Privacy Policy

Alt Design Office Co., Ltd. (hereinafter referred to as the “Company”) hereby establish this Privacy Policy (hereinafter referred to as the “Policy”) regarding the handling of users’ personal information on the websites operated by the Company (hereinafter referred to as the “Website”) and on the services provided by the Company (hereinafter referred to as the “Services”).

Where the Personal Data Protection Act of the Kingdom of Thailand (“PDPA”) applies, please also refer to our Thailand-specific regulations.

Article 1 (Personal Information)

“Personal Information” means “personal information” as defined under the Act on the Protection of Personal Information of Japan, and refers to information about a living individual that can identify a specific individual by name, date of birth, address, telephone number, contact details or other descriptions contained in such information, as well as data relating to appearance, fingerprints, or voiceprints, and information such as the insurer number on a health insurance card that can identify a specific individual by itself (personally identifiable information).

Article 2 (Methods of Collecting Personal Information)

When users use the Services, the Company may ask for personal information such as name, date of birth, address, telephone number, email address, bank account number, credit card number, and driver’s license number. The Company may also collect transaction records and payment information that include users’ personal information from the Company’s partners (including information providers, advertisers, and ad distribution destinations; hereinafter referred to as “Partners”) concerning transactions between users and such Partners.

Article 3 (Purposes of Collecting and Using Personal Information)

The purposes for which the Company collects and uses personal information are as follows:

1. To provide and operate the Services
2. To respond to user inquiries (including identity verification)
3. To send emails regarding new features, updates, campaigns, and information about other services provided by the Company that users are using
4. To contact users as necessary for maintenance and important notices
5. To identify users who violate the Terms of Use or attempt to use the Services for fraudulent or improper purposes, and to refuse their use
6. To enable users to view, change, or delete their own registration information, and to view their usage status
7. To bill users for fees in paid services
8. For purposes incidental to the purposes above

Article 4 (Changes to the Purposes of Use)

1. The Company may change the purposes of use of personal information only when the changed purposes are reasonably recognized as having relevance to the purposes before the change.
2. When the purposes of use are changed, the Company shall notify users of the changed purposes by the method prescribed by the Company or announce them on the Website.

Article 5 (Provision of Personal Information to Third Parties)

1. Except in the cases listed below and unless permitted by the Act on the Protection of Personal Information or other laws and regulations, the Company will not provide personal information to third parties without obtaining the prior consent of the user.
   1. When necessary for the protection of a person’s life, body, or property and obtaining the person’s consent is difficult
   2. When particularly necessary for improving public health or promoting the sound growth of children and obtaining the person’s consent is difficult
   3. When cooperation is necessary with a national or local government agency, or a party entrusted by such agency, in executing affairs prescribed by laws and regulations, and obtaining the person’s consent may impede the execution of such affairs
   4. When the following items have been announced or made public in advance and the Company has filed a notification with the Personal Information Protection Commission:
      1. That the purposes of use include provision to third parties
      2. The items of data to be provided to third parties
      3. The means or methods of provision to third parties
      4. That provision of personal information to third parties will be stopped upon the request of the person
      5. The method for accepting requests from the person
2. Notwithstanding the preceding item, the recipient shall not be deemed a third party in the following cases:
   1. When the Company outsources all or part of the handling of personal information within the scope necessary to achieve the purposes of use
   2. When personal information is provided as a result of business succession due to a merger or other reasons
   3. When personal information is used jointly with a specified party, provided that the items of personal information to be used jointly, the scope of joint users, the purposes of use by the users, and the name of the party responsible for the management of the personal information are notified to the person in advance or are made readily accessible to the person

Article 6 (Disclosure of Personal Information)

1. When requested by the person, the Company shall disclose personal information to the person without delay; provided, however, that the Company may decide not to disclose all or part of the information if the disclosure falls under any of the following, and if the Company decides not to disclose, it shall notify the person without delay. A handling fee of JPY 1,000 per request will be charged for disclosure.
   1. If there is a risk of harming the life, body, property, or other rights and interests of the person or a third party
   2. If there is a risk of significantly impeding the proper execution of the Company’s business
   3. If it would violate other laws or regulations
2. Notwithstanding the preceding item, as a general rule, the Company does not disclose information other than personal information, such as history information and characteristic information.

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 correction, addition, or deletion (hereinafter referred to as “Correction, etc.”) in accordance with procedures specified by the Company.
2. If the Company determines that it is necessary to respond to the request in the preceding item, the Company shall make the Correction, etc. without delay.
3. When the Company has made the Correction, etc. pursuant to the preceding item or has decided not to make such Correction, etc., the Company shall notify the user without delay.

