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TOKYU CORPORATION (the “Company”) hereby stipulates as follows this Privacy Policy (this “Policy”) to appropriately manage User Information including personal information of customers of services (“Services”) provided by the Company and/or Huber. Inc..

1. User Information to be collected and collection method“User Information” in this Policy means information related to customer identification, a customer’s action history on communication services, and other information related to customers or the customers terminals generated or stored on customers smartphones, personal computers, or other terminals that the Company and/or Huber. Inc. collect pursuant to this Policy.

   User Information the Company and/or Huber. Inc. will collect through the Services include the following in accordance with the collection method.

   1. Information provided by the customer

      Information that a customer will provide to use the Services is as follows:

      • Name
      • Address
      • Telephone number
      • Email address
      • Date of birth
      • Age
      • Gender
      • Photograph (one with content and in a form separately designated by the Company and/or Huber. Inc. ; hereinafter the same in this Policy)
      • Credit card information
      • If a Guest Member answered questions about the trip, information of answers to questions about the trip
      • Other information inputted by the customer on an input form stipulated by the Company and/or Huber. Inc.

   2. Information that, when a customer permits linkage with other services in using the Services, is provided by such other servicesIf when using the Services, a customer permits linkage with social network services and other external services, the Company and/or Huber. Inc. may collect information provided by external services with which linkage has been permitted. Such information includes the following:

      • IDs and other identification information that a customer uses on such external services
      • Other information that a customer permits on the privacy settings of such external services disclosure to linkage partners

   3. Information the Company and/or Huber. Inc. collect through the customer’s use of the ServicesThe Company and/or Huber. Inc. may collect access conditions and other information related to the method of using the Services. Such information includes the following:

