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WEAR Privacy Policy

Introduction

Your personal privacy is of the utmost importance to us at Start Today Co., Ltd., a Japanese corporation, along with our affiliates, branch offices and subsidiaries (collectively, the “Company”). In every decision we make, we consider the impact on your personal privacy, being information directly identifying you (your “Personal Information”), or as otherwise defined under applicable law, and only seek to process your Personal Information where necessary, either to serve our legitimate business interests or to provide you with a service that you have expressly requested.

This privacy policy (“Privacy Policy”) discloses how we at the Company collect, process, share and secure information gathered from you whilst using WEAR, a social networking service that specializes in fashion (“WEAR”).

1. Information Collected and Processed

The Company may collect and process the following information from you, some of which may be Personal Information. The Company will only collect and process such Personal Information where permitted by applicable law or where you have provided your consent. If you choose not to provide certain Personal Information, you may not be able to take advantage of some features of WEAR.

In providing WEAR, the Company may collect and process certain information from you, including information (1) that is either necessary or optional to register your account and for you to use WEAR; (2) on the WEAR website (“Website”); (3) through the WEAR mobile application for your smartphone (“WEAR Mobile”); or (4) through various social networking services, including Facebook and Twitter (collectively, “Social Networking Services”), in each case as described below.

(1) Information collected and processed for WEAR
・ Information necessary for account registration: email address and password
・ Information necessary for using SNS function: name or nickname and User ID
・ Optional:
o Account details – date of birth, age, country/region of residence sex, height and location of shop (if a participating shop owner)
o Information needed to identify fashion preferences – country/region of residence, photograph, body measurements, fashion preferences
o Information posted by you to public WEAR forums – images, videos, sounds, comments, messages and other related information, which may be or is accessible by the general public and is being disclosed at your own risk
o Information exchanged privately with other WEAR users – images, videos, sounds, comments, messages and other related information
o Information provided by you whilst communicating with the Company

(2) Information collected and processed on the Website
・ Analytics information used to improve WEAR – Computing device model, OS version, browser type, IP address, crash information, information on how the Website was accessed ・ Cookies (see cookie section below)

(3) Information collected and processed on WEAR Mobile
・ Analytics information used to improve WEAR – Mobile network provider, hardware model, OS version, Device ID number
・ Location information (only where you have so consented) to provide you with nearby fashion opportunities

(4) Information collected and processed on Social Networking Services
・ Information in relation to pages and interests which you have “liked” on Facebook or chosen to follow on Twitter or other similar activities on other Social Networking Services
・ Information about your WEAR activities where you have decided to share those activities on a Social Networking Service. This information will be shared amongst your “friends” and other individuals that you associate with on Social Networking Services, or it will be made public, dependent upon your settings.
・ Information regarding your friends or followers, where both you and your friend/follower have given the necessary permissions in the Social Networking Service

2. Purpose for Processing

The Company may use information collected from you, including Personal Information, as necessary for the purposes listed below. The Company will only collect and process your Personal Information pursuant to the purposes listed below where permitted by applicable law or where you have provided your consent. These purposes are:

(1) To operate and provide WEAR, and provide unique services in connection with the recommend function, customize function, follow function and other functions of WEAR;

(2) To research, analyze, and prepare statistical data for the improvement and the development of new functions on WEAR;

(3) To conduct various campaigns, prize giveaways, and surveys relating to WEAR;

(4) To handle various inquiries from you and other users, to provide after-sales services and to improve our customer service;

(5) To deliver up-to-date information and newsletters regarding WEAR, and deliver various information regarding other related services that are provided by the Company; and

(6) To provide notice in some instances when WEAR interacts with a Social Networking Service.

The Personal Information you provide will only be used for the purposes identified above, to fulfill a legal obligation, or for a legitimate business purpose which we may notify you of, from time to time. You may refuse any request for Personal Information, but we may not be able to then provide you with certain features of WEAR.

3. Public Personal Information

WEAR is a social and interactive service which allows other users to follow your fashion trends and allows you to follow the fashion trends of other users, amongst other features. In that respect, we would like to make some of your Personal Information public whilst you use WEAR, but we will only do so where you have so consented. If you do not consent to this functionality, your WEAR experience may be limited. In that respect, we would like to make your name or nickname and other registered information other than password public in association with any content (including text, photographs, videos, sounds, URL links, and other similar information) which you may post to public forums on WEAR.

If you choose to associate your WEAR account with any Social Networking Services, any Personal Information made public on WEAR may also be made public on that particular Social Networking Service.

