Spider Labs, Ltd., on behalf of its subsidiaries and divisions (collectively, “Spider Labs,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you,” or “your”) our practices regarding the personal information that Spider Labs collects, uses, and shares about end users (“Users”) of our online informational platform (the “Platform”) accessed through the website located at https://spideraf.com/, and any other websites operated by Spider Labs (each, a “Site”) or using mobile applications provided by and on behalf of Spider Labs (each, an “Application,” and each Site and Application treated as a part of the “Platform” for purposes of this Policy). Capitalized terms not defined in this Policy, shall have the meanings as defined in the Spider Labs Terms of Service, located at https://spideraf.com/terms-of-service.
1. COLLECTION OF PERSONAL INFORMATION
1.1 Personal Information We Collect. The following are categories (with non-exhaustive examples) of personal information we may collect about you:
1.2 Sources of Personal Information. We obtain the categories of personal information listed above on or through our Platform from the following categories of sources:
- Personal Information You Provide. Spider Labs collects personal information when you voluntarily submit it to us. For example, we may collect or receive personal information from Users when a User creates a User Account; edits Registration Information; signs up to receive promotional communications; uses or accesses a Service or Content available through the Platform; participates in one of our promotional sweepstakes, contests, or surveys; posts a review; submits a request to our customer service team; interacts with our social media pages; or otherwise interact with us or other Users through the Platform.
- Automatically Collected Personal Information. In addition to personal information that we may receive directly from you, Spider Labs indirectly collects other information from you automatically through the Platform. For example, we receive personal information from Users when a User visits and navigates our Platform on any device; installs and uses the Application; enables location-based features on the Application. We may also collect personal information about Users over time and across different websites, apps, and devices when a User accesses the Platform. Third parties also collect personal information this way on our Platform. Spider Labs collects some personal information automatically using Cookies or other online tracking technologies as described below.
- Personal Information Obtained from Third Parties. In addition to the personal information that we collect from you directly and automatically, Spider Labs may receive personal information about you from other third party sources. For example, we receive personal information from our business partners, social media sites, or companies that provide personal information to supplement what we already know about Users. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
1.3 Acquisition of Personal Information. Personal Information necessary for business activities will be acquired by us directly from Users and other parties, from the browser or mobile application environment, or via our partners. Additionally, when we acquire Personal Information, we will let you know or publicly announce the purpose of use thereof in advance (hereinafter referred to as “Public Announcement, etc.”) except in the following circumstances:
- Where the Public Announcement, etc., of the purpose of use will harm the life, body, asset, or other rights and interests of the subject person or a third party or is likely to harm our rights or legitimate interests;
- Where we are required to provide cooperation to the government agencies or municipal government agencies in their execution of affairs prescribed in laws and regulations, and the Public Announcement, etc., of the purpose of use to the subject person may obstruct the execution of such affairs; or
- Where the purpose of use is obvious in view of the situation of such acquisition.
2. USE OF PERSONAL INFORMATION
2.1 User Information. Spider Labs’s primary purpose in collecting personal information is to provide the Services and Content that you request on the Platform. Spider Labs may also use personal information for various purposes, including without limitation to:
- To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or other transactions. For example, if you share your personal information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use such information for calculation of charges and invoicing and to process your payment and facilitate delivery. We may also save your personal information to facilitate new product or service orders, or process returns.
- To Improve Our Products and Services. We use personal information to understand and analyze the usage trends and preferences of our Users to make our Platform, Services, or Content better, diagnose technical issues, prevent fraud, develop new features and functionality, to maintain the system, and take actions in response to failures.
- To Understand Your Interests. We use your personal information to personalize your experience on the Platform and to deliver information about products and services relevant to your interests.
- To Respond to Your Requests or Questions. We use personal information to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your feedback.
- To Determine Your Eligibility and Set Up Your Account. We use your personal information to verify your identity or determine your eligibility for some of our products, services, and promotions. For example, this may include verifying your age, date of birth, and place of residence. If you set up an Account on the Platform, we will use the Registration Information you provide in relation to that Account creation to create, maintain, customize, and secure your Account. We may use Personal Information to deny the provision of our services to those who intend to use our services for commercial, political, religious or other improper purposes, or those who are likely to take an action that may disturb the operation of our service or our business, or any action that we consider inappropriate.
