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Privacy Policy Personal Information Protection Policy

Introduction

Vision Inc. (hereinafter referred to as "the Company") and its subsidiaries and affiliates (hereinafter collectively referred to as "the Group") acquire and use personal information of all persons related to the Group (including shareholders, customers and employees, and hereinafter referred to as "you") and retain such personal information. This privacy policy, set forth by the Company, aims to clarify the purposes and methods of acquiring and handling personal information by the Group in order to deepen their awareness of your rights related to personal information.

This privacy policy applies to all those involved in the Group. In addition to this Privacy Policy, The Group may establish regulations for the handling of personal data in accordance with individual circumstances. In this case, the applicable regulations shall be applied preferentially.

The Group acquires your personal data. Our personal information includes information directly provided by our customers, information concerning the use of our services, and information obtained from third parties. In addition, personal data obtained by the Group is stored in an integrated manner by the Company.

If the EU General Data Protection Regulation (the GDPR) might apply to the Group's acquisition of personal information, the Group will manage such personal information appropriately in accordance with the GDPR. With respect to the Company's handling of personal information and the rights of the Person in cases where the GDPR applies to the Group's handling of personal information, please refer to 16 below since the provisions of 16 below will take precedence over 1 to 15.

Acquisition of personal information

The Group acquires personal information (including information relating to individuals) mainly through the following methods, and uses and stores such information as personal data.

  1. Direct acquisitions from you
  2. Acquisition from a third party
  3. Methods of acquiring based on the use of the Group's services, etc.
  4. Acquisition through Cookie or webbeacon (including similar technologies)
  5. Method of obtaining by recording calls
  6. Method of acquiring information by recording it in photographs, images, etc.
  7. Other methods of acquisition based on engagement with the Group (including stock acquisition or hiring, but not limited)

Purpose of use of acquired personal information

The Group shall use acquired personal information for the following purposes.

  1. To use for which the Purpose of Utilization is clearly recognized as the Purpose of Acquisition of Personal Information
  2. To provide products and services in the Group
  3. To provide after-sales services relevant to the above
  4. Contract examination and credit examination, etc.
  5. To charge and collect payments of various fees related to the Group's businesses and other relevant operations, and to protect receivables (including the case of entrusting the handling of personal information for charging or collection of various fees)
  6. To examine or develop new products and services related to the Group's businesses
  7. To release information concerning the above products and services
  8. Advertising
  9. To provide employees with education and training to improve their sales or solicitation skills
  10. For market research or other surveys related to the Group's businesses
  11. To launch prize awards or special campaigns
  12. To prepare statistics for management analysis and use the analysis results
  13. To respond to requests for disclosure, etc. pursuant to the Act on the Protection of Personal Information, as well as to supervise and audit the handling of personal information
  14. For activities related to CSR (corporate social responsibility)
  15. To manage contract relations with business partners
  16. To manage shareholders
    1. To exercise the rights or perform obligations pursuant to the Companies Act
    2. To provide various benefits according to the status of shareholders
    3. To implement various measures to facilitate smooth relationships between the Company and shareholders from the standpoints of an association and its members
    4. To prepare data of shareholders in accordance with specific standards pursuant to various laws and regulations
  17. For employment (including recruiting) of employees, etc. and personnel management
  18. For the welfare and benefits of employees, etc. (including notification and operation of welfare and benefit plans, etc.)
  19. To manage facilities and devices
  20. For shared use
  21. For provision to third parties
  22. Other purposes within the scope necessary to perform operations related to any of the above

Treatment of use for other purpose

The Group shall obtain your prior consent when the Group uses personal information for purposes other than acquiring such personal information, unless otherwise permitted by law.

Sensitive personal information

When obtaining sensitive personal data, the Group shall obtain your prior consent. However, this provision shall not apply when permitted by law.

Storage and management of personal information

The Group shall comply with the Act on the Protection of Personal Information, guidelines related to the Act on the Protection of Personal Information in the Economic and Industrial Fields, and other relevant laws and regulations. The Group shall also formulate rules on the handling of personal information to ensure that such laws and regulations are met, shall have the Group's employees comply with such rules, and shall take measures to manage personal, physical, and technical safety in an organizational manner.

