Article 1. (General Provisions)
- "The WithTravel Co., Ltd." (hereinafter referred to as "the Company") operating WEB service of "atta" (hereinafter referred to as "the Service") respects the privacy of users of the services (hereinafter referred to as "Users") and exerts extreme caution in managing of Usersgc personal information and information which relates to Users' privacy other than personal information (hereinafter "both personal information and information which relates to privacy" are referred to as "Privacy Information").
- The Company both abides by "Act on the Protection of Personal Information" of Japan (hereinafter referred to as "the Law") and other regulations relevant to the Law as "Business Operators Handling Personal Information" defined by the Law and handles personal information collected from Users.
In addition, about handling of Privacy Information collected from Users who lives in EU, the Company both abides by handles by "General Data Protection Regulation" (EU 2016/679, hereinafter referred to as "GDPR") and handles the information.
- The Company both sets its policy to protect and handle Usersgc personal information as below and focuses on establishment of company structure, education of employees, etc. continuously and permanently.
Article 2. (Agreement to This Policy, Withdrawal of Agreement)
- When User provides his/her Privacy Information to the Company for reason that he/she inquiries to the Company, signs up with membership, etc., he/she shall both read This Policy carefully and agree with all provisions of This Policy.
- User is able to withdraw his/her agreement to using of Privacy Information by the Company at any time.
- The agreement and the withdrawal of his/her agreement of This Article shall be by method that the Company specifies.
Article 3. (Privacy Information Collected by the Company)
- The Company is able to collect various information related to Users such as liking or interest, action history, browsing history, etc. by using access log, IP address, cookie, GPS, and other web systems, etc.
This information collected by using the web systems, etc. does not contain personally identifiable information.
Privacy Information that the Company collects from Users is as follows.
- Name, address, telephone number, mail address, and other information which falls within the scope of Personal Information;
- Information about User individual other than Personal Information;
- Location information collected by using GPS;
- IP address and access log;
- Information about browser, etc. collected by using cookie, etc.;
- The Company does not collect "Individual Identification Codes" and"Sensitive Personal Information" defined by the Law from Users.
Article 4. (Collecting of Privacy Information)
- The Company collects Usersgc Privacy Information by just and legitimate methods, and not by illegal methods that is contrary to Users' will.
- The Company notifies Users of or publishes the purpose of use of Privacy Information preliminarily.
Article 5. (Purpose of Use of Privacy Information)
The Company uses Privacy Information collected from Users for the purpose of operation of the Service and other services that the Company operates. Main purpose of use is as follows.
- To give important notice about providing the Service, etc. to Users;
- To send catalogue, present, newsletter, etc. that relates to services of the Company;
- To respond to an inquiry, etc. from Users;
- To caution or warn against Users who violates every terms, etc. of the Service, and to check against Past disposal situation of him/her;
- To confirm identity of Users when he/she requires disclosure, change, addition, deletion, etc. of his/her Registered Information.
- To improve the Service continually
- The Company makes analysis data from Privacy Information collected from Users and statistical data form the analysis data of multiple Users.
The Company pays attention not to include personally identifiable information in the data of previous section, and the Company is able to use these data without any limitation as long as the Company uses in a format that is impossible to identify the individual and that is impossible to check against or to inquire for Personal Information.
Article 6. (Provision of Personal Information to Third Party)
The Company does not provide or disclose Privacy Information to any third party without the Usersgc approval or permission; provided, however, that this shall not apply to the following.
- In the case where the Company provides or disclose in a format that is impossible to identify the individual;
- In the case where disclosing or offering is permitted in the laws and/or regulations, or in the case where disclosing or offering is required by public agency based upon the laws and/or regulations;
- In the case where disclosing or offering is required for resolving dispute, claim, etc.;
- In the case where the provision or disclosure is required for management and operation of service that the Company operates;
- In the case where the Company delegates some or all of the Service to any third party to the extent necessary to achieve the "Purpose of Use of Personal Information" or in the case where the Company transfers the Service because of transferring its business such as amalgamation or other reasons to any third party, the Company makes arrangement about handling and managing of Privacy Information same as This Policy with the third party.
