Privacy Policy

This Privacy Policy (“this Policy”) sets out how we, CreoFuga, Inc. (“us” or “we”), collect, use and handle information obtained from you (“User Information”) in connection with your use of our services (“Services”).

Article 1 (General Provisions)

1.1 We use commercially reasonable efforts to protect and handle User Information including personal information properly by complying with this Policy, the Act on the Protection of Personal Information (the “Act”) and other relevant laws and regulations.

1.2 Any separate terms or rules we may establish within the Services in relation to our handling of User Information will also be applicable in addition to this Policy. If any provision of such separate terms or rules is in conflict with any provision of this Policy, the provision of such separate terms or rules shall prevail.

1.3 This Policy is not applicable to any external services (“External Services”) provided by third-party service providers. For information regarding the handling of User Information in connection with External Services, please refer to the privacy policies or terms separately prescribed by the respective External Service providers.

Article 2 (Definition of User Information)

The term “User Information” as used herein includes personal information as defined under Article 2, Paragraph 1 of the Act (“Personal Information”) and the following information:

(1) Information provided by you:

(a) Name, address, phone number, email address (required for your user registration, personal identification and for preventing unauthorized uses);

(b) Credit card information, bank account information, company name, office name (may be required for purchasing or licensing of music pieces through the Services);

(2) Information we collect:

(a) Device information

We may collect information pertaining to your devices (including MAC addresses and other device-specific IDs) for the purpose of operating, maintaining and improving the Services and preventing unlawful acts.

(b) Access log and history

We may obtain your IP address, date of request and other information pertaining to your activities within the Services, which are generated and stored automatically when you use the Services, for the purpose of maintaining and improving the Services and preventing unlawful acts.

(c) Cookies and anonymous IDs

We may use cookies and similar technologies in connection with the Services. A cookie is an industry-standard technology that allows web servers to recognize your device information, but does not allow identification of individuals. You may choose to disable cookies by changing your device setting. However, some or all of the Services may not function properly without cookies.

Article 3 (Proper Collection)

We collect User Information only through your use of the Services in an appropriate manner and not through deception or any other wrongful means.

Article 4 (Purposes of Use)

4.1 We will use User Information in a proper manner only for the following purposes. We will never use User Information for any purpose other than those set out in this Policy without your consent:

Purpose of use Details Information Used
To provide, maintain and improve the Services - Personal identification, preventing unauthorized use
- Notifying users, providing, maintaining and improving the Services and facilitating communications without interruption
- Conducting questionnaires in connection with the Services
- Name, address, phone number, email address, credit card information, bank account information
- Company name, office name
To provide notices and responses - Informing about the Services and responding to inquiries
- Informing about our new services in connection with the Services and providing such new services
- Notifying you of any change in the Terms of Use or Privacy Policy for the Services, or notifying you in the event of termination, suspension or cancellation of the Services
- Name, address, phone number, email address
- Company name, office name
To provide to third parties Third-party recipients will use the information listed in the right column for the following purposes:
- Notifying and contacting you in connection with the use of certain contents posted by you
- Providing affiliated services
- Displaying advertisements that match your needs and interests
*\- Analyzing the effectiveness of advertisements
- Market analysis and marketing
- Name, address, phone number, email address
- Company name, office name Activity log, history
- Device information
- Cookies, anonymous ID
To generate statistical data and provide to third parties We will use the information listed in the right column for the following purposes:
- Generating statistical data in a format that is not personally identifiable by analyzing the information based on the type of industry and interests

Third-party recipients will use the statistical data generated from the information listed in the right column for the following purposes:
- Analyzing the effectiveness of advertisements
- Market analysis and marketing
- Device information
- Activity log, history
- Location information
- Cookies, anonymous IDs
- Company name, office name

4.2 We may revise the purposes of use provided for in the preceding paragraph to the extent that such revision is reasonably deemed related to the original purposes, upon which event we will notify you or publicly announce such revision through a procedure separately established by us.

Article 5 (Provision of Personal Information to Third Parties)

5.1 We will not provide Personal Information to any third party except in the case of the following circumstances:

(1) If your consent is obtained;

(2) If required by laws or regulations;

(3) If we need to take measures against you for your actual or attempted act that is harmful to others, in violation of public order and morality, or in violation of any provision of the Terms of Use for the Services;

(4) If such provision is necessary to protect the life, body or property of an individual, and the situation renders it difficult to obtain your consent;

(5) If such provision is necessary for improving public health or promoting the sound growth of children, and the situation renders it difficult to obtain your consent;

(6) If such provision is necessary for cooperating with government agencies, local public bodies or any agents thereof in executing the affairs prescribed by laws or regulations, and obtaining your consent is likely to impede the execution of the affairs concerned; or

(7) Upon merger, split, transfer of business or any other business succession involving transfer of Personal Information.