Provide to third parties

The Group may provide personal data to third parties only in the following cases:

  1. If you agree to this privacy policy. Further details on the provision of information by the Group to third parties with the consent are as follows
    1. Items of personal data provided to third parties
      All or part of personal informations obtained by the Group
    2. Methods of provision to a third party
      1. Methods using electromagnetic records (including cases where the information is provided in intangible form by e-mail, etc., and cases where the information is delivered by hand or sent by mail, etc., using a recording medium)
      2. Written method
    3. Method of receiving suspension of provision to a third party
      How to contact the reception desk stated in Item 15
  2. Cases based on a court warrant or other court decision, order or decree
  3. Cases in which the disclosure or provision is necessary to protect human life, body or property, and in which it is difficult to obtain your consent
  4. Cases in which the handling of personal information is particularly necessary for improving public health or promoting the sound growth of children, and in which it is difficult to obtain your consent
  5. Cases in which it is necessary to cooperate with a national institution, a local government, or an individual or a business operator entrusted thereby in executing the affairs prescribed by laws and regulations, and in which agree your consent is likely to impede the execution of the affairs

Provide by outsourcing

The Group may outsource the handling of personal data (excluding personal data including personal information that requires consideration; the same shall apply hereinafter in this section) to third parties to the extent necessary for achieving the purpose of use. In such cases, the Group shall select an appropriate counterparty and conclude an appropriate contract with the outsourcee so that the outsourcee will handle the relevant personal data in an appropriate manner, while at the same time grasping the status of the handling of personal data by the outsourcee in a timely manner.

Sharing

All or part of the personal data held by any of the Group is compiled into the Company and used jointly among the Group as the person responsible for the management of personal data, with the aim of ensuring safer management of personal data and improving customer satisfaction through cross-sectional provision of services by the Group.

  1. The items of personal data used jointly are as follows.
    1. Name, address, date of birth, gender, telephone number, email address, work place, etc.
    2. Address, financial institution account number, name and credit card number required for billing
    3. Contents of application service and contents of related inquiries, etc.
    4. Service usage fee, billing amount, payment status and payment method, etc.
    5. Information about the communication device itself (serial number, model name, product number, terminal unique ID, etc.)
  2. The scope of joint users is our parent company, subsidiaries and affiliated companies.
  3. The purpose of using the shared personal information is as described in "3. Purpose of using the acquired personal information".
  4. The person in charge of managing the personal data used shall be Vision Inc.

Anonymized processing information

When preparing the anonymized processing information, the Group shall process and handle the anonymized processing information appropriately in accordance with relevant laws and regulations. In addition, when the anonymized processing information is prepared, the items of personal information included and the security measures taken shall be announced.

When the Group receives the anonymized processing information, the Group will handle the anonymized processing information appropriately while implementing appropriate security control measures without checking other information.

Disclosuring procedures

Regarding the personal data possessed by the Group, if you request disclosure of your own information, the Group will respond to your request in a written form within a reasonable period and scope, after confirming your identity. We may not respond to your request for disclosure because of a law or regulation.

Correction, deletion, etc.

Regarding the personal data possessed by the Group, if you request correction, addition or deletion with respect to your information, the Group will correct, add or delete any part of the information that is found to be incorrect within a reasonable period and scope, after confirming your identity.

Suspension of use, erasure

Regarding the personal data possessed by the Group, if you request suspension of use or erasure of your information and in any of the cases below, the Group will suspend use of or erase the information within a reasonable period and scope in principle, after confirming your entity.

  1. When the Group has used your personal information beyond the scope of the purposes of use provided in 3 of this policy without your consent
  2. When the Group has acquired said personal information in an illegal or illicit way
  3. When the Group has illegally disclosed your personal information to a third party

However, when the use of a part or all of such information is suspended or such information is erased, the Group may become unable to provide the services you require despite our intention to do so.

In addition, the Group may not respond to your request for suspension of use or erasure of the information possessed pursuant to the Labor Standards Act or other laws.

Handling of advertising ID

The Company may provide behavioral targeting advertising services in conjunction with personal data for the purpose of effective advertising delivery in the App service (hereinafter referred to as "App") provided on smartphones, etc. If you wish to revoke a behavioral targeting advertisement, access the following pages and follow the procedure.

  1. Opt-out at iOS devices
    The Company's App uses the Identification For Advertisers Advertising Identification (hereinafter referred to as "IDFA").
    If you wish to restrict advertising using the IDFA, please check the following pages and follow the instructions.
    https://support.apple.com/ja-jp/HT202074
  2. Opt-out at Android devices
    The Company's App uses the Advertising ID (hereinafter referred to as "AAID").
    If you wish to restrict advertising using the AAID, please check the following pages and follow the instructions.
    https://support.google.com/googleplay/answer/3405269?hl=ja

The Company uses advertising IDs in the following Apps, and the following businesses use them for advertising services based on their use. If you wish to restrict the use of the following services, please also follow the procedures for such services.

  • App name

    Global WiFi

  • Company name

    Repro Co. Ltd.

