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プライバシーポリシー
The protection of personal information is recognized as being of great importance to Pocket Change Inc. (“our Company” and “we”). We handle personal information of individuals (the “Users”) who use the multi-currency exchange kiosk “Pocket Change”, which enables the exchange of foreign currency into electronic money, the unique electronic money issuance platform “Pokepay”, and other services managed by our Company (the “Services”) in accordance with the Act on the Protection of Personal Information (the “Personal Information Protection Act”), other applicable laws and regulations, the guidelines established by the Personal Information Protection Commission etc. and strive to protect Personal Information pursuant to the following privacy policy of our Company (“this Privacy Policy”).
Except when the definitions are specifically stipulated in this Privacy Policy, the definitions of the terms herein are based on the Personal Information Protection Act and applicable laws and regulations.
What is Personal Information?
In the Services, “Personal Information” means information that identifies a living individual User, such as name, address, telephone number, email address, credit card number and bank account number (including information that can be easily combined with other information and thereby enables one to identify a specific individual).
Collection and Use of Personal Information
In the Services, in using the Services the User may be required to register Personal Information. In addition, we may also obtain Personal Information from our business partners, shareholders, employees and employment applicants. The Personal Information obtained is used for the purpose of use specified in the applicable terms of use (the “Terms of Use”) or for the following purposes, and the information shall be strictly managed.
Personal Information of the Users who use our Company’s Services
- To provide, manage and operate the Services;
- To make necessary contact with the User for him/her to use the Services;
- To aggregate and analyze the attributes of the User, and to collect, create and send statistical data processed so that individuals cannot be identified and specified in order to manage the Services or develop new services, etc.;
- To provide telephone verification services for the purpose of improving reliability;
- To use the registered information on external services such as SNS in the Services or to provide information to such external service if the User consents to connect such external services with the Services upon use;
- To provide information and advertisement related to the Services and such services provided by our Company’s business partners, by email or other means;
- To provide financial institutions, credit card companies, etc. or affiliated companies with information necessary for use of the Services;
- To reply to inquiries;
- To conduct media coverage of the Users;
- To troubleshoot Service operations;
- To prepare and perform any contracts if the User and our Company become parties to a contract on the Services;
- To comply with legal obligations that our Company should comply with in regards to the Services;
- To detect, prevent, or otherwise address fraud, security, or technical issues;
- To protect important interests of the User’s life, health and property, etc.;
- To protect public interest or to respond to the exercise of the authority with regard to the Services which is granted to third parties by laws and regulations;
- For other purposes for which the User’s consent has been obtained; and
- In addition to the preceding items, for the purposes permitted by the Personal Information Protection Act.
Personal Information of our Company’s shareholders (in the case of a corporation, the person in charge)
- To exercise rights and perform obligations under the Companies Act;
- To manage the shareholders' meetings;
- To implement various measures to facilitate the relationship between shareholders and our Company;
- To manage shareholders, including the preparation of data in accordance with various laws and regulations; and
- For any other work related to the above.
Personal Information of employment applicants to our Company
- To confirm application history and conduct screening (including employment and outsourcing) based on resume and other submitted documents;
- To schedule interviews or discussions and to inform the applicant of the screening results;
- To review and manage wages, remuneration and other employment conditions;
- To provide information on recruitment activities and other communication incidental to recruitment activities; and
- For any other work related to the above.
Personal Information of our Company employees
- To conduct business communications and work related to equipment and facility management;
- To transfer, evaluate, award, discipline and perform other duties related to personnel management;
- To administer affairs relating to labor management;
- To perform work related to payment of wages and bonuses, etc.;
- To perform work related to education and training;
- To perform work related to benefits, etc.;
- To perform work related to safety, sanitation, and health management, etc.;
- To perform work related to employment insurance and social insurance;
- To perform work based on laws and regulations related to tax, social security and other affairs;
- To grant stock options, and to perform work related to employee stock ownership plan or other work related to shares of our Company; and
- For any other work related to the above.
If it is necessary to use the information for purposes that are not set out above, we will contact you to that effect beforehand.
Provision of Personal Information to third parties
Our Company will not provide Personal Information to third parties without obtaining the advance consent of the User, except under laws and regulations.
