Privacy Policy

Kabushikigaisya Cyberneura. (hereinafter referred to as “the Company”) hereby establishes and publicly declares its policy regarding the handling of personal information, which it will strictly adhere to.

1. Definition of Personal Information

“Personal Information” refers to information about living individuals as defined by the Personal Information Protection Law, which falls under the following categories:

  • Information that can identify a specific individual through descriptions such as name, date of birth, or other details (including information that can be easily cross-referenced to identify a specific individual)
  • Information containing personal identification codes

Personal information recorded by the Company is referred to as “Retained Personal Data”.

2. Personal Information Protection Policy

The Company fully recognizes its social mission in protecting all personal information it handles, and will comply with regulations protecting individual rights and laws related to personal information.

a. Personal information will be collected, used, and provided only within the necessary scope of legitimate business operations, employment, and personnel management. The Company will not use personal information beyond its specified purpose and will implement measures to prevent such unauthorized use.

b. The Company will comply with laws, guidelines, and other norms related to personal information protection.

c. The Company will continuously improve its personal information security system by investing appropriate management resources to prevent risks such as leakage, loss, or damage of personal information. If any issues are identified regarding personal information protection, corrective measures will be promptly implemented.

d. The Company will respond quickly, sincerely, and appropriately to complaints and inquiries regarding personal information handling.

e. The Company will continuously review and improve its management system and mechanisms for personal information protection.

3. Handling of Personal Information

Collection of Personal Information

The Company collects personal information such as names, email addresses, linked social account IDs, profiles, avatar images, addresses, phone numbers, and payment program identification IDs when providing services.

Purpose of Personal Information Use

Purpose of Personal Information Directly Obtained from Providers

The purpose will be clearly stated in writing to the provider prior to collection.

Purpose of Personal Information Obtained through Other Methods

Personal Information Received from Business Partners

To appropriately execute the commissioned business

Disclosure of Personal Information to Third Parties

The Company will not disclose personal information to third parties without the provider’s prior consent. However, disclosure may occur in the following cases:

  1. When legally required to disclose
  2. When the Company determines disclosure is necessary to protect the rights, interests, honor, or reputation of the Company, other providers, or third parties
  3. When the provider has pre-approved disclosure of their personal information

4. Notification of Retained Personal Data

For requests related to the use purpose, disclosure, correction, addition, deletion, suspension of use, erasure, and suspension of third-party provision of personal data or third-party provision records (hereinafter “Disclosure Requests”), the Company will respond as follows:

a. Business Name

Kabushikigaisya Cyberneura.

b. Personal Information Protection Manager

Yotsuyanagi Takeshi

c. Procedure for Handling Disclosure Requests

c.1. Contact Point for Disclosure Requests

Disclosure requests can be made through the personal information inquiry window below.

c.2. Procedure for Disclosure Requests

  1. After receiving your request, the Company will send you a designated request form “Retained Personal Data Disclosure Request Form”.
  2. Please send the completed request form, documents confirming the representative’s authority (if requested by a representative), and postal money order for fees (only for purpose notification and disclosure requests) to the personal information inquiry window.
  3. After receiving the request form, we will confirm your identity by cross-referencing 2 items of registered personal information (e.g., phone number and date of birth).
  4. Responses will be made in writing (via postal mail) to the individual.

c.3 Documents Required for Representative Requests

When the request is made by a representative, please include documents proving the representative’s authority and the representative’s own identification. For documents containing domicile information, only include the prefecture, and black out any additional information. Ensure that documents do not include personal numbers, or black out all digits.

c.3.1. Documents Proving Representative Authority
For Representatives Authorized by the Individual
  • Original power of attorney from the individual
  • Family register transcript
  • Residence certificate (with family relationship noted)
  • Other official documents confirming legal representation
  • Registration certificate of adult guardianship
  • Other official documents confirming legal representation
c.3.2. Representative Identification Documents
  • Driver’s license
  • Passport
  • Health insurance card

c.4. Fees for Purpose Notification or Disclosure Requests

1,000JPY per request

(To be sent with postal money order)

d. Procedures for Correction and Deletion of Retained Personal Data

The Company will appropriately handle requests for correction or deletion of retained personal data in accordance with the Personal Information Protection Law and other regulations.

Requests for correction or deletion should be made through the personal information inquiry window.

5. Company’s Personal Data Security Measures

Basic Policy

The Company establishes a “Personal Information Protection Policy” and implements commercially reasonable technical, operational, and organizational measures to protect personal data from loss, improper use, unauthorized access, leakage, alteration, or destruction.

Access Control and Management

When handling personal data using information systems, appropriate access controls will be implemented to limit personnel and the scope of personal data handled.

The Company will authenticate users with legitimate access rights based on identification.

Measures will be implemented to protect information systems from unauthorized access and malicious software.

Measures will be implemented to prevent leakage of personal data during information system use.

System Monitoring

The Company will monitor information system usage and implement measures to detect unauthorized access, improper use, malicious software, and prevent personal data leakage.

Software Vulnerability Management

The Company will identify software vulnerabilities in information systems and implement early updates and appropriate corrections. Updates addressing vulnerabilities will be prioritized over system normal operation.

External Environment Assessment

When outsourcing personal data to external businesses, the Company evaluates and appropriately supervises contractors.

Disclaimer

Internet and email communication are not completely safe or error-free. Users should be cautious about the information they provide.

The Company bears no responsibility for privacy settings or security measure bypasses on its services or third-party websites.

5. Personal Information Contact Window

Inquiries about Kabushikigaisya Cyberneura.’s personal information can be made through the following chat:

https://www.contiful.com/chat/cyberneura-privacy/