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Personal Information Protection Policy

  • Objective
  • 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.

  • Collection of personal information
  • When we gather personal information, we indicate the purpose of use in advance and gather information via legal and fair means.

  • Use of personal information
    1. We use or provide gathered personal information within a previously indicated scope.
    2. We will not use gathered personal information outside the scope of the purpose of use. We also shall implement measures to this effect.
    3. If we seek to use personal information outside the scope of the purpose of use indicated at the time of acquisition, we will gain consent in advance from the provider of said personal information (hereinafter, Provider).
  • Guidelines outlined by laws and governments
  • We comply with the provisions of relevant laws, administrative notices, guidelines, etc., when handling personal information.

  • Restrictions on third party provision
  • 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.

  • Ensuring accuracy of details
  • We work to ensure that acquired personal information is accurate and up to date within the scope necessary to achieve the purpose of use.

  • Respect for individual rights
  • 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.

  • Security management measures
  • 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.

  • Employee supervision and education
  • We conduct necessary employee supervision, training, and education to ensure correct handling of personal information.

  • Personal information protection management system creation and improvement
  • 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.

  • Basic regulations and guidelines for personal information protection
  • Security management measures and other specific measures related to this Policy shall be set forth in the basic regulations for personal information protection.

  • Disclosure of personal information protection guidelines
    1. We shall inform employees of personal information protection guidelines in accordance with the provisions outlined in management regulations.
    2. We shall publish our Privacy Policy outlining our personal information protection policy or equivalent content on our website.

Date created: May 18, 2016


Date revised: March 20, 2018 (enacted: April 1, 2018)



Geniee, Inc. Tomoaki Kudo, President and CEO

Privacy Policy

(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.

  • Definition of personal information
  • 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).

  • Specifying personal information purpose of use
  • Geniee, Inc. gathers and uses personal information for the following purposes.

    1. To provide the various services operated by Geniee, Inc. and to provide information related to said services
    2. To request payment of usage fees for services operated by Geniee, Inc.
    3. To process system utilization compensation payments for services operated by Geniee, Inc.
    4. To implement improvements to services operated by Geniee, Inc. and to develop new services
    5. To prevent the use of services operated by Geniee, Inc. in ways that violate the terms of use
    6. To conduct the hiring of candidates for employment at Geniee, Inc.
    7. To accept administrative staff dispatched from Geniee, Inc. partner companies and to conduct labor management for said staff
    8. To create data, etc., defined in Article 10 of this Privacy Policy
  • Restrictions on use of personal information
  • 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.

    1. When in accordance with law or when allowed by law
    2. When necessary for the protection of a person's life, physical well-being, or assets and it proves difficult to receive consent from the individual
    3. When particularly necessary for improving public health or promoting healthy child development and it proves difficult to receive consent from the individual
    4. When it is necessary to cooperate with the execution of legally mandated procedures conducted by the government, a local municipal organization, or a party consigned to conduct said procedures, and receiving consent from the individual may interfere with the execution of said procedures
  • Appropriate collection of personal information
  • Geniee, Inc. conducts the appropriate gathering of personal information and does not gather information via fraud or other inappropriate means.

  • Appropriate protection of personal information
  • 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.

  • Subcontractor supervision
  • 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.

  • Restrictions on third party provision
  • Excluding cases outlined below, Geniee, Inc. will not disclose personal information to a third party without prior consent from the individual in question.

    1. When in accordance with law
    2. When necessary for the protection of a person's life, physical well-being, or assets and it proves difficult to receive consent from the individual
    3. When particularly necessary for improving public health or promoting healthy child development and it proves difficult to receive consent from the individual
    4. When it is necessary to cooperate with the execution of legally mandated procedures conducted by the government, a local municipal organization, or a party consigned to conduct said procedures, and receiving consent from the individual may interfere with the execution of said procedures
  • Consignment to third parties in foreign countries
  • 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.

  • Indemnity
  • In the case of the following, Geniee, Inc. shall bear no liability whatsoever in relation to the third-party handling of personal information.

    1. When the individual discloses personal information to a third party via some means
  • Use of data, etc.
  • 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.

