Privacy Policy

The Japanese text is the original and the English text is for reference purposes.

DouDouDoujin Privacy Policy
DouDouDoujin Inc. (the “Company”) hereby establishes this Privacy Policy (the “Policy”) as follows regarding the handling of information of persons who use the services provided by the Company (the “Service”) (the “Users”).

Article 1. Scope
1.	This Policy applies to the acquisition, use, management, provision, and all other handling of User Information by the Company.
2.	Matters not set forth in this Policy shall be governed by the Terms of Service and any other individual terms separately established by the Company.
3.	In the event of any inconsistency between this Policy and the Terms of Service or any other individual terms, this Policy shall prevail with respect to the handling of User Information.

Article 2. Definitions
1.	In this Policy, the terms “Personal Information,” “Personal Data,” “Retained Personal Data,” “Anonymously Processed Information,” “Pseudonymously Processed Information,” and any other terms under the Act on the Protection of Personal Information shall have the meanings assigned to them under such Act and other applicable laws and regulations.
2.	In this Policy, “User Information” means Personal Information, Personally Referable Information, and any other information relating to a User that is acquired by the Company in connection with the use of the Service.

Article 3. Language
The Japanese version of this Policy and any individual conditions shall be the controlling text, and in the event of any inconsistency or conflict between the Japanese version and any version in another language, the Japanese version shall prevail.

Article 4. Methods of Collection
1.	The Company shall collect User Information by lawful and fair means and shall not collect it through deception or any other wrongful means.
2.	The Company may collect User Information through direct provision by Users in the course of using the Service, through automatic collection of information regarding use of the Service, and through lawful provision by service providers entrusted by the Company or other third parties having legitimate authority.

Article 5. Information Collected and Purposes of Use
The Company shall collect and use the User Information set forth in the following items for the purposes specified in each item.
1.	Information relating to account creation and login
Information collected: email address, authentication information, and other information necessary for account management
Purposes of use:
    (1) for account creation, identity verification, login authentication, and account management relating to the Service;
    (2) for the provision, maintenance, protection, and improvement of the Service;
    (3) for the prevention, investigation, and response to unauthorized access, unauthorized use, violations of the Terms of Service, and other improper conduct.
2.	Profile and other information voluntarily entered by Users
Information collected: nickname, display name, profile information, and any other information entered or displayed by a User on the Service
Purposes of use:
    (1) for display on the Service and communication among Users;
    (2) for the provision, improvement, and support of the Service.
3.	Information relating to inquiries
Information collected: email address, user account, inquiry details, and information included in communications between the User and the Company
Purposes of use:
    (1) for responding to inquiries and verifying identity;
    (2) for improving the quality of inquiry handling and maintaining records;
    (3) for responding to malfunctions, disputes, or troubles relating to the Service.
4.	Information automatically collected through use of the Service
Information collected: IP address, browser information, device information, OS information, date and time of access, browsing history, operation history, error logs, crash information, and other information relating to use of the Service
Purposes of use:
    (1) for the provision, maintenance, operation, and improvement of the Service;
    (2) for the development of new functions or new services;
    (3) for the prevention of and response to unauthorized use, spam, nuisance acts, and other conduct in violation of the Terms of Service;
    (4) for incident response, maintenance, security, and quality improvement;
    (5) for analysis of usage status and preparation of statistical data; provided, however, that such statistical data shall be used only in a form that does not identify any individual.
5.	Information collected through Cookies, etc.
Information collected: Cookies, device identification-related information, browsing history, usage history, settings information, and other related information
Purposes of use:
    (1) for maintaining login status, saving settings, and otherwise improving convenience of the Service;
    (2) for understanding, analyzing, and improving usage of the Service;
    (3) for preventing unauthorized use and maintaining security.
6.	Information relating to surveys, etc.
Information collected: survey responses, application information, and other information voluntarily provided by Users
Purposes of use:
    (1) for conducting and administering surveys, etc.;
    (2) for improving the Service, developing new services, and improving user satisfaction.

