       ◯My Number identification card

       ◯Basic resident register card

       ◯Certificate of alien registration (residence card (zairyu card), special permanent resident certificate)

       – Power of attorney (signed and sealed by the person delegating power of attorney)

       – A seal registration certificate with the same seal as the seal of the delegator stamped on the power of attorney documents)

     • C. Address

       3-1-18 Wakabayashi, Setagaya-ku, Tokyo, 154-0023
       Cocone Corporation Personal Information Disclosure Request Desk