ACCESSTRADE Privacy Policy

The definitions of terms used in this Policy are as follows:

1. "Personal Information," "Personal Data," "Retained Personal Data," and "Information Related to Personal Information":
   • Refers to those as defined in the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003), hereinafter referred to as the "Personal Information Protection Act."
2. "Partner":
   • Refers to site operators who have registered for the Service to display affiliate advertisements.
3. "Merchant":
   • Refers to companies or entities that have registered for the Service to post affiliate advertisements.

We will lawfully and fairly collect personal information, such as company names, names, addresses, phone numbers, email addresses, etc., after notifying or publicly announcing the purpose of use of personal information in advance (see the following section).

We may collect contact information from websites and various media to recruit partners and expand merchants (advertisers) through our representatives. We will not collect other personally identifiable information obtained from offline or other sources and associate it without permission with information obtained on this website (ACCESSTRADE), except for the purposes mentioned above.

We will use personal information within the necessary scope to achieve the following purposes in the Service. In cases of adding new purposes or making significant changes, we will obtain prior consent. However, when there are reasons recognized by laws, personal information may be used beyond the scope of the purpose.

1. For the provision, operation, and maintenance of the Service.
2. For identity verification, authentication services, and support.
3. For site reviews and anti-fraud measures.
4. For measuring and confirming results using personal-related information, etc.
5. For claiming and making payments of advertising rewards.
6. For guidance on the Service's advertising programs, introducing the products and services of advertisers and third parties, sales solicitations, shipping, and service provision.
7. For statistical analysis of marketing data such as performance results.
8. For after-sales service, inquiries, and complaint handling.
9. For submitting registration information to Japan Affiliate Service Kyokai （JASK）.
10. For proposing to advertisers, advertising agencies, and media representatives.
11. For dealing with individuals who use the Service for fraudulent or unfair purposes.
12. For other purposes specified individually within the Service.

1. We will use information related to personal information within the necessary scope to achieve the purposes of using personal information with your consent in the Service.
2. When providing information related to personal information to third parties where it is anticipated that such third parties may acquire it as personal data, we will provide it after taking necessary measures under the law, such as confirming that such third parties have obtained your consent.

Regarding the handling of cookies on the Service, please refer to the separate "ACCESSTRADE Cookie Policy."

To prevent leakage, loss, or destruction (hereinafter referred to as "leakage, etc.") of personal data and for other security management of personal data, we have established the "Personal Information Protection Policy" and implemented the following security measures. In the event of a significant personal information leak or similar incident that could harm you, we will follow guidelines, contact the affected you, and report to the Personal Information Protection Commission and the Japan Privacy Accreditation Council (TRUSTe).

1. Establishment of discipline in the handling of personal data
   • Establishment of "Personal Information Protection Regulations" and "Specific Personal Information Protection Regulations"
2. Institutional Security Control Measures
   • Appointment of personnel responsible for the handling of personal data and clarification of responsibilities
   • Establishment of a reporting and communication structure to the responsible party in case of incidents of leakage, etc. of personal data
   • Maintenance of records (including verification) related to the handling of personal data such as system logs to ensure compliance with regulations regarding the handling of personal data
   • Investigation of facts in case of leakage, etc., notification to affected individuals, and consideration and disclosure of measures for prevention of recurrence
   • Confirmation of the status of handling personal data, regular review, and implementation of audits
3. Human Security Control Measures
   • Regular training for employees regarding precautions for handling personal data
4. Physical Security Control Measures
   • Access control and restrictions on bringing in equipment, etc.
   • When disposing of devices or electronic media with recorded personal data, use of dedicated data deletion software or physical destruction
5. Technological Security Control Measures
   • Limiting access to information systems handling personal data by granting access rights to user IDs
   • Installing firewalls, etc., at connection points between information systems and external networks to block unauthorized access
   • Implementing protection measures such as passwords for transferred personal data
   • Ensuring security when you transmit personal information on the Service by protecting it with SSL (Secure Socket Layer), an industry-standard security feature that encrypts information for communication over the internet. By using an SSL-compliant browser, your personal information will be automatically encrypted for transmission.

