Global Produce Co.（hereinafter referred to as the “Company”）has established this Privacy Policy to ensure the proper handling of personal information as an organization in accordance with the "Personal Information Protection Act" of Japan.

• 1 Name, address, and name of representative of the Company

  Global Produce Co.
  13F Aoyama Oval bld. 5-52-2, Jingumae, Shibuya-ku, Tokyo, 150-0001, Japan
  Representative Director and President: Masaki Kouhata

• 2 Compliance with relevant laws, regulations, guidelines

  The Company shall handle personal information appropriately in compliance with the Personal Information Protection Act and other laws and regulations of Japan, as well as the guidelines of the Personal Information Protection Commission, and other guidelines.

• 3 Acquisition and Use of Personal Information

  1. (1) Personal information the Company obtains is as follows

     • Personal information such as names, date of birth, gender, occupations, and other profile information
     • Contact information such as e-mail addresses, telephone numbers, addresses
     • Still image data including the portraits of the customers
     • Information entered or transmitted by the customers through filling in forms or other methods determined by the Company
     • Referrers
     • IP addresses
     • Information on server access logs
     • Terminal identifiers, mobile device identifiers and cookies

  2. (2) When acquiring personal information, the Company shall publicly announce or notify the purpose of use of personal information (including public announcement through this privacy policy), and when the Company acquires personal information directly from the person concerned in a contract or other documents (including electromagnetic records), the Company shall clearly state the purpose of use of the personal information in advance, and acquire the information in a lawful and fair manner.

  3. (3) The Company shall use the personal information appropriately within the scope necessary to achieve the purpose of use of personal information.

• 4 Purpose of Use of Personal information

  The Company shall use personal information for the following purposes;

  1. (1) Personal information about the customers, clients and business partners (in case of corporate customers, corporate clients and corporate business partners, their officers and employees)

     [Purpose of use]

     • Identification and personal authentication of the customers
     • Providing information on in-house event productions that leads to company activation
     • Providing information related to the planning, drafting, organizing and operations of various events and seminars
     • Response to customer inquiries, consultations, complaints and supports, confirmations and record keepings
     • Improvements and enhancements of other services
     • Improvements and enhancements of the customer experience on the digital services of the Company (such as websites, mobile applications)
     • Providing advertisements and information on products, services, campaigns by means of letters, e-mails (*1 and *2)
     • Distribution of behavioral targeting advertisements (*1 and *2) using ad-serving companies such as Google and Yahoo!
     • Analysis of attribute information, behavioral histories obtained by the Company to understand the interests and preferences of the customers (*2)
     • To provide the products and services safely to the customers. To detect users who are violating the Terms of Use of the Company, notify the fact of violation and appropriative corrective actions to such users, and to investigate, detect, and prevent fraudulent activities such as fraud and unauthorized accesses that abuse the services, and to deal with these activities.
     • To contact, execute contracts, and conduct business negotiations as necessary in the course of business
     • To manage information on business partners

     (*1) The Company shall provide services, distribute advertisements by analyzing information obtained from the customers, such as website browsing histories and purchase histories.

     (*2) The Company may use information obtained from the third parties other than the Company, such as the interests, preferences and browsing histories of the customers, by linking such information to personal information that the Company already has obtained about the customers. In such cases, the Company shall obtain prior a consent from the customer and use the information within the scope of the purposes of use of the personal information listed above.

  2. (2) Personal information concerning shareholders (in case the shareholder is a corporation, their officers and employees)

     [Purpose of use]

     • Exercise of rights and performance of obligations under the Companies Act of Japan
     • Management of shareholders, including preparation of records in accordance with the relevant laws and regulations of Japan

  3. (3) Personal information of applicants for employment and recruiting activities

     [Purpose of use]

     • To contact and provide information to the applicants for recruitment and recruiting activities, and to use as necessary for other recruitment and recruiting activities.

  4. (4) Personal information concerning employees

     [Purpose of use]

     • Business communications to the employees
     • Payments of compensation (such as wages, bonuses, benefits) to the employees, for personnel and labor management, and provision of welfare
     • Health management for the employees

• 5 Provision of Personal information to Third Parties

  The Company shall not provide personal information entrusted to the Company to any third parties except in the following cases;

  • When the Company has obtained the prior consents of the customers.
  • When the Company outsources the business to the third parties within the scope necessary to achieve the purpose of use of the personal information
  • When the Company is required to provide the personal information to the third parties by laws or regulations of Japan
  • When it is necessary for the protection of human lives, human health, or properties of the Company or the third parties, and it is difficult to obtain the prior consents of the customers
  • When it is necessary for the improvement of social morals or to promote the sound growth of children and it is difficult to obtain the customer's consent.
  • When it is necessary to cooperate with the national or local governments in the executions of their legally mandated duties, and obtaining the consents of the customers may interfere with the executions of such duties

• 6 Availability of cookies and information collection modules

  1. (1) A "cookie" is a technology that records and manages information about users of our website on computers and application software. We use cookies to make our website more convenient for our customers.

