Clearly Inc. (collectively, “the Company”) recognizes the importance of privacy and strives to protect personal information as follows:
1. Acquisition of personal information
The Company complies with laws and other standards concerning the protection of personal information.
2. Use of personal information
The Company acquires personal information by legal and fair means, uses it properly within the range of the following applicable purposes of use.
- Provision and collection of information regarding the safety and proper use of our products
- Investigation and analysis of the actual status of use and user needs, etc.
- For business guidance, sales, and delivery regarding our products and services
- For various claims and confirmations (including management of credits, management, and collection of loans)
- For advertisement or promotion of the Company’s products as an example (including sending emails, flyers, and other direct mails)
- For notification of necessary matters concerning operation
- For conducting events, contacting winners, and delivering freebies, etc.
- For the implementation of surveys
- For corresponding to the after-sales support regarding products and services as well as other inquiries, etc.
- For development and improvement of the Company’s products and services, etc.
- For corresponding to applications for employment at the Company, etc.
- For simplification of customer registration as an example when a customer registers personal information with the Company using another service provided by the Company.
- For using all means of communication (mail, telephone, fax, and e-mail, etc.) to contact customers in order to provide guidance for reservation with dealers, and to provide guidance concerning the products or services, etc. of the Company, companies that are in parent-child relationships with the Company, and companies in which the Company holds shares or companies holding shares of the Company.
- For fulfillment of rights and obligations based on contracts, laws, and regulations, etc.
- For other purposes specified individually in each of our services
- For other various communication, management of responses, and delivery of related materials, etc.
- For other purposes of use expressly specified when acquiring personal information
Additionally, within the necessary range to achieve the purpose of use, the Company may preserve or process the personal information on an external cloud service provider, entrust the handling of personal information, and provide personal information to companies that are legally in parent-child relationships with the Company, or to the third parties such as companies in which the Company holds shares, or companies holding shares of the Company.
3. Management of personal information
The Company shall take necessary safety management measures to prevent leakage, loss, damage, or falsification of personal information, and shall manage personal information appropriately.
4. Provision of personal information to third parties
Within the necessary range to achieve the purpose of use expressly specified to the customer, the Company may provide the handling of personal information to subcontractors. In that case, the Company will supervise the subcontractors to ensure the proper use of personal information. However, this shall not apply in the following cases:
- When customers have consented to the disclosure of personal information
- When disclosure is required at the request of law or government office
- When disclosure is accessible without requiring customer’s consent in accordance with laws and regulations related to the protection of personal information in some cases
5. Personal information disclosure, and correction, etc.
The Company will respond to the request for disclosure, correction, deletion, or suspension of the use of the obtained personal information after confirming that it is an offer from the person in question.
[Contact Us] firstname.lastname@example.org
6. Acquisition of personal information on the website
7. Procedures for Disclosure of Personal Information
* Procedures for Disclosure of Personal Information
The Company has set up a point of contact for requests of a complaint, and disclosure, etc. regarding personal information
[Complaints and consultation services regarding personal information] email@example.com
* Method of requesting a form of document to be submitted in the case of the request such as disclosure, and other disclosures, etc.
Requests for disclosure, etc. from the person in question or a delegate will be accepted by submitting a disclosure invoice, etc. to the counter. As a general rule, the Company accepts disclosure invoices through online delivery such as emails. Please note that the Company does not accept oral requests by phone. In addition, if sensitive personal information is included in the document submitted by the person in question, the Company will accept after customers have blacked out this information and sent it back.
* Method of confirming one who requests disclosure etc. is the person in question or a delegate
Please check the following methods of confirmation.
[1 Method of verifying the identity of the person in question]
As a general rule, the person in question identification method for requests of disclosure, etc., shall be as follows: However, if the person in question wishes to verify identity by a method other than the following methods, the alternative confirmation method will be made possible after the method being evaluated as an appropriate confirmation method by the counter.
a) By delivering copies of data including the driver’s license, passport, basic resident register card with photo, insured person’s health insurance card or alien registration card, and resident card.
b) By delivering copies of document received by the person in question including the driver’s license, passport, basic resident register card with photo, insured person’s health insurance card or alien registration card, and by sending the document to the address of the person in question as noted in these copies by registered mail.
