Privacy Policy

Basic Policy

With regard to the personal information of our customers, business partners, and other related parties that is utilized in the course of our business operations, we hereby declare our commitment to complying with laws, regulations, and other norms pertaining to the protection of personal information, establishing voluntary rules and a framework with due consideration of international trends, and formulating, implementing, and maintaining the Privacy Policy set forth below.

1. 1.In order to implement this declaration, we will establish ‘Personal Information Protection Regulations’ and ensure that all of our employees (including all officers, full-time employees, part-time workers, temporary workers, and other related parties) are thoroughly informed thereof, and will continue to implement, improve, and maintain such regulations.
2. 2.In order to prevent the loss, destruction, falsification, or leakage of personal information, we will implement appropriate information security measures, including countermeasures against unauthorized access and computer viruses.
3. 3.When acquiring personal information, we will do so through lawful and fair means and will not acquire it through unauthorized methods. Furthermore, when personal information is provided to us, we will clearly disclose, notify, or publicly announce to the individual who is the subject of the personal information (hereinafter referred to as the “Individual”) the fact that we are acquiring such information and the purposes of use, prior to acquisition.
4. 4.When we indirectly obtain personal information, we will verify whether the personal information being obtained has been properly acquired from the Individual by the provider.
5. 5.We acknowledge that the Individual has the right to request disclosure, correction, suspension of use, erasure, and other actions regarding their own personal information, and we will respond appropriately to such requests from the Individual.
6. 6.When we jointly use personal information with third parties, or when we entrust personal information to third parties for the purpose of outsourcing business operations, we will investigate such third parties, execute necessary agreements, and take other legally required measures.

Established: May 1, 2015
Revised: April 1, 2020
Revised: June 1, 2026
Sho Yamada, Representative Director, UNICORN Inc.

Handling of Personal Information

1. 1
   Acquisition of Personal Information

2. We will acquire the personal information of the Individual to the extent necessary for providing the services we operate and for the administration of such services. We will acquire personal information in a proper manner and will not acquire it through deception or other unauthorized means. When personal information is provided to us by the Individual, we will clearly disclose, notify, or publicly announce to the Individual that we are acquiring such information. Furthermore, we will not acquire, use, or provide personal information that includes the following:

   1. 1)Matters relating to thoughts, beliefs, and religion
   2. 2)Matters relating to race, ethnicity, family origin, registered domicile (excluding information regarding the prefecture of location), physical and mental disabilities, criminal record, and other matters that may be the cause of social discrimination
   3. 3)Matters relating to workers’ right to organize, collective bargaining, and other collective action
   4. 4)Matters relating to participation in collective demonstrations, exercise of the right to petition, and exercise of other political rights
   5. 5)Matters relating to health care and sexual life
3. 2
   Use and Handling of Personal Information

4. The personal information of the Individual that has been acquired will be used only by authorized personnel appropriate to the specific business operations, within the scope of the purposes of use described below, and only to the extent necessary for the execution of such operations. Such information may also be used across each of our respective services.

   We handle personal information with the care of a prudent manager, in accordance with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”).

   Purposes of Use

   1. 1Human resources recruitment activities (document screening, communication with applicants, etc.)
   2. 2Security management for crime prevention and disaster preparedness
   3. 3Preparation of tax documents such as withholding tax slips and payment records
   4. 4Preparation of documents related to various social insurance programs such as health insurance, employees’ pension insurance, employment insurance, and workers’ accident compensation insurance, and management of such programs
   5. 5Management of human resources, labor affairs, employee benefits, and related matters
   6. 6Billing and payment processing in various transactions
   7. 7Payment of dividends
   8. 8Transaction reviews, credit assessments, and reporting and communication of the results thereof
   9. 9Communications related to sales visits (including business negotiations)
   10. 10Responding to inquiries (via email, telephone, etc.)
   11. 11Identity verification (including age verification) and order confirmation
   12. 12Delivery of mail, products, and other items
   13. 13Various notices and communications regarding products and services
   14. 14Various notices and communications regarding campaigns, events, surveys, seminars, and similar activities
   15. 15Password issuance
   16. 16Distribution of email newsletters
   17. 17Communications upon the implementation or use of each service
   18. 18Communications in the event of violations of terms of service, contracts, or applicable laws
   19. 19Login authentication for each service
   20. 20Distribution and sales of each service
5. 3
   Definition of Personal Information

