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Companies adopting this Privacy Policy from among Mercari, Inc., its subsidiary companies, and associated companies (defined in the separate Privacy Guide; hereinafter referred to as “the Group”) shall handle the personal information of customers and business partners (hereinafter referred to as “you” or “your”) based on the following “Privacy Policy.” In addition to the “Privacy Policy,” the Group may set out a special privacy policy for individual service categories (e.g., “financial services”) (hereinafter referred to as the “Service Privacy Policy”). In this case, both the “Privacy Policy” and the Service Privacy Policy shall be applied, and should any conflict exist between the two, the Service Privacy Policy shall prevail.

You are kindly asked to carefully read the following “Privacy Policy” and “Privacy Guide” to use the services operated by the Group (hereinafter collectively referred to as “the Service”).

1. Obtained Information

The information obtained by the Group in order to achieve the objective defined in “4. Purposes of Use of Collected Information” includes the following (hereinafter, (1), (2), and (3) are collectively referred to as “Your Information”).

1. Information obtained by the Group
   Personal Information refers to personal information as defined in Article 2, paragraph (1) of the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as “Personal Information Protection Act.”). In particular, the Group treats the following as personal information.
   1. Name, date of birth, gender, occupation, and other information that may identify a specific individual
   2. Information such as addresses, telephone numbers, account information (refers to email addresses, passwords, etc.), nicknames, etc., used in association with specific personal information
   3. Credit card information
   4. Hobbies, family structure, age, and other personal attribute information integrated with personal information
   5. Information concerning identity verification
   6. Names, nicknames, email addresses, Facebook IDs, birthdays, genders, profile images, friend information on Facebook, and other information registered on your Facebook page obtainable when you approve the use of Facebook Connect on this Service and enter your Facebook ID and password
   7. Information concerning merchants, vendors, etc., submitted to the Group when you apply to or use the Service
2. Information the Group obtains in connection with usage of the Service
   The following information concerning usage of the Service shall be obtained regardless of whether such information falls under the definition of personal information.
   1. Information related to your usage and browsing of the Service, such as the contents of the Service you have used, the date and frequency of use, and your online activities when using the Service, etc. (this includes information on cookies, information related to usage status such as access logs, etc., information on devices used, OS information, location information, and information related to your communications such as IP addresses, browser information, browser language, etc.)
   2. Posts, photographs, videos, comments, transaction messages, evaluations, and other information you post or send to the Service
   3. Information concerning your settlement status with the Service
3. Information the Group collects indirectly through business partners and third parties
   The Group may collect personal information or personal related information such as identifiers (including cookies, AdID/IDFA identifiers, and IP addresses), phone numbers, email addresses,browsing history, behavior logs such as location information, and information such as interests and, preferences,acquired from third parties, such as public data management platform operators,affiliate service providers, data analysis business operators, fraudulent use detection service providers, advertising business operators, and other service providers, link it to your personal information already held by the Group, and match and analyze said information.

2. Collection of Your Information

The Group collects information when you use the Service via the following methods, etc.

1. Collecting information directly entered on the Service
2. Collecting information you provide to the Group via email, postal mail, documents, telephone calls, etc. (the Group will record telephone calls when responding to customer telephone calls to improve response service quality, etc.)
3. Collecting information when you use or browse the Service
4. Collecting information indirectly from business partners and third parties
   This includes, but is not limited to, the following methods.
   1. Collecting your registration information from Facebook when you approve the use of Facebook Connect and enter your ID and password
   2. Collecting information about you. from third parties, such as public data management platform operators, affiliate service providers, other service providers, etc.
5. Collecting automatically (and with your consent) the details of contents displayed by third-party services

3. Managing Your Information

Each employee of the Group engaged in the management or use of Your Information shall place Your Information under strict control and take sufficient care in handling Your Information to protect personal information against unauthorized access, loss, leakage, falsification, and other similar incidents.

4. Purposes of Use of Your Information

The Group shall use Your Information for the usage purposes that the Group notifies you of when obtaining and collecting Your Information, the usage purposes set out in the terms of service, or the following purposes.

