Privacy Policy

STANDING OVATION Co. Ltd. (hereafter, “our company” or “we”) specified following Application Privacy Policy to request users to provide their information and to provide our application smoothly through our application for smartphone, named “XZ” (hereafter, “this application”), and through services about this application (hereafter, “these services”). We shall make an effort to protect users’ information.
Users shall be able to refuse the provision of their information based on their own decision if users do not wish to provide their information through this application. In this case, please note that you may not use this application or service.

Our company shall pay full attention to the management of users’ personal information, and shall treat them according to the Privacy Policy defined as following.

1 Acquisition of Personal Information

When providing this application and service, we acquire users’ following information automatically through the application or by users’ manual inputting and registration, to the extent necessary for the achievement of “purpose of use” mentioned in 2. Users’ information we collect shall be following depending on the collecting process.

1

(1)When registering as a member, users shall be requested to input information manually, such as their name, e-mail address, password, birth date, gender.
(2)After registration, users shall be requested to input information such as their height, residence, preference for fashion, as the profile information. When users use this application, we shall acquire location information from GPS. We shall acquire these information to suggest suitable coordination for each user.
(3)We shall automatically acquire the following information and informative data (Personal information such as genders, jobs or hobby, information of identifying users such as Cookie information, IP address, the identifier for advertising distribution (advertising ID, ※1) or logging information about the Internet usage such as users’ navigational and purchase history. However, these information do not include any personal information which identify users.) acquired mechanically at the time users accessed to this service. We shall acquire them for the improvement of users’ experience of the application.
(※1) “Advertising ID” indicates IDFA (Identification For Advertisers), which Apple Inc. issues on iOS, or text string created from OS of smart device such as Advertising ID, which Google Inc. issues on Android. This shall be used in the “action targeting advertisement” etc., which delivers advertisements adapting to users’ interests and preferences.
(4)When admitted the cooperation with outside services such as other social networks (Instagram/Twitter/Facebook/LINE etc.), based on the contents users agreed, we shall collect following information from the applicable outside service.
We shall acquire them for the improvement of users’ experience of the application.
(5)By requiring users to choose, input and register, we shall acquire following information for improvement of users’ experience of the application.
country, language, e-mail address, device information, IP address, profile image, cover image, nickname, personal introduction, job type, operating website (blogs, home pages etc.)
(6)When selling our goods to users, we shall request users to register their postal code, address and phone number for shipment of goods. In this case, users’ access and their purchase history shall also be accumulated.
(7)We shall store posted information by users (posted questions or answers for Q&A, posted item information, posted coordination information, posted calendar information).
(8)When users purchase our goods, they shall be requested to input credit card data on this application. However, this information shall be stored on the server of the account settlement agent system, and shall not be stored on the server of our company (applied for users in Japan).

2

When users wish to check their own information etc., it is possible by contacting us (mentioned below in 10).

3

Users’ information etc. shall be stored in servers in Japan.

2 Purposes of Use

1We shall use the personal information acquired mainly for following purposes.

(1)In the case using our services as a registered member of XZ
- -to provide and inform users of our services
- -to claim payment for the service when we provide fee-based ones
- -to notify users of the weather forecast of surrounding area
- -to deliver services and advertisements
- -to suggest reference coordination for users
- -to contact users and to make use of the improvement of services and the development of new services etc.
- -to prevent the use violating the Terms of Use, and to resolve the troubles on operation
- -to create the statistical data which would be processed in a format which prevents individual identification
- -to confirm your offer to use our e-mail distribution service and to send you e-mails
- -to notice the result and to ship goods for contests, campaigns or rewards etc. and to send gratuity for questionnaire surveys
- -to deliver information for various membership services and other services
(2)Personal information of our business clients
- -to send messages which are necessary for work, fulfillment of contracts, and management of our business clients’ information such as negotiations
(3)Personal information of people contacted our company for inquiries
- -to respond to their inquiries

2We will use users’ informative data for following purposes.

-to display the best advertisement for the user in the application which our company operates
-to provide information about goods, services and other related matters which meet users’ interests and concerns
-development and improvement of goods and services

3 Use of Statistical Data

(1)We may create the statistical data which was processed in a format that prevents individual identification based on personal information acquired. We shall use the statistical data with no limitation.
(2)To make the advertisements users see on XZ appropriate for each of them or fully ones, we may acquire and use the information about users’ attributes (genders, jobs, ages etc.), URL and contents which Cookie tries to access, and the action history such as the order of reference.

