1. Definitions

1. (1) In this Privacy Policy, personal information is as defined in Article 2.1 of the Personal Information Act.
2. (2) In this Privacy Policy, historical information and attribute information refers to information that cannot alone identify a specific individual, even if it relates to an individual. Some examples are cookies (※1), IP address information, website and app browsing history, action and purchase history, device ID, user agents (※2), referrers (※3), and attributions and other analogous information (refers to gender, age, browsing history, action and purchase history, advertising ID for mobile devices, and location information).

2. Compliance with Laws and Regulations

Our company will comply with the laws and regulations related to the protection of personal information, as well as conform our rules, including the Privacy Policy, to the Personal Information Regulations.

3. Management of Personal Information and Others

1. (1) Our company will endeavor to keep personal, historical, and attribute information (hereinafter referred to as "Personal Information and Others") accurate and up-to-date, as well as taking necessary and appropriate measures to protect it from unauthorized access, alterations, leakages, loss, or damage.
2. (2) Our company will pay the utmost attention to managing information handled by Scrumy.
3. (3) Our company restricts the access of Personal Information and Others only to employees who need it to perform their duties. Additionally, when employees manage Personal Information and Others, they are supervised to make sure they are handling it safely.

4. Limitations on the Collection of Personal Information

1. (1) Our company will not collect personal information such as the user's name, home address, workplace, and email address through Scrumy.
2. (2) When our partner (i.e. a company that uses Scrumy) uses Scrumy, we will form a Scrumy use agreement with the partner and they will be entrusted with necessary personal information for the use of Scrumy.

5. Purpose of use of Personal Information

Our company may use users' personal information for the following purposes, within the scope of the entrustment of the handling of personal information by our partners.

1. (1) For our company or partners to analyze the attributes and preferences of users and to display or send optimized content and advertisements via advertisements, email, SMS, online chat, and browser notifications.
2. (2) For our company or partners to accurately understand the contents of inquiries and to send responses.
3. (3) To monitor users' fraudulent activities.
4. (4) For the creation of analogous information and statistical information such as attributes. Additionally, when our company creates such information, we will anonymize it so that individuals cannot be identified.
5. (5) For our partners to replay visitor behavior as well as to view, record, and analyze data necessary to identify the cause of system problems and to improve services provided by partners.

6. Prohibition of Provision of Personal Information to Third Parties

Our company will not disclose personal information to third parties without the consent fo the user, except in the following cases.

1. (1) When the provision of personal information to a third party is permitted by law or without the consent of the user in accordance to Article 23, Paragraph 1 of the Personal Information Act.
2. (2) When our company entrusts necessary personal information for the reason above.
3. (3) When personal information is provided as a result of the succession of business due to reasons such as a merger.

7. Policies When our Company is Entrusted with Duties Related to Personal Information

1. (1) Our company will perform duties related to personal information entrusted to us by partners in accordance with the Privacy Policy. When our company performs duties related to personal information, we require partners that the personal information has been obtained accordingly, that it does not go against the application laws (foreign laws included), and that it does not go against the rights of the third party.
2. (2) Our company will make clear the intentions of use of the personal information (hereinafter referred to as "Scrumy usage agreement"), as well as following them appropriately. Our company will not handle personal information outside this scope.
3. (3) Our company will receive appropriate supervision from the partner the personal information has been entrusted to.

8. Supervision of Contractors

To achieve the purpose described in Section 6, our company may outsource all or parts of duties related to partners' personal information to a third party (such as an email delivery service provider). In this case, we will select the third party in accordance with the Personal Information Act, will conclude a contract including confidentiality, and will conduct necessary and appropriate supervision to ensure the third party manages personal information safely.

9. Deletion of Personal Information

Upon the termination of the Scrumy usage agreement, we will delete personal information provided by the partner within 90 days.

10. Disclosure and correction of Personal Information

When our company receives a request for disclosure, correction, deletion, or suspension of use of personal information by the user themselves, we will investigate the request within a reasonable time period and in accordance with the law, upon verification of the user. Please note that our company will charge a handling fee in such cases.

11. Collection of Historical and Attribute Information

1. (1) When our company provides Scrumy to partners, we will collect historical and attribute information of users who visit websites or applications operated by partners. Additionally, the cookies we generate as reference for browsing, activity, and purchase history cannot be used to identify users. We retain cookies for a maximum period of two years from the date the user last accessed the website.
2. (2) Our company may collect historical and attribute information from third parties that operate advertising networks.

12. Purpose of Use of Historical and Attribute Information

Our company may use users' historical and attribute information for the following purposes.

1. (1) For the purposes set forth in Section 5.
2. (2) To measure and improve the effectiveness of our, and our partners', services, advertising, and marketing.
3. (3) To analyze the market and for marketing.
4. (4) To improve our services and develop new services.

13. Prohibition of Provision of Historical and Attribute Information to Third Parties

If we disclose historical and attribute information collected by us to third parties, we will comply with the privacy policy of the website or application that collected the information. However, this does not apply to the purposes set forth in Section 6 or if the user consents to the disclosure.

14. Supervision of Contractors

To achieve the purpose set forth in Section 12, our company may outsource all or parts of the duties related to handling historical and attribute information to third parties. In this case, our company will appropriately select the third party with the purpose of protecting the information in mind, sign a contract which includes confidentiality with the third party, and appropriately supervise the entrusted party to ensure safe management of historical and attribute information.

15. Suspension of Collection of Historical and Attribute Information

1. (1) Our company will provide users with a means to stop the collection of the user's historical and demographic information. Once this suspension has been set, our company will not collect any historical or attribute information of the user.
2. (2) The suspension of the collections of historical and attribute information as described previously must be performed for each browser or device used by the user. Please note that after the suspension has been set, our company will not collect any historical or attribute information, however, if this is set by deleting cookies or other device settings, the collection may resume.

16. Continuous Improvement of the Privacy Policy

To maintain the appropriate handling of personal information, our company will review the Privacy Policy periodically and will continuously improve the system for handling personal information to meet the current standards. Additionally, if laws related to handling personal information are enacted or revised, we will establish a system to conform to the change.

17. Changes to the Privacy Policy

Our company reserves the right to change the Privacy Policy at any time without obtaining prior consent of the users. If we change the privacy policy, we will post the changes to the Privacy Policy as well as appropriate locations on our website.
The changes will take effect one week after our company announces it on the website.

18. Inquires

For any inquiries regarding the Privacy Policy or disclosure of personal information, please direct them here.

【Additional notes】

1. （※1）"Cookie" refers to a text file that identifies the computer device used by the user, without identifying the user. Cookies are stored on a device through the user's browser. Cookies do not identify the user but is commonly used by many websites to use browsing history information and such to operate and improve the website as well as optimizing content (including text, sound, images, video, and software).
2. （※2）"User agent" refers to information that is automatically sent by the browser to identify the browser and device used without identifying the user.
3. （※3）"Referrer" refers to the URL of the page from which a link originates. This URL is automatically sent by the browser when a user moves from one web page to another.