1. In the communication or provision of information on various matters concerning the Service
2. In the provision of the Service
3. In the simplification of entering information required for user registration for the Service
4. In the linking of information between the Services related to your application
5. In the confirmation of an application to the email delivery service and the sending of emails
6. In the confirmation and delivery of purchases related to the Service
7. In billing and payments related to the Service and the confirmation thereof
8. In the mailing of rewards, etc. for the cooperation in surveys, etc.
9. In the mailing of prizes, etc. for the participation in competitions, etc.
10. In the research and analysis into the usage status of the Service
11. In the improvement of the content of the Service to make it more satisfactory, or in the development of a new service
12. In the analysis of information on obtained activity history, etc., and when making determinations on and management of credit related to the Service
13. In customizing the contents of the Service to your needs
14. In the conducting of surveys on satisfaction levels related to the Service
15. In the aggregation of statistical information processed from Your Information and published as survey results
16. In the conducting of research and development related to the Service and new services
17. In the use of said information in marketing, including sending guidance or notifications on the Service, new services, and other various services
18. In the requesting of cooperation in surveys and participation in various events, and in the reporting of results, etc. therefrom
19. In the distribution or displaying of the Group’s or a third party’s advertisements that have been tailored to you
20. In the distribution or display of product information included in services provided by the Group or a third party
21. In the resolution of any issues related to the operation of the Service
22. In the prevention of any fraudulent use of the Service and to ensure security

5. Provision of Your Information to Third Parties

The Group shall provide Your Information to a third party in the following cases:

1. In cases of providing information on the Service that the Group has determined necessary in the provision of the Service
   You shall use information on others provided to you only to the extent necessary for the use of the Service in accordance with the terms of service of the Service. You shall not provide third parties with information on others without their prior consent. In addition, Your Information will be disclosed on the Service for a period of time determined by the Group.
2. In cases where the Group has determined it necessary in the operation and provision of the Service
3. In cases where information is provided to delivery companies, settlement agents, subcontractors, or other third parties in order to deliver products, settle payments, respond to your inquiries, send you inquiries from the Group, or provide related after-sales services, etc.
4. In cases where the Group is required by any court, administrative agency, regulatory agency, or other public organization to provide Your Information in accordance with laws and regulations
5. In cases where the Group has determined it necessary to provide information in order to resolve disputes with third parties or to protect the rights or interests of users of the Service or third parties, etc.
6. In cases where information is provided to third parties entrusted by the Group to carry out research, analysis, etc., in order to research and analyze the usage status of the Service, etc.
7. In cases where information is provided to third parties in order to distribute or display advertisements of the Group or a third party
8. In cases where information is provided to third parties in order to distribute or display product information included in services provided by the Group or third party
9. In cases where information is provided to academic research institutes for the purpose of academic research
10. In cases where the Group provides information such as your listing or purchase history, the information you have registered in the use of the Service, or your usage status of the Service to your credit card issuing company in order to help your credit card issuing company detect and prevent fraudulent credit card use

In addition to the above, the Group may provide Your Information in cases where the Group has determined it necessary to provide Your Information, provided that your consent has been obtained.

6. Entrustment of the Handling of Your Information to Third Parties

The Group may entrust a subcontractor with the whole or part of its handling of Your Information within the extent necessary to achieve the purposes of use specified in “4. Purposes of Use of Your Information.” In this case, the Group will fully examine whether the subcontractor satisfies the contractor selection criteria set out by the Group and ensure that the subcontractor will properly manage Your Information in the execution of a contract.

7. Shared Use of Your Information

The Group will share Your Information with other companies of the Group to the extent necessary to achieve the purposes of use specified in “4. Purposes of Use of Your Information.”

1. Information shared
   Your Information specified in “1. Obtained Information”
2. Scope of parties sharing Your Information
   The Group as defined in the preamble of the “Privacy Policy”
3. Purposes of use of parties sharing Your Information
   In the achievement of the purposes of use specified in “4. Purposes of Use of Your Information”
   Note that, in the event that Mercoin, Inc. uses shared information of any user who do not use services operated by Mercoin, Inc., the purposes of such use are limited to the resolution of any issues related to the operation of the Service, the prevention of any fraudulent use of the Service, and to ensure security.
4. Person responsible for controlling the shared use of information
   Mercari, Inc.
   For Mercari, Inc.’s address, representative, and other information, please refer to the following link:
   https://about.mercari.com/en/about/company/

8. Provision of Your Information to Third Parties in Other Countries

The Group may provide Your Information to third parties in other countries. These countries may not have systems for protecting personal information that are at an equivalent level as that of Japan. However, the Group will only provide Your Information to parties that have established a system complying with the standards required by Japan’s Personal Information Protection Act, and that are taking necessary measures to continuously maintain said compliant system. The Group shall provide information related to the said necessary measures in accordance with your request. If you would like such information, please send your inquiry via the information described in “17. Inquiries.”

Additionally, for details on the provision of Your Information to third parties in other countries, please see “Usage Purposes and Provision of Information” in the Privacy Guide.

9. Use of Cookies, etc.

You can choose whether to allow the use of cookies. Most web browsers automatically allow the use of cookies, however you can change your browser settings to block the use of cookies.

1. Should you block the use of cookies, you may not be able to use the Service properly. In addition, advertising preferences that require cookies may not be reflected.
2. The Group will automatically receive your cookie information and information on the advertisements and pages you view and your user environment from your browser and store this information on its servers, and will use this information to improve convenience such as automatic entry of email addresses when logging into the Service, for security purposes such as maintaining and protecting usage sessions, and to make the contents of services and advertisements more suited to you.
3. For details on the use of cookies, etc., please see the External Transmission Policy.