Article 7. (Managing, Maintenance of the Accuracy, Retention Period of Privacy Information)
- The Company manages Privacy Information provided or disclosed from Users closely.
In addition, in the case where the Company discloses the Privacy Information to employees, the Company both limits the number of employees that the Company discloses the information and makes arrangement about confidentiality with the employees disclosed the information.
- The Company makes an effort to keep the Privacy Information that the Company owns and handles accurate and up to date, within the scope necessary for achieving the Purpose of Use, and takes appropriate and necessary measure both to prevent the Privacy Information from being leaked, from being lost or from being injured and to manage the Privacy Information safely.
The Company stores Privacy Information disclosed or provided from Users for following period.
|Users who sign up with the Service as Member
||During the membership period
and 3 years from the expiring day
||1year from the day of disclosure or
- In the case where the Company no longer needs to use Privacy Information that the Company stores, notwithstanding the previous section, the Company makes an effort to delete the Privacy Information with no delay.
Therefore, the same shall apply to the case where User requires the Company to delete his/her Privacy Information.
Article 8. (Claim to Inquiry, etc. by Users)
- User is able to claim to inquiry, to disclose, to adjust, to add, or to delete his/her Privacy Information against the Company. In addition, User also is able to claim to suspend to use his/her Privacy Information against the Company.
- The claim of previous section shall be by method that the Company stated. Also, the claim shall be only by User himself/herself, his/her legal representative (if User is a minor), or agent who authorized by him/her about the claim.
- In the case where the Company receives the claim of section 8-1, the Company confirms the User's identity. In addition, in the case where the Company has confirmed the fact that the claim should be by the User in person, the Company responds to the claim within a considerable period.
In the case where the Company decides not to deal with the claim, the Company notifies him/her accordingly.
User shall pay following fees to the Company at the time of the claim of disclosure, etc.
|Fees for claim of disclosure and inquiry
(includes postage fee)
|Fees for claim of adding, adjusting, and deleting
Article 9. (Using of Analytical Tool, etc.)
- User is able to refuse collection of his/her Privacy Information by the Company or to hide or remove the behavioral targeting advertising either 1) by disabling cookies in his/her browser, or by opting out via the webpage which is associated with the analytical tool or the behavioral targeting advertising.
- User shall take self-responsibility for the change of setting, etc. of previous section, and the Company assumes no liability and responsibility for all damages arising from his/her change the setting, etc.: such as occurrence of disappearance of all or part of information about the Service.
Article 10. (Change of This Policy)
- The Company is able to modify This Policy in the judgement of the Company. In the case where the Company modifies This Policy, except the case of urgency, the Company preliminarily notifies accordingly to Users by method that the Company judges suitable.
- Modification of This Policy should become effective immediately when the Company uploads the updated This Policy on the Website related to the Service.
- If User is unable to agree with modified This Policy, he/she is able to claim to delete his/her Privacy Information against the Company by method stated in Article 8.
Article 11. (Measures at Leakage)
- If leakage of a part of Privacy Information that the Company reserves occurs, the Company both notifies accordingly to supervisory authorities with no delay and makes an effort to solve the problem by complying with Laws, other regulations and instructions by the authorities.
- Even if leakage of a part of Privacy Information that the Company reserves occurs, unless otherwise stipulated by law, the Company assumes no liability for indemnifying each User against his/her loss.
Article 12. (Chief Administrator)
The Company appoints the following person to be Chief Administrator of Personal Information, and tries to manage Personal Information appropriately and to improve enforcement of policies related to protection of Personal Information continuously. In addition, the following person should be the contact both for inquiry or advisement about Personal Information and for the claim of Article 8 at the Company.
Operator of the Service: the WithTravel Co., Ltd.
Desk for Inquiry: Personal Information Desk
Address of Operator: Tensho-Kandaekimae Building #201 3-7-21 Kanda-Kajicho Chiyota-ku, Tokyo 101-0045 Japan
Phone Number: +81-3-4500-2185 (available in weekdays for 10:00-17:00 in JST)
E-Mail Address: email@example.com
Method of the claim for disclosure, etc.: by mail, by email
Updated on 13th March, 2019
Updated on 15th July, 2018
Established on 8th May, 2018