Privacy Policy

Xtra Inc. (hereinafter called the “Company”), in order to protect the personal information of the user who processes Conyac (hereinafter called the “Service”) provided by the Company, shall observe the Act on the Protection of Personal Information and other related laws, regulations and guidelines and shall handle the personal information as stated below.
Company name, address and representative name
Xtra Inc.
3-7-21 Tensho Kanda-Ekimae Bld. 204, Kanda-Kajicho, Chiyoda, Tokyo 101-0045 Japan
CEO Hirokazu Ikezawa
Article 1 (Definition of Personal Information)
In this policy, personal information shall mean any information relating to an identified or identifiable natural person.
Article 2 (Acquisition and Process of Personal Information in the Service)
  1. The Company shall acquire your personal information with your consent to provide services and to achieve the purpose of processing as specified below. When you access the websites using the Service, the Company may automatically obtain the information such as your website and advertisement browsing history and status and using environment (including information on the operating system and browser) from your browser using the IP address, Cookies and web beacons.
  2. In principle, the Company does not process your personal information beyond the purpose of data processing (data processing means any process of personal data wholly or partly by automated means as well as to non-automated processing. It includes, for instance, acquiring, recording, editing, structuring, storing, modifying, changing, recovering, referring, processing, disclosing after transferring, publishing, making disclosable, sorting, combining, restricting, deleting and destroying.) listed in the table shown below.
    However,
    • (1) if the Company separately obtained your consent,
    • (2) if the Company judges that processing your personal information is necessary to execute an agreement between the Company and you,
    • (3) if processing of data is required for the Company to comply with the Company’s legal obligations,
    • (4) if processing of data is required to protect your and other natural person’s important interest,
    • (5) if the processing of personal information is required for public interest (including medical purposes such as public health, social protection and health care services) or to conduct the operation to exercise authority officially given to the Company, or
    • (6) if processing of data is required for legitimate interests pursued by the Company or third parties,
    the Company may process the personal information beyond the following purpose of processing:
Comparison table for information to be acquired and purpose of processing
Purpose of Processing Summary Purpose of Processing Details Information to be Processed
Provision, maintenance and improvement of the Service
  • Your identity verification and prevention of improper processing in the Service
  • Seamless provision, maintenance and improvement of the Service
  • Information required for provision of payment functions in the Service
  • Sales management
  • Customization of the Service information and advertisement distribution based on your age, occupation, gender, hobby, etc.
  • Improvement of ease of use, extension of functions and quality improvement in the Service
  • Temporary backup in the operation of the Service
  • Conducting a survey on processing status and environment and creating statistics to improve services on the website
  • Protecting the network and security related to the Service and protecting the Company and others
  • E-mail address
  • Name, professional affiliation and other information required for provision of the Service
  • Information required to make payment to you in the Service (such as payment bank account and PayPal account information)
  • Information on log and behavioral history
  • Your nickname and profile image used on external services and member information on external services
Notifying and contacting you
  • Notification regarding the Service, response to your inquiries, etc.
  • Notification or provision of new services related to the Service
  • Handling of any violation of the terms of processing of the Service and preventing such violations
  • Notification regarding any changes made to the terms of processing of the Service and this policy, termination and suspension of the Service and other important matters concerning the Service such as contract termination
  • Handling conflicts, lawsuits, etc.
  • Contact information such as E-mail address
  • Name, professional affiliation and other information required for provision of the Service
Entrustment of handling personal information Third parties which received the information listed on the right may process such information for the following purposes:
  • Analysis for optimization of ad delivery along with ad-network and ad-platform of DPS vendors and the like, and provision of other affiliated services
  • Support of the Company’s marketing activities
  • Name, professional affiliation and other information required for provision of the Service
  • Information obtained using Cookies (session ID, E-mail address, name and information connected to your account such as the plan under contract)
    *Only session ID is stored by the Company
  • Device information
  • Information on log and behavioral history
Creating statistical data
  • Seamless provision, maintenance and improvement of the Service
  • Customization of the Service information and advertisement distribution based on your age, occupation, gender, hobby, etc.
