Privacy Policy

Kamori Kanko Co., Ltd. (the "Company") establishes this privacy policy (this "Policy") as set out below with respect to the handling of the personal information of persons who use the application "Rusutsu App" provided by the Company (the "Service") (such persons, "Users"), and promotes the protection of personal information by building a framework for the protection of personal information, making all employees aware of the importance of protecting personal information, and ensuring that those efforts are thoroughly implemented.

Article 1 (Personal Information)

"Personal Information" means "personal information" as defined in the Act on the Protection of Personal Information (the "Personal Information Protection Act"), that is, information relating to a living individual which can identify a specific individual by the name, date of birth or other descriptions contained in such information, or which contains an individual identification code.

Article 2 (Purposes of Use of Personal Information)

The Company acquires Users' Personal Information, and uses the information so acquired, to the extent necessary for the following purposes. Where the Company uses Personal Information beyond the scope of the following purposes, it shall obtain the User's consent in advance by an appropriate method.

• (1) To provide the Service
• (2) To improve and enhance the content of the Service, or to develop new services
• (3) To provide information on new features, updates, campaigns, etc. of the Service and on other services provided by the Company (including by sending e-mail, flyers and other direct mail)
• (4) To contact Users as necessary, such as regarding maintenance or important notices
• (5) To respond to opinions, inquiries, etc. from Users concerning the Service (including verifying identity)
• (6) To report to Users on the status of their use of the Service
• (7) To request cooperation with questionnaires, interviews, etc. concerning the Service or participation in various events, or to report the results thereof
• (8) To investigate and analyze usage history, etc. of the Service and to use the results for the improvement and development of the Service and for the delivery of advertisements
• (9) Provision of Personal Information to participating companies, etc. of events organized by the Company, based on the User's consent or application
• (10) To identify Users who have violated the Terms of Service or Users who attempt to use the Service for fraudulent or improper purposes, and to refuse their use
• (11) To provide point services in the Service, such as the issuance, granting and use of points
• (12) To conduct and operate programs such as digital lotteries and stamp rallies
• (13) To provide the Service through linkage with the platform "Pokepay" provided by Pocket Change, Inc. ("Pocket Change"), the AXESS system provided by Axess Japan Co., Ltd., the payment platform Stripe provided by Stripe Japan, Inc., and other external systems (collectively, "External Systems")
• (14) To use location information for conducting stamp rallies, etc.

Article 3 (Use of Cookies, etc.)

The Company uses technologies such as cookies and information collection modules (collectively, "Cookies, etc.") to acquire Users' access information, browsing information, etc. relating to the Service. For details of the Cookies, etc. used in the Service, please refer to the cookie policy separately established by the Company.

Article 4 (Items of Information Acquired)

• 1. In providing the Service, the Company may acquire or use the following information.

• (1) Information that Users register with the Service
• (2) Device information
• (3) Location information necessary to provide features such as stamp rallies
• (4) IDs for identifying Users in the Pokepay service, the AXESS system and other External Systems linked with the Service, and other information necessary for such linkage
• (5) Usage history, purchase history, history of the granting and use of points, and other information generated in connection with the use of the Service
• (6) Information relating to push notifications
• (7) Information acquired through Google Analytics and other external analytics services
• (8) Other information necessary for providing the Service
• 2. The location information referred to in item (3) of the preceding paragraph is used to determine whether conditions have been achieved in stamp rallies, etc.; however, the Company does not continuously record or store the location information itself.

Article 5 (Linkage with External Services and Joint Use of Personal Data)

• 1. In the Service, the Company links with External Systems and records IDs and other information necessary for linking with those systems.
• 2. The privacy policies, etc. established by the operators of the relevant External Systems may apply to the scope and handling of information acquired or shared in connection with linkage with the External Systems referred to in the preceding paragraph.
• 3. The Company jointly uses Users' personal data as follows.
• (1) Items of personal data jointly used
• ① IDs for identifying Users in the Service, the AXESS system and the Pokepay service
• ② Age group, gender, and country or region
• ③ Purchase history and usage status of lift tickets
• ④ Information relating to the granting, use and balance of points
• ⑤ Name and e-mail address
• (2) Scope of joint users

The Company, Axess Japan Co., Ltd. and Pocket Change, Inc.

• (3) Purposes of use of the joint users
• ① Sale and issuance of lift tickets through linkage between the Service and External Systems
• ② Issuance, granting, use and management of points
• ③ Identity verification, prevention of fraudulent use, and response to inquiries
• ④ Analysis and improvement of the status of use of the Service
• (4) Person responsible for management

Kamori Kanko Co., Ltd. (address and representative as set out in Article 15)

Article 6 (Management and Protection of Personal Information)

The Company shall manage Personal Information strictly and, except in the following cases, shall not disclose or provide Personal Information to any third party without the User's consent. In consideration of security, the Company also takes measures for the prevention and rectification of risks such as unauthorized access to Personal Information and the loss, destruction, falsification and leakage of Personal Information.

• (1) Where it is necessary for the protection of the life, body or property of an individual and it is difficult to obtain the User's consent.
• (2) Where it is especially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the User's consent.
• (3) Where it is necessary to cooperate with a national government agency, a local government, or a person entrusted by either of them in performing affairs prescribed by laws and regulations, and obtaining the User's consent is likely to impede the performance of such affairs.
• (4) Other cases permitted by laws and regulations.