6. We define personal information as information pertaining to a living individual as set forth in the Personal Information Protection Act (including information such as name, address, and other information that can identify a specific individual, as well as information containing personal identification codes), as well as email addresses, access records, user IDs, passwords, credit card information, and other information used in conjunction with a specific individual, together with preference information, family composition, date of birth, and other attribute information pertaining to an individual when used in conjunction with personal information.

7. 4
   Information That Cannot Identify Specific Individuals

8. Cookies, IP address information, mobile device identification numbers (individual identification numbers), advertising identifiers, behavioral history information, and other information that cannot identify specific individuals are not recognized by us as personal information, as such information alone is insufficient to identify a specific individual. However, when such information is used in conjunction with personal information, it will be treated as personal information, as it is then capable of identifying a specific individual.

   In the services we provide, even when the information cannot identify a specific individual, when we use cookies, IP address information, mobile device identification numbers (individual identification numbers), advertising identifiers, behavioral history information, or other information that cannot identify specific individuals, we will disclose the purposes of use as set forth below.

   Furthermore, we may share cookies, IP address information, mobile device identification numbers (individual identification numbers), advertising identifiers, behavioral history information, and other information that cannot identify specific individuals with affiliated companies such as our parent company, and jointly use such information with such affiliated companies within the scope of the purposes of use described below.

   Purposes of Use

   1. 1Reporting advertising effectiveness measurement results to advertisers
   2. 2Reporting to advertising media for the purpose of improving advertising placement decisions
   3. 3Notifications related to advertising placement for each service, including SSP (Supply-Side Platform)
   4. 4Verification and improvement of advertising results
   5. 5Improvement of each service and enhancement of usability
   6. 6Customer classification, customer analysis, and research into consumer trends
   7. 7Delivery of optimized advertising and provision of service features
   8. 8Analysis, compilation, and processing as statistical information, and use as marketing information including reporting to other companies
9. 5
   Notification, Publication, and Modification of Purposes of Use of Personal Information

10. When we acquire and handle the personal information of the Individual, we will specify the purposes of use as precisely as possible and will clearly disclose, notify, or publicly announce such purposes of use to the Individual in advance. Furthermore, when we modify the purposes of use of personal information, we will not do so beyond the scope reasonably recognized as having relevance to the purposes of use prior to modification, and will notify the Individual of or publicly announce the modified purposes of use. However, this shall not apply in the cases set forth below.

    1. 1)When notifying or publicly announcing the purposes of use to the Individual would be likely to harm the life, body, property, or other rights and interests of the Individual or a third party
    2. 2)When notifying or publicly announcing the purposes of use to the Individual would be likely to harm the rights or legitimate interests of our company
    3. 3)When it is necessary to cooperate with a national government agency or local public authority in carrying out affairs prescribed by laws or regulations, and notifying or publicly announcing the purposes of use to the Individual would be likely to hinder the execution of such affairs
    4. 4)When the purposes of use are recognized as evident from the circumstances of acquisition
11. 6
    Scope of Use of Personal Information

12. We will not handle personal information beyond the scope necessary to achieve the stated purposes of use without obtaining the consent of the Individual.

    However, this shall not apply in the cases set forth below.

    1. 1)When required by applicable laws or regulations
    2. 2)When it is necessary for the protection of the life, body, or property of the Individual or a third party, and it is difficult to obtain the consent of the Individual
    3. 3)When it is particularly necessary for the improvement of public health or the promotion of the sound development of children, and it is difficult to obtain the consent of the Individual
    4. 4)When it is necessary to cooperate with a national government agency, local public authority, or a party entrusted by such entities in carrying out affairs prescribed by laws or regulations, and obtaining the consent of the Individual would be likely to hinder the execution of such affairs
    5. 5)When handled in a manner that does not allow identification of individuals
13. 7
    Provision of Personal Information

14. In principle, we will not provide the personal information of the Individual to third parties without the consent of the Individual.

