Cyber Communications Inc. (hereinafter referred to as “CCI”) recognizes the extreme importance of appropriately handling information - especially appropriately handling information pertaining to people’s privacy - in contributing to the creation of a richer information society. CCI obtains personal information from a variety of people, including those who have dealings with CCI, those who visit CCI, those wishing to be employed by CCI, and employees of CCI.
Additionally, CCI carries out operations in order to be able to provide support for all types of online media strategies. Its ad network (for network distribution of advertisements) and data management service are part of these operations. Through these and its other services, CCI obtains information on users who view advertisements and websites.
This is in order to allow people to know what type of privacy-related information is being handled and how it is being handled, as well as to provide an opportunity to participate in such processes.
1. Handling of Personal Information
1.1. Purpose of Use
CCI will obtain personal information in a fair and appropriate manner and use it for purposes falling within the scope indicated in “Purpose of Use” in “Table 1”. Types of personal information other than that indicated in “Type of Personal Information” in “Table 1” will be used after individual notification or public announcement of purpose of use, or after obtaining prior consent from the owner of the information.
1.2. Outsourcing Management
CCI partially entrusts operations related to personal information to outsourcing contractors as indicated in “Outsourcing” and “Scope of Outsourcing” in “Table 1” and “Table 2”. CCI considers management of outsourcing contractors an issue of paramount importance. When entrusting operations, CCI selects a contractor acknowledged as having a sufficient standard of personal information protection. CCI also clearly indicates obligations that are considered to be necessary via contracts and other such means. Additionally, CCI demands that outsourcing contractors handle personal information appropriately and continually conducts supervision and inspection necessary for safety management.
1.3. Provision to Third Parties
As a fundamental rule, CCI will not disclose and/or provide personal information to any third parties. If any such disclosure and/or provision of personal information should be conducted, it would be done appropriately and in compliance with the applicable laws.
1.4. Joint Use
In cases such as seminars held jointly with group companies or business partners, etc., CCI may allow for joint use of personal information. In such cases, CCI will clarify the purpose of use, data items, scope of users, and management supervisor beforehand and provide notification or public announcement. Additionally, it will implement thorough safety management amongst the joint users.
1.5. Disclosure and Inquiries
Please contact the service counter responsible for your information or the inquiry contact shown below for the following matters related to personal information obtained by CCI as shown in “Table 1”:
1) Notification of purpose of use
2) Requests for disclosure of, corrections to, additions to, or deletion of information
3) Requests for cancellation or termination of use
4) Other requests and inquiries
You will be provided with information such as how to carry out application procedures and the fees involved. When responding to your request, CCI will confirm that the requester is the owner of the information or a representative of the owner. Note that there is currently no “authorized personal information protection organization” to which CCI belongs.
2. Compliance with the Law
CCI will adhere strictly to laws, regulations, contracts, and other standards relating to the protection of personal information.
3. Safety Management Measures
CCI strives to prevent leakage of personal information and other issues by taking such safety management measures as maintenance and improvement of a personal information protection system, employee training and education, and management of entrance to / exit from office spaces. Additionally, CCI ensures that personal information stored on a limited basis is disposed of or deleted via appropriate methods.
4. Continuous Improvements
In light of customer requests and changing societal conditions, CCI will continuously revise and strive to improve its personal information protection management system - including this Policy - in order to maintain appropriate handling of personal information and the company’s standard of information protection.
* Websites whose links appear on pages operated by CCI may not be operated by CCI in some cases. Please note that such cases fall outside of the scope of this Policy.
