FreshVoice Webinar / FreshVoice Lite / DD Privacy Policy

EFFECTIVE DATE: AUGUST 21, 2017

(1) Basic Policy on Personal Information

1. Anet Co., Ltd (Anet Co., Ltd,” “we,” “us,” or “our”) acquires from users the minimum information required to offer all services as well as applications for the promotion of use (the "Services") that are available in the Anet Co., Ltd Website (the "Website"). We are committed to safeguarding the personal information acquired from Users with the utmost care (Users herein refers to (i) “Registered Users” who are registered as a User and (ii) “Guest Users” who use the Services other than the Registered Users). The following is our policy on personal information.

(2) Acquisition of Personal Information

1. When you register with the Services as a User, we will ask you to provide us with your email-address. We will also ask you to provide us with your name, gender and postal code for the Advanced User registration if you intend to use the services which are specifically designated by us. The information is collectively referred to as the “User Registration Personal Information”.
2. We automatically receive and record information in our server from the User's browser as an access log, including the User's IP address, cookie information, pages viewed by the User, and the User's environment. We also automatically receive and record in our server the information regarding websites outside the Services from Users who use certain features of applications. However, this information does not include information which can identify an individual, and we use the information for the purpose of managing and analyzing the use of the Website. Additionally, the type and details of the information to be obtained are recorded separately in the help page and such of each application.
3. We automatically receive and record the individual identification numbers in our server from mobile devices used by Users.
4. Where the User uses any services utilizing location information, we receive and record location information in our server from devices which are capable of sending location information, including a User's mobile devices or PCs.
5. We may ask the User to provide us with his/her address, name, telephone number, credit card information, account number and the like whenever necessary for the shipment of goods, purchase and redemption of points, job advertisement, advertising and marketing research.
6. We may receive notices which may include personal information of the Users or any third party, or acquire any disclosed personal information by reasonable means for the investigations of any violation of the terms of use.
7. If the Registered Users use the Services which allow for registration of any third party's e-mail address as the destination of information, we receive and record the information registered in our server.
8. We will not add any information acquired by means other than those set forth in (1) through (7) above to the personal information acquired through the Services.

(3) Use of Personal Information

1. We will use the personal information under the following circumstances:
 a. When a User uses the Services such as receiving e-mails or posting information at FreshVoice Webinar;
 b. When we display the information optimized for each User on the Services, including postings of information which we believe to be of interest to the User;
 c. When we analyze the use of the services for the purpose of improving our services;
 d. When we use statistical information regarding the Users to explain the Services to the Users or any third party; and
 e. When it is necessary for individual processing and transactions such as making contact with Users or any third party, verifying identification, investigating and addressing a violation of the terms of use, investigating an inquiry, and processing a shipment of goods.
2. We will not view or use the personal information for any purpose other than those described above.

(4) Disclosure of Personal Information

1. We will not disclose personal information to any third party except for in the following circumstances:
 a. When we obtain consent from the relevant User for the disclosure of personal information;
 b. When we deem it necessary for the operation of the Services, including displaying of an access log. However, in such cases, we will not disclose the User Registration Personal Information;
 c. When we use the minimum personal information of the User required for for our collaborated business with business partners and advertisers, and obtain consent from the relevant User. However, in such cases, the receiving party may not use the personal information disclosed by Anet Co., Ltd for any purpose other than the performance of the collaborated business;
 d. When we have a legal obligation to disclose personal information including in circumstances where we are required to do so by court order, or are requested to disclose the information of senders pursuant to the Act on the Limitation of Liability for Damages of Specified Telecommunications Service Providers and the Right to Demand Disclosure of Identification Information of the Senders (the Provider Liability Limitation Act);
 e. When we have a reason to suspect that a User is in violation of the terms of use, and consider that it is necessary for the protection of our rights, property, services or the like; and
 f. When there is an urgent need and an imminent danger to the life, body, or property of a User or any third party, and it is difficult to obtain consent from the relevant User.

(5) Viewing, Modifying and Deleting Personal Information

1. In principle, we make available for the Registered User himself/herself to view, modify or delete his/her User Registration Personal Information from FreshVoice Webinar Dashboard after he/she has logged into the Services. We also deal with such requests by e-mail after confirming the identity of the relevant Registered User with the prescribed procedure. Also, in the same manner, the Registered Users may elect whether or not to subscribe to any mail magazine.
2. The Registered User may, at his/her own discretion, register as an Advanced User at any time notwithstanding that he/she uses the services which require the Advanced User registration. Any Advanced User who does not use the services which require the Advanced User registration may delete his/her User Registration Personal Information, and terminate the Advanced User registration.
3. Please see FreshVoice Webinar Dashboard regarding viewing, modifying and deleting your User Registration Personal Information.
4. Once the User completes a procedure for a withdrawal from the Services, we will delete his/her User Registration Personal Information excluding the User's name after keeping the information for a certain period of time. We may keep the User Registration Personal Information prior to change or deletion as a backup for a certain period time for the purpose of preventing any User from suffering disadvantage due to operational errors, or conducting investigations in the event that we find any illegal acts by the User including cases where the User withdrew from the Services immediately after he/she has posted information in violation of the terms of use. We will not use the User Registration Personal Information of the Users in the Services after their withdrawal from the Services. We will keep User's name even after the User's withdrawal from the Services for the purpose of preventing any difficulties in the operation of our services.

