Privacy Policy
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Polygon Pictures Inc. (the “Company”) hereby establishes the following privacy policy (the “Policy”) regarding the handling of user personal information when using <span class="est3">eST<sup>3</sup></span> (the “Application”) as provided on this website.

## Article 1 (Personal Information)

“Personal information” shall refer to “personal information” as defined in the Personal Information Protection Law, and refers to information about a living individual that can be used to identify a specific individual by name, date of birth, address, telephone number, contact information, or other descriptions, etc., contained in the information, as well as information that can identify a specific individual from the information itself (personal identification information) such as appearance, fingerprint, voiceprint data, or health insurance policy holder number listed on a health insurance card.

## Article 2 (Methods of Collecting Personal Information)

The Company may request personal information such as name, date of birth, address, telephone number, e-mail address, and name of organization or company to which the user belongs during user registration.

## Article 3 (Purpose of Collecting/Using Personal Information)

The Company may collect/use personal information for the following purposes. The Company shall not use personal information for any other purpose, except with the consent of the individual or as permitted by law. In addition, in order to facilitate business operations, the Company may subcontract a part of its operations to third parties and provide personal information to said subcontractors to the extent necessary. In such cases, the Company will enter into a contract with such subcontractors regarding the handling of personal information entrusted to them, and conduct necessary and appropriate supervision to ensure the secure management of such personal information.

1. To provide and operate the service for which the Application is licensed (the “Service”).
1. To respond to inquiries from the user (including confirmation of the identity of the user).
1. To send e-mails, etc. regarding new features, updates, and other information on the Service and the Application, as well as campaigns and other services provided by the Company.
1. To contact users as necessary with information on maintenance, important notices, etc.
1. To collect opinions from users, conduct surveys, etc.
1. To respond to violations of the Terms of Use.
1. To allow users to view, change, or delete their registered information, or view usage status.
1. To issue charges to users for use of paid services (if any).

## Article 4 (Change of Purpose of Use)

1. 	The Company shall make changes to the purpose of use of personal information only when it is reasonably deemed that such is relevant to the purpose of use as stated before the change.
1. 	In the event of a change of the purpose of use, the Company shall notify the user of the purpose of use after such change by a method prescribed by the Company, or publicly announce such change on this website.

## Article 5 (Provision of Personal Information to Third Parties)

1. 	Except in the following cases, the Company shall not provide personal information to third parties without the prior consent of the user. However, cases permitted under the Personal Information Protection Law and other laws and regulations shall be excluded.

    1. When necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual.
    1. When especially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the individual.
    1. When necessary to cooperate with a national agency, local government, or individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the consent of the individual is likely to impede the execution of the affairs in question.
    1. When the Company has notified or announced the following items in advance, and has notified the Personal Information Protection Committee.

       1. The purpose of use includes provision to third parties.
       1. Data items to be provided to third parties.
       1. Means or methods of provision to third parties.
       1. Provision of personal information to third parties will be ceased at the request of the individual.
       1. Method of accepting such a request from the individual.

1. 	Notwithstanding the preceding paragraph, in the following cases, the recipient of applicable information shall not fall under the category of a third party.

    1. When the Company subcontracts all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
    1. When personal information is provided as a result of succession of business due to merger or other reasons.
    1. When personal information is used jointly with a specific entity, and where this fact, the items of personal information jointly used, the scope of joint use, the purpose of use by this entity, and the name of the person responsible for managing the personal information are notified to the individual in advance or are made readily available to the individual.

## Article 6 (Disclosure of Personal Information)

1. 	When the Company receives a request for disclosure of personal information from the individual, the Company shall disclose such information to the individual without delay. However, when disclosure would fall under any of the following cases, all or part of the information may not be disclosed, and should the Company decide not to disclose the information, the Company shall notify the individual to that effect without delay.

    1. There is a risk of harm to life, body, property, or other rights or interests of the individual or a third party.
    1. There is a risk of significant hindrance to the proper conduct of the Company’s business.
    1. There is a violation of other laws and regulations.

1. 	Notwithstanding the preceding paragraph, in principle the Company shall not disclose non-personal information, such as historical information and characteristic information.
1. 	The Company shall not disclose received personal information to any third party without prior consent.