Entrustment regarding Personal Information
We may entrust the handling of Personal Information of the User to a subcontracting company, and provide all or a part of the Personal Information retained by our Company to such company within the range necessary for achieving the purpose of use, to facilitate operations and provide good service to the Users. In such case, our Company will appropriately manage and supervise such entrusted company to take appropriate security control measures for Personal Information.
Outline of secure management measures
Our Company has obtained ISO 27001 certification for information security, and has built an appropriate system for managing confidential information including Personal Information.
Our Company has established an information security policy and developed a system to ensure appropriate information security, including compliance with related laws and regulations and establishment of internal rules.
In addition, we have established internal rules for maintaining and improving information security, and have clearly defined the persons in charge of the management of confidential information, including Personal Information, and their respective tasks.
When handling Personal Information in a foreign country (including usage and engagement of cloud service providers located overseas), our Company shall take appropriate measures necessary for secure management of Personal Information upon understanding the systems, etc. concerning the protection of Personal Information in the relevant country.
Procedures for disclosure, etc. of Personal Information
Personal Information registered with our Company's Services can be checked on the management page, smartphone app and other systems used with the relevant Service.
For disclosure of Personal Information, requests for suspension of use or deletion, etc. of Personal Information, and inquiries or opinions regarding the handling of Personal Information by our Company, please contact the following service desk.
Information on minors
If a User is a minor and shall enter Personal Information, it is necessary that parents, legal guardian or guardian consent to the contents of this Privacy Policy and the Terms of Use, etc., and give consent comprehensively that the User will use the Services pursuant to this Privacy Policy and the Terms of Use, etc.
Personally Referable Information
- Our Company uses cookies and similar technologies (hereinafter referred to as “cookies, etc.”) to analyze the usage of and improve our Company’s website and our Company’s smartphone app (access status, traffic and routing, etc.), to identify the devices used by customers to access our Company’s website, to provide input assistance and otherwise improve convenience of use, and to manage the login status to the Services and provide the Services appropriately.
- Our Company uses services provided by third parties to analyze usage status. The main services used by our Company are as follows, and the business operators of these services will also obtain information on the access status to our Company’s website through cookies, etc.
*Google Analytics (operated by Google LCC)
*Firebase (operated by Google LCC)
*Sentry (operated by Functional Software, Inc.) - As a general rule, information collected by our Company through the use of cookies, etc., such as website access history, will be collected in a form that cannot be used to identify an individual. However, the information related to our Company’s smartphone app “Pokepay” may be used together with the information registered in “Pokepay”, in which case we will take necessary measures for the secure management of such information as part of the Personal Information we keep.
- In addition to the above, by accessing our Company’s website, cookies, etc. will be sent from the business operator of the services used by our Company for delivery of advertisements. Through such cookies, etc., the business operator will obtain information on the usage status of our Company’s website and other websites.
- If you do not consent to the use of cookies, etc. by our Company or a business operator of a service used by our Company, you can stop the provision of information through cookies, etc. by the following methods:
- Disable all cookies
You can disable cookies from your browser’s settings. In this case, certain websites, such as services that require login, may become unavailable or may not be displayed correctly. - Disable specific cookies
Some cookies may be disabled by turning them off as prescribed by the business operator who uses the cookie. However, disabling cookies may restrict the functions of the services that use such cookies.
The main services used by our Company and the procedures to disable cookies for them are as follows.
Logs
In the Services, the operation information and access information of the User are recorded as a log. The recorded information includes the operation log, the IP address of the person who gained access, OS and other information of the terminal used, access dates and times; however, it is not used for the purpose of identifying individuals. The operation logs and access logs are used to manage and analyze the usage of the Services.
Changes to this Privacy Policy
We will review the operational status regarding the handling of Personal Information as appropriate, and we may change this Privacy Policy from time to time for continuous improvement of our Services. We will announce any important changes to the contents of this Privacy Policy.
Inquiries
For complaints regarding the handling of Personal Information, requests for disclosure, etc. of retained personal data and other inquiries regarding this Privacy Policy, please contact our staff below.
To: Person in Charge of Personal Information Protection, Pocket Change Inc.
First Okada Building 3F, 3-5, Shiba 4-chome, Minato-ku, Tokyo
(Updated on 05/16/2022)