- To Market Products or Services. We provide you with information about products, services, or promotions. For example, we may use cookies or other online tracking technologies to provide customized advertisements, content, and information; monitor and analyze the effectiveness of marketing activities; and track your entries, submissions, and status in any promotions. These might be third party offers we think you might find interesting. These communications may come in the form of interest-based advertising using information gathered across multiple websites, devices, or other platforms. We may also use Personal Information for various questionnaires, giveaways, campaigns, ranking events, to provide affiliate and point services and for surveys, statistics, and analyses of marketing data.
- To Secure the Platform. We use personal information to maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, business, and other Users.
- To Communicate with You. We may communicate with you about your Account or our relationship. We may also contact you about this Policy or the Terms of Service.
- As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, or government investigation and to exercise the rights and perform the duties under contracts or laws and regulations, including to take actions in relation to disputes, lawsuits, etc.
- To provide clearance services and logistics services.
- To otherwise handle matters incidental or relating to our services.
2.2 Use of Client Information. Spider Labs may also use Personal Information pertaining to contact persons, etc., of our client corporations and self-employed business owners as follows:
- For negotiation of transactions, execution of agreements, confirmation of authorities, and implementation of transactions;
- For reporting and communications necessary for transactions;
- To make or accept various consultations and inquiries;
- To prepare and submit various business documents such as estimates;
- To manage information pertaining to our partners and contact persons and verify the identity;
- To provide information regarding our services, events, etc.;
- To otherwise perform the duties under laws and regulations or contracts.
2.3 Job Applicant Information. We may use Personal Information pertaining to individuals who desire to join Spider Labs and apply for job openings for the following purposes
- For selection and other procedures for hiring, such notification of results;
- To provide information and make contacts in relation to recruiting activities;
- To improve our websites, manuals, communications, etc., intended for job applicants;
- For any and all matters relating to preliminary trainings for job applicants, job assignment, fostering of human resources, benefit package, and other labor management;
- For statistics and analyses regarding job applicants.
With regard to Section 2.1 (User Information), we may prepare anonymously processed data and provide the same to a third party upon taking appropriate protective measures to ensure that Users will not be identified or specified and that Personal Information used for the preparation of such data cannot be restored. Additionally, anonymously processed data to be prepared by us may include User Agent information (such as IP addresses, terminal device information and referrer), behavioral information such as clicks, viewing and installation, server domain information, text, image, audio and html information, and such provision will be prepared in data files and by data transmission in a secure manner.
3. SHARING OF PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this Policy, Spider Labs may share your personal information in the following circumstances:
3.1 Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or are otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
3.2 Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this policy, and we may do so with your consent.
3.3 Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service.
3.4 Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Platform. Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Policy. Access to your personal information by these service providers is limited to the information reasonably necessary for the service provider to perform its limited function. We require our service providers to keep the personal information that they are provided with confidential and to comply with all applicable laws.
3.5 Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites.
3.6 Partner or Client Offerings. We may jointly offer events, promotions, or any other product or service offerings with third party partners or our clients, which may be your employer. The personal information that you submit through an event, promotion, or other product or service offering may be combined and transmitted with the Registration Information related to your Account. Third party partners or clients may collect information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a third-party partner or client, the information that you provide may be shared with us and with that identified third party.
3.7 Social Networking. The Platform may offer you the ability to share your personal information through a social networking website (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
3.8 Public Forum and Messaging. The Platform may provide you with the opportunity to post comments, messages, or reviews in a public forum. If you decide to submit personal information at these locations, that information will be available to other Users of the Platform.
3.9 Referrals. Users may recommend other Users to join the Platform by providing their contact information or selecting friends from a social networking site. Users may also provide information about other Users of the Platform such as reviews of the services or products that he or she received, booking or scheduling information, or reference information.
