Privacy Policy

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  1. Privacy Policy

    MACROMILL, INC. Privacy Policy

    MACROMILL, INC. (the "Company") contributes to society by providing information about consumer awareness and behavior to corporations and organizations through market research, public opinion surveys, social research and medical related surveys (collectively, "Marketing Research")

    In doing so, to protect the personal information of the Company's information sources, i.e. consumers, the Company complies with the Marketing Research Code of Conduct and the Marketing Research Industry Guidelines for Protection of Personal Information as stipulated by the Japan Marketing Research Association (JMRA).

    In order to ensure the protection of personal information, the Company hereby establishes and proclaims its implementation of this Privacy Policy to take appropriate measures to secure, store and manage personal information acquired from participants in the Company's Marketing Research ("Survey Respondents") through their responses to the Company's surveys and use of the application provided by the Company, as well as personal information acquired from the Company's stakeholders, such as the Company's business partners, and from other relevant parties.

    1. 1. Appropriate acquisition, use and provision of personal information

      The Company acquires personal information for definite purposes in a fair and just manner, and uses personal information only to the extent necessary to achieve such purposes. When using the same beyond this extent, the Company will obtain the prior consent of the information subjects. The Company also takes necessary measures to prevent the handling of personal information beyond the extent necessary to achieve the purposes. Upon providing personal information to a third party, the Company will obtain the prior consent of the information subject, unless this Privacy Policy stipulates otherwise.

    2. 2. Safety management of personal information

      The Company prevents and rectifies unauthorized access to, and the loss, destruction, falsification and leakage of, personal information by taking organizational, personal, physical, and technical security measures against such risks.

    3. 3. Compliance with laws, regulations and other rules about the protection of personal information

      Upon handling personal information, the Company complies with domestic laws and regulations about personal information protection, guidelines stipulated by the governing authorities, the Marketing Research Code of Conduct and the Marketing Research Industry Guidelines for Protection of Personal Information stipulated by the JMRA, along with other relevant rules.

    4. 4. Continuous improvement of the Company's personal information protection management system

      To implement this Privacy Policy appropriately and effectively, the Company has established and operates a personal information protection management system (the “PMS”). To increase the effectiveness of the PMS, the Company provides training to all of its employees and audits the operation of the PMS for continuous review and improvement.

    5. 5. Handling of complaints and inquiries

      If you have any inquiries and complaints about the Company's handling of personal information, you can contact the Company as shown in the "Inquiries and Complaints" chapter of this document.

      As for personal information subject to disclosure, the Company will promptly handle requests from the information subject or his/her representative to notify the purposes of use of, to disclose, rectify (including making additions to or deleting part of), or suspend the use of (including suspending third-party provision of and eliminating), such personal information.

      The Company strives to protect personal information by ensuring that its officers and employees fully understand the purposes and intent of this Privacy Policy and conduct daily operations with the greatest care.

    6. 6. Change to Privacy Policy

      The Company may change this Privacy Policy due to any amendments to the laws or regulations, etc., the Company's business operational needs or any other circumstances. In the case of making the said change, the Company will publicize such change in an appropriate manner.

      June 30, 2016 (established)
      June 16, 2023 (last modified)

      Toru Sasaki, President, Representative Executive Officer and CEO
      MACROMILL, INC.
      11th Floor, Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo

    7. The Company obtained the "Privacy Mark" (granted by JIPDEC) on January 9, 2004. The Company will keep endeavoring to ensure the secure and proper handling of personal information and to maintain and improve our system that enables customers to use our services at ease.

      Contact point for matters concerning personal information protection
      Email: [email protected]
  2. Purposes of Use of Personal Information

    1. 1. Marketing Research

      (1) The Company's main business is Marketing Research. The Company surveys consumer awareness and behavior about products and services, and provides information acquired through such surveys to corporations, other organizations, etc.

      (2) The Company's methods of acquiring personal information in the process of conducting the Marketing Research business and the principal information acquired thereby are as follows.

      No. Acquisition methods Principal information acquired
      Acquisition from Survey Respondents’ registration of information on the Company's website, etc. Names, addresses, dates of birth, ages and email addresses, etc.
      Acquisition from Survey Respondents’ answers to online or offline questionnaires Contents of the answers for the questionnaires
      Acquisition from Survey Respondents' remarks or other information acquired in interview surveys Contents of the Survey Respondents' remarks made during interview surveys, or information acquired by observing the whole survey or by using measuring instruments, etc.
      Acquisition from the Survey Respondents' access logs to websites and web advertisements Access logs to websites and web advertisements, user agents and IP addresses
      Acquisition through applications provided by the Company Advertisement identifiers, device identifiers, IP addresses, operation logs of the devices and applications*1, location information*1*2, etc.

