Privacy Policy

With respect to certain services provided by SENKO Group Holdings Co.,Ltd. ("Company") known as "alphanote" ("Services"), the Company sets forth the privacy policy ("Policy") with respect to the treatment of information of users of the Services (each, a "User") including their personal information as follows:

1. Acquisition of User Information
As used herein, "User Information" shall mean any information to identify a User, his/her history of activities on telecommunication services, and any information generated or accumulated on such User's smart phone, PC or other terminal in connection with such User or his/her terminal, which the Company collects in accordance with this Policy.

User Information collected by the Company shall be categorized by method of collection as follows:
(1) Information provided by a User. Information to be provided by a User for using the Services shall be as follows:
• name
• date of birth
• any other information entered by a User on a form designated by the Company

(2) Information to be provided by other services the collaboration with which a User consents to in connection with the use of the Services. If a User consents to the collaboration with external services such as social networking services in connection with the use of the Services, the following information shall be collected from such external services based on the content of such User's consent:
• ID used by a User for such external services
• any other information disclosure of which by the collaborator is allowed by such User as set forth under the privacy policy of said external services

(3) Information collected by the Company in connection with the use of the Services by a User. The Company may collect information concerning the situation of access to and methods of use of the Services, which includes:
• information of terminals
• log information
• any cookies and anonymous ID
• position information

2. Purposes of Use of User Information
User Information shall be used for, in addition to the provision of the Services as stated below, any other purposes set forth under this Policy.

Specific purposes of use of User Information in connection with the provision of the Services shall be as follows:

(1) to provide information concerning the Services; to respond to inquiries etc.;
(2) to address any act in violation of the Company's rules and policies ("Rules") concerning the Services;
(3) to notify change of Rules regarding the Services; and
(4) any other purposes of use incidental to the foregoing.

Purposes of use other than those stated above are as follows:
(1) To generate statistical data concerning the Company's services as processed into a form which cannot identify individuals:
 Information to be used
• information of terminals
• log information
• any cookies and anonymous ID
• position information
(2) To distribute or display the Company's or any third party's advertisements:
 Information to be used
• information of terminals
• log information
• any cookies and anonymous ID
• position information
(3) To use for other marketing activities:
 Information to be used
• name
• email address
• date of birth
• any other information entered by a User on a form designated by the Company

3. Provision to Third Parties
The Company shall not provide personal information among User Information to any third party except that disclosure of such information is allowed under the Act on the Protection of Personal Information or any other law or regulation, or without the prior consent of a User; provided, however, that the above shall not apply in any of the following events:

(1) the Company entrusts the handling of personal information in whole or in part to the extent necessary to achieve the purposes of use thereof by the Company;
(2) personal information is provided in connection with the transfer of business by reason of merger or otherwise;
(3) such disclosure or provision is required in order to cooperate with national or local governmental authorities or with any person on their behalf in performing administrative affairs stipulated by laws and regulations, but obtaining such User’s consent thereto could hinder the performance of such affairs;
(4) such disclosure or provision is otherwise permitted by the Act on the Protection of Personal Information or any other law or regulation.

For User Information other than personal information, the Company may provide to a third party such information after processing the same into a form which cannot identify individuals as stated in 2. above.

4. Joint Use
In the event that the Services are jointly operated with another joint operator, the Company may use User Information jointly with such joint operator. In such case, the Company shall amend this Policy prior to the commencement of such joint use, which shall be made available to Users in advance.

5. Amendment; Termination of Use
In the event that a User requests (1) the amendment of User Information pursuant to the Act on the Protection of Personal Information because his/her personal information contained therein is not true, or (2) the termination of use of User Information pursuant to the Act on the Protection of Personal Information because the same is used beyond the scope of purposes of use previously announced, or the same is collected using false or unlawful means, the Company shall, after confirming that such request was made by the User himself/herself, conduct necessary research without delay, and amend, or terminate the use of, the content of such personal information and notify the User thereof.

If the Company decides not to amend or terminate the use of said information on a reasonable ground, it shall notify the User thereof.

In the event that a User requests the deletion of his/her personal information and the Company determines that it must accept such request, the Company shall, after confirming that such request was made by the User himself/herself, delete such personal information and notify the User thereof.

In addition to the above, if any amendment or termination of use etc. of User Information is requested by a User, the Company shall respond to it in good faith; provided, however, that Users acknowledge that the Company may refuse such amendment or termination of use in any event outside the scope of the above.

6. Management of User Information
The Company shall take appropriate security measures to prevent and correct any unauthorized access, destruction, tampering, loss or leakage of User Information collected, especially with respect to personal information, and strictly manage the same. The Company shall also appropriately manage any User Information other than personal information according to the level of importance thereof.

7. Supervision of Contractor
To the extent necessary to achieve the purposes of use of User Information, the Company shall strictly select and investigate a third party contractor when personal information is entrusted to such third party contractor in whole or in part.

The Company shall also undertake necessary and appropriate supervision of such third party contractor so that personal information shall be safely managed by it.

8. Use of Cookies
The Company may use cookies on the webpage for the provision of services to each User for the following reasons:
(1) if required for convenient use of services by a User;
(2) if required for counting the number of users of the Company's webpage; or
(3) if required for posting advertisements.

A User may refuse transmission of cookies by electing "Block all cookies" etc. on the setting concerning cookies, in which case the User cannot use certain services of the Services which require cookies.

9. Amendment of this Policy
The Company shall review the situation of management of User Information from time to time and continuously improve the same. The Company reserves the right to amend this Policy as deemed necessary at its discretion. Any changes to this Policy will be notified to Users in a manner designated by the Services; provided, however, that in the event of any change requiring the consent of Users under any law or regulation, the Company shall obtain such consent of Users in a manner designated by the Company.

10. Responsible Manager
A person in charge of management of User Information at the Company is as follows:
• SENKO Group Holdings Co.,Ltd.
• Kengo Senuma, Personal Information Protection Manager in charge of Operation of alphanote

11. Contact:
Any questions concerning the treatment of User Information by the Company may be directed to the following contact:

Email address for inquiry: info@alpha-connection.net
alphanote Operation Office