Sumita Consulting Co., Ltd. (hereinafter referred to as "the Company") establishes this Privacy Policy (hereinafter referred to as "this Policy") regarding the handling of users' personal information in the services provided on this website (hereinafter referred to as "the Services") as follows.

1.Personal Information

"Personal Information" refers to information defined as such under the Act on the Protection of Personal Information, and means information relating to a living individual that can identify a specific individual by name, date of birth, address, telephone number, contact details, and other descriptions contained in such information. It also includes data such as facial appearance, fingerprints, and voiceprints, as well as insurer numbers on health insurance cards and other information that can identify a specific individual by itself ("Personally Identifiable Information").

2.Method of Collecting Personal Information

The Company may ask users to provide personal information such as name, date of birth, address, telephone number, email address, bank account number, credit card number, and driver's license number when they register to use our services. In addition, the Company may collect information including users' personal information, transaction records, and payment details from our business partners (including information providers, advertisers, advertisement distribution partners, and other entities; hereinafter referred to as "Partners") based on transactions between users and such Partners.

3.Purpose 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 Company’s services
2. To respond to inquiries from users (including identity verification)
3. To send emails regarding new features, updates, campaigns, and information about other services offered by the Company that the user is currently using
4. To contact users as necessary for maintenance, important notices, and other relevant communications
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 of the services
6. To allow users to view, modify, or delete their registered information, and to view their usage status
7. To bill users for paid services
8. To serve purposes incidental to the above purposes

4.Changes to the Purpose of Use

1. The Company may change the purpose of use of personal information only when it is reasonably recognized that the new purpose is related to the original purpose before the change.
2. If the purpose of use is changed, the Company shall notify users of the revised purpose or publicly announce it on this website through a method prescribed by the Company.

5.Provision of Personal Information to Third Parties

1. The Company will not provide personal information to third parties without the prior consent of the user, except in the following cases or where permitted by the Act on the Protection of Personal Information and other applicable laws and regulations:
   1. When it is necessary to protect the life, body, or property of a person and it is difficult to obtain the consent of the individual.
   2. When it is particularly necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the individual.
   3. When it is necessary to cooperate with a national or local government agency, or a party entrusted by such agency, in executing duties prescribed by law, and obtaining the individual's consent may interfere with the execution of such duties.
   4. When the following matters have been announced or made public in advance, and the Company has notified the Personal Information Protection Commission:
      1. That the purpose of use includes provision to third parties
      2. The items of data to be provided to third parties
      3. The means or methods of such provision
      4. That the Company will cease the provision of personal information to third parties at the request of the individual
      5. The method by which the individual can make such a request
2. Notwithstanding the provisions of the preceding paragraph, the following cases shall not be considered provision to third parties:
   1. When the Company entrusts the handling of personal information, in whole or in part, within the scope necessary to achieve the purpose 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 specific party, and the Company has notified the individual in advance, or made it easily accessible to the individual, of the items of personal information to be jointly used, the scope of joint users, the purpose of use by the users, and the name or title of the party responsible for the management of such personal information

6. Disclosure of Personal Information

1. When a request for the disclosure of personal information is made by the individual concerned, the Company shall disclose such information to the individual without delay. However, if any of the following applies as a result of such disclosure, the Company may decide not to disclose all or part of the information. If the Company decides not to disclose the information, it will notify the individual without delay. A handling fee of 1,000 yen per request will be charged for the disclosure of personal information.
   • If there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party
   • If there is a significant risk of interference with the proper execution of the Company’s operations
   • If disclosure would result in a violation of laws or regulations
2. Notwithstanding the provisions of the preceding paragraph, the Company, in principle, will not disclose information other than personal information, such as history data and attribute information.

7.Correction and Deletion of Personal Information

1. If a user believes that their personal information held by the Company is incorrect, the user may request the correction, addition, or deletion (hereinafter referred to as “Correction, etc.”) of such personal information in accordance with the procedures prescribed by the Company.
2. If the Company determines that it is necessary to respond to such a request, the Company shall make the Correction, etc. to the relevant personal information without delay.
3. When the Company has made a Correction, etc. based on the preceding paragraph, or has decided not to make such a Correction, etc., it shall notify the user without delay.

8.Suspension of Use of Personal Information

1. If the Company is requested by an individual to suspend the use or erase their personal information (hereinafter referred to as “Suspension of Use, etc.”) on the grounds that such personal information is being handled beyond the scope of the intended use, or that it was obtained by improper means, the Company shall promptly conduct the necessary investigation.
2. Based on the results of the investigation, if the Company determines that it is necessary to comply with the request, it shall promptly carry out the Suspension of Use, etc. of the relevant personal information.
3. When the Company has carried out the Suspension of Use, etc. based on the preceding paragraph, or has decided not to do so, it shall notify the user without delay.
4. Notwithstanding the provisions of the preceding two paragraphs, if it is difficult to carry out the Suspension of Use, etc. due to high costs or other reasons, and if alternative measures can be taken to protect the rights and interests of the user, the Company shall take such alternative measures.

9. Changes to the Privacy Policy

1. The contents of this Policy may be changed without prior notice to users, except as otherwise provided by law or specifically stipulated in this Policy.
2. Unless otherwise specified by the Company, the revised Privacy Policy shall take effect from the time it is posted on this website.

10.Contact for Inquiries

For any inquiries regarding this Policy, please contact the following: Company Name: Sumita Consulting Co., Ltd. Email Address:

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