1.Definition of Personal Information

Rinmarugames recognizes personal information to be information (name, date of birth and other information which enables the identification of specific individuals) relating to a living individual prescribed in the Act on the Protection of Personal Information, information used in association with a specific individuals such as e-mail addresses, user IDs, passwords, credit cards, etc. and information concerning hobbies, family composition, age and other attribute information which integrated into personal information.

2.Cookies and IP Address Information

With respect to cookies and IP address information, as these cannot independently distinguish a specific individual, the Company does not believe this to be personal information. However, when this information is used in conjunction with personal information, this information is also deemed to be personal information.
When cookies and IP address information is used in Rinmarugames' operated media, even though a specific individual cannot be distinguished, the Company shall disclose that purpose and method. Additionally, with respect to cookies information, it is possible to refuse cookies through the browser settings. In the event the services cannot be received when cookies are refused, the Company shall make a public announcement to that effect.

3.Designation of the Purpose of Use of Personal Information

In handling personal information, Rinmarugames shall specify to the extent possible that purpose of use.

4.Restrictions on the Use of Personal Information

Rinmarugames shall not handle personal information exceeding the necessary scope to achieve the purpose of use without obtaining the prior consent of the individual concerned. In the event that personal information is acquired through mergers or other reasons, the Company shall not handle personal information exceeding the scope of the purpose of use prior to that succession without obtaining the prior consent of the individual concerned. However, in the following case this shall not be applicable.

1. When pursuant to laws and ordinances
2. When it is necessary to protect the life, limb or property of a person and when it is difficult to obtain the consent of the individual concerned
3. When there is a specific need to improve public hygiene or to promote the healthy upbringing of child and when it is difficult to obtain the consent of the individual concerned
4. When it is necessary to cooperate with organs of the state, regional public bodies or persons entrusted by such organs or bodies in the pursuit of duties prescribed in laws and ordinances and when there is a risk that by obtaining the consent of the individual concerned the pursuit of said duties will be inhibited

5.Proper Acquisition of Personal Information

Rinmarugames shall properly acquire personal information and shall not acquire personal information through deceptive or other improper means. Additionally, the Company shall pay heed so as not to indiscriminately collect information relating to a child less than 15 years of age without the consent of the child’s parent or legal guardian.

6.Notice of the Purpose of Use when acquiring Personal Information

When acquiring personal information Rinmarugames shall make public in advance that purpose of use.
However, in the following cases this shall not be applicable.

1. When there is a risk of harm to life, limb, property or other rights and interests of the individual concerned or a third party by giving notice to the individual concerned or making a public announcement of the purpose of use
2. When there is risk of harm to the rights or legitimate interest of Rinmarugames by giving notice to the individual concerned or making a public announcement of the purpose of use
3. When it is necessary to cooperate with organs of the state or regional public bodies in the pursuit of duties prescribed in laws and ordinances and when there is a risk that by giving notice to the individual concerned or making a public announcement of the purpose of use concerned the pursuit of said duties will be inhibited
4. When it can be deemed that the purpose of use is clear from the circumstances of that acquisition

7.Changes to the Purpose of Use of Personal Information

When changing the purpose of use of personal information, Rinmarugames shall not undertake a change exceeding the scope which can reasonably be deemed to have a considerable relation to the purpose of use prior to the change and shall give notice to the individual concerned or make a public announcement concerning the changed purpose of use.

8.Secure Management of Personal Information/Supervision of Employees

Rinmarugames shall stipulate personal information protection regulations and undertake the necessary and appropriate supervision of employees so as to be able to seek the prevention of the leak, loss or destruction of personal information and shall otherwise seek the secure management of personal information.

9.Supervision of Subcontractors

In the event that Rinmarugames outsources all or a portion of the handling of personal information, Rinmarugames shall conclude agreements including confidentiality with subcontractors or shall require an agreement to covenants prescribed by Rinmarugames and shall undertake necessary and appropriate supervision so as to be able to seek the secure management of personal information at the subcontractor.

10.Restrictions on Provision to Third Parties

Excluding the cases set forth below, Rinmarugames shall not provide personal information to a third party without obtaining the prior consent of the individual concerned.

