PRIVACY
POLICY

When collecting personal information through our services and products, COLDRAW (Address: 2-1-1, Nihonbashi-Muromachi, Chuo-ku, Tokyo, Japan), hereinafter referred to as “our company”, “we”, “our” or “us”, recognizes our social responsibility to properly manage personal information, and we will handle personal information in accordance with this Privacy Policy.
The Japanese version of this Privacy Policy is the original. In the event of any inconsistency, the Japanese version shall prevail even if translations into other languages exist.

Personal Information Protection Poricy

1. We will comply with laws and regulations, national guidelines, and other norms regarding the handling of personal information.
2. We will take appropriate measures such as notifying the individual or publicly announcing the purpose of use when acquiring personal information. We will not acquire personal information through deceptive or other wrongful means.
3. Personal information will be handled appropriately through strict security measures.
4. We will not use personal information beyond the scope necessary for achieving our purpose of use, unless required by law.
5. We will not provide personal information to third parties without obtaining prior consent of the individual when outsourcing the handling of personal information within the scope necessary for achieving our purpose of use, unless the provision of personal information to a third party is otherwise permitted by law.
6. When we outsource the handling of personal information to third parties, we will select appropriate business operators, stipulate necessary matters such as personal information management and confidentiality in outsourcing contracts, etc., and supervise the users and managers of personal information as necessary and appropriate.
7. When we share personal information with third parties, we will describe the matters stipulated by law in our Privacy Policy, notify the individual in advance or make the information readily accessible to the individual, and use the information jointly within the scope of such sharing.
8. In handling personal information, etc., we will take appropriate organizational, personnel, physical, and technical safety control measures.

   a.Organizational safety control measures

   We will establish an organizational management system that includes a committee and a person in charge of management, development of internal rules, preparation of statements such as management ledgers, and implementation of future improvements.

   b.Personnel safety control measures

   All employees who handle personal information, including directors, employees, and temporary employees, shall be informed and educated about the importance of protecting personal information, and will be required to sign confidentiality agreements and undergo necessary audits and supervision to ensure the effectiveness of such measures.

   c.Physical safety control measures

   Various measures to prevent theft or loss of personal information will be implemented, including control of employee access, restrictions on permitted machinery and equipment, and restrictions and controls on equipment, electronic media, and documents that handle personal data.

   d.Technical safety control measures

   We will implement systems to protect our information systems that handle personal data from unauthorized access or unauthorized software.

9. We will also respond appropriately to inquiries regarding personal information in our company's possession.
10. We will continuously review and improve our management of the protection of personal information, including our Privacy Policy, as often as necessary.
11. We will comply with the EU General Data Protection Regulation for the acquired personal information of individuals residing in the European Economic Area.

Handling of personal information

1.Acquisition of Personal Information

The types of personal information we collect are as below:

• Information such as name (full name), age, gender, e-mail address and telephone number of customers
• Information that is registered or edited by customers when using our services (including SNS) (anonymous ID, age, occupation, etc. that customers voluntarily registered)
• Individual identification information of devices when using our services (including SNS)
• Information acquired as a result of collaborations with external services
• Cookies

2.Purpose of use for personal information

In order to provide information to customers and improve our products or services, we may use the acquired personal information for the following purposes.

• We will use the acquired information to respond to inquiries about our products, our services, company information, etc.
• We will use the acquired information to send information on our products, services, events, sweepstakes, campaigns, etc., via direct mail, e-mail, various social media sites and other forms of communication.
• We will use the acquired information to disclose personal information.

3.Processing requests for disclosure of personal information

We will respond to requests, corrections, additions or deletions of personal information, requests for suspension of provision of personal information to third parties, requests for disclosure of records of provision of personal information to third parties and notifications of the purpose of use of retained personal data in accordance with national guidelines, our company rules and other regulations regarding the handling of personal information.

(1)How to request

Requests for disclosure of personal information should normally be made in writing. Request forms will be sent upon request to the contact listed in the “Contact information” section.

(2)Fee for requests

The cost of sending request forms from customers to the Company shall be borne by you. In addition to the cost of sending the forms, a commission fee of JPY 500 will be charged if personal information is requested.

(3)Notes.

Requests for disclosure of personal information should always be made in writing. If you contact us at the address given in the “Contact Information” section, we will send you the request forms.

Changes or revisions of our Privacy Policy

Our company reserves the right to revise our Privacy Policy without prior consent. We will notify customers of the revised Privacy Policy in a manner that we deem appropriate (including posting the revised policy on our website for easy access). All changes will take effect immediately upon notification and all users and customers shall be deemed to have consented to the updated Privacy Policy. For customers who do not agree to changes in our Privacy Policy, please refrain from using our services.

Contact Information

If you wish to make an inquiry regarding your personal information, please contact us via the following email address.
Contact: info@coldraw.com

Regarding Cookies

We may use cookies on our website to improve usability, understand how our website is viewed through statistical information, display the most appropriate content to our customers and deliver advertisements. Cookies will not be used for any other purposes. Cookies are pieces of information such as access history and other data that is stored in the browser of a user’s computer, mobile device, etc. when a user visits a website. By sending and receiving cookies to and from your browser, our website can display information that is optimized for each customer.

The use of cookies does not give information that identifies individual customers. You can change the settings of your browser to block the use of cookies or delete information on past cookies. However, some of the services on our website will not be accessible if you block cookies on your browser.

Our website uses Google Analytics to collect cookies and analyze website access. For more information on Google Analytics and cookies, please visit the Google Privacy & Terms webpage.

(Adopted on October 10, 2024)