(6) Protection and Management of Personal Information

1. Only the relevant User who has logged into the Services with the correct User's name and password can view his/her own User Registration Personal Information and his/her privacy is protected from other Users and any third party.
2. We use SSL encryption to protect data in the Services whenever necessary for the protection of data transmission.
3. We prohibit any person other than our staff to refer to the User Registration Personal Information. Furthermore, we keep the User Registration Personal Information in a locked and safe place, and will not bring the information outside the section managed by us.
4. We execute a confidentiality agreement with our staff and obligate them to comply with the security policy established by us.

(7) Cookies

1. We use cookies for the purpose of checking the login status of Registered Users, measuring the number of unique Users, improving User experience, and authenticating Users. Cookies work as follows:
 a. When a User accesses the Services, we send cookies to the User's browser to identify the User.
 b. When the User is logged into the Services, we send cookies to the User's browser to identify the relevant User who has logged into the Services. Furthermore, when the User makes an authentication in the Services, we send cookies to identify the authenticated User
 c. When the User permits the receiving of cookies in his/her browser's settings, cookie information will be stored in the computer used by the User.
 d. When the User sets his/her web browser to allow sending and receiving of cookies, the web server receives cookie information from the User's browser. However, for privacy protection, the User's bowser only sends cookies which are sent by the relevant web server itself.
 e. The User may refuse to allow the sending and receiving of cookies by selecting “Refuse to send or receive cookies” in the cookie send/receive settings. If the User does this, the User may not be able to use any Services which require his/her login.
2. Cookies may be used by the advertisements displayed on the Services. Where this occurs, the use of cookies by the advertisers shall be governed by each of advertiser’s own privacy policy.

(8) Third Party Tracking Systems

1. The Services acquires statistical information on the use of the website by using cookies, image files (web beacons), Mobile advertising IDs and the like generated by third party providers (*note) which enable us to investigate user trends and to distribute the most relevant advertisements to Users. Such cookies and web beacons described above may include information directly acquired by third party providers, and any cookie information collected thereby will not be provided or disclosed to us, and will be managed in accordance with the privacy policy prescribed by each third party provider. Access analytics tools also measure User attribute data acquired from advertising networks and similar services. Such information does not identify the individual and will be handled in the form of anonymous data. Furthermore, such information will not be used other than for the intended purposes.
i. For optimizing advertisement distribution:
- Google AdSense
- Google AdWords
- Google DoubleClick
- Twitter, Inc.
ⅱ. For actual number of Users:
- Google Analytics
- Firebase
- Fabric

(9) Scope of Application of this Privacy Policy

1. If the User voluntarily discloses his/her personal information on the Website, such information may be collected or wrongfully used by any third party. In such cases, we shall assume no responsibility therefor.
2. Unless otherwise specifically set forth in the Services, any website or service of any third party which is linked from the Services establishes its own provisions for the protection of personal information, which is independent from ours. We assume no obligation or responsibility with regard to these independent provisions and activities. The User should confirm the terms of use and other provisions established by each website before he/she provides his/her personal information.

(10) Revisions on Privacy Policy

1. We may revise all or part of this Privacy Policy in future. In case of any material change to this Privacy Policy, we will notify the Users in a clear manner such as posting the changes on the Services.
2. Whenever we make any change/additions to the purpose of use, the User shall have the right to choose whether or not we can use his/her personal information in the manner changed or added.

(11) Personal Information Administrator

1. Our personal information administrator is as follows:
STOUT Bldg. 3F 3-23 Kanda-Sakumacho, Chiyoda-ku, Tokyo 101- 0025 Japan
Hironori Nishihata, President and Representative Director of Anet Co., Ltd

(12) Comments/Complaints/Claims/Disclosure Request concerning Privacy

1. If you have any comments/complaints/claims/Disclosure Request concerning our privacy practices, please contact us at info@workshop-live.com We will contact you by e-mail after confirming your comment/complaint/claim, and will endeavor to address your inquiry in an appropriate manner.

(14) Revision Record

Established on AUGUST 21, 2017