  2. (2) The Service incorporates the following information collection modules. In line with this, the following information is provided to the information module providers (including those located outside of Japan) as follows;

     (1) Name of the information collection module

     Google Analytics

     (2) Information collection module provider

     Google, LLC

     (3) Items of user information to be provided

     Access counts, error logs, and the operation histories of the customers on the website of the Company (personally identifiable information shall not be included).

     (4) Purpose of use by the above providers

     To understand the status of the visits by the customers to the website of the Company.

     (5) URL of the privacy policy of the above provider

     http://www.google.com/intl/ja/policies/privacy/

• 7 Matters Concerning Security Control Measures

  The Company shall take the following security control measures necessary for the management of the personal information, including the preventions of the leakages, losses, damages or destructions. The Company shall also exercise necessary and appropriate supervisions over the employees and the commissioning parties (including sub-commissioning parties) of the Company who handle the personal information.

  1. (1) Establishment of Personal information Protection Guidelines

     • In order to ensure the proper handling of the personal information, the Company has established this guidelines (Personal information Protection Guidelines), including "compliance with related laws, regulations, guidelines" and "contact points for handling questions and complaints”.

  2. (2) Establishment of Personal information Handling Regulations Personal information

     • The Company has established "Personal information Handling Regulations" for each stage of the acquisition, use, storage, provision, deletion/disposal of the personal information, including handling methods, responsible persons/persons in charge and their duties.

  3. (3) Organizational Safety Control Measures

     • In addition to appointing a person responsible for the handling of the personal information, the Company clarifies the employees who handle personal information and the scope of the personal information handled by such employees, and has established a system for reporting to the person responsible for handling personal information if a fact of the violation of the Personal Information Protection Act of Japan or Personal Data Handling Regulations is detected or any indication of such a violation is detected.
     • In addition, the Company conducts periodic self-inspections of the status of the personal information handlings, as well as audits by other departments and outside parties.

  4. (4) Personnel Safety Control Measures

     • The company provides the regular trainings to the employees of the Company on points to keep in mind regarding the handling of the personal information.
     • The confidentiality of the personal information is stipulated in the employment regulations of the Company.

  5. (5) Physical security control measures

     • In the area where the personal information is handled, access control for the employees and restrictions on equipment that they may bring in are in place, and measures are taken to prevent unauthorized access to the personal information.
     • In addition, measures are taken to prevent thefts or losses of the equipment, electronic media, and documents that handle the personal information, and to prevent the personal information from being easily discovered when such equipment, electronic media are carried, including during transportation within the business sites.

  6. (6) Technical safety control measures

     • Access control is implemented to limit the scope of the persons in charge and the personal database handled.
     • A mechanism is in place to protect the information systems that handle the personal information from unauthorized access from outside the Company and the unauthorized software.

• 8 Handling of Personal information in Foreign Countries

  The Company may provide the personal information entrusted to the Company to the third parties located in foreign countries with the prior consents of the customers. In such cases, the personal information shall be handled appropriately in accordance with the Personal Information Protection Act of Japan and the guidelines of the Personal Information Protection Commission regarding the said Act. However, the Company may not take voluntary measures that are not legally obligated to do so.

• 9 Requests for Disclosure of Personal information

  When the Company receives a request for reference, correction, suspension of use, deletion of personal information, the Company shall promptly respond to the request after confirming the identity of the individual in accordance with the prescribed procedures. If you have any questions about this privacy policy or wish to exercise your rights, please contact the Company with the contact information in Article 10 of this privacy policy below.

• 10 Contact for Inquiries

  If you have any questions or complaints regarding the handling of the personal information, please contact the following;

  1. Address

  13F Aoyama Oval bld. 5-52-2, Jingumae, Shibuya-ku, Tokyo, 150-0001, Japan
  Global Produce Co.
  Personal Information Protection Consultation Desk, General Affairs Department

  2. Phone number

  +81-3-5738-2117

  3. Hours

  Mondays to Fridays (excluding national holidays of Japan and New Year holidays of Japan)
  9:30 a.m. - 12:00 p.m. and 1:00 p.m. - 4:30 p.m.