aumo Website Privacy Policy

1. Basic Policy

Protection of personal information

aumo, Inc. (“the “Company”) recognizes the importance of personal information, views the complete protection of personal information as its social responsibility, and promises to comply with the Act on the Protection of Personal Information, other relevant laws and regulations, guidelines, and the like, and to properly handle the personal information collected from the customers who use the Company’s services and the Company App in accordance with this Policy.

Scope

This “Privacy Policy on the website for aumo”(this “Policy”) provides for the handling of personal data on the “aumo” website (the “Website”) provided by [aumo, Inc.] (the “Company”).

2. Collection of Personal Data; Purpose of Use

List of information that will be collected

The Company may collect the following information from you in connection with the provision of the Website:

  • IP address
  • Cookie
  • Usage of the Website
  • Device and browser-specific identification information

*Cookie is a mechanism that stores a small file in the user’s browser from a website where you access. For example, when a user visit the website again, a unique ID on the Cookie file make user identifiable, so that switching the contents of website or advertisement is possible by browser (user). Information collection module used on this Company’s corporate website uses cookies to collect traffic data. This traffic data is collected anonymously and is not personally identifiable. Users can refuse collection by disabling cookies, so please check the settings of your browser.

Purpose of use

The Company will use the collected information for the following purposes:

  • Providing the services of the Website
  • Research and analysis of the use of the Website
  • Improvement of the Website’s services
  • Providing information to the third parties (including joint users) set forth in “5. Provision to Third Parties; Information Collection Module”

Legal basis

The legal basis for the processing of your personal data is;

  • Your Consent
  • Legitimate interests (To improve the user experience through the Website)

3. Our Policy regarding Children

The Website is not intended for children under 16 years of age, and we do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to browse the Website. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number or e-mail address. No one under the age of 16 may provide any personal data. In the event that we learn that we have collected personal data from a child under the age of 16, we will delete that data. If you believe that we may have received data from a child under the age of 16, please contact the contact listed in “7. Request for Disclosure, Etc.; Inquiries” under “Controller of your personal data and its contacts.

4. Administration System

Establishment of the basic policy and rules for handling personal information

In order to ensure the proper handling of personal data as an organization, the Company have established the basic policy (see “1.Basic Policy”,etc.).

The Company have established rules for handling personal data, including handling methods, responsible persons, and their duties.

Technical and physical security control measures

The Company manages access to personal data (limiting access rights to authorized personnel (including measures such as immediately revoking the accounts of employees who have moved or retired) and monitoring access status, managing physical entry controls, etc.).

The Company takes security measures to prevent unauthorized access from outside the Company (e.g., installation of firewalls).

Organizational security control measures

In addition to appointing the “Group Personal Information Protection Manager” as the person responsible for personal information management, the Company have clearly defined the responsibilities and authority of employees regarding the management of personal information.

Employees (including temporary employees) In addition to supervising employees (including temporary employees), the Company has established a system for reporting to the person in charge in the event that a violation of the law or regulations is detected or signs of such a violation are detected.

The Company has established internal rules and procedures and ensure that employees comply with them, and conduct appropriate audits of compliance.

Supervision over employees and trustees

For employees, the Company obtain written pledges and conduct regular education and training on the management of personal information.

For trustees, the Company confirm their information security measures at the time of selection and on a regular basis, and conclude contracts with trustees.

5. Provision to Third Parties; Information Collection Module

Disclosure to third parties

In the following cases, the Company may disclose personal information to third parties:

  • The Company outsources work to a third party to the extent necessary to achieve the purpose of use
  • The Company performs a merger, corporate spin-off, transfer of business, or disposes all or some of the Company’s business, assets, or stock (including cases where it is performed in connection with bankruptcy or similar proceedings)
  • The Company requests the customer’s consent for the disclosure and the customer gives such consent

However, with regard to any information that has been statistically processed so that individual customers cannot be identified, the Company may use such information for purposes other than those listed above.

Disclosure at the request of a government body, local government, public agency, or the like

In the following cases, the Company may disclose personal information to a public agency or the like:

  • Pursuant to laws and regulations (including any laws and regulations outside of the country of residence of the party that will be providing the information)
  • Disclosure is necessary to protect a person’s life, body, or property, and it is difficult to obtain the consent of the customer
  • It is particularly necessary to improve public health or to promote the healthy development of children, and it is difficult to obtain the consent of the customer
  • There is a need to cooperate with the performance of administrative work provided for by law or regulation by a national government body, local government, or a contractor for such body, and obtaining the customer’s consent may interfere with the performance of such administrative work

Information collection module

The Website contains the following information collection modules provided by the following third parties for purposes such as providing the features included in the Website and analyzing usage. With regard to the purpose of use of the information that will be collected or has been collected through such information collection module, please review the privacy policy that has been provided by each company providing an information collection module:

(To perform access analysis for the purpose of service improvement and marketing research for the Website)