We will not provide personal data to third parties without your consent. However, we will disclose personal data without obtaining your consent in the following cases:

1. When required by law
2. When necessary for the protection of human life, body, or property, and obtaining your consent is difficult
3. When especially necessary for the improvement of public health or promoting the sound growth of children, and obtaining your consent is difficult
4. When cooperation is necessary for a national agency, local public entity, or person entrusted by them to perform duties stipulated by law, and obtaining your consent may hinder the execution of such duties

We may entrust the handling of personal data in whole or in part to external parties within the necessary scope to achieve the purposes of use. In such cases, we establish certain criteria for the selection of business contractors, conclude contracts including clauses prohibiting purposes other than those specified and confidentiality clauses, and implement appropriate management and supervision.

1. Within the scope specified below, we may jointly use personal data provided by you between us and our subsidiaries.
   1. Items of personal data subject to joint use:
      • Name, address, email address, usage status of the Service, and all other personal data acquired by us regarding you.
   2. Range of parties participating in joint use:
      • Our Subsidiaries
   3. Purpose of joint use:
      • As described in "3. Purpose of Use of Personal Information." However, in the mentioned description, "the Service" should be read as "services provided by our subsidiaries."
   4. Person responsible for the management of joint use:
      • 2-4-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-0808
        Shinichiro Kawabata, President & CEO, Interspace Co., Ltd.
2. We will jointly use information regarding partners engaged in fraudulent activities specified below with the Japan Affiliate Service Kyokai (referred to as "JASK"), and members of JASK (referred to as "Member Companies").
   1. Items of Personal Data to be Shared
      1. Name of affiliate partner (corporate name in the case of corporations)
      2. URL of registered site
      3. E-Mail Address
      4. Specific details of fraudulent activities
      5. Industry to which the affected advertiser belongs
      6. Last 7 digits of registered bank account number
      7. Names of registering Member Companies
   2. Range of parties participating in joint use:
      • JASK and Member Companies
   3. Purpose of joint use:
      • To prevent individuals involved in malicious activities during partner re-evaluations and new registrations, by allowing Member Companies to refer to information about partners who have engaged in such actions, thus preventing the individuals from moving between Member Companies and repeating such activities.
   4. Name or name and address of the person responsible for the management of the relevant personal data, and in the case of a legal entity, the name of its representative:
      • JASK Japan Affiliate Service Kyokai Contact
      • List of JASK Member Companies

Providing personal information to us by you is voluntary. If you do not provide the necessary personal information for the purposes of our use, certain contents of the Service may not be appropriately provided.

When moving from the Service's website to an external website through a link, the Service's privacy policy will not apply. Even if linked from our website, actions such as browsing or interacting on external websites will be subject to the specific rules and privacy policies of those websites. Before proceeding, please review the privacy policy and terms of the respective website.

If you are registered as a partner or merchant in the Service, you can make requests for disclosure, suspension of use, information confirmation, and correction of registration information and usage history, among others, through the Service's website.

In this case, confirmation and correction of registered information and usage history can be performed through the dedicated management screens listed below:

• Partner Management Screen
• Merchant Management Screen

For requests regarding other disclosures and records of third-party provision, please contact us through the following inquiry contact.

For inquiries and complaints regarding the handling of personal information, please contact the inquiry contact.

• e-mailprivacy@accesstrade.net
• ToPersonal Information Protection Manager

We may change this policy when there are modifications in the handling of personal information or when necessary to comply with laws, etc. In such cases, the changes and their issuance date will be posted on the Service's website. In the case of significant changes, we will provide notification. However, if changes require your consent under legal requirements, we will obtain your consent through our specified method.