PRIVACY POLICY

This privacy policy sets out the basis upon which Ganapati plc (“we” or “us” or “our”) will collect and use your personal information.We will treat all personal information we receive from you in accordance with this privacy policy.

For the purpose of this privacy policy, “personal information” means any information about a living individual, from which such individual can identified. Such information may include, for example, your name, date of birth or any other information provided by you (including any information, which when used together with other information, will enable us to identify you). Please see the section entitled “Personal Information Subject to Disclosure” at section 8 of this privacy policy.

1. Collection and Use of Personal Information

We will use your personal information with your permission only and in accordance with the terms of this privacy policy. Should any proposed use of your personal information fall outside the scope of this privacy policy, we will seek your prior consent for any such use. We will also seek your consent prior to disclosing your personal information to any third party. We will seek to keep your personal information up to date.

2. Security of Personal Information

We have appropriate procedures and safety measures in place to prevent illegal access, tampering,and disclosure of personal information.

3. Personal Information Laws

We will use reasonable efforts to comply with all laws, guidelines and any other rules related to the protection of your personal information.

4. Our Personal Information Management System

Our employees are required to comply with our internal data protection policies and are appropriately trained. To maximize efficiency and improve our security measures we train our employees and audit our practices on an ongoing basis.

5. Use of cookies
Whilst using our website, we may send you cookies※ which will be stored on your computer hard drive or memory. We use cookies to improve our services. The use of cookies will not disrupt the use of our website or affect your privacy. The use of cookies will not disclose any personal information that will allow an individual to be identified.
By using cookies we may obtain information such as the browser history of a user and any information obtained will be in a form that ensures individuals remain unidentifiable, and in such a form that personal information cannot be identified. You can control cookies through your browser settings and other tools.
※Cookies are small data files that web servers send to browsers when accessing a website. Cookies will distinguish computers and keep records of what website a computer has accessed, however cookies cannot collect any personal information held in a computer.
6. Complaints and Questions
If you would like further information about our privacy policy, or have any questions, comments or complaints regarding this privacy policy or our treatment of your personal information, please contact us at: Ganapati plc Japan Office:+81-(0)3-4588-8888. It is possible for you or your authorized representative to contact us to: (a) confirm what personal information we hold about you;(b) disclose personal information to us; (c) amend or update any personal information that we hold; (d) require us to stop using your personal information or to delete such personal information from our records; or (e)require us to stop disclosure of your personal information to third parties. We will aim to respond promptly to any requests that you may have. Please note we will identify and verify users that have sent in questions and complaints in a manner that we deem appropriate. If we are unable to identify you, or you are unable to verify yourself by providing the information that we request, we may refuse to provide you with any information or refuse to carry out any request.
We, our employees, and our partners understand the importance of this privacy policy and will comply with all this privacy policy and to protect your personal information.
Purposes for which we collect Personal Information

We may collect and process your personal information for the following purposes:

1. To provide our services to you (including with- out limitation, information about our services, and associated after-sales services). 2. To enable disclosure to our third party service providers to the extent required for the provision of the services and/or operation of our website[ following “Consent of disclosure and use of personal information”.] 3. To collect statistical data in relation to our services. 4. To generate questionnaires about our services. 5. To create new services in addition to improving our current services. 6. To make suggestions and recommendations to you about other products and services we offer (for example, direct emails and magazines) 7. To allow you to participate in interactive features of the website and send out prizes for campaigns and other related promotional materials. 8. To respond to any requests you may have. 9. For identification and verification purposes. 10. To inform you of any important information regarding our services as required. 11. To prevent unauthorized use of our website and/or services. 12. To allow us to carry out all matters that are re- lated and incidental to the matters listed above.

※In this privacy policy the “service provider” means a third party service provider who provides services, or uses our services to provide services, goods, exhibition rights etc.

Personal Information Subject to Disclosure

The definition of personal information is set out in JISQ15001:2006 3.4.4.1 [Loosely translated as follows:“Personal information must be collected systematically, within a set of rules, classified and organized as a set, so that the intended personal information can be searched easily through an electronic calculator (computer), and when requested by the personal information holder, the operator must be able to disclose, add, delete,stop use, discard, cease to provide to a third party,any personal information, when the personal information holder asks to do so”.]

Below is the list of personal information that we may collect and purposes for which we may use the same.

▪︎Personal Information we may collect

1. The following types of personal information maybe collected by us:
(a) Name,(b) username,(c) address, (d) gender, (f)e-mail address, and (g) any other relevant information.

▪︎Purpose for which we may use your Personal Information

1. To provide services.
2. To provide information on our services.
3. To improve our services.
4. To respond to questions and verify your identity.
5. To provide information relating to our services and other information updates.
6. To prevent unauthorized use of our website and our services.

Dealing with User requests

We will promptly cooperate with any requests made by the owner of personal information and/or its authorized representative, to disclose, update (renew, delete or add information), to stop use (stop use of the information, or stop providing information to a third party). Please note we will identify and verify the identity of users in a manner that we deem appropriate. If we are unable to identify you, or you are unable to verify yourself by providing the information that we require, we may refuse to provide you with any information or refuse to carry out any request.

Providing Personal Information to a Third Party
We will take care and treat with caution any personal information obtained from you, and we will not provide your personal information to any third party without your prior consent, except in the following instances:
・Where we are legally required by law.
・Where there is a threat posed to a person or a person’s property.
・Where it is difficult to obtain your permission,and is disclosure is necessary for reasons attributable to protection of public health and the safety of children.

・Where the seeking of permission could prejudice a legal or regulatory operation, conducted by the government, local government or any one entrusted by the government.

・Where disclosing information to a bank, credit card company and/or other debt recovery agency for the purpose of conducting settlements for providing services.

・Where we transfer all or part of the services that we provide to a third party, to the extent necessary to operate the relevant service. Where we are disclosing information to a person who is bound by obligations of confidentiality to us. If a merger or a transfer of our business occurs for any reason, we will disclose personal information to our successor, who will also be bound by obligations of confidentiality.

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