cre8tiveAI Privacy Policy

RADIUS5 Co. Ltd. (hereinafter “the Company”) will treat personal information (as defined in Article 2, Paragraph 1 of the Personal Information Protection Law) collected during the provision of the cre8tiveAI service (hereinafter “the Service”) in the manner described below.

Clause 1: General Provisions
In order to protect user information, the Company will comply with the law on protection of personal information (Act No. 57 of May 30, 2003, hereinafter “Personal Information Protection Law”) as well as with related laws and regulations. The Company will make its utmost effort to protect and handle user data containing personal information in an appropriate manner.
The Policy applies to the use of the Service. In addition, privacy policies and other personal information protection policies posted on the Company’s website as well as provisions regarding the handling of personal information contained in the terms of use for the Service will also apply. In case of conflict between these provisions and the Policy, the Policy will prevail.

Clause 2: Information Collected by the Company and Collection Method
1 During the provision of the Service, the Company will collect personal information as established below.
(A)Information on Registered Users and those Applying for Registration
A-1)Information on Registered Users and those Applying for Registration
The Company will collect the names, email addresses, telephone numbers, departments (in case of corporations and associations), information about affiliations and other information specified by the Company (hereinafter “User Information”) of applicants for registration and registered users (including those of the person in charge when the registered user is a corporation) (hereinafter collectively referred to as “Users”) .
A-2)Terminal Information
In order to maintain and improve the Service as well as prevent fraudulent activities, the Company may collect information on the terminals used by Users (ID and other information that can identify terminals) when Users use the Service on a terminal or portable terminal. Furthermore, the Company may collect IP addresses automatically generated and saved at the time of using the Service as well as the date and time of User requests, and information on the operation history within the Service as well as information related to User activity in the Service (hereinafter “Log Information”).
A-3)Cookies and Anonymous IDs
Cookies and similar technologies are used for the Service. Cookies are an industry-wide standard technology used by web servers to identify a user’s browser. While cookies can identify a user’s browser, they cannot identify individual users. Furthermore, the use of Cookies can be disabled from the settings of an electronic terminal, but when doing so all or part of the Service may not be available.
(B) Sent Data
The Company will collect data sent to the Service by Users (including but not limited to video data, terminal location information, search history and other submissions to the Service by Users) (hereinafter “Sent Data”). The Company will collect personal information from Users based on the agreement between the Company and registered users excluding deceptive or other wrongful means and pursuant to the Company’s legal obligations. In addition, for acquiring personal information by means other than registered Users using the Service, the Company will notify or announce the intended use for such information in advance.

Clause 3: Intended Use
1 The Company will handle personal information acquired through the use of the Service appropriately and to the extent required for the following purposes. The Company will not use personal information for any purpose outside the scope of the Intended Use without the data owner's consent.

Intended Use	Details of Intended Use	Used Information
Service provision / maintenance / improvement	・To provide and allow subscriptions to the Service ・For identity verification and to prevent unauthorized access to the Service ・For the continuous provision, maintenance and improvement of the Service	・User information ・Terminal information, IP address, log information ・Cookies and Anonymous IDs ・Sent Data
Notifications and Support to Users	・To provide information and respond to inquiries related to the Service ・To notify of changes to the policy and terms of use of the Service, suspension or interruption of the Service, cancellation of contract and other important notifications related to the Service	・User information
Information Provision to Third Parties	In case the Company provides the above-mentioned user information to third parties, the third parties will use this information for the following purposes. ・To provide the Service	・User information ・Terminal information, IP address, log information ・Cookies and anonymous IDs ・Sent data

2 The Company may change the Intended Use set forth in the preceding paragraph to uses related to the original Intended Use within reasonable limits. Changes will be announced by means of notifications to Users, by publication on the Service or the Company's website or by other clear means.
3 In addition to the provisions set forth in Paragraph 1, the Company may process sent data and other personal information anonymously (as defined for “anonymously processed information” in Article 2, Paragraph 9 of the Personal Information Protection Law) or as statistical information in a way that Users cannot be identified. The Company may then use this information.

Clause 4: Information Provision to Third Parties
1 In general, the Company will not provide personal data (hereinafter defined as “Personal Data” is defined in Article 2, Paragraph 6 of the Personal Information Protection Law) to Third Parties (hereinafter defined as third parties other than the contractors specified in the next Clause) without the data owner’s consent. However, in the following cases personal data may be provided without Users’ consent to the extent permitted by laws and regulations.
(1) According to Laws and Regulations
(2) When necessary to protect a person’s life, health or property and it is difficult to obtain the consent from the data owner
(3) When particularly important to improve public health or promote health education for children and it is difficult to obtain the consent from the data owner
(4) When it is required by law to collaborate with the tasks of a national agency or a local public organization or a person acting on their behalf, and asking for the consent of the data owner may hinder the execution of these tasks
(5) When acquiring a business owning user information due to a merger, corporate division, transfer of business or other reasons.
2 In case of providing personal data to a third party based on the consent of the User, the Company will create and keep a record of the following items.
(1) Having prior consent from the User
(2) Name of third party and other information necessary to identify the third party
(3) Name of person identified by the personal data and other information necessary to identify the person
(4) Entries related to the personal data

Clause 5: Outsourcing of Personal Data Management
To the extent necessary for achieving the purposes set forth in the Intended Use, the Company may outsource all or part of the personal data acquired from Users to contractors. In these cases, the Company will sign an agreement of confidentiality with the contractor in advance pursuant to the Policy. In addition, when necessary the Company will perform appropriate supervision to ensure appropriate information security management by the contractor.

Clause 6: Security Management System
1 In order to prevent leakage, loss or damage of User information as well as to protect User information in other ways, the Company will implement the necessary measures to ensure appropriate security management of Users’ personal information. These measures include limiting access to personal data files and anonymously processed information, limiting the number of personnel authorized to access the files to the minimum required and utilizing security software to prevent unauthorized access.
2 The Company will designate the Representative Director as the person responsible for Users’ information management, implement appropriate management of Users’ information and continuously improve this management.

Clause 7: Users’ Right to Access or Modify Personal Data
For measures related to access, correction, deletion or suspension of use of personal data for this Service (hereinafter “Access of Information”), please refer to the Guide on Access to Personal Data and Related Requests（PDF）. Notwithstanding the above, in cases where the Company is not obliged by the Personal information Protection Law or other applicable laws and regulations, or the same content is requested repeatedly without a justifiable reason or when excessive technical operations are required, the Access to Personal Data requests may not be granted.

Clause 8: Changes to the Policy
1 The Company will make appropriate revisions of the manner in which Users’ information is managed, making its utmost effort to produce continuous improvements. If needed, the Company may make periodic changes to the Policy.
2 The modified Policy will be announced on the Service, published on the Company’s website or by other clear means. However, for changes legally requiring consent from users, the Company will obtain consent from Users according to the special procedure established by the Company.

Clause 9: Inquiries
Please contact us using the inquiry form below to provide opinions, ask questions or make complaints regarding the Company’s management of Users’ information or for other inquiries related to the management of Users’ information.

RADIUS5 Inc.
Email: info@RADIUS5.co.jp
(Inquiries will be received on weekdays from 11:00 to 17:00.)

02/15/2019

Note : This Agreement has been prepared and executed in the Japanese language. This English translation is only for your reference purpose. In the event of any discrepancy between the Japanese original and this English translation, The The Japanese original shall prevail over any translation thereof.