PRIVACY
POLICY

polyhedron Inc. understands personal information to mean information about a living individual as defined in the Act on the Protection of Personal Information (name, date of birth, and other information by which a specific individual can be identified), together with information used in connection with a specific individual such as an email address, membership number, password or credit card details, and attribute information about an individual — interests, family composition, age and the like — held together with that personal information.

polyhedron Inc. specifies the purpose of use as far as possible when handling personal information.

polyhedron Inc. does not handle personal information beyond the scope necessary to achieve the stated purpose of use without the prior consent of the individual. Where personal information is acquired through a merger or for another reason, it is likewise not handled beyond the scope of the purpose of use that applied before the succession without prior consent. The following cases are exceptions.

1. Where required by law

2. Where it is necessary to protect the life, body or property of a person and the consent of the individual is difficult to obtain

3. Where it is particularly necessary to improve public health or to promote the sound growth of children, and the consent of the individual is difficult to obtain

4. Where it is necessary to cooperate with a national body, a local authority or a party commissioned by one of them in carrying out duties prescribed by law, and obtaining the consent of the individual is likely to impede those duties

polyhedron Inc. acquires personal information properly, and does not acquire it by deception or other improper means.

polyhedron Inc. publishes the purpose of use in advance when acquiring personal information. The following cases are exceptions.

1. Where notifying the individual of the purpose of use, or publishing it, is likely to harm the life, body, property or other rights and interests of the individual or of a third party

2. Where notifying the individual of the purpose of use, or publishing it, is likely to harm the rights or legitimate interests of ETB RIGHTS Inc.

3. Where it is necessary to cooperate with a national body or a local authority in carrying out duties prescribed by law, and notifying the individual of the purpose of use, or publishing it, is likely to impede those duties

4. Where the purpose of use is clear from the circumstances of acquisition

Where polyhedron Inc. changes the purpose of use of personal information, it does so only within a scope reasonably considered to be duly related to the purpose before the change, and notifies the individual of the changed purpose or publishes it.

polyhedron Inc. establishes personal information protection rules and exercises necessary and appropriate supervision over its employees, so that personal information is kept secure against leakage, loss or damage.

Where polyhedron Inc. entrusts all or part of the handling of personal information to a contractor, it concludes a contract including confidentiality obligations with that contractor, or asks the contractor to agree to the terms laid down by ETB RIGHTS Inc., and exercises necessary and appropriate supervision so that personal information is kept secure at the contractor.

Except in the cases listed below, polyhedron Inc. does not provide personal information to a third party without the prior consent of the individual.

1. Where required by law

2. Where it is necessary to protect the life, body or property of a person and the consent of the individual is difficult to obtain

3. Where it is particularly necessary to improve public health or to promote the sound growth of children, and the consent of the individual is difficult to obtain

4. Where it is necessary to cooperate with a national body, a local authority or a party commissioned by one of them in carrying out duties prescribed by law, and obtaining the consent of the individual is likely to impede those duties

5. Where the following matters have been announced or published in advance

a) that provision to third parties is included in the purpose of use

b) the items of data provided to third parties

c) the means or method of provision to third parties

d) that provision of personal information to third parties will be stopped at the request of the individual

The following, however, do not count as third parties as defined above.

1. Where polyhedron Inc. entrusts all or part of the handling of personal information within the scope necessary to achieve the purpose of use

2. Where personal information is provided as part of the succession of a business due to a merger or another reason

3. Where personal information is used jointly with specific parties, and the individual has been notified in advance, or is in a position to know readily, of that fact together with the items of personal information used jointly, the range of parties using it jointly, their purpose of use, and the name of the party responsible for managing that personal information

Where polyhedron Inc. uses personal information jointly with specific parties and the purpose of use, or the name of the party responsible for its management, changes, it notifies the individual in advance of the content of the change, or places it in a state where the individual can readily know it.

polyhedron Inc. places the following matters concerning personal information in a state where the individual can know them, and answers without delay at the request of the individual.

1. The purpose of use of personal information (excluding matters for which the Act on the Protection of Personal Information provides that there is no such obligation. Where a decision is made not to answer, the individual is notified of that without delay.)

2. The contact point for enquiries about personal information

Where an individual requests disclosure of their personal information, polyhedron Inc. discloses it to the individual without delay. However, where disclosure would fall under any of the following, all or part of it may not be disclosed, and where a decision is made not to disclose, the individual is notified of that without delay.

1. Where it is likely to harm the life, body, property or other rights and interests of the individual or of a third party

2. Where it is likely to significantly impede the proper conduct of the business of ETB RIGHTS Inc.

3. Where it would breach another law

Information other than personal information, such as access logs, is not disclosed as a rule.

Where an individual requests the correction, addition or deletion (together, “correction”) of the content of their personal information on the ground that it is not true, polyhedron Inc. — except where a special procedure is prescribed by another law — carries out the necessary investigation without delay within the scope necessary to achieve the purpose of use, corrects the content on the basis of the result, and notifies the individual accordingly.

Where an individual requests that the use of their personal information be suspended or that it be erased (together, “suspension of use”) on the ground that it is being handled beyond the scope of the purpose of use published in advance, or that it was acquired by deception or other improper means, polyhedron Inc. carries out the necessary investigation without delay, suspends use on the basis of the result, and notifies the individual accordingly. Where suspension of use would require substantial expenditure or is otherwise difficult, and an alternative measure can be taken that is necessary to protect the rights and interests of the individual, that alternative is taken instead.

Where, despite a request from the individual, polyhedron Inc. decides

(1) not to notify the purpose of use

(2) not to disclose all or part of the personal information

(3) not to suspend the use of personal information

(4) not to stop the provision of personal information to third parties

it endeavours to explain the reason when notifying the individual of that decision.