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Tyffon Inc. (the “Company”) sets forth this Privacy Policy (this “Policy”) with regard to the treatment of user information, including but not limited to personal information, in the course of the performance of any services provided by the Company (the “Services”), as follows;


Article 1, Personal Information


1 “Personal Information” means “personal information” used in “Act on the Protection of Personal Information”(the “Act”).

2 The Company will comply with the applicable laws and regulations including the Act, obligations under the applicable ministerial guidelines and this Policy in handling Personal Information.


Article 2, Method of Collection


1 The personal information will be acquired by explicitly stating, notifying, or disclosing the purpose of use to the data subject in advance and in an appropriate manner to the extent necessary to achieve the purpose.

2 The Services may acquire user information automatically upon user use of the Service or when viewing the website. The Services will automatically receive and log information provided by the web browser, including user’s IP address, cookies, advertisements and websites viewed, and browsing environment.


Article 3, Security Control Measures


The Company will endeavor to maintain entrusted Personal Information to be accurate and updated to the extent necessary for the purpose(s) of its use. The Company will take necessary and appropriate security control measures in line with existing technical standards and will implement corrective actions as needed to protect entrusted Personal Information from unauthorized access, leakage, modification, loss, destruction, etc.


Article 4, Purpose of Use for Personal Information


The Company will use Personal Information only within the scope necessary for the achievement of the purpose(s) of use which has been specified on the Services in advance, except for cases in which the Company have obtained in advance consent from the individual who provides his/her Personal Information (hereafter “the individual”) and for cases permitted under the related laws or regulations.

Article 5, Provision of Personal Information to Third Parties


The Company shall not provide to any third party (including the same outside Japan) personal information contained in the User Information without the prior consent of the user, except where such provision is required due to any of the following circumstances:

1 There is an imminent and urgent threat toward a person’s life, body or property and such, and obtaining the consent of the interested party would be difficult;

2 There is a special need to enhance public hygiene or promote fostering healthy children

3 The Company is required to cooperate with state or local governmental organizations or their agents to perform their duties or obligations pursuant to applicable laws and regulations, and such performance is likely to be precluded if the consent of the user must be obtained; and

4 In addition to the foregoing, the Company is entitled to provide information pursuant to the “Act” or other applicable laws and regulations.4 In addition to the foregoing, the Company is entitled to provide information pursuant to the “Act” or other applicable laws and regulations.


Article 6, Supervision of Subcontractor(s)


The Company may subcontract the processing of entrusted Personal Information to a third party within the scope necessary for the achievement of the purpose(s) of use. Such third party will be selected after confirming sufficient level of information security, and the Company will exercise necessary and adequate supervision to the party by such means as making contracts.


Article 7, Modifying, and Deleting Personal Information


In the event that the Personal Information is false, the user may require the Company to modify or delete such information pursuant to the procedures established by the Company.


Article 8, Correction and Suspension of Use of Personal Information


If the Company is required pursuant to the provisions of the Act by the user to suspend use of Personal Information or to delete Personal Information due to the reason that such information is being handled beyond the scope of the purpose of the use previously made public, or has been collected in a fraudulent or otherwise illicit manner, then the Company shall, without delay after confirming that the request is made by the user itself, conduct an appropriate investigation and based upon the results thereof, suspend the use of such personal information or delete the Personal Information, and notify the party to that effect.


Article 9, Revision of Privacy Policy


The Company may revise all or part of this Policy in the future. Such revision shall apply to all of the user automatically, as of the time being posted within the website of the Company or other appropriate way, or notify the user of the same.


Article 10, Inquiries


Any suggestions, questions, complaints, or other inquiries on the handling of the User Information must be submitted to:

Address: TUNNEL TOKYO 9F Osaki garden tower, 1-1-1, Nishi-shinagawa, Shinagawa-ku, Tokyo 141-0033 JAPAN

Name: Tyffon Inc.


This Policy was originally drafted in Japanese. If there is a discrepancy in the Japanese version and the English version, the Japanese version shall prevail.