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Tenchijin COMPASS Privacy Policy

Tenchijin, Inc.(the “Company”) sets forth this Privacy Policy (this “Policy”) with regard to the treatment of user information, including but not limited to personal information, in the course of the performance of Service provided by the Company under the name of “Tenchijin COMPASS” (the “Service”), as follows;

1.Name of the Company, address and name of the representative

  • Tenchijin, Inc.
  • 〒103-0027 1-4-1 Nihonbashi, Chuo,Tokyo Nihonbashi Icchome Mitsui Building
  • CEO Yasuhito Sakuraba

2.User Information to be Collected and Method of Collection

For purposes of this Policy, “User Information” means information identifying users, history of actions in the Service and other information created or accumulated in relation to users or their devices, that are collected by the Company pursuant to this Policy.

The User Information that the Company may collect in the course of the Service is as follows, depending on the method of collection.


[1] Information provided by the user

The information to be provided by the user for or through the use of the Service is as follows:

  • name, name of the country, name of company, department and position, and other profile information;
  • e-mail address and other contact information;
  • credit card information, bank account information, e-money information and other information regarding payment method; and
  • information transmitted by the user through entrance forms or other methods specified by the Company;

[2] Information automatically collected by the Company in the course of the user’s use of the Service

The Company may collect information regarding access to or use of the Service, which includes the following.

  • referer
  • IP address
  • information regarding server access logs
  • cookies, ADID, IDFA and other identifiers

[3] About Google Analytics

The Company uses Google Analytics to understand the usage. The Company also uses cookies provided by Google Analytics, but the Company does not collect any information to identify individuals through Google Analytics.

In addition, the data collected through the use of Google Analytics is managed based on “Google’s Privacy Policy”. Please refer to the Google Analytics website for Google Analytics Terms of Service and Privacy Policy. The Company shall not be liable for any damages resulting from the use of Google Analytics services.

Google Analytics Terms of Service

Google Privacy Policy

3.Purpose of Use

Specific purposes of use of the User Information for the provision of the Service are as follows:


  1. provision, maintenance, protection and improvement of the Service, including but not limited to acceptance of registration for the Service, identification, record of user settings and payment of use fees that are related to the Service;
  2. measurement of traffic and actions of the user
  3. distribution, display and measuring effect of advertisements
  4. guidance and response to inquiries relating to the Service;
  5. addressing a violation of rules, regulations or policies of the Company relating to the Service (the “Rules”); and
  6. notice of modification to the Rules or related matters.

4.Method of Notice, Publication and Consent; Method of Requiring Discontinuance of Use

The user may require the Company to discontinue the collection or use of the all or a part of the User Information by choosing the applicable setting as prescribed in the Service, and promptly upon such request the Company shall discontinue such collection or use in accordance with the rules prescribed by the Company. Certain User Information is necessary to be collected or used for providing the Service, and the Company shall discontinue such collection or use of the User Information only if the user withdraws from the Service pursuant to the procedures as determined by the Company.

5.Provision of Personal Information to Third Parties

The Company shall not provide to any third party (including the same outside Japan) personal information contained in the User Information without the prior consent of the user, except where such provision is required due to any of the following circumstances:


  1. The Company authorizes such third party to handle the personal information in whole or in part to the extent necessary to accomplish the purpose of the use;
  2. The personal information is provided through a business transfer by way of merger or other similar transactions;
  3. The Company is required to cooperate with state or local governmental organizations or their agents to perform their duties or obligations pursuant to applicable laws and regulations, and such performance is likely to be precluded if the consent of the user must be obtained; and
  4. In addition to the foregoing, the Company is entitled to provide information pursuant to the Act on the Protection of Personal Information (the “Act”) or other applicable laws and regulations.

