LOCOBEE PRIVACY POLICY

With regard to the treatment of user’s information during the performance of services which IC CO.,LTD. (hereinafter referred to as the “Company”) provides through its website (URL: http://www.locobee.com/) and applications (the “Services”), the Company has established the following privacy policies (hereinafter referred to as the “Policy”) in order to comply with applicable laws and regulations concerning the treatment of user’s information, guidelines of the government and other relevant standards. All persons using the Services (hereinafter referred to collectively as “Users”, and individually as a “User”) are required to agree to the Policy set forth as follows;

User’s Information to be Collected by the Company:
- (1) When the Company collects and uses User’s information (hereinafter, including without limitation, personal information defined in the Act), it will in advance specify the purpose for such collection and use and will not use so-collected personal information in any purpose other than such specified purpose, based on Personal Information Act (referred to as the “Act”). In addition, the Company will publish the purposes for collection of User’s information and take appropriate measures for prevention of use thereof for any purposes other than the specific purposes.
- (2) The Company will take organizational and technical safety measures for appropriate management of User’s information which the Company has collected and use its best efforts to prevent and remedy the leakage, loss or other problems of such personal information.
Purpose of Use:
- (1) User’s information collected by the Company may be used not only for the provision of the Services provided in Article 2 (2), but for other purposes provided in Article 2 (3).
- (2) Specific purposes of the User’s information for the provision of the Services shall include the following:
  - ・Provision, maintenance, protection and improvement of the Services, including but not limited to, acceptance of registration for the Services, identification of individuals and calculation of use fees;
  - ・Guidance or response to inquiries concerning the Services;
  - ・Billing of use fees to Users;
  - ・Performance of data analysis and announcement of the result, in a form that cannot identify an individual:
  - ・Addressing violation of the Company’s rules, regulations, or policies, related to the Services (hereinafter referred to as the “Rules”);
  - ・Notice of any modification to the Rules; and
  - ・Other purposes incidental to the foregoing.
- (3) Purposes other than those specified in 2 (2) above shall be as indicated below:
  - (a) To use the following data of Users in order to process them as statistical data in the form that cannot identify an individual relating to the Services:
    - ・Birth date;
    - ・Sex;
    - ・Nationality;
    - ・Language; and
    - ・History of actions such as the sell and purchase history, concerning the use of the Services, as recorded in the Services.
  - (b) To use the following User’s information for distribution and notification of advertisements and information of the Company and third parties:
    - ・Device information;
    - ・Log information;
    - ・Cookie and anonymous ID; and
    - ・Location information.
  - (c) To use the following User’s information in terms of User’s cooperation on surveys concerning the Services and/or other services provided by the Company:
    - ・E-mail address;
    - ・Birth date;
    - ・Sex;
    - ・Nationality;
    - ・Language; and
    - ・Other information which Users input in the form designated by the Company.
  - (d) To use the following information for other marketing activities:
    - ・Birth date;
    - ・Sex;
    - ・Nationality;
    - ・Language;
    - ・Location information; and
    - ・Other information which Users input in the form designated by the Company.
Request for Disclosure, Correction and Suspension of Use:
Each User may, by making the prescribed setting, request the Company to suspend the use of all or part of his or her personal information. In such a case, the Company will suspend the use of the User’s personal information without undue delay. In addition, each User may request the Company to disclose his or her personal information registered with the Company and, if there is any error or inaccuracy in such personal information, the User may request the Company to make corrections thereof.
Provision of Personal Information to Third Parties:
The Company will not provide any third party with User’s information without prior consent of the User thereto, or unless required by the Act and/or other applicable laws and regulations, and except for the cases specified in Article 4 (1)-(4). When the Company consigns the treatment of User’s information to a third party (including but not limited to a third party located overseas), it will select as consignee a third party that has taken adequate measures for protection of User’s information in accordance with the Act and other applicable laws and regulations, and supervise the protection of such information by the consignee as necessary.
- (1) The Company domestically consigns all or part of the treatment of User’s information pursuant to necessary purposes for use of such information;
- (2) The User’s information is provided to a third party through a business transfer by way of merger, consolidation or other similar transactions;
- (3) The provision of User’s information is necessary for the Company’s cooperation in fulfillment of legally required duties by the government or other party entrusted with such duties by any of the foregoing and, if requiring the User’s consent to such provision of their personal information, it is likely to interfere with the fulfillment of the duties; and
- (4) The provision of User’s information is allowed by the Act or other applicable laws and regulations.
Response to Request of the Disclosure, Correction or Suspension of Use, Complaint, Consultation concerning User’s Information:
If the Company is required by the User to disclose, correct, suspend the use of registered User’s information, based on the Act, the Company shall, after confirming that the requesting party’s identity, without delay, based on the result thereof, disclose, correct, or suspend the use of such personal information and notify the User to that effect. If the Company determines that no such disclosure, correction, suspension of use or otherwise be made for a reasonable reason, it will notify the User thereof.
Inquiries:
Any opinions, questions, complaints, and inquiries concerning the treatment of User’s information must be submitted to: [support@locobee.com ]
Procedure to Modify the Privacy Policy:
The Company will from time to time review the status of treatment User’s information and continuously improve it as appropriate and may modify the Policy. Any modification to the Policy shall be notified to Users through the Services. If the User uses the Services after notification of a modification hereof, the User shall be regarded as having agreed to the modification; provided, however, that in case of the modification for which User’s consent is required, the Company will obtain such consents from the User in a prescribed manner.

【Established on　 January, 27, 2017】