1. When pursuant to laws and ordinances
2. When it is necessary to protect the life, limb or property of a person and when it is difficult to obtain the consent of the individual concerned
3. When there is a specific need to improve public hygiene or to promote the healthy upbringing of child and when it is difficult to obtain the consent of the individual concerned
4. When it is necessary to cooperate with organs of the state, regional public bodies or persons entrusted by such organs or bodies in the pursuit of duties prescribed in laws and ordinances and when there is a risk that by obtaining the consent of the individual concerned the pursuit of said duties will be inhibited
5. When prior notice or public announcement of the following matters has been made
   1. Provision to a third party is included in the purpose of use
   2. Data items to be provided to a third party
   3. The means or method of the provision to a third party
   4. Suspending the provision of personal information to a third party in accordance with the request of the individual concerned

However, the cases set forth below shall not fall within the third party prescribed above.

1. Cases in which Rinmarugames outsources all or a portion of the handling of personal information within the scope required to achieve the purpose of use
2. Cases in which personal information is provided as a result of the succession of business in a merger or otherwise
3. Cases in which personal information is used jointly with specific persons and in which this fact, the items of the personal information used jointly, the scope of the joint users, the purpose of use by the person using it, and the name of the person or business responsible for the management of the personal information are, in advance, notified to the individual concerned or are put in a readily accessible condition for the individual concerned

When personal information is used jointly with specific persons and when there are changes to that purpose of use or the name of the person or business responsible for the management of personal information, Rinmarugames shall, in advance, notify the individual concerned or put in a readily accessible condition for the individual concerned about the details of the change.

11.Public Announcement, etc. of Matters concerning Personal Information

Rinmarugames shall put the matters listed below concerning personal information in accessible condition for the individual concerned and shall respond without delay in accordance with the request of the individual concerned.

1. Purpose of use of the personal information (However, excluding matters for which no obligation is prescribed in the Act on the Protection of Personal Information. When a decision not to respond has been made, a notice to that effect shall be given without delay to the individual concerned).
2. The contact point for inquiries relating to personal information

12.Disclosure of Personal Information

When there is a request from the individual concerned for the disclosure of personal information, Rinmarugames shall disclose the personal information to the individual concerned without delay. However, in the event that any of the following apply due to the disclosure, there are cases where all or a portion of that information shall not be disclosed and, in the event a decision not to respond has been made, a notice to that effect shall be made without delay.

1. When there is a risk of harm to life, limb, property or other rights and interest of the individual concerned or a third party
2. Where there is a risk of a significant impediment to the appropriate implementation of the operations of Rinmarugames
3. When this would violate other laws and ordinances

As a general rule disclosure will not be made of information other than personal information such as access log-on information, etc.

13.Corrections, etc. of Personal Information

When there is a request from the individual concerned to correct, add or delete (hereafter referred to as “correction, etc”) the content of personal information on the ground that the personal information is contrary to the fact, Rinmarugames shall, excluding cases in which special procedures are prescribed by other laws and ordinances for such correction, etc., make a necessary investigation without delay within the scope necessary to achieve the purpose of use and, based on those results, shall make correction etc. of the personal information and shall notify the individual concerned to that effect.

14.Discontinuance of the Use of Personal Information, etc.

When a request is received from the individual concerned to discontinue using or to erase (hereafter referred to as “discontinue using, etc.”) the personal information of the individual concerned on the ground that the personal information is being handled exceeding the scope of the purpose of use publically announced in advance or on the ground that the personal information was obtained through misleading or otherwise improper means, Rinmarugames shall make a necessary investigation without delay and, based on those results, shall discontinue using, etc. the personal information and shall notify the individual concerned to that effect. However, when to discontinue using, etc. the personal information entails a large expense or when to discontinue using, etc. the personal information would be difficult, the Company shall take alternative measures when it can take necessary alternative measures to protect the rights and interests of the individual concerned.

15.Explanation of Reasons

Notwithstanding a request for the individual concerned, when Rinmarugames decides any of the following, Rinmarugames shall strive to explain the reasons when notifying the individual concerned of that decision.

1. Not to give notice of the purpose of use
2. Not to disclose all or a portion of the personal information
3. Not to discontinue using personal information
4. Not to suspend the provision of personal information to a third party