5.2 For the purpose of making our affiliated services (“Affiliated Services”) available to you, we shall be able to provide User Information to our partners (“Partners”) that provide the Affiliated Services if your consent is obtained.

Article 6 (Outsourcing)

We may outsource the handling or management of Personal Information, in whole or in part, to third-party service providers, upon which event we will execute a confidentiality agreement with each of such third parties in advance on the terms that conform to the provisions of this Policy and conduct necessary and appropriate supervision over such third parties to ensure proper and safe management of Personal Information.

Article 7 (Sharing of Personal Information)

We may share Personal Information with our Partners but only to the extent necessary for providing the Affiliated Services, upon which event we will publicly announce in advance the names of such Partners, purpose of use and types of information to be shared.

Article 8 (Information Gathering Modules)

The Services are equipped with the following information gathering module(s) to allow analysis of User Information. Accordingly, we may provide User Information to the following module service provider(s). The information gathering modules use Cookies and other technologies to collect User Information while excluding information that is personally identifiable. The information collected is managed in accordance with the privacy policies and other terms and conditions prescribed by the respective provider(s) listed below:

(a) Google Analytics by Google, Inc.: http://www.google.com/intl/ja/policies/privacy/

Article 9 (Targeted Advertising)

9.1 In order for us or other third-party advertising providers to conduct targeted advertising (“Targeted Advertising,” which is a technique used to distribute advertisements based on various traits of each user), we collect, store and use your activity logs (obtained in a format that is not personally identifiable), device information and other account information in the course of provision of the Services or External Services.

9.2 We may provide the information collected pursuant to the preceding paragraph to third-party advertising providers (“Advertising Providers”) in a format that is not personally identifiable for the purpose of providing advertisements tailored to your interests and preferences.

9.3 The information provided to such Advertising Providers will be handled by them in accordance with their respective privacy policies and terms.

Article 10 (Security)

10.1 For the purpose of preventing any leakage, loss or damage of User Information, we take necessary and appropriate measures to securely manage User Information by allowing only minimal and limited access to files containing Personal Information, collecting access logs and implementing security software.

10.2 We appoint our Representative Director as the person in charge to properly manage User Information and continuously improve the quality of such management.

Article11 (Retrieval, Correction and Deletion)

11.1 You may submit a request to access Personal Information you have previously provided us by following the procedure below:

(1) Submit a request using the designated form on our website or application, or by mailing a completed form together with a copy of an identity verification document (or a confirmation of your agent’s authority if requesting through an agent). 380 yen will be charged for each request submitted by mail.

(2) Upon verifying your identity pursuant to the preceding item, we will provide you with the requested information to the extent deemed reasonable. However, we may not be able to accommodate your request if we are not required to do so under the Act or other relevant laws or regulations, or if the same request is repeatedly submitted without justifiable grounds.

11.2 If you discover any inaccuracy in the Personal Information you have previously provided us, you may submit a request to modify, add to or delete relevant Personal Information by following the procedure below:

(1) Submit a request using the designated form on our website, or by mailing a completed form together with a copy of an identity verification document (or a confirmation of your agent’s authority if requesting through an agent).

(2) Upon verifying your identity pursuant to the preceding item, we will make the requested modification, addition or deletion of your Personal Information to the extent deemed reasonable. However, we may not be able to accommodate your request if we are not required to do so under the Act or other relevant laws or regulations, if the same request is repeatedly submitted without justifiable grounds, or if such modification, addition or deletion requires excessively technical work.

Article12 (Revisions)

12.1 We use commercially reasonable efforts to continuously review and improve our handling of User Information, and may revise this Policy from time to time as necessary.

12.2 We will notify you of any revisions to this Policy by announcing on our website or through other means that can be easily noticed. However, if we are required by applicable laws or regulations to obtain your consent in order for us to make certain revisions, then we will do so in a manner separately established by us.

Article13 (Inquiries)

For any inquiries regarding our handling of User Information, including any suggestions, questions, complaints or comments for us, please contact our Personal Information Help Desk at:

CreoFuga, Inc.
Personal Information Help Desk
Inquiry Form: https://en.creofuga.net/info/inquiry

[Amended August 20, 2015]

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