  • Improvement of ease of use, extension of functions and quality improvement of the Service
  • All or a part of the above mentioned information
  • E-mail address
  • Name, professional affiliation and other information required for provision of the Service
  • Information required to make payment to you in the Service (such as payment bank account and PayPal account information)
  • Information on log and behavioral history
Article 3 (Change of Purpose of Processing)
The Company may modify the purpose of processing in the preceding article within the reasonably acceptable range where it has relevance to the purpose of processing prior to change, and when such change is made, the Company shall notify you of or announce such change with this policy according to the procedure specified separately by the Company and shall obtain your consent again.
Article 4 (Acquisition of Personal Information)
  1. The Company shall lawfully acquire your personal information with your consent, without using false and other illegal means.
  2. If the Company acquires your personal information in other means than your use of the Service, the Company shall notify you of or announce its purpose of processing your personal information in advance according to the procedure specified separately by the Company and shall obtain your consent to acquire your personal information.
Article 5 (Security Management)
  1. In order to prevent user’s information leakage, loss or damage and protect other users’ information, the Company has taken necessary and appropriate measures for user information security management such as restricting access to the personal information file, minimizing the number of access right holders, recording access logs and installing security software for preventing illegal access of outsiders. In the case of entrustment to a third party of handling all or a part of personal information, the Company shall enter into a Non-Disclosure Agreement, etc. based on this policy with such third party and shall appropriately supervise such third party to keep the personal information secure.
Article 6 (Handling of E-mail Address)
  1. Concerning your E-mail address obtained through processing the Service, in order to prevent it from being lost, stolen, destroyed, manipulated, leaked or illegally accessed externally, the Company shall comply with the laws, regulations and other rules related to personal information and take all possible measures for its protection.
  2. In order to protect your E-mail address, the Company allows only a limited number of right holders among the employees to access your E-mail address.
  3. Notifications concerning matters which the Company must let you know, such as “Important Notice” will be sent to all users.
Article 7 (Processing Using Cookies and Other Technologies)
  1. Some pages in the website for the Service utilize a technology called “Cookie” and similar technologies.
  2. Cookie is identification data for an individual user and is transmitted from the server (HTTP) used for the website operation to the user’s browser. Using Cookies makes recording the user information in his/her computer hard disk and the like possible.
  3. In the website, Cookies are used to collect information such as user’s personal page login information and the overall trends and patterns on the website. The website uses the collected information to analyze the access trend and to provide better services.
  4. Cookies can identify an individual browser but cannot identify an individual user.
  5. Also, depending on the browser, the Cookie function can be disabled by changing the settings; however, as a result, all or part of the services on the webpage may become unavailable.
Article 8 (External Services/ Links)
The Company may provide the Service in cooperation with external services (hereinafter called “External Services”) such as LINE and Facebook. When you wish to use the Service along with External Services, the Company may provide your personal information to such External Services providers.
Article 9 (Disclosure and Sharing of Personal Information)
  1. Concerning personal information among user information, the Company may disclose or share the personal information with a third party in the case where the disclosure is authorized by the Act on the Protection of Personal Information and other laws and regulations, as well as in any of the following cases upon obtaining your consent:
    • (1) When all or part of the personal information is entrusted to a third party within a range required for attaining the Company’s purpose of service
    • (2) When the personal information of the Service users is escrowed to payment system companies, credit card companies and banks for charging the users the usage fee
    • (3) When the personal information is provided to the other party or the third party following business mergers or other events
    • (4) When the Company is officially requested to disclose the personal information under the laws and regulations by public institutions such as court and police
Article 10 (Disclosure and Modification of Personal Information)
  1. You have the following rights in the relationship with the Company:
    • The right to access to your own personal information
    • The right to modify or delete your own personal information
    • The right to restrict processing
    • The right to object to processing
    • The right to data portability
  2. When you wish to disclose, modify, add, delete or restrict the personal information you have provided or request to portability and the like, please refer to the contact information shown in the following article to contact the Company.