4. SECURITY OF PERSONAL INFORMATION
We strive to protect Personal Information. For instance, when transmitting Personal Information and other confidential information (such as credit card numbers), we encrypt such information by using SSL (Secure Socket Layer) to protect such information. No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
5. YOUR CHOICES. You can make the following choices regarding your personal information:
5.1 Access to Your Personal Information. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law.
5.2 Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your Account. Note that we may keep historical information in our backup files as permitted by law. If our Platform does not permit you to update or correct certain personal information, please contact us as described below.
5.3 Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information by contacting us as described below. We will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this subsection within the timeframes required by law.
6.LIMITED USE DUE TO NON-PROVISION OF PERSONAL INFORMATION.
7. OPTING OUT.
7.1 Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Platform, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your Account, to fulfill orders for products and service you have requested or deliver notifications directly to you through the Platform.
7.2 Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites. If you wish to limit third parties’ collection of information about your use of our Platform, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE PLATFORM. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
7.3 Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, we do not modify your experience based upon whether such a signal is broadcast.
8.ACQUISITION OF PERSONAL INFORMATION THROUGH MEANS NON INVOLVING IDENTITY VERIFICATION.
9. HANDLING OF COOKIE INFORMATION.
9.1 When a User uses our service or views our website, we may automatically acquire the User’s cookie, IP address, IDFA, AAID and other information from the User’s browser. We may use such information for the purpose of identifying the User, delivering optimal advertisement, analyzing for delivery of optimal advertisement, developing a new service, and optimizing our services for Users.
9.2 The User may elect to allow the use of cookies and other information. If the User elects to not allow the use of such information, there may be a case where the User is unable to use all or part of our services or activate certain advertisement settings which require cookies and other information, and the User may experience a problem in using our services.
9.3 Also when you would like to request notification or disclosure of the purpose of use of the aforementioned information, correction, addition or deletion of a portion thereof, suspension of the use thereof, deletion thereof, or suspension of provision to a third party, we will accommodate your request through the procedures set forth in this Privacy Policy.
9.4 Additionally, for the steps to activate or inactivate cookies, IDFA, AAID, or other information or to delete such information, please see the manuals or Help pages for your OS or browser (with regard to advertising identifiers of third parties such as Google and Apple, please see the privacy policies of such parties).
9.5 For any question regarding the identification document, fees, and other specific procedures, please also make an inquiry to our contact indicated below.
10.GOOGLE ADS ACCOUNT DATA.
- We do not ask for your AdWords user name or password.
- We do not store any user information from your Google Ads account.
- We will not trade or sell any information from your Google Ads account.
- We will not make any changes to your Google Ads account without your approval.
- We use Google Ads API Access to set a tracking template, and to forward fraudulent IPs, Placements, and Audiences.
11.ADVERTISING TECHNOLOGY. We provide anti ad fraud tools to our partners. Our partners and their partners that adopt our anti ad fraud tools may place a JavaScript tag (or any similar technological measure) in a server, website or application which is part of the advertising network, and when an end user uses the server, website or application containing a JavaScript tag, the IP address, User Agent, IDFA, AAID, referrer, URL, time stamp, browser information, user interaction data (such as clicks, cursor location and movement, touches and scrolls), and other behavioral history information are acquired from such end user (the information so acquired shall be referred to collectively as the “Behavioral History Information”). We use such Behavioral History Information for the purpose of taking anti ad fraud measures through bot detection and other monitoring of unauthorized use, optimizing anti ad fraud measures, conducting analysis to optimize our anti ad fraud measures, and developing new services. Also when you would like to request notification or disclosure of the purpose of use of your Behavioral History Information, correction, addition or deletion of a portion thereof, suspension of the use thereof, deletion thereof, or suspension of provision to a third party, we will accommodate your request through the procedures set forth in this Privacy Policy. Additionally, for the steps to activate or inactivate IDFA, AAID, or other information or to delete such information, please see “9. Handling of Cookie Information”.
12.EUROPEAN USERS.
12.1 Lawful bases for processing. Spider Labs is required to inform you of the lawful bases of our processing of your personal information, which are described in the table below. If you have questions about the lawful basis of how we process your personal information, contact us at the address listed in the section titled “CONTACTING US” below.
We will use your personal information only for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider deidentification, aggregation, and other forms of anonymization of personal information to be compatible with the purposes listed above and, in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.