6.Proper Management

The Company implements strict security measures and the following safety control measures to prevent unauthorized access, falsification, destruction, leakage, and loss of user information the Company has collected:


Safety management measures for the organization

  • Establishment of a management system, including the appointment of a person responsible for management, establishment of internal regulations and operation in accordance with the regulations, maintenance of a personal information management ledger, and continuous improvement and establishment of an organizational management system through internal audits and management reviews, etc.

Human security management measures

  • Education and training on personal information protection for all employees who handle personal information, conclusion of confidentiality agreements, audits and supervision, etc.

Physical security management measures

  • Access control to buildings and floors where personal information is handled, prevention of theft, disaster prevention measures against fire, power outages, etc., restrictions on taking out data and documents, and locking of locks during storage.

Technical security management measures

  • Minimize the number of persons who have access to personal data, and manage, authenticate, and control access to personal data in accordance with their duties; take measures against unauthorized software on the system and against viruses; encrypt data during transfer, transmission, and reception; and monitor the information system.

7.Disclosure of Personal Information

Upon request from the user to disclose its personal information under the Act, the Company shall, without delay, disclose to the user such information (or, in the event of non-existence of such personal information, notify the user to that effect) after confirming that the request is made by the user itself, to the extent required to do so under the Act and other applicable laws and regulations.

Please note that you must pay a commission (1,000 yen per disclosure) for disclosure of personal information.

8.Correction and Suspension of Use of Personal Information

8.1 If the Company is required pursuant to the provisions of the Act by the user to (1) correct the content of personal information due to the reason that such information is false, or (2) suspend use of personal information due to the reason that such information is being handled beyond the scope of the purpose of the use previously made public, or has been collected in a fraudulent or otherwise illicit manner, then the Company shall, without delay after confirming that the request is made by the user itself, conduct an appropriate investigation and based upon the results thereof, correct the content or suspend the use of such personal information, and notify the party to that effect. In cases where the Company decides not to make such correction or suspension of the use, the Company shall notify the user to that effect.

8.2 In the event that the Company is required by the user to delete its personal information and has determined that it is necessary to accept such request, the Company shall, after confirming that the request is made by the user itself, delete such personal information and notify the party to that effect

8.3 Should the Company not be obligated to correct, or suspend use of, information under the Act and other applicable laws and regulations, Sections 8.1 and 8.2 shall not apply.

9.Inquiries

Any suggestions, questions, complaints, or other inquiries on the handling of the User Information must be submitted to:

【Address】
〒103-0027 1-4-1 Nihonbashi, Chuo,Tokyo Nihonbashi Icchome Mitsui Building
Tenchijin, Inc. “Personal Information Protection Contact”
【Contact Information】
info@tenchijin.co.jp
【Reception time】
Monday-Friday (except Japanese national holidays and year-end and New Year holidays) 
9:30 a.m. – 12:00 p.m. and 1:00 p.m. – 4:30 p.m.

10.Cookie

On our website, as with a lot of other websites, the Company may use cookies or another automatic information collection program, where necessary, subject to your consent.

Cookies are the function to store the information about a user on the user’s browser or hard drive through our website. By using cookies, you can save time to re-type the information already stored on your hard drive.

Also, we may use cookies to improve your experience on our website by keeping the record of when and how you use our website. You can set your browser to disable the functionality of cookies; however, in a few cases, some of our website features may not function as a result.

11.Procedure to Amend this Privacy Policy

The Company may amend this Privacy Policy as necessary; provided, however, that in the event of an amendment to this Privacy Policy that legally requires the consent thereto of the users, this Privacy Policy after the amendment shall be applied only to the users that have given the consent in the manner specified by the Company. In the event of any amendment to this Privacy Policy, the Company shall inform the effective time and content of the amended Privacy Policy by posting on the website of the Company or other appropriate way, or notify the user of the same.

This Policy shall be executed in the Japanese language. Japanese shall be the governing language and any translation of this Policy into any other language is for convenience of reference only and shall not bind the parties hereto.


[Prescribed on July 1st, 2022]

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