As a cutting-edge network entertainment operator, Dwango Co., Ltd. (“the Company”) prioritizes the future of communications. Toward the realization of its vision, the Company takes the measures specified herein based on awareness of its social responsibility and the need to protect personal information relating to clients and employees.
The Company shall employ a personal information manager to chair its Risk Management Committee, and shall operate a related management system. Specific corporate regulations shall mandate criteria for administration of appropriate acquisition, use and provision of personal information, and training shall be provided as appropriate. All staff shall handle personal information in accordance with these regulations.
The Company shall implement a reasonable level of safety management to prevent and remedy any personal information leakage, unauthorized access, unjust falsification, loss and damage.
The Company may collect names, addresses, dates of birth, telephone numbers, e-mail addresses, bank account details and other personal information (as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information) as well as consent details/acquired information (“User Information”) from users of services provided by the company (“the Services”).
The following data collected by the Company with permission from the user of the Services permitting linkage with external services:
- ID and other information relating to the user for external services
- Information approved by the user for disclosure to linked external services based on privacy settings
The following data relating to access to and use of the Services:
- Device identification information
- Communication history
- History of services used and pages/advertisements viewed by the user
- Cookie information
- Location information
2.Purposes of use
The Company defines the purposes of use for User Information as follows, and shall not use such for any other purposes:
- Service provision
- Response to queries
- E-mail communication regarding new functions, updates, promotions and other information related to the Services
- Dispatch and return of orders, free gifts and prizes
- Interaction with users for confirmation of delivery
- Orders, payment and other processes
- Essential communication regarding maintenance and other matters
- Tabulation and analysis of attributes relating to personal information and User Information, and production of statistics (not allowing individual identification) supporting provision of the Services, such as the development of new services or provision to affiliates
- Marketing research/planning and R&D
- Improvement of the user experience, such as customization of advertising and content provided to individual users of the Services
- Capacity for users to view, change or delete registration information and view usage status
- Charging for fee-based services
- Provision of information to users on their content uploads to the Services
- Provision of information to users regarding services offered by sponsors and affiliates in advertising. The term “affiliates” here relates to affiliate operators jointly providing services and entities conducting joint research with the Company or its group companies. Personal information shall not be provided to affiliates except as specified in 3 and 4 below, and in such cases the Company shall provide appropriate supervision.
- Provision of the minimum amount of User Information necessary where services are provided by an affiliate in conjunction with the Company (“Joint Services”)
- Provision of collected information to affiliates (not including user IDs or other information allowing individual identification) for joint research regarding service and technological improvement (with potential publication of results)
- Provision to group companies
3.Provision to group companies
The Company may provide personal information and User Information for use by its group companies.
Users may opt out of such provision (see “10. Contact information”).
Information to be provided
- All personal information and User Information collected by the Company
- Delivery in writing, via recorded media or by electronic transmission
4.Provision to third parties
The Company shall not provide personal information to third parties without user consent except when:
- required to do so by laws or regulations;
- the Company outsources personal information to the extent necessary for the purposes of use;
- provision is necessary to protect life, person or assets, and obtaining user consent is impractical;
- provision is necessary in the interests of public health or the sound development of minors, and obtaining user consent is impractical;
- there is a need to cooperate with national or local government bodies or related subcontractors in the performance of relevant duties as prescribed by laws or regulations, and such performance may be hindered by the need to obtain user consent; or
The Company may subcontract certain tasks, including the handling of personal information, to the extent necessary for the provision of goods and services. In such cases, the Company shall conclude an agreement requiring the subcontractor to take measures against leaking or re-providing personal information without the Company’s consent, and shall supervise the subcontractor appropriately. Subcontractors may contact users directly where necessary in the provision of goods and services.
The Company shall provide the Services in accordance with laws and other regulations to prevent leakage of personal information. However, the Company shall not be responsible for issues caused by the acquisition of personal information by any third party in the following cases:
- A user provides personal information to another user via functions of the Services or by other means.
- A user is identified by chance from information input by another user via the functions of the Services.
- Leakage or similar occurs with no negligence on the part of the Company.
If a user requests disclosure of personal information in accordance with the Act on the Protection of Personal Information, the Company shall disclose such information after verifying the identity of the requesting party, and shall notify the user if the information is not on record. This shall not apply if the Company is not required to disclose such information in accordance with the Act on the Protection of Personal Information or other laws/regulations.
If a user requests amendment (correction, addition or deletion) of personal information due to inaccuracy, the Company shall conduct diligence as necessary without delay to the extent necessary for the purposes of use after verifying the identity of the requesting party, decide whether to amend the information based on the results of verification, and notify the user of the outcome. This shall not apply if the Company is not required to make amendments in accordance with the Act on the Protection of Personal Information or other laws/regulations.
9.Suspension of use
If a user requests suspension of use or deletion of personal information in accordance with the Act on the Protection of Personal Information due to handling outside the purposes of use or acquisition by unlawful means, and the request is deemed valid, the Company shall fulfill the request without delay after verifying the identity of the requesting party and notify the user of the outcome. This shall not apply if the Company is not required to implement suspension or deletion in accordance with the Act on the Protection of Personal Information or other laws/regulations.
Feedback, questions, complaints and other inquiries regarding personal information can be submitted to the inquiry desk.
To request disclosure, amendment, suspension of use or deletion of personal information, contact the inquiry desk with the following information:
-  The information in question
-  The service to which the request pertains
-  The reason for the request
-  The desired action (disclosure, amendment, suspension of use or deletion)
Requesting parties shall be required to provide identifying documentation as specified by the Company. Upon verification, the Company shall handle the request without delay in accordance with the Act on the Protection of Personal Information. Documentation verifying the authenticity of proxy requests must also be provided.
Optimal service provision cannot be guaranteed to users whose information is not kept up to date.
This policy shall be interpreted exclusively on the basis of its original Japanese version. Any translations are provided for user convenience only, and shall not be valid for such interpretation.