Article 6. Restriction on Purpose of Use
1.	The Company shall use User Information only within the scope necessary to achieve the purposes of use set forth in the preceding Article.
2.	The Company shall not use Personal Information beyond the scope necessary to achieve the stated purposes of use without the prior consent of the individual concerned, except in any of the following cases:
    (1) where required by law;
    (2) where necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of the individual concerned;
    (3) where particularly necessary for the improvement of public health or the sound development of children and it is difficult to obtain the consent of the individual concerned;
    (4) where it is necessary to cooperate with a national government agency, a local government, or a person entrusted by either in executing affairs prescribed by law, and obtaining the consent of the individual concerned is likely to impede the execution of such affairs;
    (5) where otherwise permitted by law.

Article 7. Provision to Third Parties
1.	The Company shall not provide Personal Data to any third party without the prior consent of the individual concerned, except in any of the following cases:
    (1) where required by law;
    (2) where necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of the individual concerned;
    (3) where particularly necessary for the improvement of public health or the sound development of children and it is difficult to obtain the consent of the individual concerned;
    (4) where it is necessary to cooperate with a national government agency, a local government, or a person entrusted by either in executing affairs prescribed by law, and obtaining the consent of the individual concerned is likely to impede the execution of such affairs;
    (5) where otherwise permitted by law.
2.	Notwithstanding the preceding paragraph, where the Company receives a lawful request for disclosure from a court, investigative authority, administrative authority, or other public authority having legal authority to make such inquiry, or where the Company reasonably determines that disclosure is necessary to protect the rights or interests of a User or a third party and such disclosure is permitted by applicable laws and regulations, the Company may provide information to the extent necessary in accordance with applicable laws and regulations.

Article 8. Outsourcing, Business Succession, and Statistical Information, etc.
1.	The Company may outsource all or part of the operations necessary for the provision, operation, maintenance, analysis, or inquiry handling of the Service to a third party. In such case, the Company shall exercise necessary and appropriate supervision over such contractor.
2.	In the case described in the preceding paragraph, the Company may provide Personal Data to the contractor to the extent necessary for the performance of the outsourced operations.
3.	The Company may provide User Information to a successor in connection with a merger, company split, business transfer, or other business succession.
4.	The Company may create, use, or provide to third parties statistical information or Anonymously Processed Information in a form that does not identify any individual, in accordance with applicable laws and regulations.
5.	Where the Company creates or uses Pseudonymously Processed Information, the Company shall handle such information appropriately in accordance with applicable laws and regulations.
6.	When creating or providing Anonymously Processed Information to a third party, the Company shall take appropriate measures, including proper processing, security control measures, and publication of required matters, in accordance with standards prescribed by law.

Article 9. Use of Foreign Service Providers
1.	The Company may use services provided by business operators located outside Japan to the extent necessary for the provision of the Service, analysis, form operation, and other necessary purposes.
2.	Where the Company entrusts the handling of Personal Data to a foreign business operator or provides Personal Data to such operator, the Company shall take necessary measures in accordance with applicable laws and regulations.
3.	Where required by law, the Company shall provide the individual concerned with the information required by law in relation to such provision or outsourcing.

Article 10. Security Control Measures
1.	The Company shall take necessary and appropriate security control measures to prevent or correct leakage, loss, damage, unauthorized access, unauthorized use, and other risks relating to User Information.
2.	The Company shall endeavor to implement organizational, human, physical, and technical security control measures, including access control, authentication management, encryption of communications, log management, supervision of contractors, and other necessary measures.

Article 11. Disclosure, Correction, Suspension of Use, etc.
1.	A User may request that the Company, in accordance with applicable laws and regulations, disclose, correct, add to, delete, suspend use of, erase, or cease third-party provision of the User’s Retained Personal Data held by the Company.
2.	In making a request under the preceding paragraph, the User shall follow the procedures separately prescribed by the Company and submit information or documents necessary for identity verification.
3.	Upon receiving a request under the preceding two paragraphs, the Company shall respond within a reasonable period and scope in accordance with applicable laws and regulations, and shall notify the individual concerned of the result.
4.	The Company may decline all or part of a request in accordance with applicable laws and regulations if any of the following applies:
    (1) where the identity of the individual cannot be verified;
    (2) where the request is made by an agent whose authority cannot be verified;
    (3) where responding is likely to harm the life, body, property, or other rights or interests of the individual or a third party;
    (4) where responding is likely to seriously impede the proper conduct of the Company’s business;
    (5) where responding would violate another law or regulation;
    (6) where the Company is otherwise not obligated to respond under applicable laws and regulations.
5.	Details of the procedures for requests for disclosure, methods of identity verification, and other matters shall be as separately prescribed by the Company.

