Privacy Policy for UrFund

Privacy Policy

200WEST Corporation (hereinafter referred to as "the Company") respects the importance of personal information and complies with all applicable laws and regulations regarding the protection of personal information. (hereinafter referred to as "the Company") respects the importance of personal information, and in order to ensure the thorough protection of such information, the Company has established the following privacy policy (hereinafter referred to as the "Policy") in compliance with applicable laws and regulations regarding the protection of personal information. The following privacy policy (hereinafter referred to as the "Policy") has been established in order to ensure the protection of personal information. By using our services, you are deemed to have agreed to this Policy.

1. Compliance with Related Laws, Regulations, Guidelines, etc.
We will comply with the Personal Information Protection Law and other related laws and regulations, guidelines set forth by the Personal Information Protection Committee, and this Policy, and will handle personal information legally and appropriately.

2. Acquisition of personal information
We will acquire personal information in a lawful and appropriate manner.

3. Purpose of Use of Personal Information
The Company will specify the purpose of use of personal information to be acquired as much as possible, and employees authorized for specific tasks will handle personal information appropriately within the scope necessary to achieve the said purpose. In addition, we will take measures to ensure that personal information is not used for any other purposes. The types of personal information and purposes of use are as follows:

(1) The types of personal information that we expect to obtain are as follows
(i) Name, address, contact information (telephone number, e-mail address)
(ii) Occupation, place of employment, date of birth, gender
(iii) Other information obtained for the purpose of use.

(2) The purposes of use of personal information by the Company are as follows
(i) Personal information obtained through inquiries
To respond to opinions and inquiries from customers
(ii) Personal information obtained through employment applications
(iii) Personal information obtained through the use of services provided by the Company
(iii) Personal information obtained from customers through the use of services provided by the Company
To contact and respond to customers
(iv) Information obtained in connection with the Company's outsourcing of business operations
To execute the entrusted business.

4. Consignment of personal information
We may outsource the handling of personal information to subcontractors in order to facilitate business and provide better services within the scope necessary to achieve the above purposes of use. However, the personal information to be entrusted shall be limited to the minimum necessary to perform the entrusted operations.

5. Provision of personal information to third parties
We will not provide personal information to third parties (excluding subcontractors) unless we have the prior consent of the individual or are permitted to do so by law. (excluding subcontractors), except with the prior consent of the individual or as permitted by law.

6. Management of personal information
(1) Ensuring Accuracy of Information
We will keep personal information accurate and up-to-date to the extent necessary to achieve the purpose of use, and will endeavor to delete personal information when it is no longer necessary to use it.

(2) Safety Control Measures
We will take necessary and appropriate measures to prevent leakage, loss, or damage of personal information and for other safety management.

(3) Supervision of Employees
When having employees handle personal information, we will ensure that they are familiarized with the proper handling of personal information, provide them with appropriate training, and supervise them as necessary and appropriate.

(4) Supervision of contractors
When outsourcing the handling of personal information, we will select a subcontractor that has appropriate security control measures in place and conduct necessary and appropriate supervision of the subcontractor.

7. Inquiries regarding personal information
(1) When the Company receives a request from the individual or his/her representative to be notified of the purpose of use of retained personal data, the Company will notify the individual without delay, except in the following cases
(i) When the purpose of use of retained personal data that identifies the individual is clear
(ii) Where there is a risk of harm to the life, body, property, or other rights or interests of the individual or a third party
(iii) Cases in which there is a risk of harm to the Company's rights or legitimate interests
(iv) When it is necessary to cooperate with a government agency or local public body in the execution of its legally prescribed duties, and there is a risk of interfering with the execution of such duties.

(2) When disclosure of retained personal data is requested by the person or his/her representative, except in the following cases, the Company will notify the person without delay.
(i) When there is a risk of harm to the life, body, property, or other rights or interests of the person or a third party
(ii) If there is a risk of significant hindrance to the proper conduct of our business
(iii) When it is in violation of laws and regulations

(3) If the person or his/her representative requests correction, addition, or deletion of retained personal data, we will investigate without delay and take appropriate action based on the results.

(4) If the individual or his/her representative requests that the retained personal data be discontinued or erased, and it is found that there is a reason for the request, the Company will take appropriate action.

(5) In the case of a request as described in the preceding four paragraphs, please contact us by e-mail at the address listed in 12 below. The personal information provided in the e-mail will be used for the purpose of responding to the request and will be kept in strict confidence.

8 Acquisition and Use of Attribute Information, Action History, etc.
(1) For the purpose of improving customer convenience, delivering advertisements, and obtaining statistical data, the Company collects and uses behavioral history, etc. (including attribute information, hereinafter referred to as "behavioral history, etc.") of customers when they visit the website, etc. 

(2) Action History, etc. specifically includes the following. Although Action History, etc. is not information that can identify an individual by itself, it is handled as personal information if it can be easily cross-checked with other information and thereby identify a specific individual.
(i) Identifiers such as cookies, IP addresses, IDFA (Apple Inc.), Google Advertising ID (Google Inc.), etc.
(ii) Location information, browsing history, purchase history, search history, and other behavioral information related to Internet usage

(3) Behavioral information is obtained from the services (web pages, applications, etc.) of the Company and third-party companies that use the Company's services, using technologies such as cookies and Javascript. We may also receive such information directly from third-party companies through other means.

(4) The purposes of use of behavioral history, etc. are as follows
(i) Delivery of behaviorally targeted advertisements
(ii) Delivery and provision of optimized content
(iii) Measurement of advertising effectiveness
(iv) Acquisition of statistical data and marketing research and analysis
(v) Provision of results of measurement and analysis of advertising effectiveness to third-party companies using the Company's services
(vi) Provision of data utilization solutions to third-party companies using our services
(vii) To conduct access analysis within the Company's website
(viii) To display the most appropriate advertisements on other companies' websites based on the contents of users' interests and their usage on the Company's website
(ix) To provide customized services for each user by referring to the user's stored registration information when the user logs in to the authentication service.
(x) To plan, improve, and develop other services
(xi) For purposes incidental to the above purposes of use

9. Acquisition and Use of Anonymously Processed Information
We will create and provide anonymized processed information (including but not limited to behavioral history) to third parties after taking appropriate protective measures to ensure that specific individuals cannot be identified and that the personal information used to create the information cannot be restored. We may create and provide anonymized processed information (including, but not limited to, behavioral history) to third parties to the extent permitted by law. We will handle such anonymized processed information appropriately in accordance with laws and regulations to the extent necessary to achieve the purposes of use stipulated above. 10.

10. Continuous improvement
We are committed to continuous improvement to ensure that personal information is handled appropriately. We will also reflect such improvements in this Policy from time to time.

11. Revision of this policy
We reserve the right to revise this policy without notice, except as otherwise provided by law or other regulations.

12. For inquiries regarding personal information, please contact
Roppongi 5-chome, Minato-ku, Tokyo 106-0032
Roppongi Ignoppor, 5-9-20-702 Roppongi, Minato-ku, Tokyo, Japan
200WEST Corporation

Revised on February 9th, 2023