PLEASE NOTE WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.
12.2 Retention. Spider Labs retains your personal information:
- For so long as your Account is active or as needed to provide you with the Platform or to fulfill our contractual obligations;
- As necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; and
- For so long as is necessary for the purposes for which we collected such personal information.
12.3 Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.
13.CALIFORNIA USERS.
13.1 Personal Information That We Collect Use and Disclose. We describe:
- the categories of personal information we may have collected about you in the preceding 12 months in the section above called “Personal Information We Collect”;
- the categories of sources from which we collect your personal information in the section above called “Sources of Personal Information”;
- the business and commercial purposes for which we collect this information in the section above called “Use of Personal Information”; and
- the categories of third parties to whom we disclose this information in the section above called “Sharing of Personal Information”.
We must also disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law. The CCPA also calls this latter category a “sale.” Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. In the proceeding twelve months, we have disclosed the following categories of personal information in the manner described.
13.2 Your Rights as a California Resident. The CCPA provides California residents with the rights listed below:
- Right to Access. You have the right to request that Spider Labs disclose certain information to you about our collection and use of your personal information over the past 12 months, including:
- The categories of personal information we collected about you.
The categories of sources of the personal information we collected about you. - Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- The categories of personal information we collected about you.
- Right to Delete. You have the right to request that Spider Labs delete any of your personal information that we collected from you and retained, subject to certain exceptions.
- Right to Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our products and services.
Please note, these rights are not absolute and in some cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
13.3 How to Exercise Your California Privacy Rights. To exercise the access and deletion rights described above, please submit a request to us and provide the information we request that is required to verify your request by emailing us at [email protected] or writing to us at the mailing address identified in the “Contacting Us” section below.
When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You may also designate an authorized agent to make a request on your behalf. If you do so, we may require the requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
13.4 Additional California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Spider Labs are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to us at the addresses listed below.
14.EXERCISING YOUR PRIVACY RIGHTS.
14.1 No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
14.2 What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
14.3 Time to Respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
14.4 No discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.
15.CONTACTING US
When you would like to request notification or disclosure of the purpose of use of Personal Information, correction, addition or deletion of a portion thereof, suspension of the use thereof, deletion thereof, or suspension of provision to a third party, please make a request to our contact indicated below. We will accommodate such requests in an appropriate manner and to a reasonable extent pursuant to the law. For such purpose, we will verify your identity with the identification document designated by us and confirm the specifics of your request, and we will also ask you to submit a copy of the relevant documents.
For any question regarding the identification document, fees, and other specific procedures, please also make an inquiry to our contact indicated below.
For any inquiry concerning the handling of Personal Information or if you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at:
Spider Labs, Ltd.
Attention: Personal Information Manager
Minamiaoyama ST Bldg. 4F, 7-10-3 Minamiaoyama, Minato-ku, Tokyo 107-0062
Email: [email protected]
GDPR Policy
For individuals residing in the European Economic Area (“EEA”), Spider Labs, Ltd. has adopted the following additional provisions for the processing ('processing' means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction) of personal information and other information provided by individuals residing in EEA based on the General Data Protection Regulation (“GDPR”).These additional provisions shall prevail to the extent it conflicts with any provision in the main body of the Privacy Policy.
1.Processing of the Information
(1) Categories of the information
We collect and retain from individuals residing in EEA the Information including the following categories (collectively the “Information”):
Basic information (name, address, phone number, e-mail address, etc.)
Additional information (occupation, title, office information (company name, address, telephone number, department name), etc.)
Informative matters/Messages (e-mail, website form input, fax, a phone note, letter, the answers to the questionnaires, etc.)
Information collected on the internet (IP address, device and OS information, cookies, mobile identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID or similar mobile identifiers, interactions within an app, information regarding which advertisements have been seen or clicked on, etc.)
(2) Purposes of use:
We will use the Information for the purposes described in Article 5 of the Privacy Policy.
(3) Acquisition of the Information
We collect the Information from the following sources in conducting business related to our facilities, services and products:
Direct acquisition from an individual: by telephone, letter (including email and other electro-magnetic records), business cards, verbally, through the internet, etc.
