1. Definition of personal information

In this privacy policy, personal information shall mean personal information as defined by Article 2, Paragraph 1 of the Personal Information Protection Act.

2. Purpose of personal information

Our company will use personal information for the following purposes.
(1) To provide a reception avatar communication service named AVACOM (if the name or content of the service is changed for whatever reason, this includes the service after the change) and other services operated by the Company (hereinafter "our service").
(2) To provide information regarding our services, respond to inquiries, etc.
(3) To provide information about our products, services, etc.
(4) To respond to acts that prohibit our company's terms, conditions, etc. (hereinafter "Terms, etc.") regarding our services.
(5) To notify you of changes to the terms and conditions of our services, etc.
(6) To help improve our services, develop new services, etc.
(7) For employment management and internal procedures (personal information of executives and employees), for selection and communication in recruitment activities (personal information of applicants).
(8) For shareholder management, corporate law, and other legal procedures (regarding personal information of shareholders, stock acquisition rights holders, etc.).
(9) In connection with our services, to create statistical data processed into a format that does not identify individuals.
(10) To disclose to third parties in accordance with the provisions of this privacy policy.
(11) For other purposes incidental to the above purposes of use.

3. Change of purpose personal information

Our company may change the purpose of personal information within the scope reasonably deemed to be relevant, and in the event of a change, the individual who is the subject of the change (hereinafter "principal") will be notified or announced.

4. Restrictions on the use of personal information

Our company will not handle personal information beyond the scope necessary to achieve the purpose without obtaining the consent of the person, except as permitted by the Personal Information Protection Act and other laws and regulations. However, this does not apply in the following cases.
(1) Cases in which the handling of personal information is based on laws and regulations.
(2) Cases in which the handling of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person.
(3) Cases in which the handling of personal information is specially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person.
(4) Cases in which the handling of personal information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned

5. Appropriate acquisition of personal information

5.1 Our company will acquire personal information appropriately and will not acquire it by deception or other wrongful means.
5.2 Our company will not acquire Special Care-Required Personal Information (as defined in Article 2, Paragraph 3 of the Personal Information Protection Act) without the prior consent of the person, except in the following cases.
(1) Cases falling under any of the items in Section 4 apply.
(2) Cases in Special Care-Required Personal Information have been disclosed by the person, a national agency, a local government, a person listed in each item of Article 57, Paragraph 1 of the Personal Information Protection Act, or any other person specified by the rules of the Personal Information Protection Commission.
(3) Cases in obtaining Special Care-Required Personal Information that is obvious from its appearance by visually observing or photographing the person.
(4) Cases in receiving Special Care-Required Personal Information from a third party, and the provision by the third party falls under any of the items in Section 7.1.
5.3 When receiving personal information from a third party, we shall confirm the following items in accordance with the regulations set forth by the Personal Information Protection Commission. However, this excludes cases where the provision of personal information by the said third party falls under any of the items listed in Section 4 or Section 7.1.
(1) The name and address of the third party, and in the case of a corporation, the name of its representative (in the case of an unincorporated organization with a designated representative or administrator, the name of its representative or administrator)
(2) Background of the acquisition of the personal information by the third party

6. Management of Personal Information Security

To ensure the proper handling of personal information, we have established this privacy policy and take measures for the secure management of personal information. These measures include the development and improvement of methods for handling personal information and the management system, training and awareness activities for employees, access control to areas where personal information is handled, entry/exit management of such areas, installation of antivirus software, and other information security measures to prevent leakage and other risks. We also ensure that personal information that is no longer retained is securely disposed of or erased by appropriate methods. When providing personal information to a third party located overseas or when storing it abroad, we take security management measures after understanding the personal information protection systems of each respective country.
Additionally, when entrusting the handling of personal information in whole or in part, we select contractors who meet the selection criteria established by our company to ensure that the entrusted party manages personal information securely. We also enter into outsourcing agreements with these contractors and conduct necessary and appropriate supervision by regularly receiving written reports from the contractors or using other methods to monitor their handling of personal information.

7. Provision of Personal Information to Third Parties

7.1 Except in cases that fall under any of the items listed in Section 4, we will not provide personal information to third parties without obtaining prior consent from the individual. However, the following cases do not constitute the provision of personal information to third parties as defined above.
(1) Cases where personal information is provided to the outsourcing of all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
(2) Cases where personal information is provided due to the succession of business resulting from a merger or other reasons.
(3) Cases where personal information is used jointly in accordance with the provisions of the Personal Information Protection Act.
7.2 Notwithstanding the provisions of Section 7.1, when providing personal information to a third party located in a foreign country (excluding countries specified by the Personal Information Protection Commission Regulations under Article 28 of the Personal Information Protection Act and organizations that have established a system that meets the standards specified in those regulations), we will obtain the prior consent of the individual to allow the provision of their personal information to the foreign third party. This does not apply to cases that fall under any of the items listed in Section 4.
7.3 When we provide personal information to a third party, we will create and retain records in accordance with Article 29 of the Personal Information Protection Act.
7.4 When we receive personal information from a third party, we will perform the necessary checks in accordance with Article 30 of the Personal Information Protection Act and will create and retain records of those checks.