10. Google Analytics

To research and analyze the usage status, etc. of the Service, the Group uses Google Analytics (a service provided by Google LLC) on the Service. For an explanation regarding the terms of service of Google Analytics, please visit the Google Analytics site, and for an explanation regarding the privacy policy of Google LLC, please visit the company’s site.

Google Analytics Terms of Service:
https://www.google.com/analytics/terms/us.html
Google Privacy Policy:
http://www.google.com/intl/en/policies/privacy/

Google Analytics uses cookies and other methods to track your usage status, etc. Should you prefer your data not be used by Google Analytics, please use the Google Analytics Opt-out Browser Add-on provided by Google LLC.

Google Analytics Opt-out Browser Add-on:
https://tools.google.com/dlpage/gaoptout?hl=en

11. Use of Logs and Device Information, etc.

1. Logs
   The Group collects IP addresses, browser types, and browser language, etc., automatically generated when users visit the Service.
   The Group uses such information to analyze a user’s environment and provide a better service, as well as to prevent unauthorized activities that may interfere with the normal provision of service. The Group saves and manages search records in a form that does not allow individuals to be identified, and uses them for the purpose of creating statistical data and other purposes.
2. Device information
   The Group may collect device information, including identifier information of devices, etc.
   The Group uses such information to provide a better service and prevent unauthorized activities that may interfere with the normal provision of service.

12. Correction of Your Personal Information by the Group

Should there be any changes to information that may impede the delivery or billing of products, such as personal information including municipality name and postal code, names of financial institutions, or credit card expiration dates, etc., the Group may amend the registered personal information.

13. Management and Security of Personal Information

The Group will securely store Your Information that it has collected on a server that cannot be accessed by general users and make efforts to protect Your Information against unauthorized access, loss, destruction, falsification, or leakage.

14. Information of Minors

If you are a minor, the Group shall require a parent, custodian, or guardian to agree to the contents of the “Privacy Policy” and the terms of service, etc., as well as comprehensively agree that you will use the Service based on the “Privacy Policy” and the terms of service.

15. Improvements and Revisions to the “Privacy Policy”

The Group works on making improvements to the “Privacy Policy” as necessary.

1. The Group may revise the “Privacy Policy” in accordance with revisions to laws and regulations, operational needs, or other reasons. The Group will notify you in the case of any revisions to the “Privacy Policy.”
2. Please make sure to check the latest version of the “Privacy Policy” before accessing the Service or using the Service of the Group.

16. Procedures for Disclosure, Correction, and Discontinuation of Use of Personal Information

You can confirm and correct the information you have registered on the Service at any time.

Should you request the Group to disclose personal information that you cannot check yourself on the Service, or records related to the provision to third parties, you may request the disclosure in accordance with the procedures separately prescribed by the Group, except in the following cases.

1. In the case that the disclosure may harm the life, body, property, or other rights or interests of the person in question or a third party
2. In the case that the disclosure may significantly interfere with the proper business operations of the Group
3. In the case that the disclosure violates laws and regulations
4. In the case that the Group cannot confirm that the request for disclosure has been made by the person in question

If, as a result of the disclosure, you determine that the contents of the personal information retained by the Group contain false information, you may request that the Group makes corrections, additions, or deletions to said personal information in accordance with the procedures separately prescribed by the Group. In this case, the Group will conduct an investigation within the extent necessary to achieve the purposes of use without delay and, based on the investigation results, make corrections, additions, or deletions to such personal information.

In addition, you may also request that the Group discontinues using, erases, or discontinues providing personal information to third parties in accordance with the procedures separately prescribed by the Group. In this case, the Group will conduct an investigation within the extent necessary without delay, and should it recognize any inappropriate handling of personal information by the Group or otherwise considers that your request has reasonable grounds, the Group will discontinue using, erase, or discontinue providing such personal information to third parties to the extent necessary for protecting your rights and interests. However, in cases where your request is insufficient or lacks reasonable grounds, or in cases where it is difficult for the Group to satisfy your request under the relevant laws and regulations, the Group may not be able to respond to your request.

Please note that should you request the disclosure of personal information that you cannot check yourself on the Service, or records related to the provision to third parties, the Group may charge a fee for the disclosure in accordance with the procedures separately prescribed by the Group.

17. Inquiries

If you have any inquiries about the “Privacy Policy,” please inquire via the contact information below.

The Group shall handle your information on payment services, including operations of issuance of prepaid payment instruments provided by the Group and funds transfer services, as well as other finance-related businesses, (hereinafter referred to as the “Financial Service”) as follows.

