Global Privacy Policy (GDRP, CCPA)
This page has been translated from the official Japanese version into English for the convenience of our international readers. In the event of any discrepancy, the Japanese original shall prevail. |
Excite Limited (“Excite”, “we”, “us”, “our”, or “Excite’s”) is committed to protecting the Personal Information (information about an identified natural person or identifiable natural person) of persons residing in the European Economic Area (“EEA”) and in the United Kingdom and California (EEA residents, UK residents and California residents are collectively referred to as “Users”) information about an identified or identifiable natural person, hereinafter referred to as “Personal Information”) in accordance with the EU General Data Protection Regulation and the GDPR as incorporated into UK law by the EU Withdrawal Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendment etc.) EU Withdrawal Regulation 2019 ( UK GDPR) (GDPR and UK GDPR are collectively referred to as “GDPR”), and the California Consumer Privacy Act (“CCPA”), and other applicable laws and regulations, and will be handled in accordance with the “Global Privacy Policy (GDPR, CCPA)” (this “Privacy Policy”) The information will be handled in accordance with the “Global Privacy Policy (GDPR, CCPA)” (the “Privacy Policy”). Matters not described in this Privacy Policy shall be governed by the terms and conditions of the service used by the User and Excite’s Privacy Policy. However, if there is any conflict between Excite’s Privacy Policy and this Privacy Policy, this Privacy Policy shall take precedence in the handling of Users’ Personal Information.
1. Personal Information We Collect
We may collect from you the Personal Information, including the following:
- Name, date of birth, age, e-mail address, user’s ID and password, telephone number, fax number, address
- Occupation, department, title, and company address
- Access history information such as IP addresses, browser and OS information, cookie information, etc. associated with access to the website.
- Details of your inquiry to our company
Users are required to provide us with certain Personal Information when registering for our services. The required Personal Information is listed on the form. If such Personal Information is not provided, we may not be able to provide all or part of our services to you.
2. Objectives and Legal Basis for Use of Personal Information
We collect Personal Information from you primarily for the following purposes. The purposes for which we use the Personal Information we collect and the legal basis for such use are described below:
- For registration procedures and provision of services in various services (Performance of a contract)
- To process applications for prizes, gifts, surveys, etc., to contact users, and to send prizes, etc. (Performance of a contract)
- To confirm orders for products and paid services, to make payment, and to ship products (Performance of a contract)
- To provide the minimum necessary information to our business partners when users use services that we jointly provide with our business partners (Performance of a contract)
- For recommendation information based on each history, and for information regarding new products and various services, etc. (Consent or legitimate interests (Normal business conduct))
- Development of new products and services, and marketing research for such products and services (Legitimate interests (Normal business conduct))
- To customize the advertisements and content that users see on the website and services for each user and to improve their convenience (Consent or legitimate interests (Normal business conduct))
- To understand and analyze the status of service usage based on browsing, service orders, and other activity history or location information (Legitimate interests (Normal business conduct))
- To compile Personal Information into statistical data that cannot be used to identify individuals and to conduct marketing research, develop new products and services, and improve the quality of our services (Legitimate interests (Normal business conduct))
3. Sources of Personal Information
We collect Personal Information from users as follows:
- We obtain your Personal Information directly from you when you decide to provide it to us (i.e., when you fill out a form that appears on our website).
- We obtain the user’s Personal Information when it is indirectly provided to us by the user’s electronic communication terminal device or Internet browser.
- We may also obtain information from third parties such as advertisers and their agents to the extent that it is necessary for our services, and we may combine such information with each other or with information collected through other services.
- We obtain Personal Information about users from social media platforms (e.g., Facebook) to which users have previously provided information.
4. Disclosure and Sharing of Personal Information
We may share Personal Information with the following parties.
- We share Personal Information with our group companies.
- We may use third parties, such as marketing companies and IT service providers to perform services. In such cases, it may be necessary to share Personal Information in order to use services. Shared Personal Information will be used for purposes determined by us under our direction.
- As required by law, we may disclose Personal Information to law enforcement authorities in response to legal requirements, court orders, or requests by government agencies or law enforcement authorities. We may disclose Personal Information to public law enforcement agencies.
- If permitted by law or ordinances, we may disclose Personal Information to third parties (including legal counsel) as necessary to establish, sue, defend, or exercise our rights against legal claims, protect our property, the rights or property or safety of others, or to support external audits, compliance, or corporate governance functions.
5. Rights of Residents in the EEA
Users who are residents of the EEA or in the United Kingdom have the following rights under the GDPR with respect to their Personal Information, provided that they meet the requirements of the GDPR.
- Right to withdraw consent to the handling of Personal Information
Users may withdraw their consent at any time, even if we have obtained your consent to handle your Personal Information. This withdrawal does not affect the processing of previous Personal Information to which the user has already consented. However, if the user withdraws consent, the user may not be able to use all or part of the service.
- Right to access Personal Information
Users may access their Personal Information held by the company.