Article 12. Information Necessary for Account Maintenance
If a User does not consent to provide, or fails to provide, the email address, authentication information, or any other information necessary for the provision of the Service and maintenance of the User’s account, the Company may be unable to provide all or part of the Service.

Article 13. Handling After Account Deletion
1.	If a User deletes the User’s account for the Service, the Company shall appropriately process the User Information of such User in accordance with applicable laws and regulations, the Terms of Service, this Policy, and other rules separately prescribed by the Company.
2.	Even after deletion of an account, the Company may retain User Information for a certain period to the extent reasonably necessary for legal compliance, log retention, dispute response, prevention of unauthorized use, accounting treatment, and other operational purposes of the Service.

Article 14. Use of Cookies, etc.
1.	When a User uses the Service or views pages of the Service, the Company may use Cookies and other similar technologies to obtain browsing history, usage status, device information, and other information.
2.	Information obtained through Cookies, etc. may, under applicable laws and regulations, be treated as Personally Referable Information or Personal Information.
3.	The Company shall use Cookies, etc. for maintaining login status, saving settings, analyzing usage status, analyzing malfunctions, maintaining security, improving the Service, and other purposes set forth in Article 5.
4.	The Company may use Google Analytics in order to understand and analyze usage of the Service. The handling of information in Google Analytics shall be governed by Google’s terms of use and privacy policy.
5.	The Company may use Google Forms to provide surveys and other input forms. The handling of information in Google Forms shall be governed by Google’s terms of use and privacy policy.
6.	Users may restrict or disable the use of Cookies, etc. by changing browser settings or by any other method designated by the relevant service provider; provided, however, that doing so may make certain functions of the Service unavailable.

Article 15. Disclaimer
1.	With respect to the acquisition of Personal Information by a third party in any of the following cases, the Company shall not be liable except where the Company has acted intentionally or with gross negligence:
    (1) where the User has disclosed Personal Information to a third party by using functions of the Service or by any other means;
    (2) where the individual has become identifiable as a result of information entered by the User on the Service or due to other circumstances;
    (3) where information has been viewed, stolen, or leaked in an environment not compatible with appropriate encrypted communication such as TLS, or in a communication path outside the control of the Company;
    (4) where damage has occurred due to unauthorized access or any other cause beyond the Company’s control, despite the Company having taken reasonable security control measures.

Article 16. Amendments to this Policy
1.	The Company may amend this Policy due to changes in laws and regulations, changes to the content of the Service, operational necessity, or any other reason.
2.	If the Company amends this Policy, the Company shall notify Users of the amended content and the effective date by posting such information on the Service or by any other method deemed appropriate by the Company.
3.	The amended Policy shall take effect on the effective date notified pursuant to the preceding paragraph.

Article 17. Contact Information
1.	Inquiries regarding this Policy, the handling of User Information, disclosure of Retained Personal Data, complaints, consultations, and any other matters relating to Personal Information shall be accepted through the inquiry form designated by the Company or any other contact point separately designated by the Company.
2.	The Company shall respond within a reasonable scope except where prohibited by law or where doing so would interfere with business operations.

Article 18. Business Operator Handling Personal Information
DouDouDoujin Inc.
Station Ai, 1-2 Tsurumai 1-chome, Showa-ku, Nagoya, Aichi 466-0064, Japan

Article 19. Person Responsible for Handling Personal Information
Shoichiro Mizutani, Representative Director
Supplementary Provision
This Policy shall come into effect on October 31, 2024.