  3. If the Company receives your request based on the preceding clause, the Company shall confirm your identity and shall handle your request on your personal information within a reasonable range. Provided, however, that this shall not apply if the Company is not responsible for the disclosure and the like under the Act on the Protection of Personal Information and other laws and regulations.
Article 11 (Contact Information)
Should you have any questions, comments, complaints or other matters related to the Company’s handling of personal information, please contact the Company:
Xtra Inc.
E-mail :support@conyac.cc
(The hours of reception are on weekdays between 10:00 and 17:00.)
Article 12 (Organization and Structure)
  1. The Company assigns the person responsible for information security to the personal information officer to conduct appropriate management of the personal information and continuous improvement.
  2. The Company abides by the Act on the Protection of Personal Information, the Guidelines Regarding the Protection of Personal Information in the Telecommunications Business of the Ministry of Internal Affairs and Communications of Japan, etc. Also, the Company keeps on making effort to improve the personal information protection management system as the social environment changes.
  3. In order to prevent personal information leakage, loss or damage and protect other personal information, the Company has taken necessary and appropriate measures for security management of personal information such as restricting access to the personal information file, minimizing the number of access right holders, and installing security software for preventing illegal access of outsiders. Also, the Company shall appropriately supervise both its employees and its contractors (including subcontractors) that handle personal information. Main security management measures of the Company are:
    (Basic policy development)
    The Company develops the basic policies including “Observation of the related laws, regulations and guidelines, etc.” and “Contact to ask questions and make a complaint” to ensure appropriate handling of personal information.
    (Setting up rules on handling of personal information)
    The Company sets up the internal rules on basic personal information handling procedure including how to acquire, use and store personal information.
    (Corporate security management)
    The Company assigns the personal information officer and has the reporting system for handling of personal information.
    (Individual security management)
    The Company organizes regularly training on how to handle personal information.
    (Physical security management)
    The Company has taken measures to make access to personal information difficult for other person than the employees who are authorized to handle the personal information and the person who submitted such personal information.
    (Technical security management)
    The Company has taken measures against access to personal information without good reason by clarifying devices and the employees to process personal information.
Article 13 (Indemnity)
The Company shall assume no responsibility whatsoever for any of the following cases:
  1. When your own personal information is disclosed by yourself to a third party, no matter what means you used.
  2. When you input information that was not required by the Company on the Service, made yourself identifiable and such action caused damage to you.
Article 14 (Privacy Policy Modifications)
The Company shall timely review the operation status on the handling of personal information and strive to improve it on a constant basis and may modify this policy as needed. The revised policy will come into effect between you and the Company after the announcement on the Company’s website and obtaining your consent.
Article 15 (Other Notice)
The Service provided by the Company may contain links to External Services which the Company have no influence on. The Company shall assume no responsibility whatsoever for any of the contents and the protection of personal information at these External Services.
Article 16 (Personal Information Retention Periods)
When the retaining of personal information acquired from you and to be processed is no longer needed for the purpose specified in Article 2, the Company shall delete such personal information without delay. Provided, however, that the Company may retain the personal information, which is no longer needed for the purpose in Article 2, in the following cases:
  1. When the Company retains the personal information for public interest
  2. When the Company processes the personal information for a scientific study
  3. When the Company processes the personal information for creating statistics
If there is a conflict between the English version of the terms and the Japanese version of the terms, the Japanese version shall prevail, govern, and control.
  • Established on February 09, 2013 (detail)
  • Revised on February 04, 2015 (detail)
  • Revised on April 06, 2018 (detail)
  • Revised on January 18, 2019 (detail)
  • Revised on April 10, 2019 (detail)
  • Revised on November 30, 2021

  • End