TownWiFi, Inc.(“the Company”) sets forth this Privacy Policy(“this policy”) with regard to the treatment of users’ information, including but not limited to personal information, during the performance of services provided by the Company(the “Services”), as follows;

1 User’s information to be Collected and Method of Collection
1. The term "personal information" as used in Policy shall mean information about a living individual which can identify the specific individual by name, date of birth or other description contained in such information (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual).
2. The Company shall not acquire personal information by a deception or other wrongful means.

2 Purpose of Use
1. When personal information, the Company shall specify the purpose of utilization of personal information (hereinafter referred to as "Purpose of Utilization") as much as possible.
2. The Company shall not handle personal information about a person, without obtaining the prior consent of the person, beyond the scope necessary for the achievement of the Purpose of Utilization specified, extent to cases;
- Cases where the provision of personal data is based on law or regulation
- Cases where the provision of personal data is necessary for the protection of the life, body or property of an individual and where it is difficult to obtain the person’s consent
- Cases where the provision of personal data is particularly necessary for improving public health or promoting the sound growth of children, and where it is difficult to obtain the consent of the person
- Cases where the provision of personal data is necessary for cooperating with a state organization, a local government, or an individual or business operator assigned to execute the affairs prescribed by law or regulation and where obtaining the consent of the person is likely to impede the execution of the affairs

3 Matters pertaining to the provision of personal information to a third party
The Company shall place the personal information acquired under proper control and shall not provide any personal information to any third party without the consent of the person concerned, except in the following cases;
- Cases where the provision of personal data is based on law or regulation
- Cases where the provision of personal data is necessary for the protection of the life, body or property of an individual and where it is difficult to obtain the person’s consent
- Cases where the provision of personal data is particularly necessary for improving public health or promoting the sound growth of children, and where it is difficult to obtain the consent of the person
- Cases where the provision of personal data is necessary for cooperating with a state organization, a local government, or an individual or business operator assigned to execute the affairs prescribed by law or regulation and where obtaining the consent of the person is likely to impede the execution of the affairs.

4. Joint Use
Cases in which personal data is used jointly between the Company Group and in which this fact, the items of the personal data used jointly, the scope of the joint users, the purpose for which the personal data is used by them, and the name of the individual or business operator responsible for the management of the personal data is, in advance, notified to the person or put in a readily accessible condition for the person.

5. Supervision of Trustees
When the Company entrusts an individual or a business operator with the handling of personal date in whole or in part, it shall exercise necessary and appropriate supervision over the trustee to ensure the security control of the entrusted personal data.

6 Compliance with laws, regulations and norms
The Company will comply with laws and regulations, guidelines set up by the national government and other norms pertaining to the handling of personal information, and will harmonize its privacy management rules with these laws, regulations, guidelines and other norms.

7. Implementation of security controls
While no Website can guarantee 100% security, the Company has implemented appropriate administrative, technical, and physical security procedures to help protect the personal information the Users provide to us. To ensure the accuracy and security of personal information, the Company controls access to, and implements restrictions on the taking out of, personal information from the Company’s premises. The Company has adopted measures to prevent unauthorized access to personal information, using reasonable measures commensurate with the presumed risks in an effort to prevent any personal information from being leaked, lost or damaged. The Company will regularly review and adjust these security measures.

8 Disclosure of personal information and response to complaints and inquiries
If a user, in accordance with the procedures announced by the Company and in connection with the user’s own personal information, makes a request for the disclosure, correction, addition, deletion, discontinuation of use or provision of the information, or makes a complaint or inquiry , the Company will carry out proper user identification and respond promptly to the matter.

9 Procedures to meet requests for notice of the purpose of use, for disclosure, correction, addition, deletion and discontinuation of use, and for erasure or discontinuation of provision of personal information subject to disclosure (hereinafter “Certain Requests”)
(1) Address for filing Certain Requests
To file Certain Requests, please fill in the application form designated by the Company with the necessary information and send it by mail to:
Takeihro Ogita
President and Representative Director
Town WiFi
Postal address: 2-7-16, Toranomon, Minato-ku, Tokyo, Japan
(2) Documents and forms to be submitted for filing Certain Requests
Please supply the documents specified in A and B below.
A. An application form for Certain Requests regarding personal information (please request the application form by an e-mail to info@wifishare.jp) Print out the form and fill in the required information.
B. A document for personal identification (such as a photocopy of the applicant’s driving license, passport, student identification card and health insurance certificate)
(Filing Certain Requests by proxy)
When filing Certain Requests by proxy, please enclose the documents specified below in addition to those specified in A and B above. (Filing with a letter of proxy)
i) A copy of the letter of proxy (please request the application form by an e-mail to info@wifishare.jp)
This copy must bear the signature and registered seal of the person associated with the personal information.
ii) A copy of the certificate of seal registration
iii) A document for personal identification of the proxy (such as a photocopy of the proxy’s driving license, passport and health insurance certificate)
(Filing by legal representative)
i) A document certifying that the legal representative has the authority of statutory representation (such as an abstract of the family register)
ii) A personal identification document of the legal representative (such as a photocopy of his or her driving license, passport and health insurance certificate)
(3) Fee concerning Certain Requests
No fee is required for a request for notification of the purpose of use pursuant to paragraph (2) of Article 24 of the Act or a request for disclosure under paragraph (1) of Article 25 of the Act.
(4) Method of responding to Certain Requests
The Company will respond in writing to the applicant’s address as specified on the application form.
(5) Purpose of utilization of personal information acquired from Certain Requests
The Company will use personal information acquired through requests for investigation for the application process, personal identification, response to applications and other purposes to the extent necessary.
(6) Information on job applicants:
Screening for recruitment by the Company and its subsidiaries, communications with applicants and entry procedures for successful applicants

10 Cookies
The Company may use cookies and similar others in order to provide Users of the Services with enhanced services. Users may reject or restrict cookies by configuring their apps, but this may impose constraints on use of the Services. Users may in some cases be unable to control the use of web beacons.

11 Inquiries
For any complaint or inquiry regarding personal information received by the Company, please use the following e-mail address or postal address.

Takehiro Ogita
President and Representative Director
TownWiFi
Postal address: 2-7-16, Toranomon, Minato-ku, Tokyo, Japan
Email: info@wifishare.jp


12. Policy Modification
The Company shall be entitled to at any time modify the Policy in its own discretion. The Company shall notify in advance the User of any intended modification by the Company of the Services. By accessing or using the Services in any manner, you agree to be bound by the Agreement.

[Prescribed on 9/1/2015]
[Revised on 17/10/2016]

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