Privacy Policy
株式会社Kinobo (“we,” “the Company”) has established the following Privacy Policy (“this Policy”) regarding the handling of personal information of those who use our service Ukrainavi (https://ukrainavi.com/) (“Users”). We have built a personal information protection framework, made every employee aware of the importance of protecting personal information, and are committed to thoroughly implementing these efforts to promote the protection of personal information.
1. Personal Information
“Personal information” refers to “personal information” as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, “the Personal Information Protection Act”): information about a living individual that can identify a specific individual by name, date of birth, or other description contained in the information, or that contains an individual identification code.
2. Purposes of Use of Personal Information
We acquire and use Users’ personal information to the extent necessary for the following purposes. If we use personal information beyond the scope of the following purposes, we will obtain Users’ consent in advance through an appropriate method.
(1) To provide our service (“the Service”)
(2) To improve the content of the Service or develop new services
(3) To provide information about new features of the Service, updates, campaigns, and other services we offer (including sending emails, flyers, and other direct mail)
(4) To provide necessary contact such as maintenance and important notices
(5) To respond to Users’ opinions and inquiries regarding the Service (including identity verification)
(6) To report to Users on their use of the Service
(7) To request cooperation with surveys and interviews related to the Service, to request participation in various events, or to report the results thereof
(8) To investigate and analyze usage history of the Service, and use the results to improve/develop the Service and deliver advertising
(9) To provide personal information to companies participating in events hosted by the Company, based on Users’ consent and application
(10) To identify and refuse service to Users who violate the Terms of Use or who attempt to use the Service for fraudulent or improper purposes
3. Management and Protection of Personal Information
We manage personal information strictly and will not disclose or provide data to third parties without Users’ consent, except in the cases listed below. We also take measures to prevent and correct risks such as unauthorized access to personal information, and its loss, destruction, falsification, or leakage, with due consideration for safety.
(1) When necessary to protect a person’s life, body, or property, and it is difficult to obtain the User’s consent
(2) When especially necessary for improving public health or promoting the sound development of children, and it is difficult to obtain the User’s consent
(3) When it is necessary to cooperate with a national government agency, local public body, or a party entrusted by either in executing affairs prescribed by laws and regulations, and obtaining the User’s consent would impede the execution of such affairs
(4) Other cases permitted by law
4. Outsourcing the Handling of Personal Information
We may outsource all or part of the handling of personal data to the extent necessary to achieve the purposes of use. In such cases, we will thoroughly review the eligibility of the outsourcing party, establish confidentiality obligations and other matters in the contract, and provide necessary and appropriate supervision of the outsourcing party.
5. Joint Use of Personal Information
To the extent necessary to achieve the purposes of use, we may jointly use Users’ personal information within the following scope and for the following purposes.
<Purpose of joint use>
• To provide and improve the Service
<Scope of personal information jointly used>
The minimum information necessary for the above purpose
<Scope of parties jointly using the information>
• Only outsourcing partners who comply with personal information protection standards equal to or stricter than this Policy
<Party responsible for managing the personal information>
• 株式会社Kinobo (Representative: Ryo Horiki)
6. Disclosure of Personal Information
When a User (limited to the individual concerned; the same applies hereafter in this article) requests disclosure of personal information we hold, we will disclose it to the User without delay. However, if disclosure would fall under any of the following, we may choose not to disclose all or part of it, and if we decide not to disclose, we will notify the User of that fact without delay.
(1) When disclosure may harm the life, body, property, or other rights or interests of the User or a third party
(2) When disclosure may significantly impede the proper conduct of our business
(3) When disclosure would otherwise violate laws and regulations
7. Correction of Retained Personal Data
If the personal information we hold is incorrect, Users may request that we correct, add to, or delete (“correct, etc.”) that personal information.
Upon receiving such a request, we will conduct the necessary investigation without delay, and if we determine the request to be justified, we will correct, etc. the personal information without delay.
After determining whether or not to carry out the correction, etc. under the preceding paragraph, we will notify the User without delay.
8. Suspension of Use of Personal Information
Users may request that we suspend use of, delete, or stop providing to third parties (“suspend use, etc.”) the personal data we hold.
Upon receiving such a request, we will conduct the necessary investigation without delay, and if we determine the request to be justified, we will suspend use, etc. of the personal data. However, if suspending use, etc. would require a large expense or is otherwise difficult, and we are able to take an alternative measure necessary to protect the User’s rights and interests, we will take that alternative measure instead.
After determining whether or not to carry out the suspension of use, etc. under the preceding paragraph, we will notify the User without delay.
9. Procedure for Amending the Privacy Policy
We will review the content of this Policy as appropriate and work to improve it. The content of this Policy may be changed, except for matters otherwise provided for by law or elsewhere in this Policy. The revised Privacy Policy shall take effect once we have notified Users by our prescribed method or posted it on our website.
10. Compliance with Laws and Norms
We comply with the applicable laws of Japan and other norms regarding the personal information we hold.
11. Handling of Complaints and Inquiries
We accept complaints and inquiries from Users regarding the handling of personal information and respond to them appropriately and promptly. We will also respond promptly and appropriately to Users’ requests such as disclosure, correction, addition, deletion of, or refusal to use or provide, such personal information.
12. Security Control Measures
We prevent unauthorized access to, and the loss, destruction, falsification, and leakage of, the personal information entrusted to us by Users by implementing organizational, physical, personnel, and technical measures, including restricting access to personal information files, recording access logs, and implementing security measures to prevent unauthorized external access. In the unlikely event that a leak or similar incident involving Users’ personal information occurs, we will promptly report it to the relevant regulatory authority in accordance with the Personal Information Protection Act and related guidelines, and will take the necessary measures, including preventing similar incidents and preventing recurrence, in accordance with the instructions of that authority. For details, please see the attached “Security Control Measures for Personal Information.”
13. Company Address, Representative’s Name, and Personal Information Protection Manager
Our address, representative, and personal information protection manager are as follows.
Address: 東京都渋谷区恵比寿四丁目11番7号
Representative: Ryo Horiki
Personal Information Protection Manager: Ryo Horiki
14. Contact for Inquiries
If you have any requests for disclosure or correction, opinions, requests, or other inquiries regarding our handling of personal information, please contact the consultation desk below.
株式会社Kinobo Personal Information Handling Desk
Email: privacy@kinobo.co.jp
Established October 1, 2015
Revised August 1, 2023