    However, in the cases set forth below, we may provide the personal information of the Individual to third parties.

    • ·When the consent of the Individual has been obtained
    • ·When required by applicable laws or regulations
    • ·When it is necessary for the protection of the life, body, or property of the Individual or a third party, and it is difficult to obtain the consent of the Individual
    • ·When it is particularly necessary for the improvement of public health or the promotion of the sound development of children, and it is difficult to obtain the consent of the Individual
    • ·When it is necessary to cooperate with a national government agency, local public authority, or a party entrusted by such entities in carrying out affairs prescribed by laws or regulations, and obtaining the consent of the Individual would be likely to hinder the execution of such affairs
    • ·When disclosure of personal information is requested by a court, public prosecutor’s office, police authority, tax office, bar association, or an institution with equivalent authority
    • ·When all or part of our business operations are outsourced to a third party within the scope necessary to achieve the stated purposes of use
    • ·When disclosure is made to parties that bear confidentiality obligations to us, such as attorneys, accountants, or the Japan Affiliate Service Association, as required for our business operations
    • ·When the personal information of an Individual using a paid service is entrusted to payment system companies or credit card companies (with which confidentiality agreements have been executed) that are our business contractors, for the purpose of billing such Individual for service fees
    • ·When the personal information of an Individual participating in a seminar is disclosed to companies co-hosting such seminar
    • ·When necessary for the exercise of our rights
    • ·When processed statistically in a manner that does not allow identification of individuals
    • ·When disclosed to a business successor in the event of a business succession due to merger, business transfer, or other circumstances
    • ·
      When the matters set forth below have been notified or publicly announced even without the prior consent of the Individual

      • ·That the purposes of use include the provision of personal data to third parties
      • ·The items of personal data to be provided to third parties and the methods of such provision
      • ·That the provision to third parties of personal data by which the Individual is identified will be suspended upon the request of the Individual
      • ·The method for accepting requests from the Individual
15. 8
    Supervision of Contractors

16. When entrusting all or part of the handling of personal information to contractors, we will execute agreements with such contractors that include confidentiality provisions, or require such contractors to agree to our prescribed terms and conditions, and will exercise necessary and appropriate supervision to ensure that personal information is securely managed by such contractors.

17. 9
    Regarding Disclosure, Correction, Addition, Deletion, Suspension of Use, Suspension of Provision, and Erasure of Personal Information

18. When a request is made for disclosure, correction, addition, deletion, suspension of use, suspension of provision, or erasure of the Individual’s personal information, we will verify the identity of the Individual and confirm the veracity of the information through our prescribed procedures, and will promptly take the necessary measures, including disclosure, correction, addition, deletion, suspension of use, suspension of provision, or erasure, with respect to the personal information provided by the Individual. However, there may be cases in which we are unable to comply with such requests when any of the following circumstances apply. In such cases, we will notify the Individual to that effect and provide an explanation of the reasons.

    1. 1)When there is a risk of harm to the life, body, property, or other rights and interests of the Individual or a third party
    2. 2)When there is a risk of significant hindrance to the proper execution of our business operations
    3. 3)When compliance would constitute a violation of applicable laws or regulations
    4. 4)When a request for correction, addition, or deletion of personal information has been made by the Individual on the grounds that the content of the personal information differs from the facts, but verification of veracity confirms that the content of the personal information is accurate
    5. 5)When special procedures are prescribed by other applicable laws or regulations
    6. 6)When a request for suspension of use or erasure of personal information has been made by the Individual, but the personal information is being handled within the scope of the stated purposes of use and does not constitute unauthorized acquisition
    7. 7)When suspension of use or erasure of personal information would require considerable expense or is otherwise difficult to implement, and appropriate alternative measures necessary to protect the rights and interests of the Individual have been taken
    8. 8)When a request for suspension of provision of personal information has been made by the Individual, but the provision of personal information does not violate the provisions of Article 23 or Article 24 of the Personal Information Protection Act
    9. 9)When suspension of provision of personal information to third parties would require considerable expense or is otherwise difficult to implement, and appropriate alternative measures necessary to protect the rights and interests of the Individual have been taken

    If you wish to request disclosure, correction, addition, deletion, suspension of use, suspension of provision, or erasure of your personal information, please contact us at the inquiry contact information provided in Section 14 below.