## Article 7 (Correction and Deletion of Personal Information)

1. 	If a user’s personal information held by the Company is incorrect, the user may request the Company to correct, add, or delete said personal information in accordance with procedures prescribed by the Company (“corrections”).
1. 	If the Company receives a request from a user as described in the preceding paragraph and deems it necessary to respond to said request, the Company shall perform corrections to the relevant personal information without delay.
1. 	If the Company performs corrections based on the preceding paragraph, or has decided not to make corrections, the Company shall notify the user without delay.

## Article 8 (Ceasing Use of Personal Information)

1. 	When the Company receives a request from an individual to stop using or delete their personal information (“ceasing use”) on the grounds that it has been handled beyond the scope of the purpose of use or that it has been obtained by wrongful means, the Company shall conduct an investigation as necessary without delay.
1. 	If, based on the results of such investigation as described in the preceding paragraph, the Company determines that it is necessary to comply with the request, the Company will cease use of the relevant personal information without delay.
1. 	If the Company ceases use of personal information based on the preceding paragraph, or decides not to cease use, the Company shall notify the user without delay.
1. 	Notwithstanding the preceding two paragraphs, in cases where ceasing use would involve significant cost or would otherwise be difficult to perform, and alternative measures to protect the rights and interests of the user are possible, such alternative measures may be taken.

## Article 9 (Changes to Privacy Policy)

1. 	The Company shall endeavor to accurately respond to the needs of users, advances in information technology, and other changes in the social environment regarding the handling of personal information, and shall continuously improve this policy and other rules and regulations as necessary, including timely and appropriate reviews.
1. 	The Company may make changes to this Privacy Policy from time to time to comply with laws and regulations, changes to the content of our services, or for other business reasons, to the extent permitted by law. Changes to this Privacy Policy shall be listed on this website.

## Article 10 (Management of Personal Information)

The Company shall keep personal information accurate and up-to-date to the extent necessary to achieve the purposes for which it is used, and shall endeavor to delete such personal information without delay when it is no longer necessary.  
In addition, the Company shall properly manage the personal information it has obtained and take the utmost care to prevent leaks, loss, or damage of such information. With respect to the protection and appropriate handling of personal information, the Company shall provide internal education to managers and employees, audit the maintenance and compliance with internal rules and regulations concerning the protection of personal information, and implement access control and security measures, and other safety management measures. In addition, the Company shall set a separate retention period for personal information in accordance with the purpose of use, and dispose of the information in an appropriate manner after the relevant period has elapsed.

## Article 11 (Regarding Cookies)

Cookies, device fingerprinting, or similar technologies may be used for the purposes of providing more convenient services to users. These allow identification of the user’s terminal device on repeated visits to the Company’s website, allowing improvements to usability. In addition, the Company’s website uses access analysis tools to improve services, and in doing so, the Company may conduct analysis via cookies, device fingerprinting, or similar technologies.  
Small pieces of information, including cookies, that a web server sends to a user's browser for efficient operation of the Internet may be stored in a file on the user's disk. Cookies allow web servers to record the pages visited by users and other information. The use of cookies makes it possible to identify the computer used by the user, but individual users cannot be identified unless they enter personal information on the Company’s website (cookies themselves do not contain any personally identifiable information). In addition, the Company may publish aggregate information statistically processed from information obtained through the use of cookies, but this shall not include information that can identify individual users.  
The purpose of the Company’s use of cookies is to improve and expand our services and provide a comfortable user environment, and the Company shall not use cookies for any other purpose.
The Company’s advertisements are placed on various websites on the Internet by third-party distributors. Third-party distributors may use cookies to deliver advertisements based on information about past visits to the Company’s website.  
Cookies can be rejected (opt-out) via a simple process. By rejecting cookies (opting out), the user can prevent information about them from being associated with a particular browser. The user can thereafter reject (opt-out) the Company’s ad-serving cookies without having to delete or modify other cookies associated with the user’s browser. Should the user not wish to receive the Company’s cookies, cookies can be rejected (opt-out) from the settings for each browser used.

## Article 12 (Inquiries)

Inquiries regarding this policy can be made to the following:

Address: 		1F Daiwa Azabu Tce, Minami Azabu 3-20-1, Minato, Tokyo 106-0047  
Company Name: 	Polyon Picture Inc.  
President and CEO: Shuzo John Shiota  
Department: 	People Department  
E-mail address: 	privacycenter@ppi.co.jp