4. Sensitive Personal Information

We do not seek to collect, process or store any sensitive Personal Information from you whilst using WEAR, being Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of information concerning health or sex life (your “Sensitive Personal Information”) unless required by applicable law or as necessary for a feature of WEAR which you have requested and where you have provided your explicit consent.

If you do not wish for us to collect, process or store your Sensitive Personal Information, then please do not provide us with any Sensitive Personal Information.

5. Storage, Retention and Disclosure of Personal Information

Storage of Personal Information
Personal Information collected by us may be stored and processed anywhere in the world including Japan. You acknowledge that this may result in your Personal Information being processed in a country with lesser data protection and privacy laws than is found in your country of residence. When we transfer your Personal Information to other countries, we will make sure that such transfer takes place in accordance with local law requirements, and we will protect that Personal Information as described in this Privacy Policy.

Retention of Personal Information
We will retain your Personal Information only for as long as necessary to fulfill the purposes listed above or which have otherwise been notified to you. Any consent provided by you for the use of your Personal Information for such purposes will remain valid after termination of the Company’s relationship with you to the extent permitted by applicable law so long as you do not request otherwise. Our obligations under statutory retention obligations (e.g. for tax and accounting purposes) remain unaffected.

Disclosure of Personal Information
We will not disclose your Personal Information to a third party, unless you request or otherwise consent to such disclosure or such disclosure is required or permitted by applicable law or, if in our good-faith belief, we determine that such disclosure is necessary to: (a) comply with any law applicable to us or comply with a legal process or investigation involving the Company or WEAR (including fraud protection and risk reduction, business sale/transfer and as part of bankruptcy, liquidation or other similar proceedings); (b) protect or defend the rights or property of the Company, the Company brand, WEAR’s brand and you; (c) protect the life, health, body, vital interests and similar of you and other users; or (d) act in the public interest.

We may share aggregated, non-personally identifiable information with third parties for industry analysis, demographic profiling, marketing and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

6. External Service Providers

We may employ third party companies and individuals to facilitate certain functions for the Company. These third parties may have access to your Personal Information only to perform these tasks on our behalf and they are obligated through contract not to use your Personal Information for any other purpose or to disclose your Personal Information to any other third party without our consent.

Where we share your Personal Information with a third party, we will require the third party to subscribe to the same level of privacy protection as is required by applicable law and not to use your Personal Information for any purpose not authorized by us. We do not sell or lease Personal Information about you to any third parties for their marketing use.

7. Accessing and Correcting Your Personal Information

You may review, amend, block or delete your Personal Information that you provide to the Company either by visiting your accounts settings page as part of the WEAR service or by contacting the Company as described below. Where such requests are made, we may ask you to provide proof of your identity using an official identification document (e.g. driver’s license, insurance card, passport or resident card) or other similar documentation. We may also charge a fee for the actual cost of complying with such requests, but will only do so where permitted under applicable law.

Please note, we will seek to honor your requests where possible, but we may need to retain some of your Personal Information or otherwise not comply with your request where permitted or required under applicable law. Where this is the case, we will notify you of why we are unable to comply.

8. Security

The Company’s Security
We take measures to maintain the confidentiality of your Personal Information and protect it from unlawful disclosure. We will not make your Personal Information available to the general public unless required to do so by applicable law.

We safeguard your Personal Information on the internet by maintaining strict physical, electronic, and administrative safeguards to protect your Personal Information from unauthorized or inappropriate access, accidental or intentional manipulation, loss and destruction. Our security procedures are continually enhanced. These safeguards include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store Personal Information.

We further restrict access to your Personal Information to those individuals with a need to know that information in order to operate, develop or improve WEAR. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Your Personal Security
When creating an account for WEAR, please take care to keep any email address, password and/or other identification information confidential, and do not disclose or share this information with anyone. Where you do disclose such information, you are solely responsible for all activities undertaken on your account.

9. Cookies and Log Data

Cookies are small packets of information which are stored by your web browser. They are put on your web browser by the websites that you visit. These packets of information do not contain Personal Information about you but they do allow us to know if you visit the same website twice or if you visit related websites. We may also use cookies to help identify opportunities which may be of particular interest to you.

You will be aware that the laws in many European Union countries require you to provide a form of consent before cookies are placed on your web browser unless the cookie is necessary for the website to work.