Please note that this Policy will be applied together with the “Privacy Policy” separately prescribed by the Group (hereinafter referred to as the “Common Policy”), and should any conflict exist between the two, this Policy shall prevail.

1. Definition of Terms

The terms used in this Policy shall have the meanings as defined in the Common Policy, except those individually defined in this Policy.

2. Obtained Information

Notwithstanding “1. Obtained Information” in the Common Policy, the Group shall obtain information, including personal information, on the Financial Service (hereinafter, (1) and (2) are collectively referred to as “Your Information”) as follows.

1. Information obtained by the Group

   a. Name, date of birth, gender, occupation, and other information that may identify a specific individual

   b. Information such as addresses, telephone numbers, account information (refers to email addresses, passwords, etc.), nicknames, etc., used in association with specific personal information

   c. Credit card information

   d. Bank account information

   e. Hobbies, family structure, age, and other personal attribute information integrated with personal information

   f. Information related to official certificates such as a driver’s license, residence certificate, etc., submitted for identity verification, and transaction purposes

   g. Names, nicknames, email addresses, Facebook IDs, birthdays, genders, profile images, friend information on Facebook, and other information registered on your Facebook page obtainable when you approve the use of Facebook Connect on this Service and enter your Facebook ID and password

   h. Any other information you provide to the Group in association with the provision, etc. of the Financial Service

2. Information the Group obtains in connection with usage of the Financial Service

   i. Information related to your usage and browsing of the Financial Service, such as the contents of the Financial Service you have used, the date and frequency of use, and your online activities when using the Financial Service, etc. (this includes information on cookies, information related to usage status such as access logs, information on devices used, OS information, location information, and information related to your communications such as IP addresses, browser information, browser language, etc.)

   j. Information related to the issuance, purchase, acquisition, use in payments, withdrawal, deletion, or balance of money-transfer points, charged points, or charge-free points, and other information related to points

   k. Information related to the usage of advance third-party payments and payment status

   l. In addition to j and k listed above, information related to transactions and payments on Mercari Services or point merchants (including information on purchased products and stores of purchase (including sellers on Mercari), etc.)

   m. Any other information related to your usage status of the Financial Service

3. Purposes of Use of Your Information

Notwithstanding “4. Purposes of Use of Your Information” in the Common Policy, the Group shall use Your Information it has obtained described in 2. above for the following purposes.

4. Provision of Your Information to Third Parties

Notwithstanding “5. Provision of Your Information to Third Parties” in the Common Policy, the Group shall provide Your Information to third parties in the following cases.

1. In cases of providing information on the Service that the Group has determined necessary in the provision of the Service
   You shall use information on others provided to you only to the extent necessary for the use of the Service in accordance with the terms of service of the Service. You shall not provide third parties with information on others without their prior consent. In addition, Your Information will be disclosed on the Service for a period of time determined by the Group.
2. In cases where the Group has determined it necessary in the operation and provision of the Service
3. In cases where information is provided to delivery companies, settlement agents, subcontractors, or other third parties in order to deliver products, settle payments, respond to your inquiries, send you inquiries from the Group, or provide related after-sales services, etc.
4. In cases where the Group is required by any court, administrative agency, regulatory agency, or other public organization to provide Your Information in accordance with laws and regulations
5. In cases where the Group has determined it necessary to provide information in order to resolve disputes with third parties or to protect the rights or interests of users of the Service or third parties, etc.
6. In cases where information is provided to third parties entrusted by the Group to carry out research, analysis, etc., in order to research and analyze the usage status of the Service, etc.
7. In cases where information is provided to third parties in order to distribute or display advertisements of the Group or a third party
8. In cases where, provided that your consent has been obtained, the Group provides information to a third party necessary for you to use external services operated by said third party
9. In cases where the Group provides information to financial institutions related to your claims necessary for the purposes of financing or liquidating claims for the Group
10. In any other cases where the Group has determined it necessary to provide Your Information and obtain your consent

5. Entrustment of Handling of Your Information to Third Parties

The Group may entrust a subcontractor with the whole or part of its handling of Your Information within the extent necessary to achieve the purposes of use specified in “3. Purposes of Use of Your Information.” In this case, the Group will fully examine whether the subcontractor satisfies the contractor selection criteria set out by the Group with respect to the financial service and ensure that the subcontractor will properly manage Your Information in the execution of a contract.

6. Shared Use of Your Information

1. Information shared
   Your Information specified in “1. Obtained Information”
2. Scope of parties sharing Your Information
   The Group
3. Purposes of use of parties sharing Your Information
   In the achievement of the purposes of use specified in “3. Purposes of Use of Your Information”
4. Person responsible for controlling the shared use of information
   Merpay, Inc. For Merpay, Inc.’s address, representative, and other information, please refer to the following link: https://jp.merpay.com/about/