- Right to delete Personal Information
Users may request the deletion of Personal Information that we handled about them if the Personal Information has been handled illegally, or if there is no legal basis for the handling.
- Right to correct Personal Information
Users may request that we correct any inaccuracies in Personal Information we handle.
- Right to restrict the use of Personal Information
Users may request that the handling of Personal Information about them be restricted in certain cases.
- Right to data portability
Users may receive the personal information you provide to us in a structured, publicly available, machine-readable format. However, this right is limited to Personal Information that is provided based on the user’s consent or contract and for which the processing of Personal Information is automated.
Users have the right to object to our handling of their Personal Information.
Users may also object to the relevant supervisory authority if they believe that we have handled their personal information in violation of applicable law.
*For information on how to exercise various rights to Personal Information, please refer to “13. Contact for Inquiries”.
6. Rights of Residents in California
Users who are residents in California have the following rights under the CCPA with respect to their personal information, provided that they meet the requirements of the CCPA.
- Right to request disclosure of information regarding the handling of Personal Information
Users may request disclosure of the following information regarding your Personal Information that we have collected in the past 12 months up to a maximum of two times in any 12-month period.
・Category of Personal Information we collect about users
・Category of the source of acquisition pertaining to such Personal Information
・Business or commercial purposes for which such Personal Information is collected
・Category of the third party to whom such Personal Information was disclosed
・Specific Personal Information obtained by the company with respect to the user
・Types of customer Personal Information disclosed by the company for business purposes
・Types of third parties to whom Personal Information is disclosed for each type of Personal Information
- Right to delete Personal Information
Users may request that we delete Personal Information we have collected from them pursuant to the CCPA.
- Right to opt-out of the sale of Personal Information
We have not sold, and will not sell without notice, the Personal Information of California users, but you may request that we stop selling your Personal Information or that we not sell your Personal Information in the future.
- Right to be free from discriminatory treatment
Users have the right not to be treated unfairly or discriminated against in exercising or having exercised any of the above rights.
*For information on how to exercise various rights to Personal Information, please refer to “13. Contact for Inquiries”. If the user exercises his/her rights through an agent, the user must submit a power of attorney to the company, either directly or through an agent.
7. Transfer of Personal Information to a Third Country
We may transfer Personal Information acquired in the EEA to Japan or other countries inside or outside the EEA as necessary. The countries to which personal information is transferred include Japan and other countries that have received sufficiency certification under the GDPR, as well as countries that have not received sufficiency certification. In the case of transferring users’ personal information to countries that have not been certified as adequate, we will take appropriate protective measures, such as the standard data protection provisions stipulated in Article 46.2 of the GDPR. To obtain more information, such as a copy of the document used to protect the user’s personal information, please contact us in writing by mail.
8. Retention Period of Personal Information
We will retain the Personal Information of users for the period necessary to achieve the purpose for which it is used or for the period specified by applicable laws and regulations. In determining the retention period of personal information, we use the following criteria: (1) whether the user continues to use our services, (2) whether there is a legal obligation that we must comply with, and (3) whether we need to fulfill a contract to which the user is a party. We will delete the Personal Information as soon as possible after the purpose of use is fulfilled or the period stipulated by applicable laws and regulations has expired. However, in order to comply with our legal obligations and to protect our rights and interests, we may retain and use your information after the retention period has expired.
9. For Children Under 16 Years of Age
We will not intentionally obtain or handle such information without the consent of the individual or his/her guardian. If we discover that we have directly collected and processed Personal Information about a child under the age of 16, we will take steps to delete the information as soon as possible.
10. Cookies etc.
We use cookies and similar technologies (informative data) to collect user information in order to improve user convenience, improve the site and services, and provide appropriate information. For more information, please see this page.
11. Change in This Privacy Policy
We may change or update this Privacy Policy at any time without limiting your rights as described in this Privacy Policy. Please refer to the Update Date notice for the date this Privacy Policy was last updated and check this page periodically for the most current information.
12. Contact Information
We handle Personal Information as an administrator and have appointed a Personal Information Protection Manager to ensure that issues related to the protection of Personal Information are handled appropriately. Contact information is as follows:
To: Excite Japan Co., Ltd., Chief Privacy Officer
3-20-1 Minami-azabu, Minato-ku, Tokyo 106-0047, Japan
13. Contact for Inquiries
For opinions, questions, or complaints regarding users’ Personal Information, please contact us.
If you wish to exercise your rights regarding your Personal Information, please contact our inquiry office with the following information.
・Details of Personal Information
・Name of service
・Reason for exercising rights
・How you would like us to respond
After receiving a communication from the user regarding the exercise of rights, we will ask the user to present the documents necessary for identification as specified by us, and we will confirm that the request is from the user himself/herself. Upon completion of such confirmation, we will respond to the request. If the request is made by a person other than the user on behalf of the user, the user will be asked to submit a document certifying that he/she has the right of representation.
Last update: June 21, 2023
Excite Japan Co., Ltd.