      *1 Except when acquiring the operation logs in the applications provided by the Company, acquired only from the Survey Respondents who have turned on the button for indicating their consent, which is contained in the application provided by the Company.
      *2 Please refer to "Location Information" for the purpose of use or other information related to the location information acquired by the Company through the applications it provides.
      Acquisition through the provision of information from entrusters of the Marketing Research operations (the Company's clients) Information concerning the Survey Respondents possessed by the clients.
      Acquisition from a third party which the Company has a partnership with*

      * The personal information that will be acquired shall be limited to that which the said third party is able to provide to the Company under the law, such as personal information for which the said third party obtained consent to the provision thereof from the Survey Respondent.
      Information concerning the Survey Respondents, possessed by the clients.
      Acquisition from the information being published online or offline*

      * e.g. Information published on websites, or commercially available newspapers
      Information published online or offline
      Other acquisition methods accompanying or related to the Company's Marketing Research business Various types of information according to the acquisition method

      Concerning No.4 above, please click the opt-out button if you wish to stop the collection of information using cookies by the Company. Please refer to the page below for the details of cookies.
      [Opt-out button]
      [Link to explanation of cookies]

      (3) The Company uses the personal information of Survey Respondents that is acquired through each of the methods above for the purposes set forth below (the "Marketing Research-Related Purposes"); provided, however, that the location information (the "Location Information") acquired by the Company through the applications it provides (the "Apps") shall be excluded from such personal information. Please refer to "Location Information" for the purposes of use of the Location Information. If the Company uses the personal information for any purpose other than the purposes set forth below, the Company will obtain the consent of Survey Respondents by giving prior notification of the details of such usage by stipulating such details in the Company's terms and conditions posted on the Company's website or other documents, etc., or by email or phone call, unless obtaining consent is not required under the laws and regulations.

      1. (i) Matters required for Marketing Research, such as selection of Survey Respondents, requests for participation, sending survey sheets, examination and analysis of the survey results, and provision of the survey results to the Company's clients (including providing the survey results to the Company's clients on the assumption that it will be re-provided to any end-client* in the case that a client conducts Marketing Research entrusted by the said end-client, or to the co-implementers of the Marketing Research in the case that a client implements the said Marketing Research with multiple companies);
        * An end-client refers to a customer of the Company's client.

      2. (ii) Interviews or door-to-door surveys conducted by researchers;

      3. (iii) Delivery of targeted advertisements for the purpose of extracting Survey Respondents*;

        * For example, in order to ask Survey Respondents about their recognition or impression, etc. of the web advertisements which are the subjects of the Marketing Research (the "Research Target Web Advertisements"), the Company may deliver the Research Target Web Advertisements through the web services that the said Survey Respondents are using on a daily basis.

      4. (iv) Matters required for the implementation of extended advertisement delivery** (meaning methods such as finding users acting analogous to the users who have visited the relevant website, but have not visited the said website yet, and delivering targeted advertisements to them, or finding users acting analogous to the users who have purchased a certain merchandise or service, and delivering targeted advertisements to them; the same shall apply hereinafter);
        ** Extended advertisement delivery is a method to find users whose purchase behaviors or web behaviors are analogous to the Survey Respondents and to deliver advertisements to them, and is not something that delivers advertisements directly targeting the Survey Respondents.

      5. (v) Provision/redemption of points, payment of gratuities, and sending free gifts and samples to Survey Respondents;

      6. (vi) Responses to inquiries from Survey Respondents, and making contact to check the details of support and registered information;

      7. (vii) Identity verification, display of registered information, and other procedures on the membership page of a Survey Respondent;

      8. (viii) Campaigns or rewards relevant to the operation of Marketing Research, sending of email newsletters, etc.;

      9. (ix) Development, provisions and improvement of advertisement delivery models, purchase prediction models, marketing support system and other marketing solutions; and

      10. (x) Other matters accompanying or related to the above.

    2. 2. Transactions such as business activities

      When the Company's business partners such as the Company's customers and related companies inquire about the Company's services or participate in a seminar or campaign sponsored or supported by the Company, the Company will use personal information acquired from the Company's business partners, such as by exchanging business cards, for the purposes defined below:

      (1) For negotiation, communication, discussion, examination, order placement, settlement and response about business transactions;

      (2) For providing and receiving services based on business transactions; and

      (3) For providing, collecting, and transmitting information about the Company's services.

    3. 3. Recruitment activities

      The Company uses the personal information of a job seeker who applied for or inquired about the Company's job offer for the following purposes. If the job seeker has joined the Company, the Company will use the personal information of such person for employment management purposes.

      (1) To provide recruitment information to the job seeker;

      (2) To examine and determine whether or not to employ the job seeker and provide notification of the result; and

      (3) To check application history.