Article 7 (Entrustment of Handling of Personal Information)

The Company may entrust all or part of the handling of Personal Information to the extent necessary to achieve the purposes of use. In such cases, the Company shall thoroughly examine the suitability of the entrusted party, stipulate matters such as confidentiality obligations in the contract, and exercise necessary and appropriate supervision over the entrusted party.

Article 8 (Disclosure of Personal Information)

A User may request the Company, in accordance with the procedures prescribed by the Company, to disclose Personal Information held by the Company. Upon receiving such a request from a User, the Company shall disclose it to the User without delay. However, the Company may decline to disclose all or part of it where disclosure would fall under any of the following, and if it decides not to disclose, it shall notify the User to that effect without delay.

• (1) Where disclosure is likely to harm the life, body, property or other rights or interests of the User or a third party
• (2) Where disclosure is likely to seriously interfere with the proper conduct of the Company's business
• (3) Where disclosure would otherwise violate laws and regulations

Article 9 (Correction, etc. of Personal Information)

• 1. If Personal Information held by the Company is incorrect, a User may request the Company, in accordance with the procedures prescribed by the Company, to correct, add to or delete such Personal Information (collectively, "Correction, etc.").
• 2. Upon receiving a request under the preceding paragraph, the Company shall conduct the necessary investigation without delay and, if as a result it determines that the request under the preceding paragraph is well-founded, shall make the Correction, etc. of such Personal Information without delay.
• 3. When the Company has determined whether or not to make the Correction, etc. under the preceding paragraph, it shall notify the User concerned without delay.

Article 10 (Suspension of Use, etc. of Personal Information)

• 1. A User may request the Company, in accordance with the procedures prescribed by the Company, to suspend the use of, erase, or suspend the provision to third parties of Personal Information held by the Company (collectively, "Suspension of Use, etc.").
• 2. Upon receiving a request under the preceding paragraph, the Company shall conduct the necessary investigation without delay and, if as a result it determines that the request under the preceding paragraph is well-founded, shall carry out the Suspension of Use, etc. of such Personal Information. However, where the Suspension of Use, etc. of the Personal Information would require a large amount of expense or would otherwise be difficult, and alternative measures necessary to protect the User's rights and interests can be taken, the Company shall take such alternative measures.
• 3. When the Company has determined whether or not to carry out the Suspension of Use, etc. under the preceding paragraph, it shall notify the User concerned without delay.

Article 11 (Procedure for Changes to the Privacy Policy)

The Company shall review the content of this Policy from time to time and strive to improve it. The content of this Policy may be changed, except for matters otherwise provided for by laws and regulations or by this Policy. The amended privacy policy shall take effect when the Company notifies Users by a method prescribed by the Company, or when it is posted on the Service or on the Company's website.

Article 12 (Compliance with Laws, Regulations and Norms)

The Company complies with the laws and regulations of Japan and other norms applicable to the Personal Information it holds.

Article 13 (Handling of Complaints and Consultations)

The Company accepts complaints and consultations from Users regarding the handling of Personal Information and responds to them appropriately and promptly. The Company also responds promptly and appropriately to requests from Users for the disclosure, correction, addition or deletion of such Personal Information, or for refusal of its use or provision.

Article 14 (Security Control Measures)

The Company prevents unauthorized intrusion into, and the loss, destruction, falsification and leakage of, Personal Information entrusted to it by Users by taking organizational, physical, human and technical measures, such as restricting access to personal information files, recording access logs, and implementing security measures to prevent unauthorized access from outside. In the unlikely event that an incident such as a leakage of a User's Personal Information occurs, the Company shall, in accordance with the Personal Information Protection Act and related guidelines, promptly report to the supervisory authority and notify the User, and, following the instructions of that supervisory authority, take the necessary actions, including measures to prevent the occurrence of similar incidents and measures to prevent recurrence. For details of the security control measures taken by the Company, please contact the inquiry desk set out in Article 16.

Article 15 (Company Name, etc.)

The Company's name, address and the name of its representative are as follows.

Name: Kamori Kanko Co., Ltd.

Address: Kamori Building 3, 4-1 Kita 4-jo Nishi 4-chome, Chuo-ku, Sapporo, Hokkaido

Representative: Representative Director 加森 久丈 (Kamori)

Article 16 (Inquiry Desk)

Please direct inquiries regarding the Company's handling of Personal Information to the following.

Customer Service Desk

Mail: rusutsu-app@rusutsu.com

Cookie Policy

• 1. Kamori Kanko Co., Ltd. (the "Company") may use cookies and other information collection modules, etc. (collectively, "Cookies, etc.") in the service "Rusutsu App" provided by the Company (the "Service"). When using Cookies, etc., the Company can acquire Users' access information, browsing information, etc. relating to the Service through the Cookies, etc. Such information acquired through Cookies, etc. ("Cookie Information") does not include information that by itself can identify and specify the User.
• 2. If a User does not permit the use of Cookies, etc. on the Service, please disable Cookies, etc. in the User's browser settings, etc. If Cookies, etc. are disabled, the convenience of the Service may be impaired, or the scope of use of the services provided in the Service may be limited.
• 3. For details of the Cookies, etc. used in the Service, please refer to the following.

Google Analytics

• Recipient: Google LLC
• Information acquired: IP address, unique device identifier, User behavior information (clicks and page transitions on the site, etc.), URLs of pages viewed by the User, location information, time spent, etc.
• Purpose of use: To understand the status of use of the Service in order to improve the Service and to provide services better suited to Users' interests and needs

※For details of data handling in Google Analytics, please see here (https://policies.google.com/technologies/partner-sites?hl=ja).