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 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").
Personal Information Protection Supervisor: Yoshinori Inoue, Manager, R&D Division, Management Information Systems Development Dept.