4 Providing Information to Third Party

(1)Among users’ information, we shall not provide personal information to third party without users’ prior agreement except for the cases that Personal Information Protection Law or other laws accept to disclose the information. However, this shall not apply for the following cases.
- 1.We shall outsource all or part of the handling of personal information to the consigned company to the extent necessary for the accomplishment of purposes of use. By carefully selecting the consigned company, we shall set condition about matters necessary for preventing users’ personal information from leaking, and ask the company to manage the information appropriately―for example, when making a contract, we shall place obligations about personal information, such as appropriate management and confidentiality.
- 2.in the case the information shall be particularly necessary for the protection of people’s life, body and property, for improvement of public health, or to promote the healthy development of children, and where it is difficult to obtain the consent from the user himself/herself
- 3.in the case a national institution, a public organization or any persons entrusted by them shall be obligated to cooperate with the execution of the affairs defined by laws, and where there shall be a possibility that impede such execution by obtaining the user’s consent
- 4.in other cases admitted by laws
(2)When admitted by laws or for the purpose of providing appropriate and effective advertising distribution for users, we shall provide the informative data to third company (Interspace Co., Ltd.) such as the identifier for advertising distribution, IP address and log information about Internet usage. In this case, we shall sign a contract, including confidentiality, with the third company and shall monitor appropriately that the third party would treat the informative data properly in accordance with Privacy Policy etc., and that they would build the safety management.

5-1 Opt-Out

If you do not wish the delivery of targeted advertisements and wish to disable (opt-out) the acquisition of related informative data, please check procedures on WEB pages etc. mentioned below.

(1)In the case you wish to opt-out the use of Cookie issued by third company
Google Inc.: download page of “Google Analytics Opt-out Browser Add-on”
https://tools.google.com/dlpage/gaoptout?hl=en
(2)In the case you wish to opt-out the use of anonymous ID, identifier for advertising distribution, and the unique ID in the application, which are used by third party
Please contact Interspace Co., Ltd.
(3)In the case you wish to opt-out the delivery of the application’s targeted advertisements, please process at the following pages.
IDFA（Apple Inc.）
https://support.apple.com/en-ca/HT202074

Advertising ID (the help page of “Google Inc. Play Console”)
https://support.google.com/googleplay/android-developer/answer/6048248?hl=en

5-2 Service of Third Party

Our company shall use the following third party to improve services for the purpose mentioned at the right of each item.

-Google Dashboard - ata analysis
-Analytica - data analysis
-OneSignal - push sending
-Fabric Crashlytics - crash analysis
-AWS

Also, for the reference to provide more appropriate services to meet users’ interests and needs, we use Google Analytics provided by Google Inc. for the understanding and analysis of the usage of our services. Google Analytics analyzes the usage of our services by using Cookie. The methods of collection and use of access information adopted by Google Inc. are defined by Terms of Service in the services of Google Analytics and Privacy Policy in Google Inc.

6 Disclosure, Correction, Deletion etc. of Personal Information

(1)When there would be following offers from users about their information, our company shall deal with them without delay.
confirmation of the purposes of use, disclosure of information, correction, addition or deletion, suspension of use, suspension of offering information to third party

However, regarding the disclosure of information, the above policy shall not apply when defined in laws that our company does not have the responsibility for disclosure. When disclosing, we may ask for the prescribed fees.
Also, the server logs which have the information of IP address etc. shall be maintained for one month in our company. The period may be longer if needed.
(2)Users may delete their data anytime to satisfy their “right to be forgotten”. Using the “function for unsubscribe”, users may delete their data from their terminal, and as a result, their account shall also be deleted, and the user’s data on our server shall be anonymized. If needed, the anonymized data also may be deleted.

7 Identifying Individuals

Our company shall confirm individuals by using either of following methods.

(1)by sending an e-mail to the e-mail address we have already provided from the user, and by requesting him/her to reply to it
(2)by confirming the user’s name, address, phone number and birth date at the time of procedure.

8 Correction

Our company may correct all or part of this “Privacy Policy”.
The significant revisions shall be notified on our site.

9 Disclaimers

Our company shall assume no responsibility in the following cases.