8. Disclosure of Personal Information

When we are requested by an individual to disclose personal information in accordance with the provisions of the Personal Information Protection Act, we will promptly disclose the information after confirming that the request is indeed from the individual. If the requested personal information does not exist, we will notify the individual to that effect. However, this does not apply if we are not obligated to disclose the information under the Personal Information Protection Act or other laws and regulations. Please note that a fee of 10,000 yen (about 69.5USD 2024/10/1) per request will be charged for the disclosure of personal information.

9. Correction of Personal Information

If an individual requests the correction, addition, or deletion of their personal information (hereinafter "correction, etc.") on the grounds that it is not accurate, in accordance with the Personal Information Protection Act, we will promptly conduct the necessary investigation within the scope necessary to achieve the purpose of use, after confirming that the request is from the individual. Based on the results of this investigation, we will correct the personal information and notify the individual accordingly. If we decide not to make any corrections, we will also notify the individual of this decision. However, this does not apply if we are not obligated to make corrections under the Personal Information Protection Act or other laws and regulations.

10. Suspension of Use of Personal Information

If an individual requests the suspension of use or deletion of their personal information (hereinafter "suspension of use, etc.") in accordance with the provisions of the Personal Information Protection Act, on the grounds that their personal information is being handled beyond the scope of the publicly disclosed purpose of use or has been obtained through fraudulent or improper means, or if the individual requests the suspension of provision (hereinafter "suspension of provision") of their personal information to third parties without their consent, we will promptly suspend the use or provision of the personal information upon confirming that the request is from the individual and determining that the request is valid. We will then notify the individual of the action taken. However, this does not apply if we are not obligated to suspend the use or provision of personal information under the Personal Information Protection Act or other applicable laws and regulations.

11. Handling of Anonymized Information

11.1 When we create anonymized information (as defined in Article 2, Paragraph 7 of the Personal Information Protection Act, and limited to those that constitute an anonymized information database, etc., as defined in Article 16, Paragraph 7 of the same Act, hereinafter the same), we will process personal information in accordance with the standards set forth by the regulations of the Personal Information Protection Commission.
11.2 When we create anonymized information, we will take safety management measures in accordance with the standards set forth by the regulations of the Personal Information Protection Commission.
11.3 When we create anonymized information, we will publicly disclose the items of information related to individuals that are included in the anonymized information, in accordance with the regulations of the Personal Information Protection Commission.
11.4 When we provide anonymized information (including both anonymized information we have created and that provided by third parties, the same applies hereinafter unless otherwise specified) to a third party, we will publicly disclose in advance the items of information related to individuals included in the anonymized information and the method of provision, in accordance with the regulations of the Personal Information Protection Commission. Additionally, we will clearly indicate to the third party that the information being provided is anonymized information.
11.5 When handling anonymized information, we will not engage in the following actions to identify the individuals from whom the personal information used to create the anonymized information was derived.
(1) Cross-referencing anonymized information with other information.
(2) Obtaining information about descriptions or personal identification codes that were removed from the personal information, or information about the methods of processing conducted under the provisions of Article 43, Paragraph 1 of the Personal Information Protection Act (this applies only to anonymized information provided by third parties).
11.6 The Company shall take necessary and appropriate measures to ensure the secure management of anonymized information, to handle complaints regarding the creation and other handling of anonymized information, and to take necessary actions to ensure the proper handling of such information. The Company shall also endeavor to disclose the details of these measures.

12. Use of Cookies and Other Technologies

12.1 Our services may use cookies and similar technologies. These technologies help us understand the usage of our services and contribute to improving them. Users who wish to disable cookies can do so by changing their web browser settings. However, disabling cookies may result in the inability to use some features of our services.
12.2 Advertisements for our services may be displayed on websites across the internet by third-party providers such as Google and Yahoo!. Additionally, we may encrypt personal information we hold and match it with the information held by such providers to deliver advertisements. The main services we use are listed below. Please refer to the information below for the names of third-party providers, their privacy policies, and how to opt-out of their advertising services.

13. Contact Information

For requests for disclosure, opinions, questions, complaints, or other inquiries regarding the handling of personal information, please contact the following office.
ARCO TOWER 18th Floor, 1-8-1 Shimomeguro, Meguro-ku,Tokyo 〒153-0064
AVITA Co., Ltd. (CEO/CTO: Hiroshi Ishiguro)
Tel: 080-2944-5115
E-mail: contact@avita.co.jp
EC site dedicated contact: info@avitashop.jp

14. Continuous Improvement

We will periodically review the operational status of personal information handling and strive for continuous improvement. As necessary, we may revise this privacy policy.

[Established on December 1, 2021]
[Revised on December 26, 2023]
[Revised on January 15, 2024]
[Revised on September 30, 2024]