Regarding handling
of personal information

Ernie Co., Ltd. (hereinafter referred to as the “Company”) stipulates the following privacy policy (hereinafter referred to as the “Policy”) regarding the handling of user information including personal information for the services provided by the Company (hereinafter referred to as the “Service”).

This refers to “personal information” referred to in the Personal Information Protection Law; it is information about a specific living individual and refers to descriptors such as the individual’s name, sex, date of birth, address, telephone number, email address, password, etc., that can be used to identify a specific individual (including information that can be easily compared with other information and thereby used to identify a specific individual).

This refers to the information collected by the Company based on the Policy, including information related to user identification, the history of users' actions on the communication service, and other information generated or accumulated in relation to the user or the user’s device.

This refers to an individual or corporation stipulated in the Batoner Terms of Use (Article 1, Paragraph 3), and is a party who has signed a contract regarding the provision of the Service by the Company, and who receives its provision from the Company.

The user information the Company collects for the Service, depending on the collection method, will be as follows.

The information provided by the user in order to use the Service or through the use of the Service is as follows.

• ・The information provided when the user registers for the Service
• ・Text, audio, etc., generated when using the Service
• ・Analysis of the above text, audio, etc.
• ・Information related to the user's profile including name, date of birth, gender, occupation, etc.
• ・Information related to ways to contact the user including email address, telephone number, address
• ・Information related to payment including credit card information, bank account information, electronic money information, etc.
• ・Still-image information including pictures of the user
• ・Information entered or sent by the user through an input form or other method specified by the Company

If the user permits linking with other services, such as social networking services, when using the Service, the following information will be collected from the external services based on the content whose sharing was consented to when this permission was given.

• ・The ID used by the user for the external service
• ・Other information that the user has consented to disclose to linked services, based on their privacy settings on the external service

The Company may collect information about your access to the Service and how you use it. This includes the following information.

• ・Referrer
• ・IP address
• ・Information related to the server access log
• ・Cookie, ADID, IDFA and other identifiers

Personal information and user information collected by the Company in the Service will be used only for the following purposes and will not be used for any other purpose.

• (1) To provide, maintain and protect the Service, including registration acceptance, identity verification, user authentication, documenting of user settings, calculation of usage fees to be paid, etc.
• (2) To improve and enhance the Service, and to develop similar new services and supplementary services
• (3) For security purposes, or other maintenance and inspection of the service
• (4) To measure user traffic and behavior
• (5) To respond to inquiries regarding the Service
• (6) To respond to acts that violate the Company’s terms, policies, etc. (hereinafter referred to as the “Terms and Regulations”)
• (7) To send notifications of changes to the Terms and Regulations, etc.

The Company will not provide personal information within user information to a third party (including those outside Japan) without the prior consent of the user. However, this does not apply in the following situations, when the information is provided to the third party out of necessity as follows.

• (1) When the Company outsources all or part of the handling of personal information to the extent necessary to achieve the purpose of use
• (2) When personal information is provided during business succession due to merger or other reasons
• (3) In cases where it is necessary to cooperate with a national institution, local public entity or an individual entrusted to carry out work stipulated by laws and regulations, and when obtaining the user's consent may pose a risk of hindrance to the execution of this work
• (4) Other situations permitted by the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Law”) as well as by other laws

The Company will, when jointly using the personal information of the user as follows, notify the user of the information of (1) to (4) in advance through a method designated by the Company.

• (1) The items of personal information used jointly
• (2) The scope of parties using it jointly
• (3) The purposes of use of the parties using it jointly
• (4) The name or title of the person who is responsible for the management of personal information

• 1.When the user requests the release of their personal information based on the provisions of the Personal Information Protection Law, the Company will disclose it to the user without delay after confirming that the request comes from the user themselves. (If the relevant personal information does not exist, we will notify the user of that). However, this does not apply if the Company has no obligation to release the information under the Personal Information Protection Law or other laws.
• 2.Please note that a fee (¥1000 per transaction) will be charged for the release of personal information.

• 1.The user can, for the reason that the personal information held by the Company is not true, request the Company to correct, add to or delete (hereinafter referred to as “Corrections”) personal information, based on the provisions of the Personal Information Protection Law and through the procedure designated by the Company.
• 2.When the Company receives a request from the user as per the preceding paragraph, after confirming that the request comes from the user themselves, it will conduct the necessary investigation without delay; based on the result, it will make Corrections to the relevant personal information if necessary and notify the user of this.
• 3.If the Company decides, as a result of the investigation as per the preceding paragraph, that it will not make Corrections for reasonable reasons, it will notify the user to that effect.
• 4.The provisions of the preceding paragraph will not apply if the Company is not obligated to make Corrections under the Personal Information Protection Law and other laws.

• 1.The Company will, when requested by the user to suspend the use of or delete the user's personal information (hereinafter referred to as “Suspension of Use”) for the reason that it is being used beyond the scope of the purpose of use or has been obtained through improper means, conduct the necessary investigation without delay, and based on the result, perform the Suspension of Use of personal information and notify the user to that effect, based on the provisions of the Personal Information Protection Law. However, if large costs will be necessary for the Suspension of Use of personal information, or in other situations where the Suspension of Use will be difficult, and if alternative measures to protect the individual's rights and interests are available, the alternative measures shall be taken.
• 2.If the Company decides, as a result of the investigation as per the preceding paragraph, that it will not perform Corrections for reasonable reasons, it will notify the user to that effect.
• 3.The provisions of the preceding 2 paragraphs will not apply if the Company is not obligated to make Corrections under the Personal Information Protection Law and other laws.

• 1.The Company shall appropriately review the operational status regarding the handling of user information and shall strive for continuous improvement, and may change the Policy as necessary.
• 2.The Company shall be able to change or add to the contents of the Policy (hereinafter referred to as “Changes to the Policy”) in the following situations.
  • ①When the Changes to the Policy match the general interests of the user
  • ②When the Changes to the Policy do not violate the purpose of the contract and are reasonable in light of the necessity of the changes, the appropriateness of the contents after the changes, and other circumstances related to the changes.
• ３．If the Company changes the Policy as per the preceding paragraph, the Company shall notify the user by a method designated by the Company not later than seven days before the effective date of the change. After this notification of the relevant changes, if the user continues to use the Service or if the procedure for termination of use is not carried out within the period specified by the Company, it shall be deemed that the user agrees to the Changes to the Policy. However, in the case of changes that require the consent of the user by law, the Company shall obtain the user’s consent by a method designated by the Company.

For requests for release of personal information, etc., as well as complaints and consultations, please contact the Company’s support desk.

[Formulated 2020 August 18]