There is no agreed standard for how companies comply with these laws, however, we do the following:

・ We only use cookies that are necessary for WEAR or where you have provided your express or implied consent
・ We respect your wishes and you can inspect, delete or block any cookies used by us by selecting the appropriate control in your web browser. However, if you choose this setting you may be unable to log on to your WEAR account or access certain other areas or features of WEAR.
・ We support technologies which have been developed and are being developed for your web browser which allow you to be more selective about the cookies that your web browser will accept ・ We use a tool called “Google Analytics” to collect information about use of WEAR. If you wish to opt out of your visit information being reported to Google through Google Analytics, you may be able to install the Google Analytics opt-out browser add-on, which can be found at https://tools.google.com/dlpage/gaoptout. We also support the Do Not Track browser setting for Firefox, Internet Explorer, Chrome and Safari. Do Not Track is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain kinds of information about you. For more details, including how to turn on Do Not Track, visit www.donottrack.us.

Cookie Cookie Purpose Nature of the Cookies Cookie Type
Web Analytics Google Analytics: tracks each user's amount of visits, and the time of the first, the previous, and the current visit Third Party Persistent
Web Analytics Google Analytics: tracks how long you stay on a site - when a visit starts and approximately ends Third Party Persistent
Web Analytics Google Analytics: tracks where a visitor came from (e.g. search engine, search keyword, link) Third Party Persistent
Device Identification Identify your device (e.g. computer, phone, tablet PC) so that content is delivered in the correct format First Party Session
Language Identification when navigating the website First Party Session
Server Identification Identify the Server which served the request (managed by Microsoft) First Party Session
Session Identification Identify the Session which is currently used (managed by Microsoft) First Party Session
Print Specification to print First Party Session

Definitions:
・ “First Party” Cookie – A cookie placed by this Website
・ “Third Party” Cookie – A cookie placed by another domain (e.g. not this Website)
・ “Persistent” Cookie – The cookie information is stored on your device even after you close your web browser
・ “Session” Cookie – The cookie information is temporarily stored in your web browser’s memory

We do not seek to collect your Personal Information and where we do, we strive to anonymize your Personal Information as soon as practicable.

Some content or applications on WEAR may be provided by third parties, including content and application providers. These third parties may use cookies or other automatic data collection technologies to collect information about you when you use WEAR. This information may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about how your information may be used by any of these third parties, you should contact the responsible provider directly.

Log Data
Whenever you use WEAR, our servers automatically record the information that your device sends. These server logs may include information such as your computer’s IP address, browser type, the date/time of your request, the webpage you visited before you came to the Company’s Website or other statistics. This information may be used to analyze and improve the WEAR service and the Company’s Website.

10. Third Party Links

For your convenience, we may include links to other websites and services, including e-commerce websites, in the provision of WEAR. We provide these links as a convenience only and we do not endorse the content or services offered by, or the privacy policies in place at, these other websites. This Privacy Policy covers only Personal Information that we collect, and websites and services not operated by or on behalf of the Company to which links are included in WEAR may have privacy policies that differ substantially from this Privacy Policy.

We have structured WEAR to make it reasonably clear when you leave WEAR and enter another website or service. Whilst we make reasonable efforts to try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites. We encourage you to review the privacy policies posted on all websites you use or access.

11. Miscellaneous

Children’s Privacy
WEAR is not intended to be used by individuals who have not yet reached the age of majority under the applicable law in the country in which the individual resides and may not be used in the United States by individuals under the age of thirteen (13) (“Minors”). If you are under the age of thirteen (13) and are located in the United States, do not use WEAR or provide any information through the Website, WEAR Mobile or our Social Media Services. We do not knowingly solicit or collect Personal Information from Minors, and we do not knowingly market our products or services to Minors. If we learn that we have collected Personal Information regarding a Minor, we will remove that Personal Information. The Company is not responsible for any liability, damage, or loss arising from the removal of any such Personal Information. If you suspect that a Minor has registered for the WEAR service, please notify us using the contact information provided below.

Changes to this Privacy Policy
Please check this Privacy Policy periodically to inform yourself of any changes. Although we reserve the right to modify or supplement this Privacy Policy, we will provide notice to you on the Website, WEAR Mobile or the relevant pages of our Social Media Services of any major changes for at least thirty (30) days following the change. Changes to the Privacy Policy are effective at the time they are posted to the Website, WEAR Mobile or the relevant pages of our Social Media Services. Your continued use of WEAR after posting will constitute your acceptance and agreement to be bound by such changes.

Contacting Us
You may opt out of the collection and processing of your Personal Information at any time using the [“Contact Us”] page on the Website and WEAR Mobile. You may also withdraw your consent and “unsubscribe” from any email list or similar at any time by following the instructions set forth in the email message or the [“Contact Us”] page on the Website and WEAR Mobile. However, we may then not be able to provide certain functionality of WEAR.

If you have any questions about this Privacy Policy or how to exercise your rights, please contact us at [wear-privacy@starttoday.jp]:

Last Revised: March 10, 2014