Acquisition from persons with proper authorization to provide information for an individual: an individual applying on behalf of another, a party introduced by a second party, business partners and agents.
Acquisition from published material or public sources: internet, newspapers, telephone directories, books and other publications, etc.
Acquisition from third parties’ data analytics tools embedded in third party websites and mobile applications
(4) Provision to a third party:
We provide the Information to a person who falls under any of the following items:
a business operator whom we entrust with handling of the Information;
a Joint User among which we jointly use personal Information; and information providing destination specified by laws and regulations, etc., in case of provision of the Information under laws and regulations, etc.
(5) Retention Period
We retain the information for the period necessary to accomplish its purpose of processing. Following the retention period, we eliminate or anonymize such Information in a secure way within a reasonable period of time.
2.Legal Basis
We process the Information based on your consent in principle. The processing of the Information in the absence of your consent shall be based on
(i) the necessity for the performance of the contract with you,
(ii) the necessity to take steps at the request of you prior to entering into a contract,
(iii) the necessity for the purposes of the legitimate interests pursued by us or a third party, or
(iv) the necessity for compliance with a legal obligation to which we are subject.
The legitimate interests pursued by us or a third party include
(i) an increase in operating income from marketing and improvement of services, and
(ii) improvement of the convenience, security, etc., of our website and services.
3.Transfer of the Information to a Third Country located outside of EEA
We store the Information in Japan. In addition, we may transfer the Information to business partners of ours located in countries outside of the EEA.
We may transfer the Information to third parties located in countries outside of the EEA, where the Information may not receive the adequate protection, as they do not have legal frameworks for the protection of Information equivalent to that of the EU.
By agreeing to any form of documents which refers to the Privacy Policy including these additional provisions, you shall be deemed to have consented to (a) the processing of Information by us in accordance with the Privacy Policy including these additional provisions, (b) the storage and processing of Information in any country where the Company or its affiliates may use facilities (including cloud storage and cloud computing operated by third parties) or in which we engage service providers.
4.Data Subject’s Rights
You have the following rights with respect to us based on laws and regulations and you may exercise these rights by contacting our DPO. In the event that you exercise these rights, we will respond in good faith, barring statutory exceptions, after confirming that the requesting person is the person in question.
The right of access: The right to obtain confirmation as to whether or not the Information concerning you is being processed, and where that is the case, (the right to) access to the Information and the accompanying information.
The right to rectification: The right to obtain the rectification of inaccurate Information concerning you.
The right to erasure: The right to obtain the erasure of personal information concerning you in certain cases.
The right to restriction of the processing: The right to obtain restriction of the processing in certain cases.
The right to object to the processing: The right to object to the processing of Information based on the purposes of the legitimate interests pursued by us or third parties.
The right to data portability: The right to receive the Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us.
5.Withdrawal of Consent
You can withdraw consent on the processing of information at any time. Withdrawing consent does not affect the lawfulness of the processing based on consent before the withdrawal. You can withdraw consent by contacting our DPO.
6.Lodging a Complaint with an Authority
You have the right to lodge a complaint on the processing of Information with the protection authority having jurisdiction over your residence.
7.Automated Individual Decision-Making, including profiling
We do not make decisions based solely on automated processing, including profiling.
8.Security and confidentiality measures
We handle the Information with appropriate security and confidentiality measures.
9.Data Protection Officer（DPO）and EU Representative and these contacts
(1) DPO
Data Protection Officer
Minamiaoyama ST Bldg. 4F, 7-10-3 Minamiaoyama, Minato City, Tokyo 107-0062
Spider Labs, Ltd.
Email: [email protected]
(2) EU Representative
Eurico Doirado
Spider Labs Office, R. Braamcamp 84, 3º DTO, 1600-892 Lisboa, Portugal
Email: [email protected]
Last Revised: [April 22, 2024]
Previous Amendments:
Amended on October 11, 2012
Amended on July 5, 2013
Amended on April 1, 2019
Amended on October 15, 2019
Amended on September 17, 2021
Amended on December 5, 2022
Amended on April 22, 2024