Table 1: Personal Information to Be Obtained Directly by CCI
|Type of Personal Information||Purpose of Use||Method of Acquisition||Outsourcing||Scope of Outsourcing|
|Personal information of clients||Invitation and/or communication of the services including proposals, special offers, seminars, questionnaires, etc.||Obtained directly from the individual (via business card, email, etc.)||No|
|Delivery of publications, newspapers, seasonal greetings, etc.||Yes||Delivery of publications, newspapers, goods|
|Personal information of business partners||Invitation and/or communication of the services including proposals, special offers and seminars directed to outsourced companies, etc.||Obtained directly from the individual (via business card, email, etc.)||Yes|
|Delivery of publications, newspapers, seasonal greetings, etc.||No||Delivery of publications, newspapers, goods|
|Personal information of Visitors at CCI’s office||Notification of arrival of the visitor to the person visited and gatekeeping at office entrances ,||Obtained directly from the individual||No|
|Personal information of job applicants for CCI||Work and notifications involved in recruitment, employment, and screening; implementing questionnaires, etc., as reference for future recruitment activities; personnel database after enrollment||Obtained directly from the individual or recruiting sites and recruiting companies||Yes||All recruitment-related work; screening & scheduling; notifications; implementing and processing questionnaires|
|Personal information of people who make inquiries to CCI||Response to inquiries, requests, complaints, etc.||Obtained directly from the individual (via telephone, email, fax, letter, etc.)||Yes|
|Personal information of employees of Dentsu Group companies||Various business operations and maintenance of a business promotion structure system (details specified separately within CCI)||Obtained directly from the individual or via each Group company||Yes||Application differs case by case (announced separately internally)|
|Personal information obtained via third party||Conducting operations such as general surveys, consumer awareness & behavior research, and personalizing (information based on personal attributes and behaviors)||Obtained via documents and/or digital data||Yes||Surveys, analysis, registry management, database server operation, opt-in mail delivery, etc.|
Table 2: Personal Information to Be Obtained for Commissioned Work
|Type of Personal Information||Scope of Commissioned Work (Purpose of Use)||Outsourcing||Scope of Outsourcing|
|Personal information received from clients for the purpose of entrusted operations||Execution of commissioned work which includes sweepstakes, campaigns, events, membership offerings, requests for materials, inquiry response, general surveys, consumer awareness and behavior surveys, and personalized data management (information based on personal attributes and behaviors) , etc.||Yes||Implementation of sweepstakes, delivery of prizes and goods, surveys, analysis, registry management, promotion office management, delivery of direct mails, database server operation, opt-in mail delivery , delivery of mail magazine,etc.|
1. Obtainment and Purpose of Use
The content of and purpose of use of informative data*1 obtained by CCI are as follows.
In cases in which users come into contact with CCI services - such as cases in which users view advertisements distributed by CCI or access apps or web content containing analysis tools provided by CCI - CCI may obtain user history information (for example: the time of website access, IP address information*2, user agent information*3, information contained within cookies*4, advertisement click history/conversion history*5, referrer information*6, and advertisement identifiers*7, etc.)
Additionally, CCI provides various services for data use to partner corporations, including media companies. In order to provide these services, in some instances CCI receives user attribute information (for example: user age, sex, region of residence, etc.) from partner corporations.
However, CCI does not receive information from which specific individuals can be identified.
Informative data is used for such things as: distribution reports to advertisers; advertisement distribution control and determination of improper advertisement distribution; development of advertisement menus for partner corporation websites and apps; customer/user analysis; joint research with research institutes; recommendations; and control of partner corporation advertisement distribution and content distribution. Control of advertisement distribution includes the distribution of “targeted advertisements” that select and distribute optimal advertisements to users who have accessed websites or apps. This utilizes cookies and other technologies.
CCI ascertains what information is necessary for the provision of its various services and does not obtain informative data that is unnecessary for the provision, improvement, or enhancement of its services.
*1 “Informative data” means logged information, from which specific individuals cannot be identified, pertaining to Internet use including, without limitation, the personal information such as gender and/or interests, the information contained in cookies, IP address information, browsing history and purchase history.
*2 “IP address information” refers to the identification number assigned to computers connected to networks such as the Internet or intranets. This identification number can be used to ascertain the regional location of the user’s computer.
*3 “User agent information” refers to the type/version of browser utilized by the user, the type/version of OS, and other such information.
*4 “Cookie” refers to data that is temporarily written and stored on the computer of someone accessing a page; this is done via the web browser. Cookies contain unique ID information and other data for the purpose of distinguishing between individual users.
*5 “Conversion history” refers to a log of results/actions desired by a website operator, including requests for product information and product purchases, etc.
*6 “Referrer information” refers to the URL of the website that a user accessed immediately before the site currently being viewed.
*7 “Advertising identifier” refers to IDFA, AdvertisingID, and other identifiers whose character strings can be reset (or changed) for the purpose of distinguishing individual devices (including mobile information devices).
2. Provision to Third Parties
After CCI has obtained informative data and inferred information such as user interests and age group, etc., in certain conditions it may categorize said users and provide information (segment information) pertaining to said category to advertisement distributors, media companies, advertising companies, advertisement sponsors, or other such affiliate companies. Segment information provided by CCI will be used for such things as distribution of targeted advertisements, recommendations, development of advertisement offerings, and customer/user analysis, etc.
Note that CCI does not allow segment information it has obtained to be used to identify specific individuals without users’ consent. CCI provides segment information only to affiliate companies that comply with applicable laws and CCI’s own standards.
3. About Opting Out
CCI offers users the ability to stop (“opt out” of) targeted advertising by CCI that utilizes cookies. CCI also offers users the ability to stop the creation of segment information regarding them and the provision of said information to third parties (to affiliated companies). If you wish to opt out, please do so from the page linked below.
Click here to opt out
Users who opt out must do so for each browser they use. Because of this, users must repeat opt out procedures when using a computer different from the one they originally opted out from or when they have installed a new browser. Additionally, please note that it will be necessary to repeat opt out procedures if you have deleted cookies issued by CCI.