    4. 4. Matters concerning shareholders

      The Company will use the personal information about the Company's shareholders for the following purposes:

      (1) To enable the exercise of rights or the fulfillment of obligations as shareholders under the laws;

      (2) To provide benefits to shareholders;

      (3) To take measures to promote a favorable relationship between shareholders and the Company; and

      (4) For shareholder management, such as the creation of shareholder data based on specific standards under laws and regulations.

    5. 5. Use of published information

      The Company will use information published online or offline for the following purposes:

      (1) Implementation of Marketing Research

      (2) Development, provision and improvement of marketing solutions

  3. Personal Information Subject to Disclosure

    For the purpose of this Privacy Policy, "Personal Information Subject to Disclosure" means personal information that forms part of a collection of information in such a way that specific personal information can be retrieved by a computer, or a collection of information to which a fixed set of rules is applied to arrange the personal information contained therein so that it is structurally organized to enable specific personal information to be easily retrieved from it, and which has a table of contents, an index, or anything else that aids in retrieval, for which the Company is authorized to respond to all requests made by the information subject to disclose, rectify, make additions to, delete part of, suspend the use or third-party provision of, or eliminate, the information.

    1. 1. Types of Personal Information Subject to Disclosure

      1. (1) Information about Survey Respondents:

        Information that includes the name, address, age, date of birth and email address that the Survey Respondent has registered on the website operated by the Company and other information that the Company has acquired during Marketing Research, as well as records related to the provision of such information to or from any third party (hereinafter referred to as "Third-Party Provision Records," excluding those designated under any ordinance as information regarding which revealing its existence damages the public interest or any other interest).

      2. (2) Information about business partners:

        Information provided to the Company by business partners, such as names, telephone numbers (including mobile and fax numbers), email addresses, company/organization names, division names, titles, workplace addresses, and any other contact information, as well as Third-Party Provision Records of such information.

      3. (3) Information about job seekers

        Names, telephone numbers (including mobile and fax numbers), addresses, ages, dates of birth, email addresses, and any other information described in the CV or provided by the job seeker to the Company via the website operated by the Company, as well as Third-Party Provision Records of such information.

      4. (4) Information about shareholders:

        Names, addresses, and any other information in the shareholder registry, as well as Third-Party Provision Records of such information.

      5. (5) Public information:

        Information published online or offline, as well as Third-Party Provision Records of such information.

    2. 2. Purposes of use of Personal Information Subject to Disclosure

      The Company uses Personal Information Subject to Disclosure only within the range of the purposes defined in "Purposes of Use of Personal Information" in this Privacy Policy.

  4. Request to Disclose Personal Information Subject to Disclosure

    As for Personal Information Subject to Disclosure, the Company will promptly handle requests from the information subject or his/her representative to notify the purposes of use, to disclose, rectify (including making additions to or deleting part of), or suspend the use of (including suspending third-party provision of and eliminating), such information.

    Method to readily confirm personal information online:
    Personal information which you have registered as a MACROMILL monitor may be confirmed on the "MACROMILL-monitor-dedicated page (MY PAGE)". As for the Company's monitors, please first consider confirming your personal information using this method.

    < Click here for the types of information for which you can request the above actions.>

    1. 1. Contacts for the request for disclosure

      1. (1) For information provided as the Company's monitor on the website operated by the Company, please use the email address and login password that you used to register as a monitor to log in to the website operated by the Company; and then move to the MACROMILL monitor page (MY PAGE) to ask for disclosure, etc. The Company will then promptly handle such request.
      2. (2) For the disclosure of information that cannot be handled as set forth in (1), please complete the Company's form described below, enclose all the required documents, and mail them to the following address. Please write, "Request form for disclosure of personal information enclosed," in red on the envelope.
      3. Personal information protection administrator, MACROMILL, INC.
      4. 11th Floor, Shinagawa East One Tower, 2-16-1, Konan, Minato-ku, Tokyo, 108-0075
    2. 2. Documents to submit when making a request for disclosure, etc.