  • Explanation

    The Global WiFi App acquires device system log information, device-specific information, advertising ID, etc. for the purpose of providing information that the Company considers useful to customers. To acquire such information, the Global WiFi App uses Repro, which is a push notification analysis and distribution service provided by Repro Co. Ltd. (hereinafter referred to as "Repro").
    Upon use of the Repro, the Company will send the system log information of the device, the information specific to the device, the advertising ID, etc. to Repro, but the Company cannot identify individuals by the system log information of the device, the information specific to the device, the advertising ID, etc. In addition, under the responsibilities of the Repro, Repro shall manage system log information of device, information specific to device, ID for advertisements, and others in accordance with the policy of Repro.
    For more information, please review Repro's privacy policy. https://repro.io/company/legal/privacy/
    Customer may opt out to Repro to collect system log information, device-specific information, advertising IDs, etc. If you wish to opt out, please contact the e-mail address listed on Repro's website as follows:
    https://repro.io/company/legal/privacy/

How to accept disclosure etc., and the contact

The Group appoints a person responsible for personal information management. For inquiries related to the handling of personal information, please contact the following.
≪Contact office≫
Address: 5F Shinjuku Island Tower, 6-5-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo
VISION Inc. Personal Information Contact Office
Phone: 03-5325-0200
Masaya Hayashi, Information Management Officer
The Office is open from 9:00 am to 5:00 pm on weekdays (*).
* Except on Saturdays, Sundays, national holidays, year-end and New Year holidays

GDPR

If you have your habitual residence in the European Economic Area, this Chapter VIII shall prevail against Chapters I to VII above with respect to our processing of personal data and data subject rights.

Summary of PRIVACY NOTICE

This summary Privacy Notice ("Summary Notice") will provide you with a summary of the accompanied, detailed Privacy Notice (hereafter "Full Notice", together "Summary and Full Notice") on the data processing activities of Vision Inc., located at Shinjuku i-Land Tower 5F, 6-5-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-1305, Japan ("Vision", „our", "we" or "us") with respect to individually identifiable information ("Personal Data") about users of our site (https://www.vision-net.co.jp/) ("Website").

Scope of applicability
This Summary and Full Notice applies to you if you are a user of our Website.

Processing of your Personal Data (categories of Personal Data)
We process the following of your Personal Data collected during your visit of our Website: your full name, your date of birth, your gender, your country, your postal address including your street and number, city, zip code, phone number, e-mail address, your IP-address, host name, user agent, browser identification, referrer, the date/time of your access to the Website, and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you. For more details see 1. of the Full Notice or click here.

Processing purposes
We process your Personal Data for the following purposes: providing WiFi router rental services, billing and collecting fees for our services, granting prizes and conducting campaigns, introducing goods or services of us or our business partners, managing and administrating your account, get in contact with you concerning your queries, security and fraud prevention, conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and service. For more details see 2. of the Full Notice or click here.

Legal justifications for the processing of your Personal Data
One of the key privacy law requirements is that any processing of Personal Data has to have a legal justification. We generally use the following legal justifications: (1) You have given your consent to the processing (Art. 6(1)(a) GDPR; "Consent Justification"), (2) the processing is necessary for (a) the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR; "Contract Performance Justification") (b) compliance with a legal obligation (Art. 6(1)(c) GDPR; "Legal Obligation Justification") and (c) realizing a legitimate interest (Art. 6(1)(f) GDPR; "Legitimate Interest Justification"). For more details and the matching of purposes and corresponding legal justifications see 3. of the Full Notice or click here.

Data transfers and recipients and legal justification for such transfers
We transfer your Personal Data to our service providers, and, in accordance with applicable law, other governmental authorities, courts, external advisors, and similar third parties, some of the aforementioned recipients located in jurisdictions outside the EU. For more details see 4. of the Full Notice or click here.

Retention periods for and deletion of your Personal Data
Your Personal Data will be deleted once they are not any longer needed for the purposes motivating their original collection or as required by applicable law. For more details see 5. of the Full Notice or click here.

Your statutory rights
You have a number of rights with regard to the processing of your Personal Data, each as per the conditions defined in applicable law, such as the right to have access to your Personal Data, to have them corrected, erased or handed over. Please refer any of your questions to [email protected] For more details see 6. of the Full Notice or click here.

Changes of this Summary and Full Notice as well as further notices
This Summary and Full Notice are subject to change. You will be notified adequately of any such changes. Further, you will be notified adequately through further relevant privacy notices (e.g. for specific purposes) in case such is not covered by this Summary and the Full Notice.

  • How to contact us

If you wish to exercise your data subject rights or if you have any other questions concerning this Summary and Full Notice, please address your request to us, who can be contacted at:
Vision Group Personal Information Contact,
Shinjuku i-Land Tower 5F, 6-5-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-1305, Japan,
Email: [email protected]
Tel: 03-5325-0200.