Google Analytics Opt-out Browser Add-on

https://tools.google.com/dlpage/gaoptout/?hl=en

Disclosure to third parties outside of the country

When you agree to this Policy, you acknowledge that the collected data set forth in this Policy may be transferred outside of your country or region and that there may be cases where the country or region to which the data is transferred does not have laws or regulations imposing protection obligations that are equal to or greater than the laws and regulations regarding personal data and other privacy protection in your country or region. You agree that the Company will disclose the collected data set forth in this Policy to its parent company, GREE, Inc., and its affiliates as well as its approved subcontractors, media, and/or ad agents located in Japan, or the country other than your country of residence where the approved subcontractor, media or ad agents establish its hub for the purpose of use set forth in this Policy.

6. Method of Notices, Announcements, or Obtaining Consent; Method of User Involvement

Notices and announcements

This Policy is posted and announced on the Website. The Company may amend this Policy, and any important changes will be announced on the Website. The amended Policy will become effective when it is posted on the Website You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. In the case of withdrawing your consent, please contact us after confirming the following “Controller of your personal data and its contacts” section.

7. Request for Disclosure, Etc.; Inquiries

Request for access, rectification, erasure, restriction of processing, object to processing, data portability, etc.

You have the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. For these requests, please contact the ” Controller of your personal data and its contacts ” below.

Inquiries

For inquiries, consultations, and complaints regarding the handling of personal information on this website, please contact the contact listed below under “Controller of your personal data and its contacts.

Data Protection Officers (DPO)

Company elected the data protection officer is involved, properly and in a timely manner,

in all issues which relate to the protection of personal data.

Post: Data Protection Officer

GREE, Inc.

Roppongi Hills Gate Tower, 6-11-1 Roppongi, Minato-ku,

Tokyo, Japan

dpo@gree.net

Controller of your personal data and its contacts

aumo, Inc.

Sumitomo Fudosan Shinjuku Central Park Tower 13F -18-1, Nishi-Shinjuku, Shinjuku-ku, Tokyo, Japan

info@aumo.jp

8. Administration Policy

Amendment of this Privacy Policy

The terms of this Privacy Policy may be revised or amended. Unless otherwise specified by the Company, the revised or amended Privacy Policy will come into effect when it is posted on the Website.

Retention Policy

Personal information will be deleted when it is no longer needed to achieve the “Purposes of Use” listed above, except as necessary to comply with applicable laws, regulations, or orders from government, courts, or other regulatory agencies.

Others

Please note that if you do not provide Company with the latest and accurate information of yourself, you may not receive appropriate service.

9. Terms for specific Countries

If you reside in any of the places listed below, the relevant terms shall apply;

1. United States (Last Reviewed Date: April 3,2023*)

This Privacy Notice Section 1 (“United States Privacy Notice”) supplements and modifies the “aumo Website Privacy Policy” of [aumo, Inc.] (the “Company”) and applies solely to the user who resides in United States of America (“consumers” or “you”). We adopt this United States Privacy Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), and unless otherwise specified, the terms used in this California Privacy Notice have the meaning defined in the CCPA

1.1 Your personal information the Company collects

  • IP address
  • Cookie
  • Usage of the Website
  • Device and browser-specific identification information

1.2 How the Company collects your personal information

  • Automatic acquisition (acquired automatically when using the Website)

1.3 The purpose to collect and sell your personal information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

(1) The purpose to collect your personal information

  • Providing the services of the Website
  • Research and analysis of the use of the Website
  • Improvement of the Website’s services
  • Providing information to the third parties (including joint users) set forth in “5. Provision to Third Parties; Information Collection Module”

(2) The purpose to sell your personal information

  • Research and analysis of the use of the Website
  • Providing information to the third parties (including joint users) set forth in “5. Provision to Third Parties; Information Collection Module”

1.4 Sharing or sales of your personal information

(1) The Company may sell your personal information subject to your right to opt-out to those sales

Google LLC (To perform access analysis for the purpose of service improvement and marketing research for the Website)

1.5 Your Rights and Choices

(1) You have the right to request from the controller access to and rectification or erasure of personal information or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. For these requests, please contact the “Controller of your personal data and its contacts” above.

(2) Personal Information Sales Opt-Out

DO NOT SELL MY PERSONAL INFORMATION

IF YOU WANT THE COMPANY NOT TO SELL YOUR PERSONAL INFROMATION, PLEASE FOLLOW THE INSTRUCTION AS FOLLOWS :

You may opt-out of future sales at any time after opting-in to personal information sales. You have the right to direct us to not sell your personal information at any time (the “right to opt-out”).

  • To opt-out the sale of your personal information to Google LLC

 Please go to “Google Analytics Opt-out Browser Add-on” to opt-out.

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, Company will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include personal information, if necessary to verify your identity and the nature of your request.

Established on April 3,2023