Tsunagaru Inc. ("we", "us", or "our") is a company that mainly expands influencer marketing in Japan and other countries. YORIMICHI ("our Service"), the service operated by Tsunagaru Inc., provides contents on Japan and coordinates PR projects in Japan. This Privacy Policy applies to our treatment of personal information or personal data (collectively, "personal information" or "personal data") in connection with our Services. Individual and corporate users ("users," "you," "your," "yours") may provide us with user's personal data upon accessing our Service. This Privacy Policy informs you of our privacy policies regarding information collection, scope of use, way of sharing, and disclosure of personal data, as well as user's choices of data treatment.

Scope of policy

This Privacy Policy informs you of how we or our affiliated companies collect and use user's personal data in connection with providing our Services. This policy applies to all of the users who use websites, apps or other services in relation with the Services. This Privacy Policy applies especially to the following.

-Influencers: users who register with our Services to collect information, join projects that clients offer or otherwise use our Services.

-Clients: users who register with our Services to offer projects to influencers, to search information about influencers or otherwise use our Services.

This Privacy policy also applies to both users who give us personal data and users who view received information. This Privacy Policy complies with Japanese applicable law and the General Data Protection Regulation ("GDPR") applied in the European Economic Area ("EEA").

Data administrator

The data administrator set forth as the following treats personal information and collects personal information with affiliated companies.

Tsunagaru Inc.
Unicom Ningyocho Bld. 9F, 1-6-10, Nihombashi Ningyocho, Chuo-ku, Tokyo, Japan

Please contact our data protection division about treating data questions, comments and complaints.

Tsunagaru Inc., our affiliated companies, or their agent(s) may collect:

1. User's data

Including:

-user profile:
We collect user's data when users register or update user's account information. We will collect user's name, email address,phone number, login ID and password, payment information, bank information (related to payment information), passport number or identification number issued by government entities (if needed by laws), date of birth and photos or signature. We also collect activated user's data set on their account.

-user's contents:
We collect data users sent or provide when users contact a support center; users make a statement to other users and contact us for other reasons.

2. Data input when you use our services

Including:

-Location information
Depending on our services users access, settings of the equipment and permission of online settings, we may collect exact or approximate location information by GPS, IP address and Wi-Fi.
If you are an Influencer, we collect location information when you use our services as foreground on user's equipment (when website is launched and displayed on user's screen).
You can use our services without permitting us to collect user's location information. This may cause you access limited service.
For example, you need to input user's location by hand if user's setting doesn’t allow us to collect user's location information.

-Transaction information
We collect detailed information when you access our services and deal with transactions. This includes types of services you ask or provide, transaction detail, the date of the transaction and so on.

-Usage information
We collect information of users access and operation histories.
This includes date and time, place of access, website page view, system crash and other activities, browser type, as well as website or service users access before accessing to our service. We may collect such information from Cookies, pixel tag and similar tracking technologies.

-Device information
We may collect device information users use to access our service.
This includes hardware model, IP address, OS and its version, software, file and its version, selected language, devise identification data, advertisement identification data, serial number, devise operation information and mobile network information.

-Communication data
Users can access to our company by our Service, websites and the other services. To provide these service we collect phone number, SNS information and text message information (including location and date). We may use the information for customer support (including resolution of conflict among users), and/or to make sure safe and secure and to improve and analyze our service.

3. Information from the other source

Including:

-Feedback from users such as evaluation and complaint

-Users who provide their information regarding introduction program

-Users who access our service as a substitute

-Users or third parties who provide statement or conflict information

-Our business partners users access when users create their account or access our services, which includes payment service provider, social media service, apps or website with using our company’s API and apps or website we use user's API.

-Financial service provider

-Official information sources

-Marketing service provider.

We can combine user's information and our information from the above resources.

We use the collected data to:

1. Provide service and contents

We use the collected personal data to provide, personalize, maintain and improve our services, including:

-To create and update users account information

-To identify users

-To arrange payment for various services

-To perform in-house work for providing our service such as trouble shooting for software bugs and technical issues, analyzing data, conducting tests and surveys, monitoring and analyzing usage of service.

2. Safety and security

We use the collected data to maintain our services safety secure.
The purpose of the usage is as follows.

-We judge users before and/or after users access our Service.

-We use information of device, location information, profile, usage of service, and/or others to prevent, find and/or restrain fraud or unsafe action.

3. Customer support

Tsunagaru Inc. uses collected personal information to support users' use of our services when users contact our customer support service as following.

-We direct user's questions to the appropriate customer support person

-We investigate and address user's concerns

-We monitor and improve our customer support responses

4. Research and development

Tsunagaru Inc. may use personal data we collect for test, research, analysis and development of current or future services. We also use collected information to improve and enhance safety and security of our Services or other services, develop new functions, services and/or products, and/or finance solutions in connection with our Services or other services.

5. Communications from Tsunagaru Inc.

Tsunagaru Inc. may use collected personal information to communicate with you (including delivery of newsletters) about products or services, promotions, studies, surveys, news, updates or events.
We may also use personal information to promote and process contests, fulfill any related awards if needed, and serve users relevant advertisements and content about our services and those of our business partners. Users may receive these communications based on user's profile.

6. Legal proceedings and requirements

Tsunagaru Inc. may use collected personal information to investigate or address claims or disputes relating to usage of our Services or other services, otherwise as allowed by applicable law, or as requested by regulators, government entities, or official inquiries.

