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Privacy Policy

With regard to the handling of user information, including the personal information of all registered users (hereinafter, the “Users”), in the services provided by UDN Ltd. (hereinafter, “the Company”) via this website (hereinafter, “the Service”), the Company shall set out a privacy policy as detailed below (hereinafter, “the Policy”), construct a mechanism for user information protection and ensure thorough awareness of the importance of user information protection, and thoroughly implement corresponding efforts, thereby furthering the efforts for protecting user information.

1. Management of user information

The Company shall retain the information of Users in the correct and most up-to-date state, and take steps necessary to prevent unauthorised access, loss, corruption, falsification, or leakage of user information, including security system maintenance, management structure improvement, and thorough staff training, In addition, the Company shall implement safety measures, and ultimately ensure that stringent information management is conducted.

2. Collection of user information

In the Policy, the term “user information” shall refer to the information related to the identification of the User, action histories in communications services, as well as information generated or accumulated in the User’s smartphone, personal computer, or other terminals (hereinafter, collectively termed “Terminals Used”), which pertain to either the User or the Terminal Used by the User. Hence, the term shall indicate the information collected by the Company on the basis of the Policy.

User information collected by the Company within its Services shall be categorised according to the method of collection, as follows:

The information provided by Users

The information provided by Users in order to use the Services is as follows:

  • ・User ID
  • ・Password
  • ・Name
  • ・Email address
  • ・Other information entered by Users when using the Services, into specified Service screens.

Due to additions and modifications to the contents of the Service, Users may be asked to provide other information, such as the following:

  • ・Date of birth
  • ・Sex
  • ・Telephone number
  • ・Occupation
  • ・Online nickname

(1) Information provided from other external services, as permitted by the User for the Service to cooperate with them in the use of the Services
If the User allows connection of the Service with other external services (including but not limited to social networking services) while using the Service, the following information shall be collected from the external service, based on the details agreed upon when the permission is given.

  • ・The ID used by the User in the external service.
  • ・Information which the user agreed to disclose to the other parties by the privacy settings of the other service.

(2) Other information acquired from the terminal device used
The following information pertaining to the access status to the Services and method of use may be collected depending on the settings on the terminal device used by Users. However, the User’s authorisation must be obtained in advance for the acquisition of terminal and location information. Users who do not wish to acquire Cookies can set Cookie usage to Off in the browser of the Terminal Used.

  • ・Terminal information
  • ・Log information
  • ・Cookies
  • ・Anonymous ID
  • ・Location information

3. Purpose of user information usage

The specific purposes of using user information in the Services are as follows:

  • (1) For Service registration, identity confirmation, ascertaining usage status, and for promoting and improving the provision, maintenance, protection, and usage of the Services.
  • (2) To provide information and respond to inquiries regarding the Service, the Company, or the products and services of other companies in the Company’s group.
  • (3) To deal with acts that violate regulations, the Policy, and other statutes of the Company, (hereinafter, “Regulations, etc.”) pertaining to the Services.
  • (4) For notification of changes and so forth in the Regulations, etc. pertaining to the Services.
  • (5) For the creation of statistical data associated with the Company’s Services, processed into a format wherein the User cannot be identified.
  • (6) To distribute or display newsletters, email magazines, or advertising by the Company or a third party.
  • (7) For other marketing purposes.
  • (8) For other usage associated with the above purposes.

4. Request for discontinuation of use of Personal Information

Users can request to discontinue the use of some or all of their information by applying the prescribed settings in the Services. In such cases, the Company shall promptly discontinue use in accordance with its own stipulations. However, information which is required for the use of the Service shall be maintained and will be discontinued only after the User withdraws from the Service as set by the Company.

5. Disclosure of user information to third parties

The Company shall manage all user information appropriately, and shall not disclose or provide this information to any third party, unless one of the following applies.

  • (1) The User has consented.
  • (2) Disclosure is made to a business party entrusted by the Company to conduct its operations.
  • (3) The Company will store the user information on a server managed by a corporate entity which is located in the United States (this is envisioned to be in Washington State, but shall not be limited to the state).
  • (4) It is provided as statistical data in a state where Users cannot be identified.
  • (5) It is necessary to protect the life, body, or assets of the individual, and it is difficult for the consent of the User to be obtained.
  • (6) There is a particular necessity in order to improve public health, or promote the healthy education of children, but it is difficult for the consent of the User to be obtained at that time.
  • (7) It is necessary to cooperate in the execution of legally-stipulated work by a national organisation or local government, or another party acting on their behalf, and yet there is a risk that obtaining the consent of the User might hinder the execution of their action.
  • (8) It is necessary to disclose this information under the law.

6. Disclosure of personal information

If the Company is demanded by the User to disclose his or her personal information under the provisions of the Personal Information Protection Act, the information shall be disclosed to the User without delay, once it has been confirmed that the request is made by the User (if the Company does not have the personal information, it shall notify the User of the fact). However, this does not apply to information that the Company is not obliged to disclose under the Personal Information Protection Act, or other such laws or regulations.

7. Correction and amendment, stopping usage, etc., of personal information

  • (1) If the Company is demanded by the User to correct, add to, or delete the contents of their personal information (hereinafter, “Corrections”) under the provisions of the Personal Information Protection Act because ①the personal information is not accurate, or the Company is demanded to discontinue usage of the personal information under the provisions of the Personal Information Protection Act, ②it is being treated in a manner that goes beyond the scope of usage purposes as declared, or it is being acquired through unfair means, then the Company will conduct the necessary investigation without delay once it has been confirmed that this is a request from the User himself/herself. If Corrections will be made to the contents of the personal information based on the result of the investigation, or the usage stopped, the User will be notified. When there is a justifiable reason not to make Corrections or not to stop usage, the User will likewise be notified. This is provided, however, that the Company is not under obligation to make Corrections or stop usage under the Personal Information Protection Act, or other such laws or regulations.
  • (2) If the company is demanded by the User to delete the latter’s personal information, and the Company deems it necessary to respond favourably to the request, then the personal information shall be deleted and the User shall be notified of this fact, once it has been confirmed that this is a request from the User.

8. User information for deleted accounts

If a User has withdrawn from a Service, then the user information that has been provided by the User will be deleted/disposed of appropriately, based on the Company’s regulations.

9. Compliance with and review of laws and regulations

The Company shall comply with the laws and other regulations that apply to the personal information it retains, review the contents of the policy accordingly and work toward its improvement.

10. Modification procedure for the Privacy Policy

The Company shall review the status of operations regarding the handling of user information as appropriate, and may modify the Policy if necessary, as part of the endeavour of continuous improvement. In the case of modifications of contents wherein the consent of the User is a legal requirement, however, this consent shall be obtained through a method set by the Company.


For further enquiries on the Company’s handling of personal information, please enquiry through the contact form.