[2 Method of verifying a delegate’s claim]
In general, when the submission of an invoice for disclosure, etc. is made by a delegate, the procedure for confirming the identity of the person in question and the delegate along with the authority of the delegate, shall be as follows. However, if the delegate wishes to use a method other than the following methods to confirm the identity of the person in question and the delegate along with the authority of the delegate, the alternative method will be made possible after the method is evaluated as an appropriate confirmation method by the counter. As for the confirmation of the identity of the person in question and the delegate, the identification method of the person in question shall be applied (however, for the delegate, it is not necessary to deliver the copy of the resident card). As for the authority of the delegate, when the delegate is a legal representative of a minor when he/she is a legal representative of an adult guardian on the copy of the family register, the data copy of the commencement of guardianship judgment will be requested and confirmed. When the delegate is an arbitrary delegate, the delivery of data copies of the warrant and the seal registration certificate of the person in question will be requested and confirmed. However, when a delegate is a qualified person, the delivery of proven data regarding the qualification (registration number, and certificate of seal registration pertaining to employment seal, etc.) will be requested and confirmed.
As for the fees when requests are made for disclosure, etc. from the person in question, are set as follows:
1) The fee for purpose of use notification shall be $10.00(1,000 Yen) per notification of the purpose of use.
2) The fee for disclosure request shall be $10.00(1,000 Yen) per disclosure request.
3) No fees will be charged if the disclosure claim is not included in 1) and 2) as above, etc.
4) Method of fee collection Fees will be collected by sending cash registered information or payment by transfer to a financial institution after the notification of the notice pertaining to the request for disclosure, etc.
8. Regarding the Use of browsing history, behavior history, etc.
For easy access to the Website operated by the Company (collectively, “the Website”) and to the Smartphone applications, etc. (collectively, “the Application”, and “the Website, etc.” is collectively referred to as the Website and the Application), Cookies (*1), ad IDs (*2), Access Logs ( *3) and other behavioral history, etc. may be used by the Company for the purpose of improving service quality and delivering advertisements suitable for customers. Please note that this information does not contain personally identifiable information.
(※1) Regarding Cookies
(※2) About ad IDs
An ad ID is a string attached to a smartphone or tablet app that is used to display ads (behavioral targeting ads) that match customer’s interests and concerns. The ad ID may identify the customer’s device and record what has been doing in the app, what ads have been viewing, and so on. On iOS, it is called IDFA, on Android, it is called AdID, the customer may reset it by own self (relapse number) or stop it from sending.
(※3) About access logs
Moreover, the Website also enables Google Analytics advertising features and use the following features:
- Remarketing by using with Google Analytics
- Impression reports about the Google Display Network
- User distribution report and interest report of Google Analytics
Third-party distributors, including Google, have access to Cookies, anonymous IDs, and other records of the processed access to the Website, etc. with the purpose of providing the best ads based on user’s interests, concerns or location, and so on. Customers can disable these features by rejecting cookies from browser settings or by using the Google Analytics opt-out add-on. The Application may collect app usage conditions by utilizing the app analytics tool Firebase Analytics and the website analytics tool Google Analytics. These access logs are used to analyze the usage of the Application and to improve the Application and its services, they are not used for any other purpose.
9. Regarding the handling of personal information in Clearly Application & My Clearly App
The Company collects the following types of information:
*Information about features.
Information about the features used in the Application, frequencies of usage, and duration of usage Information about the type of device.
*Technical log information.
The Company collects technical information about the Application, including but not limited to:
- Details of the method of the Application usage
- Internet Protocols
- Device event information such as crash, system activity, hardware settings, browser type, browser language, and the date and time of customer’s requests and URL references
- Location information
If location and GPS operating services are used, the Website may collect information about the country and location where the Application is being used. Data is collected for complementing all user’s data in all applications, so it can’t be used to identify customer’s current or past location.
Method of use regarding the collected information:
The collected data used for the Application is served as an important part of the constant provision, maintenance, protection, and improvement of the Company’s services, it is used when proposing the improvement of existing features and development of new applications. The collected information in the Company’s application will not be used beyond the purposes of use specified in the Basic Policy on Handling Personal Information without permission from the customer.
By uninstalling the Application, customers can easily stop the Company’s information collection. About the offer to the third party The Company will not share the information acquired through the Application with companies, organizations, or individuals other than the Company, without the consent of the customer, the Company will not exceed the range specified in the Basic Policy on Handling Personal Information. However, the Company may entrust its affiliates and other consignees or individuals to process the Application Data on the Company’s behalf. The Company may share anonymous information with public institutions, companies, organizations, and individuals that are apart from the Company, or partners of the Company (publishers, advertising companies or connected sites, etc.).
Last Updated on Feb 14, 2023