      • IDs unique to contractual parties or terminals (such as IDs generated by OS (Android ID), owner terminal identification number (UDID), subscriber identity number (IMSI), and MAC address)
      • Log information
      • Identification information generated by the use of cookie technology
      • Location information
2. Purposes of use
   1. User Information will be used for the provision of the Services as stipulated in Paragraph (2) of this Article 2, and may also be used for other purposes as stipulated in Paragraph (3) of this Article 2 by the Company and/or Huber. Inc..
   2. The specific purposes of use of User Information related to the provision of the Services are as follows:
      1. To accept registration, confirm identification, and calculate use fees;
      2. In a case where the customer uses the Services to request provision of products or services for which a third party other than the Company and/or Huber. Inc. are the seller or a Guide, to disclose to the provider or a Guide of such products or services the customer’s User Information that is necessary for the provision of such products or services, and to appropriately provide such products or services to the customer;
      3. To maintain and protect the Services, improve the accuracy of the recommendation function related to the Services, and otherwise enhance the quality of the Services;
      4. To provide explanations and respond to inquiries concerning the Services;
      5. To send information regarding after-care services related to the Services, and new products and services;
      6. To deal with conduct that violates the Company’s and/or Huber. Inc.’s rules, policies and the like (“Rules etc.”) relating to the Services;
      7. To give notice of any changes to Rules etc. relating to the Services; and
      8. For purposes of use ancillary to the foregoing purposes of use.
   3. Purposes of use other than those set forth in the above Paragraph (2) of this Article 2 are as follows:
      1. To create statistical data processed in a format that cannot identify individuals in relation to the Company’s and/or Huber. Inc.’s services;(Type of User Information that will be handled)
         • IDs unique to contractual parties or terminals
         • Age
         • Gender
         • Residential area
         • If a Guest Member answered questions about the trip, information of answers to questions about the trip
         • Information regarding screen transitions within pages
         • Other log information
         • Other identification information generated by the use of cookie technology
         • Location information
      2. To improve the accuracy of the recommendation function related to the Services, and to otherwise distribute or display advertisements of the Company and/or Huber. Inc. or third parties(Type of User Information that will be handled)
         • IDs unique to contractual parties or terminals
         • Age
         • Gender
         • Residential area
         • If a Guest Member answered questions about the trip, information of answers to questions about the trip
         • Information regarding screen transitions within pages
         • Other log information
         • Identification information generated by the use of cookie technology
         • Location information
      3. To use for marketing and other information analysis(Type of User Information that will be handled)
         • Name
         • Email address
         • Date of birth
         • Age
         • Gender
         • Residential area
         • Information regarding screen transitions within pages
         • Other information inputted by the customer on an input form stipulated by the Company and/or Huber. Inc.
      4. To use for the information about merchandise, services, courteous treatment, events, campaign, seminar and others from the Company, Tokyu Group Companies, Huber. Inc. and affiliated companies, and public relations, and responses to inquiries, document requests and others(Type of User Information that will be handled)
         • Name
         • Email address
         • Date of birth
         • Age
         • Gender
         • Residential area
         • Information regarding screen transitions within pages
         • Other information inputted by the customer on an input form stipulated by the Company and/or Huber. Inc.
3. Method of requesting discontinuation of useBy performing the prescribed settings for the Services, the customer may request discontinuation of use of all or part of his/her User Information; in such a case, in accordance with the Company’s and/or Huber. Inc.’s stipulations, the Company and/or Huber. Inc. will promptly discontinue such use. Depending on the type of User Information, the collection or use of such information may be a condition to the Services, and in such a case, if and only if the customer cancels the Services in a manner prescribed by the Company and/or Huber. Inc., the Company and/or Huber. Inc. will discontinue such collection.
4. Consent to provision of User Information to third partiesBefore using the Services, a customer must consent to the provision of User Information by the Company and/or Huber. Inc. to third parties as set forth below.
   1. If by methods prescribed by the Company and/or Huber. Inc., a Guest Member shall input personal identification information (the customer’s User Information that is necessary to identify a Member designated by the Company and/or Huber. Inc.) and answers to questions about the trip.(User Information that will be provided)The customer’s(Guest’s) name, telephone number, email address or Facebook account, If a Guest Member answered questions about the trip, information of answers to questions about the trip, and other information that the customer(Guest) inputs or Provides etc. on an input form stipulated by the Company and/or Huber. Inc. through the Services use procedures.
   2. If a customer(Guest) intends to use the Services and carry out procedures relating to products or services that the Services Provide or contact the Guide Member of such Contents etc., disclosure by the Company and/or Huber. Inc. of the following User Information to persons who Provide etc. such products or services.(User Information that will be provided)The customer’s(Guest’s) name, telephone number, email address or Facebook account, If a Guest Member answered questions about the trip, information of answers to questions about the trip, and other information that the customer(Guest) inputs or Provides etc. on an input form stipulated by the Company and/or Huber. Inc. through the Services use procedures.
5. Provision of personal information to third parties
   1. Without obtaining prior consent under the preceding paragraph, unless permitted under the Personal Information Protection Act or other laws and regulations, the Company and/or Huber. Inc. will not provide any User Information that is personal information to third parties without obtaining the prior consent of the customer; provided, however, that the following will not apply in the following cases:
      • If the Company and/or Huber. Inc. outsource the handling of personal information in whole or in part within the scope necessary to realize the use purposes;
      • If personal information is provided in conjunction with a merger or other business succession;
      • If, in a case where it is necessary to cooperate with a government agency, local public agency, or a person entrusted by either of the foregoing in the carrying out of work stipulated under laws and regulations, the act of obtaining the consent of the customer is likely to hinder such work; or
      • If otherwise permitted under the Personal Information Protection Act or other laws and regulations
   2. If the Company and/or Huber. Inc. provide Personal Information to third parties, the Company and/or Huber. Inc. will comply with setting, storing etc. records of the provided date of Personal information, third parties’ name etc. as provided for by the Personal Information Protection Act and rules of the Personal Information Protection Commission.
6. Safety management for protection of personal informationThe Company and/or Huber. Inc. will stipulate rules based on the Personal Information Protection Act to protect personal information it acquires, publicize and emphasize such rules to its employees, and work towards maintaining and enhancing safety management measures necessary to protect the personal information acquired by the Company and/or Huber. Inc..
7. Disclosure of personal informationIf a customer requests disclosure of personal information pursuant to the stipulations of the Personal Information Protection Act, after confirming that such request is from the customer himself/herself or a legitimate agent (presentation of personal identification documents may be requested), the Company and/or Huber. Inc. will make disclosure to the customer without delay (if the relevant personal information does not exist, the customer will be notified to that effect); provided, however, that the foregoing will not apply in cases where the Company and/or Huber. Inc. are not obligated to make disclosure under the Personal Information Protection Act or other laws and regulations. It should be noted in advance that there will be a fee (500 yen per request) for disclosure of personal information.
8. Correcting and discontinuing use etc. of personal information
   1. If (i) on the grounds that personal information is not true, a customer requests correction of the content of such information pursuant to the Personal Information Protection Act, or (ii) on the grounds that personal information is being handled beyond the scope of use purposes announced in advance or that personal information was obtained through deceit or other unauthorized means, a customer requests discontinuation of use of personal information pursuant to the Personal Information Protection Act, or (ⅲ) on the grounds that personal information is provided to third parties in contravention of Restriction on Third Party Provision of the Personal Information Protection Act, a customer requests discontinuation of the provision to third parties, after confirming that the request is from the customer himself/herself, the Company and/or Huber. Inc. will perform the necessary investigation without delay, and on the basis of the findings of such investigation, correct the content of, discontinue the use of personal information or discontinue the provision to third parties, and notify the customer to that effect. If the Company and/or Huber. Inc. decide not to correct, discontinue use or discontinue the provision to third parties based on a valid reason, the customer will be notified to that effect.
   2. If a customer requests removal of his/her personal information, and the Company and/or Huber. Inc. determine that it is necessary to comply with such request, after confirming that the request is from the customer himself/herself, the Company and/or Huber. Inc. will remove the personal information, and notify the customer to that effect.
   3. If under the Personal Information Protection Act or other laws and regulations, the Company and/or Huber. Inc. are not obligated to carry out correction etc. or discontinuation of use etc., the preceding two paragraphs will not apply.
9. Contact point for inquiriesOpinions, questions, complaints, and other inquiries concerning the handling of User Information should be addressed to the following:Address: Kamakura shunju-square 2F 2-14-7 Komachi, Kamakura-shi, Kanagawa 248-0006Huber. Inc., Department in charge: Customer Support Center (Manager: Keisuke Yonekura)E-mail： support@m.huber.co.jp
10. Procedures to amend this PolicyThe Company and/or Huber. Inc. will perform appropriate reviews of the state of operations relating to the handling of User Information, work towards continuous improvement, and may amend this Policy when necessary. If this Policy is amended, customers will be notified by posting on the Company’s and/or Huber. Inc.’s webpage; provided, however, that for amendments that require the consent of customers under laws and regulations, the consent of customers will be obtained by methods prescribed by the Company and/or Huber. Inc..