Privacy Policy and Handling of Personal Information

1. Name or title of business operator

AXXZIA Inc.

2. Name or occupation title, affiliation and contact information of administrator of personal information protection (or his/her proxy)

Manager of personal information protection Management department Yasuhito Fukui
Email: privacy@axxzia.co.jp

3. Use purpose of personal information handled by the Company

We do not use personal information for any purposes other than those stipulated in the following items.

1. To introduce our products and services to customers
2. To engage in order procedures, confirmation of order content, and changing procedures on behalf of customers
3. To engage in future improvement pertaining to opinion/request toward the Company, and responding to inquiry
4. To request customers to provide us with their opinion and review concerning our service
5. To send out prize to applicant of campaign, etc.
6. To create statistical material categorized per customer attribute (age, address, etc.) for product development and marketing.
7. To transmit information, provide/display service that matches the preference of each customer
8. To provide service through device/apps. sold/provided by us
9. To ship our products
10. To manage information of customer who purchased our products
11. To implement counseling
12. To provide answers to various inquiries and opinions made toward our IR
13. To provide various information concerning status of shareholders, and to carry out policies in order to make a smooth relation with shareholders
14. To exercise rights pursuant to relevant laws and regulations such as Companies Act, performance of obligation, and management of shareholders/shares
15. To engage in contact/cooperation/negotiation/performance of contract, etc. pertaining to our business divisions in relation to clients
16. To engage in personnel management/salary payment/deduction related processing/entering and existing of room control, etc. pertaining to our employees
17. To implement provision of information/selection procedure for applicant/contact pertaining to result/procedure before entering the Company relating to our employment

※In addition, we may engage in a separate contact to a subject person in advance, and may use it for purposes individually agreed by a subject person

4. Personal data safety measures

We will take reasonable safety measures in relation to personal data access management, restriction on the means of carrying out, unauthorized access, leakage, loss, destruction, alteration, etc., so as to maintain the accuracy and security of personal data, and in case of an accident related to personal data such as leakage, we will immediately take appropriate measures including measures to prevent recurrence.
The following security measures are taken for the personal data retained by our company (retained personal data):

1. Establishment of regulations regarding the handling of personal data
   We have established regulations regarding how to handle personal data, etc. at each stage, including acquisition, usage, storage, provision, deletion, and destruction.
2. Understanding of external environment
   When handling personal data overseas, we conduct safety control measures after understanding the regulations regarding personal data protection in the relevant countries (see URL below).
   https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku
   (Personal Data Protection Commission website　“Surveys of systems regarding personal data protection in foreign countries”)
3. Systematic safety control measures
   We appoint a chief privacy officer and protect, manage and use personal data appropriately. We also conduct regular checks and audits into how personal data is handled by the audit department and other parties.
4. Human safety control measures
   We provide regular education regarding the points of consideration in terms of the handling of personal data to ensure that employees handle personal data appropriately.
5. Physical security control measures
   We conduct entrance and exit control at the rooms of employees in the territories handling personal data and measures to prevent unauthorized persons from viewing personal data. We also take measures to prevent the theft and loss, etc. of devices, electronic media, and documents, etc. used to handle personal data, as well as measures to prevent leakage of personal data when carrying devices and electronic media, etc. used to handle personal data.
6. Technical safety control measures
   We limit the persons in charge and the scope of personal data to be handled by implementing system construction, management, operations, and security measures, etc. We also implement a structure to protect the system used to handle personal data from illegal access from outside.

5. Outsourcing of personal information

We may outsource work to handle personal information to external business operator within the scope necessary to achieve specified use purpose. In such case, we will engage in proper control and supervision of outsourced party by executing confidentiality agreement with such external business operator. (Outsourced party refers to transporter, printing company to send out direct mail, outsourced company to collect overdue payment of product, etc.)

6. Providing personal information to a third party

We do not provide or disclose personal information to a third party such as other business operator and individual without the permission of a subject person provided, however, that it shall not apply if falling under any of the following items.