Cookies are small text files that are stored on user's browser or device, by websites or apps, or online media or advertisements.
Tsunagaru Inc. uses cookies and similar technologies for the following purposes such as:

-Authenticating users

-Recording users’ usage trend and settings histories

-Determining the popularity of content

-Delivering and measuring the effectiveness of advertising campaigns

-Analyzing site traffic and trends

-Understanding user's online behaviors and interests of our services

-Implementing audience measurement or analytics services others provide for us or having others track and report on the performance of those advertisements on our behalf across the Internet. These entities may use cookies, web beacons, SDKs(Software Development Kits), and/or other technologies to identify user's device when users visit our site and use our services, as well as when users visit other online sites and services.

Tsunagaru Inc. may share the information we collect under the following circumstances.

1. With other users

-If users are an influencer, we may share with clients user's profile such as user names, age and photos of user's profile, user's travel information such as travel schedule and travel location.

-If users are a client, we may share information the name of a contact person on client’s side, telephone number and email to influencers.

2. At user's request

This includes sharing user's information with:

-Tsunagaru Inc’s business partners. For example, if users requested a service through a partnership with or promotional offering made by a third party, we may share user's information with those third parties.

3. With the general public when users share content on SNS or social forums

We value hearing from our users like social media’s comments.
When users communicate with us through like those channels, user's communications may be viewable by the public.

4. With the owner of YORIMICHI accounts that users may use

If users use a profile associated with the other party, we may share user's travel information with the owner of that profile. This occurs, for example, if users are:

-An influencer using an account owned by a partner company

-A manager acting as a substitute

5. With YORIMICHI service providers and business partners

We may provide personal information to its vendors or consultants, marketing partners, research firms, and other service providers or the other business partners. This may include:

-Business partners we are in the tie-up

-Payment processors and brokers

-Marketing partners and marketing platform providers

-Data analytics providers

-Research partners, including those performing surveys or research projects in partnership with YORIMICHI or on YORIMICHI’s behalf.

-Vendors that assist us to enhance the safety and security of our services

-Consultants, lawyers, accountants and other professional service providers

6. For legal reasons and in the event of a dispute

Tsunagaru Inc. may share user's personal information if we believe it is required by applicable law or regulation, operating agreement, legal process or governmental request, or when the disclosure is appropriate due to safety or similar concerns.
This includes sharing user's information with law enforcement agencies, government agencies, or other third parties as necessary to enforce our terms of use, user agreements, or other policies, to protect our or the third parties’ rights and/or property.
This also includes sharing user's personal information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

7. With user's consent

Tsunagaru Inc. may share user's personal information other than as described in this Privacy Policy if we notify users and users consent to the sharing.

Tsunagaru Inc. may create statistic data (which herein means data from which an individual is not identifiable) based on the personal information provided or made available by users and non-personal information such as personal attribute, and will be entitled to use, without any limitation, such statistic data for any purpose related Tsunagaru Inc.'s or a third party's business or entitled to provide or disclose such statistic data to any third party.

Tsunagaru Inc. may create statistic data (which herein means data from which an individual is not identifiable) based on the personal information provided or made available by users and non-personal information such as personal attribute, and will be entitled to use, without any limitation, such statistic data for any purpose related Tsunagaru Inc.'s or a third party's business or entitled to provide or disclose such statistic data to any third party.

If a specific individual identifiable by the personal information (the "Principal") inquires of Tsunagaru Inc. as to whether or not the personal information concerning such Principal is being managed by Tsunagaru Inc., we shall promptly give reply as to such inquiry.

Tsunagaru Inc. shall in principle disclose the personal information without delay if requested by the Principal for disclosure, and shall in principle revise or modify the personal information of the Principal without delay if requested by the same person for revision or modification.

In addition, if Tsunagaru Inc. receives a request as to the right to data portability, we shall review the request and process the personal information as requested by the Principal to the extent required by law including GDPR.

The Principal may withdraw his/her consent made hereunder at　any time, provided, however, that the withdrawal will not affect the　legitimacy and lawfulness of our handling of the personal　information based on his/her consent given prior to the above　withdrawal.

Tsunagaru Inc. requires user profile information in order to provide our Services and retains such information for as long as the relevant user maintains user's YORIMICHI account or as long as Tsunagaru Inc. needs to retain such information in order to provide our Services or customer support, to enhance the user experience, to perform other operational purposes, to exercise its legal rights against the relevant user or perform its legal obligations for the relevant user, to create statistic data, or to provide information to the related user as to our Services or other services or products.

Once such information is no longer necessary in light of the above purposes, we take steps to prevent access for any purpose other than compliance with legal requirements or for purposes of safety, security and fraud prevention and detection.

A User may request deletion of such user's account at any time through below inquiry.

Following such request, we delete the information that it is not required to retain, as soon as practical. In certain circumstances, we may be unable to delete user's account, such as if there is an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete user's account as described above.

We may also retain certain information if necessarily for its legitimate business interests, such as fraud prevention or enhancing users' safety and security. For example, if we freeze a user's account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that user from opening a new YORIMICHI account in the future.

Tsunagaru Inc. may occasionally update this Privacy Policy. If we make significant changes, we will notify users of the changes, at least two (2) weeks prior to the changes, through the notification on our Services or through others means, such as email. To the extent not prohibited under applicable law, by using our Services after such notice, it shall be deemed that users consent to our updates to this Privacy Policy.

We encourage users to periodically review this policy for the latest information on our Privacy Policy.

This Privacy Policy is made in Japanese language and may be translated into other languages if necessary. However, only Japanese text shall have legal effect and this English text and other translations are intended solely for convenience of reference.

Tsunagaru Inc.

Unicom Ningyocho Bld. 9F, 1-6-10, Nihombashi Ningyocho,
Chuo-ku, Tokyo

+81-3-6380-1543
yorimichi@tsunagaru.co.jp