With its slogan of “Bringing Learning to People Everywhere!”, UIcommons Inc. (the “Company”) provides learning opportunities across a variety of life and lifestyle situations, primarily through its “GoGetterz” online comprehensive learning platform, utilizing the internet, mobile, live events and a wide variety of other media. All of our employees are aware of the importance of the personal information the Company handles in the course of its business activities, and we work to protect that personal information in line with our Policy on the Protection of Personal Information (the “Privacy Policy”), as stated below.

• The Company complies with all laws, government policies and other standards regarding the handling of personal information in all of its businesses, including its handling of employee personal information, and manages such information appropriately.
• When collecting personal information, the Company shall clarify in advance the purpose of such information collection, and upon obtaining the individual’s prior consent, shall obtain said information in a lawful manner and use it appropriately within the scope of said purpose.
• When using personal information it has collected for other than the intended purpose, or when providing personal information to a third party, the Company shall obtain the individual’s prior consent.
• When entrusting personal information it has collected to an outside party, the Company shall select a vendor that meets adequate protection standards, and shall take appropriate steps to ensure personal information is protected through contracts and other means.
• In response to the risk of leak, loss of or damage to personal information, the Company shall take reasonable security measures and corrective action, working to ensure the security of that information.
• The Company shall establish a Personal Information Inquiry Center, and shall promptly respond to complaints from individuals regarding the handling of personal information, as well as to requests for advice, disclosure, corrections and deletions.
• The Company shall set forth internal rules regarding the collection, management and handling of personal information, establish systems for personal information protection, and shall continually review and make improvements to these rules and systems.

October 1, 2015
Haruo Matsubara
CEO
UIcommons Inc.

Handling of Personal Information

UIcommons Inc. (the “Company”) shall respect the privacy of users of this site (the “Users”), and shall take the utmost care in the management and handling of personal information as defined below.

Personal Information

Personal information refers to information about an individual in which the name, address, telephone number, mail address and other descriptions, etc. comprising said information can be used to identify the individual. This includes personal information that can easily be checked against other information, resulting in identification of the individual even when identification cannot be made through the personal information alone.

Intended Use of Personal Information

The Company shall use the personal information it obtains on its Users for the following purposes (the “Intended Use”). It shall not use said information beyond the Intended Use.

1. When User uses the Company’s service
   Personal authentication during and after login, and automatic display of member information on various pages.
2. When executing transactions provided by the Group
   When a User pays tuition fees, enters giveaways, or applies for other transactions, personal information is used to conduct business necessary for payment settlement, response to User inquiries, inquires from the Company to the User, related follow-up services and for executing other transactions.
3. In the Company’s advertising, marketing, etc.
   • To provide information, including various email newsletters for Users, etc.
   • To provide information on services via email, post, telephone, etc.
   • To personalize the content and advertising a User sees based on user attributes such as gender, age, address, hobbies and preferences, etc., or through the User’s purchasing history and history of viewing websites operated by the Company.
   • To develop new services and improve existing ones by analyzing User use of the services.
   • To exchange information and opinions with Users via questionnaires, campaigns, and bulletin boards, and for contact with users related to blogs and other services.
4. In response to User inquiries
   • To respond to email, post, telephone and other inquires from Users.
5. In association other business
   • Other use required in providing the Company’s services in association with items 1. through 4. Above.

Providing Personal Information to Third Parties

As a rule, the Company does not provide personal information to third parties without obtaining the personal consent of the User. Personal information shall be provided only when User consent has been obtained after first specifying the recipient of the information and its content. However, in the following cases personal information may be provided without User consent to the extent that doing so does not violate relevant law.

1. When the User is deemed to have caused detriment to a third party.
2. When particularly necessary to improve public health or advance the healthy development of children, and when obtaining the personal consent of the User is difficult.
3. When necessary to cooperate with the execution of the legally prescribed duties of a state body, local public body or a party to whom such duties have been entrusted, and when obtaining the personal consent of the user may hinder the execution of those duties.
4. When the User has explicitly requested that the information be disclosed or provided to a third party.
5. When such disclosure or provision is allowed by law.

Procedures for Responding to Requests for Disclosure, etc.

The Company shall respond promptly in the event of a request from a User or his or her proxy for notice of the intended use of personal information; for disclosure; for corrections or additions to or deletion of personal information; or for discontinuation of use of or provision personal information to a third party (the “Request for Disclosure, etc.”).