      1. (1) When you make a request for disclosure using the method set forth in Section 1, Paragraph (2) above, please download the request form set forth in (i) below, fill in the necessary information, and enclose it together with two of the documents for personal identification listed in (ii).
        1. (i) A request form prescribed by the Company (Request form for disclosure of Personal Information Subject to Disclosure)
        2. (ii) Documents for personal identification:
          1. a.A copy of your driver's license
          2. b.A copy of your health insurance card;
          3. c.A copy of your passport;
          4. d.A copy of your basic resident register card; and/or
          5. e.A copy of any other official documents for personal identification.
      2. (2) When a request for disclosure is made by a legal representative of a minor or adult ward or a representative appointed by the information subject to make a request for disclosure, please also enclose the following documents in addition to the documents listed in the preceding paragraph.
        1. (i) In the case of a legal representative (one copy each of a, b, and c):
          1. a. Document that verifies the legal representation authority One copy of the family register, extract of family register, certificate from the court of domestic solutions, certified copy of registration, or any other document that proves the qualification
            * It must be a copy that was issued within 30 days before the request for disclosure.
            * Please black out the registered domicile information before submission.
          2. b. Document that identifies the person with parental authority or the guardian of the adult ward One copy of the driver's license, passport, health insurance card or basic resident registration card that indicates the same name and address as those in the form submitted by the person who requests the disclosure
            * Please black out the registered domicile information before submission.
          3. c. One original certified copy of the residence certificate (photocopy not acceptable)
        2. (ii) In the case of a representative appointed by the information subject (one copy each of a and b)
          1. a. One copy of the Company's proxy form; and
          2. b. One original copy of the registered seal certificate of the person.
    3. 3. Fees for requests for notification of purposes of use and for information disclosure

      With regard to any request for notification of the purposes of use or for information disclosure made by the information subject or his/her representative, the Company will charge a certain fee, depending on the details of the request and the method of notification or disclosure by the Company. Such fee shall be paid via bank transfer into the bank account designated by the Company (any bank transfer fee shall be borne by the requester). In this case, the Company will respond to the request after confirming the bank transfer of such fee.

    4. 4. Method for responding to requests for disclosure

      The Company will respond to any request for the notification of the purposes of use of, or rectification or suspension of use, etc. of, personal information by mail.

      In principle, the Company will respond to any request for information disclosure by mailing a written document or a CD-ROM containing electronic records of the relevant information, in accordance with the requester’s designation upon making the request; provided, however, that in cases where it is difficult for the Company to disclose the relevant information using the method designated by the requester, such as where the mailing of the CD-ROM containing electronic records requires great expense, the Company may respond to such request by mailing a written document, despite the designation.

    5. 5. Purposes of use of personal information acquired in relation to a request for disclosure, etc.

      The Company will only use the personal information acquired in relation to a request for disclosure, etc. to the extent necessary to handle the request. The submitted documents will be stored for two years after the response to the request is completed and will be disposed of after such period.

    6. 6. Cases wherein the Company cannot respond to a request for disclosure, etc.

      Please note that there may be cases where the Company cannot respond to a request for disclosure, etc. if any of (i) to (xi) below applies. In that case, the Company will notify the applicant to that effect, together with the reason therefor.

      1. (i) The Company cannot identify the information subject, for example, because the addresses indicated in the form, indicated in the documents for identification, and registered at the Company, do not match;
      2. (ii) The Company cannot verify the representative's right of representation for a request by the representative;
      3. (iii) The application documents are deficient;
      4. (iv) The information that the applicant asks to disclose is not Personal Information Subject to Disclosure;
      5. (v) The fulfillment may risk the life, body, property, or any other right or interest, of the information subject or a third party;
      6. (vi) The fulfillment may encourage or induce illegal or unjust acts;
      7. (vii) The fulfillment may risk national security, damage the relationship of trust with other countries or international organizations, or cause a disadvantage in negotiations with other countries or international organizations;
      8. (viii) The fulfillment may obstruct the prevention, suppression, or investigation of crimes or the maintenance of public safety and order;
      9. (ix) The fulfillment may seriously obstruct the Company's appropriate business operations;
      10. (x) The fulfillment violates the laws and regulations; or
      11. (xi) The Company does not bear any obligations for disclosure, etc. under the laws or regulations.
  5. Third-Party Provision of Personal Information

    (1) The Company properly manages the personal information it has acquired, and will not provide information from which a specific individual can be identified directly, such as names, addresses, phone numbers, email addresses, etc., to any third party without the prior consent of the information subject, except in the cases where:

    1. (i) The provision is based on the laws and regulations;
    2. (ii) The provision is required to protect the life, body or property of any person, and it is difficult to obtain the consent of the information subject;
    3. (iii) The provision is particularly required to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the information subject;
      The application documents are deficient;
    4. (iv) The provision is required to support the activities defined under the laws and regulations that are conducted by governmental organizations, local governments, or those delegated thereby, and the acquisition of consent from the information subject may obstruct the conduct of such activities;
    5. (v) The receiver of such information is an academic research institute, etc., and the receiver needs to handle the personal data provided by the Company for academic research purposes (including cases where such academic research constitutes part of the purposes for handling such personal data, but excluding cases where such handling threatens to wrongfully infringe upon the rights and interests of an individual);
    6. (vi) The Company asks other research companies ("Partner Research Companies") for cooperation in Marketing Research, and the Company needs to check for the existence of any overlap of monitors between the Partner Research Companies and the Company; or
    7. (vii) The Company receives an inquiry from its client or any third party with whom the Company has a contractual relationship, such as its alliance partner (an "Alliance Partner;" collectively referred to with the clients as "Clients, etc.") about the existence of any overlap between the Company's Survey Respondents and the monitors, members and customers of such Client, etc., and the Company needs to respond to such inquiry to the extent required for the Marketing Research-Related Purposes;
    8. (viii) The Company or any of its Clients, etc. provides telephone numbers or email addresses to any other Client, etc. of the Company to the extent necessary for extended advertisement delivery; or
    9. (ix) It is necessary to confirm the Survey Respondents' usage status of the website advertisements and applications subject to research in order to obtain the results intended by the Company or Client, etc. through Market Research, and it is necessary to provide telephone numbers and email addresses to the Company's Clients, etc. in order to acquire such information.
    10. * In cases where Item (vi), (vii), (viii) or (ix) applies, the Company shall impose on the relevant Partner Research Companies or Clients, etc. the condition that they must not use personal information for any purpose other than those set forth above. The Company shall provide personal information to the Partner Research Companies or Clients, etc. by taking necessary procedures to improve security, such as hashing or encryption.

    (2) Among the Survey Respondents' personal information possessed by the Company, the Company may, for the Marketing Research-Related Purposes, provide its Clients, etc. with information regarding which a specific individual cannot be identified directly from such information alone, such as: IDs allocated by the Company to Survey Respondents for information management purposes ("Monitor IDs"); and attribute information, survey responses, website access logs, advertisement identifiers, device identifiers and IP addresses of Survey Respondents (the same shall apply in cases where the Clients, etc. re-provide the same to any third parties).
    The Clients, etc. may use any information provided by the Company either alone or in combination with information possessed by the Clients, etc. for the Marketing Research-Related Purposes. In cases where a specific individual may be identified by combining information provided by the Company and that possessed by any Client, etc., the Company shall arrange the following matters with such Client, etc.:
    (i) Limitation on the use of information provided by the Company within the range of the Marketing Research-Related Purposes;
    (ii) Prohibition on re-identifying an individual such as by combining information provided by the Company with information possessed by the Clients, etc., such as names, addresses, phone numbers and email addresses, from which a specific individual can be identified directly; and
    (iii) Range of persons or entities to which the Clients, etc. may re-provide information (if applicable), and the purposes for which the receiver of the re-provided information shall be permitted to use such information.
    * This provision applies in cases where the Company provides part of the personal information to Clients, etc., and the same shall not apply in cases involving the provision of personally referable information (defined under the amended Act on the Protection of Personal Information in Japan as information relating to a living individual which does not fall under personal information, pseudonymously processed information or anonymously processed information).

    (3) The Company may compare information received from the entruster upon entrustment with information possessed by the Company.

    (4) The Company may subcontract the handling of personal information to a third party within the extent of the purposes of use. In that case, the Company makes a contract with the third party about personal information protection, and obliges the third party to take appropriate safety management measures.

    (5) For the personal information provided by the Company to a third party, the privacy policy, etc. of the said third party shall be applied.

  6. Sharing of Personal Information between the Company and its Subsidiaries and Affiliates

    The Company may use personal information obtained by the Company jointly as follows. The Company will make efforts to maintain strict information management when using personal information jointly.

    Jointly used personal data items: Information about Survey Respondents, business partners, and job seekers as set forth in "1. Types of Personal Information Subject to Disclosure" and "Personal Information Subject to Disclosure" in this privacy policy.

    Scope of joint users: The Company and group companies of the Company (the companies which are introduced as group companies on the Company's website https://www.macromill.com/global/company/group.html)

    Purpose of joint usage: The purposes set forth in "Purposes of Use of Personal Information" in this Privacy Policy.

    Name of person or business operator responsible for managing the joint usage: The Company

    Toru Sasaki, President, Representative Executive Officer and CEO
    11th Floor, Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo

  7. Provision to Overseas Third Parties

    (1) The Company may provide personal information it has acquired to third parties located overseas (meaning countries or areas located outside Japan), in any of the following cases:

    1. (i) The Company provides the personal data to third parties located in countries which have systems of personal data protection equivalent to those of Japan in terms of protecting rights and interests of the information subjects set forth in the rules of the Personal Information Protection Commission;
    2. (ii) It is ensured between the Company and the third parties who receive personal data from the Company that measures are implemented regarding the handling of such personal data according to the intent of the laws and regulations and in a sufficient and reasonable manner;
    3. (iii) The third parties who receive personal data are certified under certain global frameworks regarding the handling of personal information;
    4. (iv) Any of the cases set forth in Paragraph (1) of "Third-Party Provision of Personal Information" apply (provided, however, that, in any of the cases set forth in Items (vi) through (ix), provision shall be limited to the personal information of information subjects who have agreed to the application of this Privacy Policy);
    5. (v) The Company provides information which cannot, by itself, identify the specific individual, such as Monitor IDs of Survey Respondents, attribute information of Survey Respondents, or the contents of Survey Respondents' responses to surveys, to the Company's clients located overseas (regardless of the country) for conducting Marketing Research (limited to personal information of information subjects who have agreed to the application of this Privacy Policy);
      * This provision applies in cases where the Company provides part of the personal information to Clients, etc., and the same shall not apply in cases where personally referable information is provided.
    6. (vi) The information subject's consent is obtained for the provision of his/her personal information to third parties, such as in Item (v); or
    7. (vii) The Company provides information for the purpose of subcontracting all or part of the Marketing Research or the development of marketing solutions, to the extent necessary, to such subcontractor.

    (2) Since the overseas third parties to which the personal information will be provided shall be considered depending on each case, the names of the countries in which such third parties are located cannot be identified at the time of your agreement with this Privacy Policy. Please refer to the website of the Personal Information Protection Commission
    (https://www.ppc.go.jp/en/aboutus/roles/international/cooperation/) for information on personal information protection systems in foreign countries.

    (3) Since the overseas third parties to which the personal information will be provided shall be considered depending on each case, information related to the measures for personal information protection to be taken by such third parties cannot be provided at the time of your agreement with this Privacy Policy.

  8. Inquiries and Complaints

    For inquiries and complaints about the Company's handling of personal information and this Privacy Policy, please contact us at the following contact point

    1. MACROMILL Personal Information Help Desk

      11th Floor, Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo 108-0075
      * The contact from is available here.

      Chief Privacy Officer: General Manager of the Legal and General Affairs department
      * For questions about MACROMILLmonitors, please visit here.

      The Company is a member of the following authorized personal information protection organization:

      Personal Information Protection Consultation Service Office,
      Japan Institute for Promotion of Digital Economy and Community
      Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
      TEL: 03-5860-7565, TEL: 0120-700-779

  9. Personally Referable Information

    If the Company provides any personally referable information retained by the Company to any third party and it is assumed that such third party will acquire such personally referable information as personal data, the Company will confirm that the consent of the information subject is obtained regarding such third party's acquisition of the information as personal data, except where any of the cases set forth in Paragraph (1), Items (i) through (iv) of "Third-Party Provision of Personal Information" apply. The Company further confirms that, in the case where such third party is located overseas, the information subject is provided with information that is to serve as a reference for the information subject in accordance with the laws and regulations, prior to obtaining consent from such third party.

    The Company may acquire, as personal data from which the information subject can be identified, any information that is related to any person who has agreed to this Privacy Policy and that is regarded as personally referable information by the relevant provider. The information which may be acquired as personal data and the third parties who may become providers of such information are as follows:

    1. (1) Information which may be acquired as personal data:

      1. (i) Advertisement identifiers and any information related thereto, such as access logs;
      2. (ii) Cookies and any information related thereto, such as access logs; and
      3. (iii) Other information that the Company receives from the relevant provider for the Marketing Research-Related Purposes.
    2. (2) Third parties who may become providers:

      1. (i) The Company's clients and end-clients; and
      2. (ii) Any third parties that have contractual relationships with the Company, such as the Company's affiliates.
  10. Location Information

    In the event that, regarding the Location Information, there is any provision in the other chapters which is inconsistent with the content stipulated in this "Location Information" chapter, the provisions of this chapter shall prevail.

    The Company may acquire, via the Apps, the Location Information from the devices in which the Apps are installed (the "Devices").

    * The Location Information will only be acquired from the Devices of the Survey Respondents who consent to the provision of the Location Information on the Apps, and never from the Devices of those who do not consent to the acquisition.
    * Even if you consent once to the provision of the Location Information on the Apps, you may at any time cease the Company's acquisition of the Location Information by cancelling the consent via the Apps.

    The details of the contents, purposes of use and other matters related to the Location Information provided to the Company through the Apps are as set forth below:

    Item Details
    Contents of the Location Information 1. Location information from the Devices' GPS

    < Detailed Item>
    ・Longitude and latitude
      *Relying on the accuracy of GPS
    ・Measurement date and time
    ・Sending date and time
    ・Advertisement identifier
    ・Information on devices used
    ・GPS accuracy (error)
    ・Name of measurement app
    2. Beacon information for the Devices