    1. Statistical data created by processing personal information into a format that does not enable the identification of individuals
    2. The viewed ads and pages, gender, occupation, age, etc. of users viewing or using Geniee, Inc. websites or applications, or those of Geniee, Inc. partner companies as well as the time of use, usage method, usage environment, and other information related to the use and viewing of pages and advertisements.
    3. IP address, cookie information, location information, and terminal identification information

    Geniee shall store and save the above data as necessary for operations.

  • About disabling behavior targeting
  • 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
  • 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.

    CONTACT US

    URL:https://en.geniee.co.jp/inquiry/
    TEL:+81-3-5337-8210
    Personal Information Protection Supervisor: Yoshinori Inoue, Manager, R&D Division, Management Information Systems Development Dept.

    プライバシーマーク

Privacy Policy of EU Personal Data

(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
  • ‘‘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.

  • Information Geniee collects and uses
    • (1)Information that you provide to us:

    • When you register for and use our services, we collect the information that you provide to us, such as your name, email address, phone number, date of birth and language.
    • (2)Information we collect or receive:

    • When you use our services or our third-party partners’ services, we may collect the following information of you.
    1. Information about your browser
    2. Cookies
    3. Information about your device, including operating system, model, device indentifiers such as your IDFA or AAID
    4. Your geographic location
    5. IP address
    6. Information about your activity on web pages or apps visited or used. We do not passively track your activity but only receive information about your activity in connection with requests specifically made to our system to serve you an ad, measure your interaction with an ad or to place you into an interest-based category for future use by a client to help make the ads they show to you more relevant.
    7. Information about ads served, viewed or clicked on, including the type of ad, where the ad was served, whether you clicked on it and whether you visited the advertiser's website or downloaded the advertiser's app.
    8. Information about you or inferences about your interests that a third-party partner has collected about you and shared with us such as information about your interests or demographic information (your age or gender) or to help make the ads served to you more relevant. For clarity, we do not independently collect information about your interests or demographic information for use within our system, but we do allow our third-party partners to utilize their own data or third-party data they have access to in connection with the services.
    9. Information about your internet service including information about which Internet Service Provider (ISP) is used by you.
  • Purpose and legal basis of using EU Personal Data
  • (1) We use the information you provided to us for the following purposes:

    1. To provide, maintain and improve various services operated by us and to provide information related to said services.
    2. To prevent the use of services operated by us in ways that violate the terms of use.

    (2) We may use the information we collected for the following purposes:

    1. We may use cookies or other technologies on some of the features of our services. Cookies help us to ensure the safety and smooth functioning of certain features of our services and they also help us to collect information about your user preferences. We sometimes use information collected from cookies to improve your user experience and the quality of our services. For example, by saving your user preferences, we may be able to customize our services in ways that you prefer. You may be able to disable cookies in your browser settings or set your browser to alert you when cookies are being used. If you disable cookies, you may not be able to use all of the features of our services.
      The legal basis for the processing pursuant to this item is Art. 6 para. 1 (b) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – “GDPR”).
    2. We also may permit our third-party partners to set cookies and use web beacons and similar technologies within our services to help us perform various internal functions necessary to operate our business and to collect information about your use of our and others’ services across your devices. We and these third parties may use that information to provide you advertisements, across the Internet and mobile applications and devices, about goods and services that may be of interest to you.The legal basis for the processing pursuant to this item is Art. 6 para. 1 (f) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – “GDPR”).
      You may have the right to object, on grounds relating to your particular situation, at any time to the processing pursuant to this item. To exercise this right you may at any time contact us as provided for in Section 8 below.
  • How your information is shared
  • (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:

    1. advertisers
    2. advertisement distribution company
    3. research company

    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.

  • Original source of EU Personal Data
  • When we do not obtain your EU Personal Data directly from you, we obtain such data from the Internet publishers which you accessed to.

  • Period for which EU Personal Data Stored
  • (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.

  • Your rights
  • 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
  • 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.

    CONTACT US

    URL:EURepresentative.Geniee@ashurst.com
    https://en.geniee.co.jp/inquiry/
    TEL:+81-3-5337-8210

    Data protection officer: Yoshinori Inoue, Manager, R&D Division, Management Information Systems Development Dept, Geniee, Inc.
    Email: y.inoue@geniee.co.jp

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