Article 8 (Suspension of Use, etc. of Personal Information)

1. Upon request from the person, the Company shall conduct necessary investigations without delay where personal information:
   1. Has been handled beyond the scope of the purposes of use
   2. Has been obtained by fraudulent means
   3. Has been used in a manner that may encourage or induce illegal or improper acts
   4. Is retained personal data that the business operator no longer needs to use
   5. Has been subject to leakage or other incidents
   6. Otherwise is handled in a manner that may harm the rights or interests of the person

1. Based on the results of the investigation in the preceding item, if the Company determines it is necessary to respond to the request, it shall suspend use or delete such personal information (hereinafter referred to as “Suspension of Use, etc.”) without delay.
2. If the Company has implemented Suspension of Use, etc. pursuant to the preceding item or has decided not to implement Suspension of Use, etc., the Company shall notify the user without delay.
3. Notwithstanding the preceding two items, if Suspension of Use, etc. involves substantial cost or is otherwise difficult to implement, and alternative measures necessary to protect the user’s rights and interests can be taken, the Company shall take such alternative measures.

Article 9 (Changes to this Privacy Policy)

1. Except where otherwise provided by laws or by this Policy, the Company may change the contents of this Policy without notifying users.
2. Unless otherwise specified by the Company, the revised Policy shall take effect when posted on the Website.

Regulations Applicable in the Kingdom of Thailand

This section sets out specific additional information that the Company is required to provide to users residing in Thailand and their rights regarding the handling of personal information in accordance with local laws, based on the Personal Data Protection Act of the Kingdom of Thailand (“PDPA”). If there is any inconsistency between this section and the main body of the Privacy Policy, this section shall prevail.

1. Handling of Personal Information
   The methods and purposes for handling users’ personal information, retention periods, the categories of personal information handled by the Company, and the provision of such information to third parties are as described in the Privacy Policy above.
2. Legal Basis
   As a general rule, the Company relies on users’ consent as the legal basis for the use of personal information. Where consent is not obtained, the legal basis shall be the necessity for the performance of a contract with the user, the necessity to take steps at the user’s request prior to entering into a contract, the necessity for legitimate interests pursued by the Company or a third party, or the necessity to comply with legal obligations to which the Company is subject. Legitimate interests include, for example, increasing business benefits through marketing and service improvements, and enhancing convenience and security on the Company’s Website.
3. Cross-Border Transfers of Personal Information
   For the performance of a contract with the user or to take steps at the user’s request prior to entering into a contract, the Company may transfer personal information obtained outside Japan to Japan or to third countries. When transferring personal information to a third country, the Company will handle such information using appropriate security and confidentiality measures.
4. Users’ Rights
   Users have the following rights under applicable laws and regulations. Users may exercise these rights by contacting the inquiry desk for personal information protection described in the Privacy Policy above. Upon receiving a request, and unless an exception under applicable laws applies, the Company will verify the requester’s identity and respond in good faith.
   1. Right of access to personal information
      The right to confirm whether personal information is being used and, if so, to access such personal information and related information
   2. Right to rectification of personal information
      The right to have inaccurate personal information corrected
   3. Right to erasure of personal information
      The right to have personal information erased in certain circumstances
   4. Right to restriction of processing
      The right to restrict the use of personal information in certain circumstances
   5. Right to object to processing
      The right to object to the use of personal information based on legitimate interests pursued by the Company or a third party
   6. Right to data portability
      The right to receive personal data provided to the Company in a structured, commonly used, and machine-readable format and to transmit that data to another operator without hindrance from the Company
5. Withdrawal of Consent
   Users may withdraw their consent to the use of personal information at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. Users may withdraw consent by contacting the inquiry desk for personal information protection described in the Privacy Policy above.
6. Right to Lodge a Complaint with a Supervisory Authority
   Users may lodge a complaint with a national, regional, or international supervisory authority in accordance with applicable laws and regulations regarding the Company’s handling of personal information.
7. Personal Information Required to Provide the Services
   To provide the Services, the Company requires the following information:
   1. Basic information (e.g., company name, individual’s name, telephone number)
   2. All information necessary for website production
8. Automated Decision-Making, Including Profiling
   The Company does not make decisions based solely on automated processing, including profiling, of personal information.

Created: May 27, 2022

Contact

If you have any questions about this Policy, please contact us at:
Email: contact@alt-design.tech