    < Detailed Item>
    ・Information on beacon devices contacted
    ・Measurement date and time
    (for each entry to and exit from the area)
    ・Advertisement identifier
    ・Information on devices used
    ・Strength of beacon signal
    ・Distance from beacon
    ・Name of measurement app
    ※Measurements rely on the condition of the Devices or signals.
    Purposes of Use ・To create statistical outputs by analyzing and aggregating the Location Information (including, without limitation, conducting it by linking to other information possessed by the Company)
    ・To select the Survey Respondents for the questionnaires by using the Location Information
    ・To provide the Company's clients or other third parties with the Location Information
    ・To develop and improve the products and services of the Company, its clients, its business partners or others.
    Provision from the Company to third parties ・The Company may provide the Location Information to its clients or other third parties after conducting meshing or other appropriate processing thereon; provided, however, that the Location Information shall not contain any information that is able to directly identify, without matching with other information, a specific individual by itself (including, but not limited to, name, detailed address, phone number or email address).
    Benefits the Survey Respondents receive by providing the Location Information to the Company ・The Survey Respondents will have a chance to be selected as the Survey Respondents for the Marketing Research that the Company implements using the Location Information; provided, however, that such Survey Respondents will be selected from among those who meet the requirements of the Survey Respondents, therefore participation in the Marketing Research using the Location Information is not guaranteed.
  11. Transmission of Information from the Device Used

    1. 1. Transmission of User Information

      If you use the website or apps provided by the Company, information regarding the user, such as access logs and operation logs, may be sent to the Company and third-party companies approved in advance by the Company from the device being used. The Company will handle the acquired information according to the Company’s Privacy Policy. Information collected by third-party companies will, in principle, be handled at the responsibility of said third-party companies according to their privacy policies, etc. Please refer to the following page for details on the transmission of information to third-party companies. Transmission of User Information to Third-Party Companies (PDF: Japanese Version Only)

    2. 2. Cookies

      1. (1) What are cookies?
        1. A "cookie" is a file that is saved on the device being used by a person who accessed a website, and is used by the website server to exchange information with the browser of the device being used.
        2. Website servers can write in voluntary information in cookies of the device being used to visit a website, and that information can be referenced when such website is accessed again from the device being used. For example, by writing in an identifier (cookie ID) in the cookie when the user visits a website, when the website is accessed again from the same device, the user’s browser can be identified by referring to such identifier. By doing so, the browsing history, such as which website the user visited, can be collected. The user can also save the effort of entering the same information repeatedly by storing the information the user entered in cookies.
        3. By changing the settings of the browser being used, the user can reject the use of cookies.
      2. (2) Use of cookies by the Company
        1. The Company uses cookies on websites operated by the Company and on websites operated by third-party companies such as the Company's Alliance Partners. In addition, information such as a user's access logs that are collected by using cookies are collected as the browsing history of the website.

          The Company will use cookies to improve the users' convenience in using the services. In addition, by using cookies, collected browsing history will be used for the Marketing Research-Related Purposes or for the purpose of delivering advertisements.

          If you wish to stop the collection of browsing history by the Company's use of cookies, please click the opt-out button below. After you opt out, your browsing history will not be collected. If you change your browser or delete cookies, you must configure the opt-out settings again. Please note that you will not be able to use some of the services provided by the Company if you opt out.

        1. Cancel opt out (opt in)

          Status

          Opt out inactive.

      3. (3) Use of cookie information by third-party companies
        1. Please note that on the websites operated by the Company, third-party companies permitted by the Company, such as the Company's Alliance Partners, may be collecting information by using cookies. If there are requests from users, third-party companies may be able to stop the collection, etc. of information by using cookies. For more details, please refer to the sections "Transmission of User Information to Third-Party Companies (PDF: Japanese Version Only)" and "Opt-Out."

          Please note that, even on the external websites that the Company's Survey Respondents visit during Marketing Research, third-party companies may be collecting information by using cookies.

          Information collected by using cookies by third-party companies will, in principle, be handled at the responsibility of said third-party companies pursuant to their privacy policies.
    3. 3. Advertising identifiers

      On the apps provided by the Company, the Company or third-party companies permitted by the Company may be collecting advertising identifiers of the device being used. In addition, advertising identifiers of Android devices are called "Android Advertising ID," and advertising identifiers of iOS devices are called "IDFA,"

      If there are requests from users, third-party companies may be able to stop the collection, etc. of advertising identifiers. For more details, please refer to the sections "Transmission of User Information to Third-Party Companies (PDF: Japanese Version Only)" and "Opt-Out."

      In addition, by changing the device settings, users may restrict the transmission of advertisements by use of advertising identifiers. If you want the restriction settings, please change your settings according to the instructions on each website below.

      ・Setting of IDFA, advertisement identifier for iOS devices
      [Apple Support Center]
      ・Setting of Google Advertising ID, advertisement identifier for Android devices
      [Advertisement ID - Google Play Help]
      If there is any discrepancy between the Japanese and English versions of this Privacy Policy, the Japanese version will apply to you.