19. 10
    Voluntary Nature of Providing Personal Information

20. When a request is made for disclosure, correction, addition, deletion, suspension of use, suspension of provision, or erasure of the Individual’s personal information, we will verify the identity of the Individual and confirm the veracity of the information through our prescribed procedures, and will promptly take the necessary measures, including disclosure, correction, addition, deletion, suspension of use, suspension of provision, or erasure, with respect to the personal information provided by the Individual. However, there may be cases in which we are unable to comply with such requests when any of the following circumstances apply. In such cases, we will notify the Individual to that effect and provide an explanation of the reasons.

21. 11
    Regarding Links

22. Our websites contain links to certain external websites; however, we do not share personal information with such websites. We assume no responsibility whatsoever for the collection of personal information on linked websites, and we strongly encourage you to review the privacy policies of any linked websites.

23. 12
    Regarding Security

24. Our websites employ special encryption communication technology known as SSL and manage personal information on dedicated servers protected by a security system known as a Firewall, in order to safeguard the important personal information registered by the Individual and to take all possible measures to prevent unauthorized access from external sources and information leakage.

25. 13
    Regarding Updates to the Privacy Policy

26. In the event that the Privacy Policy is updated, such updates will be posted on this website. By posting the most current Privacy Policy on this website, we ensure that the methods of collecting and using personal information are always accessible. We respectfully request that you review this policy on a regular basis.

27. 14
    Regarding the Use of External Services

28. In providing our services, we may utilize APIs and other services provided by external service providers. When using each external service, we will comply with the terms of service and privacy policy established by the respective service provider. The primary external services we utilize and their handling are as follows.

    1)YouTube API Services

    We use YouTube API Services (including YouTube Data API) in our advertising product (UNICORN) for the purpose of analyzing and classifying video content. Information acquired: publicly available information related to content such as videos, channels, and playlists, which does not constitute information that identifies specific individuals.

    Purposes of Use:
    • ·Content analysis and classification
    • ·Analysis of the advertising delivery environment
    • ·Advertising effectiveness analysis and reporting
    • ·Providing insights for advertisers and advertising agencies
    • ·Service improvement and feature development

    We do not profile individual users, nor do we acquire viewing histories or other non-public information. Information that has been acquired will be retained to the extent necessary to achieve the stated purposes of use, and will be promptly deleted or updated when no longer necessary or when the information has been deleted or made private at the source.

    The use of YouTube API Services in this service is subject to the YouTube Terms of Service

    (https://www.youtube.com/t/terms), and the handling of acquired information is governed by the Google Privacy Policy (https://policies.google.com/privacy).

29. 15
    Contact Information

30. With respect to inquiries regarding disclosure, correction, addition, suspension of use, suspension of provision, erasure, and other matters relating to personal information, as well as opinions and requests concerning the handling of personal information, we have established the dedicated contact below and will endeavor to respond appropriately and promptly.

    Dedicated Contact

    Sumitomo Fudosan Shinjuku First Tower 5F, 5-1-1 Nishishinjuku, Shinjuku-ku, Tokyo 160-0023, Japan

    Inquiry Contact: Please contact us via the inquiry form.

    Please note that we are unable to accept any requests or inquiries made in person at our office.

    Request to the Individual

    • ·On our websites, your registered information may be protected by an ID and password. Please ensure that you manage your ID and password responsibly.
    • ·In order to ensure the safe use of each of our services and websites, we ask that you refrain from unnecessarily posting the personal information of others or your own personal information on our websites.