1. If consented by a subject person concerning provision of information
2. In the case where it is difficult to obtain a consent of a subject person, sending a prior notice to a subject person, or taking similar measure in place of such notice pursuant to the procedures stipulated by laws and regulations, etc.
3. In the case where information of officers and shareholders of corporation or other organization included in the information of such corporation or other organization, and in the case of providing information disclosed or publicly announced by a subject person or such corporation or other organization, if notice is made to a subject person or placing it in a condition where easily accessible by a subject person in advance
4. In the case of outsourcing work to external business operator within the scope necessary to achieve the specified use purpose pursuant to the provision of the above “Outsourcing of personal information”
5. In the case of providing personal information accompanying the succession of business due to merger and other reasons, and if handling such personal information within the scope of use purpose prior to succession
6. In the case of joint use of personal information, if joint use is stipulated by an agreement
7. If disclosure is required by laws and regulations
8. In the case where it is necessary to protect life, body or property of a person, and it is otherwise difficult to obtain the consent of a subject person
9. In the case the information is especially necessary for improvement of public health or promotion of sound growth of children, but is difficult to obtain the consent of a subject person.
10. When there is a need to cooperate with national institutions, local public organizations, or those who have been entrusted by these organizations to execute duties in line with legal stipulations, amidst situations whereby obtaining the consent of a subject person would create barriers to the execution of these duties.
11. In the case of other person excluded from obligation of personal information handling business operator, etc., and personal information in need of consideration disclosed by the provision of personal information protection committee rules, or personal information in need of consideration stipulated by government ordinance
12. In the case where it is necessary to cooperate with implementation of work stipulated in laws and regulation by national institution, local public organization or a person entrusted by such institution/organization, if obtaining the consent of a subject person may interfere with implementation of such work
13. When using it as statistical information (information that cannot specify a customer)
14. When the personal data is disclosed to a payment company with the consent of the customer in order for the payment company to provide identity verification, confirmation of billing address, credit check and other services

7. Cookie

Cookie refers to one of data accumulated in your hard drive including your information. Use of Cookie will not be linked to personally-identifying information on our website. Even if you refuse Cookie, you can still use our website. On our website, Cookie is being used in product detail page and shopping cart. Shopping cart will not operate if you reject Cookie. We do not use Cookie to collect unnecessary information. If you wish to use it in a cart format (not limited to our website), we recommend you to activate Cookie settings in your browser. We do not use Cookie for any purposes other than to display purchase history of cart/yourself, so please active Cookie settings in your browser if you wish to use it in a cart format. Our website contains page that uses such Cookie to collect access log to help improve usability of our website, and for your further convenience to save time from having to input personal information when you revisit our website.

8. Procedures to respond to request for disclosure, etc.

1. Retained personal data
   If a subject person requests for notice, disclosure, correction of content, addition or deletion, suspension of use, erasure and suspension of provision to a third party concerning use purpose (hereinafter, “disclosure, etc.”) pertaining to retained personal data handled by the Company, please contact the following paragraph 9 “Personal information inquiry counter”.
2. Place of request for disclosure, etc.
   Please contact the following paragraph 9 “Personal information inquiry counter” concerning the request for disclosure, etc. If you request for disclosure, etc. concerning your own personal information retained by us, please submit a document prescribed by the Company by entering necessary matters in such document.
3. Upon your request for disclosure, etc., we will confirm the identification of a subject person. Depending on the case, we may ask you to mail us the copy of public certificate for confirmation purposes.
   ※ If you are using a proxy, we will have you submit the letter of proxy for confirmation purposes. Please also note that if you are using proxy, you will need to submit a copy of public certificate for both subject person and proxy. Furthermore, we do not accept any request for disclosure, etc. via telephone, email, FAX, etc., so please submit request through a method such a simplified registered mail where we can obtain the sending record.
4. Among request for disclosure, etc., if request falls under “Use purpose notice” or “Disclosure”, a service fee up to 1,000 yen will be charged. We will contact you separately if the case clearly exceeds such amount.

9. Personal information inquiry counter

If you have any request, question, complaint, consultation, etc. concerning our handling of personal information and retained personal data, etc., please contact the following “Personal information inquiry counter”.

AXXZIA Inc. Personal information inquiry counter
Shinjuku Sumitomo Building 35F, 2-6-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo, 163-0235 Japan
Email: privacy@axxzia.co.jp

To further improve protection of your personal information, we may change “Handling of personal information” without a prior notice due to business necessity, enforcement of new laws and regulations, revision of existing laws and regulations, and other reasons. If we make any changes, we will make notice by displaying it on our website. Please confirm the latest content of our website when using our service.

Data Collection Methods

For the website, we use a technology called cookies that identifies the user's browser. We do not use access data that is two years old from the date of collection.

Access data is collected by other companies, such as ad-serving companies, and is used for purposes such as the delivery of behaviorally targeted advertising. For details, please refer to the policies of the relevant service providers. For the privacy policy and opt-out method of each service provider, please refer to the following.

▼ Privacy Policy and Opt-Out Method of Each Advertising Service Provider
In the case of apps, IDFA (iOS devices) and AAID (Android devices) technology is used to identify the user's device. These identifiers can be reset or opted out by the user.
For more information, please click here >.

How to reset and opt-out

• For iOS devices
  Go to "Settings" > "Privacy" > "Ads" and select "Limit Tracking Ads".
• For Android devices
  Go to "Settings app" > "Google" > "Ads" and select "Opt out of personalized ads".