  12. Privacy notice

    OUR POLICY ON USING YOUR PERSONAL DATA (Limited to Online Surveys)

    effective on February 1, 2019

    We, Macromill, Inc. take your privacy very seriously and undertake to process your personal data in compliance with applicable privacy laws including the EU General Data Protection Regulation ("GDPR"). Below is our policy on how we use your personal data in the context of our online surveys. We may modify, add to, or delete part of this policy from time to time. You can obtain the latest version at the following link: https://group.macromill.com/privacy.html

    SCOPE OF APPLICATION

    This policy will apply to the online surveys that we conduct that are subject to the application of the GDPR. Online surveys or surveys that are not subject to the application of the GDPR will be subject to the application of our privacy policy and separate policies according to the contents of such surveys. Furthermore, the most recent version of our privacy policy may be confirmed at the following link: https://group.macromill.com/privacy.html

    HOW WE USE PERSONAL DATA, ON WHAT GROUND

    When you participate in this survey, we collect and use your personal data including your unique respondent identification number ("RIN") and the responses you provide. We obtain your RIN from a third-party market research company that assigned the RIN to you and provided us with a survey panel consisting of respondents including you ("Panel Vendor"). We are unable to identify you with your RIN. We collect and use your personal data for the purpose of this survey on the legal ground that our client that commissioned us to conduct this survey has legitimate interest to do so, i.e. obtaining precious insight that helps our client better serve its customers and develop better products or services.

    SENSITIVE PERSONAL DATA

    We may ask you to provide sensitive personal data about you, such as those revealing your health condition, sexual life, political opinion, religious/philosophical view, racial/ethnic origin or trade-union membership. Privacy laws require us to obtain your explicit consent when we collect and use sensitive personal data. In this context you may choose not to provide sensitive personal data; on the other hand, we assume you gave us your explicit consent by providing us with sensitive personal data in your responses. We will bring this to your notice when we ask for your sensitive personal data. You can at any time withdraw your consent to our using your sensitive personal data. However, because we are not in a position to identify you with the data we have, if you wish to withdraw your consent, we will request you to provide us with additional information that, together with the data we have, enables us to identify you as the particular individual that can legitimately exercise the right to withdraw the consent.

    HOW LONG WE KEEP YOUR PERSONAL DATA

    We will keep your personal data you share with us in this survey as long as you are registered with the Panel Vendor, during which period of time we are unable to identify you as particular individual with those data. When you unsubscribe from the Panel Vendor and it deletes your RIN, then your personal data will be irreversibly anonymized, i.e. nobody can any longer by any means identify you with the data you have shared with us.

    WHO WE SHARE YOUR PERSONAL DATA WITH

    We disclose your personal data to the following entities:
    •   to the Panel Vendor; we share with them your responding status, i.e. the fact that you participated in the survey and/or you completed it, irregular responses if any, etc.;
    •   to our client that commissioned us to conduct this survey; Our clients do not have the right to demand to us for additional information to identify an individual., therefore they are unable to identify you as particular individual; and
    •   to our service providers that provide us with services necessary to conduct this survey, including cloud platform, IT operation and maintenance service.
    We will not disclose your personal data to anybody else without your consent, unless we are required to disclose them to competent public authorities under legal obligations we are subject to.

    TRANSFERS TO NON-EU COUNTRIES

    By responding to this survey, your personal data (your RIN and responses) will be transferred to Japan, where we are based and which has received an adequacy decision in accordance with Article 45 of GDPR. We protect your rights with personal data in compliance with GDPR, Japanese laws or a data transfer agreement pursuant to Article 46 of GDPR signed between the Panel Vendor and us. This agreement imposes on us contractual obligations to protect your rights, obligations equivalent to those laid down in GDPR. If a data transfer agreement has been signed, contact us to obtain a copy of the full text of the data transfer agreement. We will not further transfer your personal data to any third-country outside of the European Economic Area.

    YOUR LEGAL RIGHT

    Provided that certain conditions are met, you have the legal rights to request from us the following:
    •   information on what personal data we have about you and access to your personal data and other supplementary information;
    •   having your personal data rectified;
    •   having your personal data erased;
    •   having our processing of your personal data frozen;
    •   obtaining your personal data in a structured, commonly used and machine-readable format; and
    •   not holding you subject to automated decision making and profiling.
    As we are not in a position to identify you with the data we have, if you wish to exercise the rights above, we will request you to provide us with additional information that, together with the data we have, enables us to identify you as the particular individual that can legitimately exercise the rights above. Please contact us for further information about exercising your rights.

    COMPLAINT

    You can lodge complaints about our way of processing your personal data with data protection supervisory authority of your country of residence.

    INQUIRY

    For further information and inquiry, please contact the email address below. The proper department will respond according to the contents of the information or inquiry:
    email: [email protected]