GDPR Privacy Policy

The Company will collect and process the following types of personal information in relation to the Service:

1. Basic information of the Users (name, date of birth, gender, etc.);
2. Contact information (email address, phone number, address etc.);
3. Credit card information;
4. Information entered or sent by the User through input forms or other methods specified by the Company;
5. Amount of reward paid to the User, etc.;
6. Inquiries and questionnaire responses by the User; and
7. Any other information obtained by the Company from the User.

The Company collects and processes personal information within the scope necessary to achieve the following purposes of use in connection with the Service. Please note that the User may not be able to use all or part of the Service if the User doesn’t consent to providing personal information.

1. To carry out operations related to the provision of the services and products offered by the Company (including not only existing services and products but also newly developed ones; the “Company Services, etc.”).
2. To provide recommendations regarding the Company Services, etc., to Users and to communicate with the User;
3. To develop, plan, provide, maintain, improve the quality of, provide after-sales services for, conduct campaigns, survey, business activities and related activities of Company Services, etc.;
4. To develop, plan, provide, maintain, improve quality, offer after-sales services, conduct campaigns and surveys, and carry out business and related activities for the Company Services, etc.;
5. To conduct advertising, promotion, and marketing activities for the Company Services, etc. (including the use of personal information for information analysis and marketing; the User may receive information about services, benefits, and events via email, direct mail, etc.).
6. To analyze browsing and usage history trends related to the Company Services, etc. and to optimize the provision of services, products, or advertisements;
7. To share the registration information of the individual User with the User who is the corporation or organization using the Services;
8. To carry out other operations incidental to the purposes listed above.

The Company may provide the Users’ personal information to the following businesses and authorities in the following manner:

1. The Company uses outsourcing companies such as service providers and security service providers to offer the Service, and these contractors will access and process the Users’ personal information to the extent necessary to offer the Service;
2. The Company may disclose personal information to public authorities in accordance with applicable laws and regulations (including ordinances, court rulings, and administrative orders and recommendations);
3. The Company may provide personal information that, by itself, does not enable the identification of specific individuals to advertising distribution service providers partnered with the Company for the purpose of delivering advertisements tailored to the User’s interests and preferences, verifying their effectiveness, and providing Service; and
4. The Company may make the registration information of the individual User accessible to the User who is the corporation or organization as part of the Service.

The Company primarily collects personal information from the Users or companies or organizations to which the Users belong.

For the purpose of offering the Service, the Company may transfer Users’ personal information to the countries outside of the User’s country of residence　(an “International Transfer”).
When the Company conducts an International Transfer of Users’ personal information, we will take necessary measures for the protection of personal information, such as implementing an adequate level of protection and executing standard contractual clauses as set forth by the competent supervisory authority. Users who would like more information, such as obtaining a copy of the standard contractual clauses, etc., are to contact us by mail or e-mail at the location provided in Section “11. Inquiries” below.

The Company will retain Users’ personal information for as long as it is necessary to fulfil the purposes of use prescribed in this Policy.
To determine the appropriate retention period for the personal information, we consider: (i) whether the Company has an ongoing relationship with the User; (ii) whether the Company is legally obligated to store such User’s personal information; and (iii) whether storing such User’s personal information is necessary to fulfill the contract with the User.

Users may have the following rights with respect to their own personal information, in accordance with the GDPR:

1. The right to seek access to personal information (including copies thereof);
2. The right to request correction;
3. The right to seek removal (the right to be forgotten) when certain conditions are met;
4. The right to restrict (cease the processing of) the processing of personal information if certain conditions are met;
5. The right to receive personal information in a structured, machine-readable form if certain conditions are met (the right to data portability); and
6. The right to file a complaint with a supervisory authority.

These rights may be limited, on an exceptional basis, if complying with a User’s request would infringe upon the rights of the Company or a third-party, or if we are requested to delete information that we are required to retain in accordance with the laws and regulations. The exceptions to these rights are set out in the GDPR.
Users who wish to exercise these rights are to contact us by mail or e-mail at the location provided in Section “11. Inquiries” below.

Users may have the right at any time to object to the processing of personal information that is being processed in accordance with legitimate interests under the GDPR.
Users may also have the absolute right under the GDPR to refuse direct marketing if their personal information is being handled for direct marketing purposes.
Users who wish to exercise these rights are to contact us by mail or e-mail at the location provided in Section “11. Inquiries” below.

Users have the right to withdraw their consent whenever the Company handles their personal information based on their consent. This withdrawal does not affect the legality of any treatment based on consent previously given.
Users who wish to exercise these rights are to contact us by mail or e-mail at the location provided in Section “11. Inquiries” below.

The personal information that Users are required to provide for the provision of the Service is indicated in the form to be completed by each User. Users are under no obligation to provide such personal information, but if such personal information is not provided, the Company will be unable to offer the Service.

For inquiries regarding personal information, please contact the below:

KDDI iret, Inc. – Legal Department
TORANOMON HILLS MORI TOWER F7, 1-23-1, Toranomon, Minato-ku, Tokyo 101-0063, Japan
E-mail:iret-legal@iret.co.jp

The contact information for the Company’s representative in the EU is as follows:
Name：TMI Avocats & Associés
Address：40 avenue Niel, 75017, Paris, France
E-Mail：iret_EUrep@tmi.gr.jp

The contact information for the Company’s representative in the UK is as follows:
Name：TMI Associates London LLP
Address：CityPoint One Ropemaker Street, London EC2Y 9SS, United Kingdom
E-Mail：iret_UKrep@tmi.gr.jp