The reception time for all counters is from 9 AM to 5 PM on weekdays except for national holidays in Japan.

  • Full Notice

We are delighted about your interest in our Website. Your privacy is important to us. Hereafter, we provide you with detailed information on dealing with your personal data on this Website.

This Full Notice is applicable for the Website only. Other Vision websites may be governed by other privacy policies. Please also note that parts of the Website may contain links to such other Vision websites or third party websites which may be governed by other privacy policies.

This Website uses cookies. For further information please read our cookie policy - which you will find here.

  1. Categories of Personal Data
    We process the following Personal Data about you (hereinafter jointly "Your Data"):
    1. your full name, your date of birth, your gender, your country, your postal address including your street and number, city, zip code, phone number, e-mail address (hereinafter jointly "Contact Data");
    2. your IP-address, host name, user agent, browser identification, referrer, and the date/time of your access to the Website(hereinafter jointly "Technical Data"); and
    3. any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you (hereinafter jointly "Form Data").
  2. Processing purposes
    We process Your Data to the extent permitted or required under applicable law, for the following purposes:
    • to perform a contractual obligation under contracts between you and Vision or to take steps at your request prior to entering into a contract with us (hereinafter "Contract Purposes");
    • to provide the Website in an optimized way for you and to currently enhance the user experience of the Website (hereinafter "Quality Purposes");
    • to send you marketing materials, such as newsletters to provide you with the latest information about our products and services which might be of interest to you (hereinafter jointly "Marketing Purposes").
  3. Legal justification for the processing of Your Data
    Generally, the provision of Your Data is voluntary. However, if you do not provide Your Data, the use of the Website may be different. Particularly, if you do not provide Contact Data, we do not provide our Wi-Fi router rental services to you.

    Furthermore, We rely on the following legal justifications for the processing of Your Data:

    YOUR DATE

    • Processing purposes

      Contract Purposes
      Quality Purposes
      Marketing Purposes

    • Categories of Your Data involved

      Contact Data
      Form Data
      Technical Data
      Contact Data
      Marketing Data
      Form Data

    • Legal basis

      Contract Performance Justification
      Legitimate Interest Justification
      Consent Justification

  4. Data transfers and recipients and legal justification for such transfers
    1. Recipients
      1. Third parties: We may transfer Your Data to governmental agencies and regulators, courts, and government authorities, all in accordance with applicable law based on Legal Obligation Justification and to external advisors acting as controllers (e.g., lawyers, accountants, auditors etc.) based on Legitimate Interest Justification.
      2. Service providers: We contract with third party service providers as part of our normal business operations to provide the Website and related services to you (i.e., cloud service providers, call center service providers, and logistic companies).
    2. Cross-Border Data Transfers
      1. We may transfer Your Data outside of the country you are located. Some recipients of Your Data are also located in another country for which the European Commission has not issued a decision that this country ensures an adequate level of data protection as of the date of this Privacy Notice, namely: Japan.
      2. By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Art. 46(5) GDPR, we have established that all recipients located outside the EEA will provide an adequate level of data protection for Your Data and that appropriate technical and organizational security measures are in place to protect Your Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law. Such agreements are accessible upon request from [[email protected]].
  5. Retention periods for and deletion of Your Data
    1. Your Data processed for the purposes hereunder will be stored only to the extent necessary. If a judicial or disciplinary action is initiated, Your Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
    2. In principle, we will retain Your Data as long as required or permitted by applicable law. Afterwards, we will remove Your Data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.
  6. Your statutory rights
    Under the conditions set out under applicable law (i.e., the GDPR), you have the following rights:
    1. Right of access: You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes - inter alia - the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed.
      You have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, wemay charge a reasonable fee based on administrative costs.
    2. Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
    3. Right to erasure (right to be forgotten): You have the right to ask us to erase your Personal Data.
    4. Right to restriction of processing: You have the right to request the restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
    5. Right to data portability: You have the right to receive the Personal Data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another entity without hindrance from us.
    6. Right to object:

      You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by Us and We can be required to no longer process your Personal Data. In general, you have the right to object to our processing of your personal data for direct marketing purposes. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by Us. Exercising this right will not incur any costs. Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

      Please note that the aforementioned rights might be limited under the applicable national data protection law. We remain the universal point of contact for your execution of these rights.

      Please refer any of your questions to [email protected]

      In case of complaints you also have the right to lodge a complaint with the competent supervisory authority, in particular in the member state of your habitual residence or alleged infringement of the GDPR.

Additional Clauses

The Privacy Policy is effective from [2018/5/26].
Incidentally, we may change the Privacy Policy along with the establishment and amendment of laws, regulations and various guidelines. We will publish any changes to the Privacy Policy on our website.