(1)In the case the user himself/herself disclosed their personal information to third party using the function of our company’s services or using another way.
(2)In the case people were able to identify individuals by the information having disclosed by the user himself/herself on our company’s services.

10 Contact

If you have any opinions, questions, complaints, wish to contact with the data protection officer, or for other inquiries, please contact the following e-mail address.

STANDING OVATION Co. Ltd.
[email protected]

11 Right of Users

People who live in some countries, including the European Economic Area, shall have certain legal rights about their own personal data. In accordance with exclusions which are regulated in laws, the users have rights of requesting the access to information, or demanding the update, deletion and correction of the information.
If you live in EU member country and can be applied GDPR, and when you exercise the rights on GDPR, please contact the e-mail address mentioned above in10. Also, when users would not be able to receive appropriate treatment, they may make an objection against regulatory administrative authorities.

Special Information
For EU Users

Beginning May 25, 2018, the processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (hereafter, “GDPR”). Below is the information as relates to EU users' rights and our responsibilities, under this regulation.

STANDING OVATION Co. Ltd. (hereafter, “our company”), which provides “XZ” service, adopts the following handling policy regarding personal data of XZ users (hereafter, “users”) who live in European Economic Area (hereafter, “EEA”).
“Personal data” refers to the data which identify users including their name, address, birth date, gender, phone number, e-mail address, name of the company, and online identifiers such as IP address and so on.

1.EU User Rights

If you are a user in the EU, about our handling of users’ personal data, you may request access, correction, deletion, limitation for processing, objections against processing, and data portability, in accordance with the provisions of related regulations.
About the exercise of these rights, please refer to the information below or contact our company.

(1)Explanation of How We Use Users’ Information

-You have the right to request an explanation of the personal data that our company has about you and how our company uses that information.
-You also have the right to receive a copy of the information that our company collects about your personal data if collected on the basis of consent or because our company requires the information to provide the services that you request.

(2)Correction

If our company has information about you that is inaccurate, you have the right to request correction of your information. You may correct or request the correction by sending an e-mail to our following e-mail address.

E-mail Address: [email protected]
Contact Name: Yoshihiro Ogita

(3)Deletion

You may request deletion of your accounts at any time. You may request deletion through the Settings menu in the XZ app.

(4)Objections and Complaints

-You have the right to object to our processing of personal data, including for marketing purposes based on profiling and/or automated decision making. Our company may continue to process your information notwithstanding the objection to the extent permitted under GDPR.
-You also have the right to make an objection, relating to our company's handling of your personal information, against our company or data protection authorities which have jurisdiction over the location of your residence.
-You may also submit questions, comments or complaints to our company’s Data Protection Officer. Their contact information is as detailed in (2).

2.Grounds for Legality of Data Processing

GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, our company processes the information of EU users based on legal basis specified under the GDPR:

(1)to provide the services and features you request

Our company must collect and use users’ personal data in order to provide services which satisfy users. This includes:

User profile information (including profile image) that is necessary to establish and maintain your account, user’s name, gender, birth year, height, residence, e-mail address, positional information obtained from GPS, collaborating information with SNS (Instagram/Twitter/Facebook/LINE), device information, job contents, operating website (blogs, home pages etc.)

(2)to protect the vital interests of our users or of others

XZ may process users’ personal information, including disclosing data, when required by law enforcement authorities in case of threats to the safety of users or of others.

(3)for our company’s legitimate interests

Our company collects and uses users’ personal data to the extent necessary for protecting its legitimate interests. This includes collecting and using information for following purposes:

-to optimize our service and develop new services
-for research and analytical purposes about fashion
-for direct marketing purposes―this includes, for example, analyzing data to identify preferences and establishing marketing messages to match user demand.
-to provide information to law enforcement authorities about criminal acts or threats for public safety
-to provide customer support
-to enforce XZ’s Terms of Use

(4)for the legitimate interests of other persons or parties

Our company collects and uses users’ personal data to the extent necessary for the interests of other persons or the general public.

(5)Consent

Our company may collect and use users’ personal data on the basis of their consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any services that require use of the personal data we collected or used on the basis of your consent.

Our company relies on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you. If you are an EU user, the following data collections or uses are done on the basis of your consent:

In addition to the above, our company may collect users’ personal data through voluntary surveys. Their responses to such surveys are collected on the basis of consent, and will be deleted once no longer necessary for the purposes collected.