The purpose of this Policy clarify the basic policies of for ensuring the appropriate and safe management of personal information gathered from customers for Company operations related to the revenue maximization platform for online media and marketing support services for advertisers and ad agencies we provide.
When we gather personal information, we indicate the purpose of use in advance and gather information via legal and fair means.
We comply with the provisions of relevant laws, administrative notices, guidelines, etc., when handling personal information.
We will not leak or disclose gathered personal information to any third party. However, this shall not be the case when provision is requested by an administrative authority in accordance with law and we have gained consent in advance from the Provider.
We work to ensure that acquired personal information is accurate and up to date within the scope necessary to achieve the purpose of use.
We respect the Provider's rights related to personal information and shall respond quickly to any requests, complaints, or consultations from Providers regarding personal information, including for disclosure, revisions, or the stoppage of use.
We conduct the strict management of personal information and implement appropriate safety measures to protect personal information from unauthorized access, leaks, loss, damage, or destruction.
We conduct necessary employee supervision, training, and education to ensure correct handling of personal information.
To ensure the protection of personal information, we shall construct a personal information protection management system and conduct regular audits to maintain and improve this system.
Security management measures and other specific measures related to this Policy shall be set forth in the basic regulations for personal information protection.
Date created: May 18, 2016
Date revised: March 20, 2018 (enacted: April 1, 2018)
Geniee, Inc. Tomoaki Kudo, President and CEO
(Created February 1, 2011)
Revised April 6, 2015
Revised May 25, 2017
Revised December 12, 2017
Revised March 20, 2018 (enacted April 1)
Geniee, Inc. defines our privacy policy for the operation of services we provide as follows. Furthermore, we may revise all or a part of this Privacy Policy. Notifications concerning important changes will be placed on our website.
Geniee, Inc. defines personal information as information related to an individual that can be used to identify a specific person by referencing the name, date of birth, or other descriptions contained in said information (including information that can easily be cross-referenced with other information to identify an individual).
Geniee, Inc. gathers and uses personal information for the following purposes.
Geniee, Inc. shall not handle personal information beyond the scope required to achieve the purpose of use without receiving prior consent from the individual. Even in cases where we acquire personal information as the result of a merger or other reasons, we will not handle personal information beyond the scope required to achieve the purpose of use prior to said merger, etc., without receiving prior consent from the individual. However, this shall not apply in the following cases.
Geniee, Inc. conducts the appropriate gathering of personal information and does not gather information via fraud or other inappropriate means.
Geniee, Inc. implements appropriate measures to ensure that user personal information is accurate and up to date. We also ensure the appropriate and secure management of user personal information.
When Geniee, Inc. will consign all or a portion of the handling of personal information, we will conclude an agreement with subcontractors that includes a confidentiality clause or require consent to an agreement outlined by Geniee, Inc. Furthermore, we will conduct necessary and appropriate supervision to ensure personal information security management by subcontractors.
Excluding cases outlined below, Geniee, Inc. will not disclose personal information to a third party without prior consent from the individual in question.
Geniee, Inc. may consign, in accordance with laws, etc., and limited to the extent required to fulfill the purpose of use, all or a portion of the handling of personal information to a third party in a foreign country. Currently, the relevant consignee is a Geniee, Inc. Group company located in Vietnam.
In the case of the following, Geniee, Inc. shall bear no liability whatsoever in relation to the third-party handling of personal information.
Geniee, Inc., through the various services we provide, gathers and uses the following data to the extent that it is not defined as personal information. The use of this data, etc. includes use for the distribution of behavior targeting-based ads defined in the following article, provision to third parties, as well as use for the provision and improvement of Geniee, Inc. services.
Geniee shall store and save the above data as necessary for operations.
Geniee, Inc. provides behavior targeting-based ads. Behavior targeting-based ads refers to advertising services that use user website and application browsing history, EC website purchasing history, and other behavior history information to distribute targeted ads. Ad history information does not include information that enables the identification of a specific individual. Persons who do not wish to receive behavior targeting-based ads may click on the following URL to follow procedures to disable such ads (hereinafter, "Opt-out").
URL:https://geniee.co.jp/optout.html
Inquiries concerning our personal information protection policy, this Privacy Policy, complaints, notification of the purpose of use of personal information, disclosure, revision, addition or deletion, stoppage of use, removal from or stoppage of use of personal information by third parties.
URL:https://en.geniee.co.jp/inquiry/
TEL:+81-3-5909-8181
Personal Information Protection Supervisor: Manager, R&D Division, Management Information Systems Development Dept.
(Created on May 28, 2018)
Geniee, Inc. (''Geniee'') defines our privacy policy of EU Personal Data for the operation of services we provide as follows. Furthermore, we may revise all or a part of this Privacy Policy of EU Personal Data. Notifications concerning important changes will be placed on our website.
‘‘EU Personal Data'' means any information relating to an identified or identifiable natural person (you) within the EEA (European Economic Area) region, such as your name, date of birth, email address, or other data set forth in Article 2 of this Privacy Policy of EU Personal Data.
(1)Information that you provide to us:
(2)Information we collect or receive:
(1) We use the information you provided to us for the following purposes:
(2) We may use the information we collected for the following purposes:
(1)We may share information with other Geniee affiliated companies to process for purposes that are consistent with those disclosed in this Privacy Policy.
The legal basis for sharing your information with our affiliated companies is Art. 6 para. 1
(f) GDPR.
you may have the right to object, on grounds relating to your particular situation, at any time to such sharing. To exercise this right you may at any time contact our European representative as provided for in Section 8 below.
(2) We may provide the information you provided to us to our third-party partners as follows:
The legal basis for sharing your information with our affiliated companies is Art. 6 para. 1
(f) GDPR.
you may have the right to object, on grounds relating to your particular situation, at any time to such sharing. To exercise this right you may at any time contact our European representative as provided for in Section 8 below.
When we do not obtain your EU Personal Data directly from you, we obtain such data from the Internet publishers which you accessed to.
(1)We will store the information you provided to us until you contact us to erase your information.
(2)We will store the information we collect or receive until the default setting term of the browser you are using.
You have the right related to your EU Personal Data as follows, and may use your right by contacting us by the method set forth on Article 8 of this Privacy Policy of EU Personal Data.
a. to request from us access to and rectification or erasure of EU Personal Data,
b. to request the restriction of processing concerning the data subject,
c. to object to processing as well as the right to data portability,
d. to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal,
e. to lodge a complaint with a supervisory authority.
Inquiries concerning this Privacy Policy of EU Personal Data, complaints, notification of the purpose of use of personal information, disclosure, revision, addition or deletion, stoppage of use, removal from or stoppage of use of personal information by third parties.
URL:EURepresentative.Geniee@ashurst.com
https://en.geniee.co.jp/inquiry/
TEL:+81-3-5909-8181
Data protection officer: Manager, R&D Division, Management Information Systems Development Dept, Geniee, Inc.