Edo Gijuku Co., Ltd. (hereafter “the Company”) sets forth this privacy policy (hereafter “this Policy”) concerning the handling of personal information, including personal information of the Registered User, at providing the service (hereafter “the Service”) as follows:

Collected Personal Information and Collection Method

In this Policy, “Personal Information” refers to information concerning the identification of the Registered Users, their telecommunication activity histories, and other device-related information generated by or accumulated in the Registered Users’ devices, such as smartphones, PCs., etc., which the Company collects in accordance with this Policy. Typical Personal Information the Company collects are as follows, depending on the collection methods:

1. Personal Information to be provided by the Registered User shall be as follows:

・Name

・Email address

・Date of birth

・Credit card information

・Photo

・Other information entered by the Registered User in the form provided by the Company

2. If the Registered User permits the Company to affiliate the Service with other services while using the Service and thereby allowing the Company to link the Registered User’s information with external services, such as social network service, and use information from the said other services, the Company collects the following information in accordance with the consent granted at such permission:

•User ID of the Registered User in the said external service;

•Other information the Registered User gives the affiliated service the permission to disclose through the privacy setting of the said external service:

3. The Company may collect information concerning the statuses of access to the Service and on how the Service is used. Such information includes:

・Device information

・Log information

・Cookie and anonymous ID

・Location information

Purpose of Use

Other than being used for the provision of the Service under Paragraph 2, Personal Information may be used for other purposes as specified in Paragraph 3.
2. Main purposes of the use of Personal Information concerning the provision of the Service are as follows:

To provide, maintain, protect, and improve the Service, such as registration, personal identification, and calculation of usage fees, etc.;
To make announcements concerning the Service and responding to inquiries, etc.;
To take countermeasures against actions in violation of the Company’s Terms and Conditions, policies, etc. concerning the Service (hereafter “the Terms, etc.”);
To announce changes made on the Terms, etc. concerning the Service, etc.; and
For other purposes of use in connection with the above purposes.
3. Purposes of use other than the foregoing Paragraph 2 are:

To generate statistic data in connection with the Service (referring to device information, log information, Cookie and anonymous ID, and location information), which has been processed to make any individuals unidentifiable;
To distribute or display advertisements of the Company or third parties; and
Name, email address, date of birth, and other information entered by the Registered User in the form designated by the Company to be used for marketing.
Methods of Notification, Publication or Obtainment of Consent, and Method of Request for Suspension

1. The Company shall obtain Registered User’s consent prior to the collection of the following information:

Device information
Location information
The Registered User may request the suspension of use of the whole or a part of Personal Information through the setting specified under the Service. In this case, the Company will promptly suspend the use in accordance with the Company’s rules. For some information items, however, the collection or use constitutes the precondition for the use of the Service. For such information items, the Company shall suspend the collection only when the Registered User quits the Service through steps specified by the Company.

Outbound Transmission, Provision to a Third Party, Presence of Information Collection Module

1. To distribute targeted advertisements based on Personal Information, the Service has the following built-in information collection modules. In this connection, the Company provides Personal Information and lesson movies to the information collection module providers in the following manner:

Provider of the information collection module;
Items of Personal Information to be provided;
Method of provision;
The said provider’s purpose of use;
Purpose for connecting to external services for the purpose of facilitating the use of the Company’s service;
Presence of third-party provision at the said provider; and
URL of the said provider’s privacy policy.
2. Lecturers are assumed to have granted permission to the Company in advance concerning the use of the right of their publicity by the Company free of charge when they register for the Service.

Third-party Provision

Except for Personal Information permitted for disclosure under the Act on the Protection of Personal Information or other laws, the Company does not provide personal information to a third party without first obtaining Registered User’s consent, unless:

The Company outsources whole or a part of the handling works of Personal Information within the extent necessary to fulfill the purpose of use;
Personal Information is handed over as a part of business succession due to merger, etc.;
Personal Information is provided to information a collection module provider in accordance with the foregoing article;
The Company must cooperate with an agent of the national or local government executing works designated under laws, for which the said works may be hampered if the Registered User’s consent is given;
The Company affiliates its business for the development and expansion of the Service under contract and provide Personal Information to the affiliated company for joint use; and
It is permitted under the Act on the Protection of Personal Information or other laws.
Disclosure of Personal Information

When the Registered User requests the Company to disclose Personal Information in accordance with the Act on the Protection of Personal Information, the Company will promptly disclose such information upon confirming the authenticity of the request (or, if such personal information is not held with the Company, will notify as such,) unless the Company is not under the disclosure obligation based on the Act on the Protection of Personal Information or other laws. The Registered User is asked to acknowledge that the Company charges a handling fee (1,000 yen per disclosure) for the disclosure of Personal Information.

Amendment, Suspension from Use, etc., of Personal Information

1. If the Company receives a request from the Registered User to: (1) amend Personal Information in accordance with the Act on the Protection of Personal Information on the basis that the said Personal Information is not correct; or (2) suspend the use of Personal Information in accordance with the Act on the Protection of Personal Information on the basis that such information is used beyond the extent of the published purpose of use or the said information has been collected through a false or illicit method, the Company will promptly make necessary investigations upon confirming the authenticity of the Registered User’s request, amend or suspend the use of such Personal Information, and notify the Registered User of the result. If the Company decides not to amend or suspend the use of such Personal Information on a reasonable basis, the Company will notify the Registered User of such decision.

2. If the Registered User requests the Company to delete Personal Information pertaining to the said Registered User, the Company will, upon confirming the authenticity of the request from the Registered User, delete such Personal Information and inform the Registered User of such result, provided that the Company concludes that conformity to such request is necessary.

3. If it is not the Company’s responsibility to amend, or suspend from use of, Personal Information under the Act on the Protection of Personal Information or other laws, the foregoing two paragraphs shall not apply.

Contact for Inquiries

For any opinions, questions, claims, or any other inquiries concerning Personal Information, please contact the following address:

　　Address: 9th Floor, Shintaiso Bldg. No. 3, 2-10-12

　 Dogenzaka, Shibuya-ku, Tokyo

　 Edo Gijuku Co., Ltd.

　　Email: support@app-Edo Gijuku.com

Amendment Procedure of Privacy Policy

The Company will review the operational circumstances concerning the handling of Personal Information from time to time in its effort for continuous improvement and, in this regard, may change the terms of this Policy as necessary. Whenever a change is made, the Company will inform the Registered User of such change. If such change is subject to the Registered User’s consent under laws, the Company will obtain such consent through a method specified by the Company.

[Established on June 11, 2015]