1. In the Company’s advertising, marketing, etc.
   • Personal attributes
     Name, telephone number, name of employer (or school), telephone number of employer (or school), department name, occupation, email address, etc.
2. Making a Request for Disclosure, etc.
   • As a rule, requests are accepted by post. Because this requires the use of a prescribed “Request for Personal Information Disclosure, Correction, Deletion, etc.” form, the User should contact the Personal Information Inquiry Center noted at bottom.
     A “Request for Personal Information Disclosure, Correction, Deletion, etc.” form will be sent; the User should fill out the required items on that form before returning it along with any required documentation.
3. Documentation, etc. to be submitted when making a Request for Disclosure, etc.
   (In the case of an application directly from the User)
   • The “Request for Personal Information Disclosure, Correction, Deletion, etc.” (in the form prescribed by the Company).
   • A copy of an official proof of identification, including a driver’s license, passport, Basic Resident Registration Card (with photo), or other government-issued license (with photo).
     (In the case of an application from a legal proxy)
   • The “Request for Personal Information Disclosure, Correction, Deletion, etc.” (in the form prescribed by the Company).
   • A copy of the individual’s official proof of identification, including a driver’s license, passport, Basic Resident Registration Card (with photo), or other government-issued license (with photo).
   • Document providing proof of a relationship with the User of parental authority, either a family registry or resident registration certificate.
   • Document providing proof of a relationship with the User of adult guardianship, conservatorship, or limited guardianship, either a Certificate of Registered Matters of the adult guardian, conservator or limited guardian, or an elective decision document issued by the court (copy).
   • A letter of proxy signed by and affixed with the seal of the individual making the Request for Disclosure, etc., or the seal registration certificate of the individual making the Request for Disclosure, etc. (issued within the previous three months).

   Note: “Permanent Domicile” should be blacked out when submitting copies of official identification documents.

4. Application fee for Request for Disclosure, etc. and method of collection
   A fee of 840 yen will be charged for each notice issued (disclosure of personal information, notification of intended use). Postage in the amount of said fee should be included with the “Request for Personal Information Disclosure, Correction, Deletion, etc.” form and attached documentation.
   Note: Documents and fees submitted will not be returned.
5. Method of notification in response to a Request for Disclosure, etc.
   Notification will be sent by registered mail.
   To allow time for administrative procedures and internal review, notification will be sent approximately two (2) business days from receipt of the “Request for Personal Information Disclosure, Correction, Deletion, etc.” The User will be contacted in advance if more time is required and notification cannot be provided within two business days.
6. Intended use of information obtained with regards to a Request for Disclosure, etc.
   Personal information obtained in association with a Request for Disclosure, etc. shall not be used for any purpose other than work related to the disclosure request.
   Note that documents submitted shall be retained for two (2) years following completion of the response to the Request for Disclosure, etc. after which they will be shredded and disposed of.
7. Precautions
   Understand that in the event any of the following apply, disclosure cannot be made. If disclosure is not possible, the User will be notified of the reason.
   • When disclosure may harm the life, limb, assets or other rights and benefits of the subject of disclosure or other third party.
   • When the subject of disclosure cannot be verified.
   • In the event of an request by proxy, where proxy authority cannot be verified.
   • When the applicant is unable to complete the Company’s procedures.
   • Otherwise when doing so would constitute a violation of the law.
   • When doing so may significantly hinder the reasonable conduct of the Company’s business.

Data Collected

In general, users can navigate around the website without sharing any personal information about themselves or represented organization. However, there are areas of the whole website that do require users to register with an email address and be logged-in to provide a customized experience, including a user’s usage and management of the contents of the website, event management, and any purchases. The site may request and need to know the user’s name, age, company name, street address, or telephone number as well as payment information to fulfill certain functionalities. Sections or portions of the website may not be accessible to users who have not registered and/or logged onto the website platform. 
The website collects and stores a user’s IP address, device type used, browser, operating system, and also the user’s latitude and longitude gathered from the IP address. This data is used to present geographic-relevant contents, language, and payment systems in an automated fashion per user’s collected IP address. This collected data is strictly used to enhance the performance and experience of the website to its users and is not deliberately shared with any third parties.
The website may also feature registration and other functionality such as content sharing via social media frameworks. These social media outlets include, but are not limited to, Facebook, Twitter, Instagram, and YouTube. These social media sites may set and use browser cookies to manage and maintain the user’s usage and navigation on the website; however, these interactions and features will be governed by the privacy policy of the respective social media company.

Outsourcing of Personal Information Processing

The Company may outsource all or part of the work related to the handling of personal information. Note that the Company shall bear responsibility for the handling of personal information by the outsourcing company.

Use of Statistically Processed Data

The Company may use the personal information provided to prepare statistical data, structured so that individuals cannot be identified. The Company shall be able to use such statistical data without limitation.

Personal Information Management

The Company shall maintain the latest and most accurate personal information, and shall put in place steps to prevent unauthorized access to and loss, destruction, alteration and leakage, etc. of personal information.

Contact for Personal Information Disclosure, Complaints and Consultation

UIcommons Inc. Personal Information Inquiry Center (Personal information protection administrator: Haruo Matsubara)
Shinagawa East One Tower 7F, 2-16-1 Konan, Minato-ku, Tokyo, 108-0075
Tel. 03-6822-8020 (11 a.m. – 7 p.m. excluding Sundays and national holidays)

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