The below outlines the way in which Helixes Inc. handles information related to customers ("Customer Information") within COMPANY's service, REClike ("SERVICE").

Article 1 (General Rules)

1 In order to protect Customer Information, COMPANY will exercise appropriate handling and protection of Customer Information pursuant to this privacy policy ("THIS POLICY") while being in compliance with the Personal Information Protection Act and other related legal provisions.
2 THIS POLICY applies to the handling of Customer Information within SERVICE (including services provided by COMPANY that are connected to SERVICE). Additionally, the policies regarding personal information protection outlined in the privacy policy posted on the website managed by COMPANY and which outline the provisions of the terms of use of REClike concerning the handling of personal information, will be applied for the applicable provisions. In cases where these provisions conflict with those outlined in this privacy policy, this privacy policy is to take precedence.
3 THIS POLICY is not applicable to services connected to SERVICE that are provided by entities other than COMPANY ("EXTERNAL SERVICES"). For the handling of personal information in these EXTERNAL SERVICES, please reference the privacy policies of their respective operators.

Article 2 (Collected Information)

1 COMPANY collects Customer Information, including personal information ("personal information" here and below as defined by the Personal Information Protection Act, Article (2) Clause (1)), in SERVICE.
(1) Information Provided by the Customer
Email address (In the case of a Facebook login, this can include telephone number, email address, name, profile pictures, and gender)
This information is registered by the customer in order to register an account, verify user identity, and prevent fraudulent use.
(2) Information Collected by COMPANY During Use of SERVICE
a. Terminal Device Information
In order to have the necessary system information to run the service, to maintain and improve SERVICE, and to otherwise prevent fraudulent activities, we may collect information on the devices (information to identify the device including terminal ID) being used by the customer.
b. Log Information and Activity History
COMPANY, in order to operate, maintain, or otherwise improve SERVICE and prevent fraudulent activities, will collect information on the automatically generated and saved IP address, the date and time of request from the customer, and the operation history of SERVICE when SERVICE is used.
c. Cookies and Anonymous IDs
In some cases, SERVICE will make use of a technology known as "cookies" and other related technologies. Cookies are a standard industry technology that allows servers to identify user computers. Though cookies can identify the user's computer, they cannot idenfity the customer's personal information. Furthermore, cookies may be rendered ineffective through certain settings on the user's device; however, this may lead to being unable to use all or part of SERVICE.
2 COMPANY will not collect Customer Information through deceit or other fraudulent means. Additionally, if Customer Information is gathered by additional means through use of SERVICE, COMPANY will alert in advance or otherwise publicly announce the purpose of using that information.

Article 3 (Purpose of Use)

１ COMPANY will use Customer Information collected by SERVICE properly in the following capacity. Information will not be used for other purposes than the following without the consent of the customer.
(1) Providing, maintaining, and improving SERVICE
- To ensure identity verification and prevent fraudulent use
- To ensure the smooth provision, maintenance and improvement of SERVICE
- Telephone number and email address
- Name, address, credit card and other payment information
(2) Correspondence with and notifications to the customer
- To handle information and questions related to SERVICE
- To notify or otherwise provide new services related to SERVICE
- To notify users of important changes in SERVICE including changes to the terms of service or this privacy policy and the suspension, cancellation, or the contractual annulment of SERVICE.
- Email address
(3) Third party providers
- Third parties that receive the aforementioned information will use the applicable information in the following ways.
・To provide joint services
・To display advertisement information that meets the needs, interest, and concerns of the customer
・To analyze ad effectiveness
・For market analysis and marketing
- Device information
- Log information and activity history
- Cookies
2 There may be cases in which COMPANY makes changes to the aforementioned purposes or to provisions with considerable connection to these purposes within a reasonably acknowledged capacity. In such cases, COMPANY will use a separately established means to notify customers or otherwise make public announcements of such changes.

Article 4 (Protection of Personal Information)

COMPANY will work towards the proper management of personal information by establishing a chief administrator for the handling of personal information and make strong efforts to establish a system that prevents illegal access to personal information, loss of personal information, and alteration or leakage thereof.

Article 5 (Third Party Providers)

1 Excluding the following cases, COMPANY will not provide personal information to third parties.
(1) If customer agreement is received
(2) In cases based on laws and ordinances
(3) In cases where necessary measures must be taken against activities where, in using SERVICE, customers harm the interests of others, act contrary to public order and morals, and engage in other activities or attempts that violate the terms of use of SERVICE
(4) In cases where it is necessary to protect lives and property, making it difficult to receive customer consent
(5) When it is necessary to cooperate with national agencies, local government bodies, or organizations that have been entrusted by these bodies in carrying out their duties pursuant to law and receiving customer agreement would become a hindrance in carrying out these applicable activities
(6) In cases where operations including the customer's personal information are inherited for reasons such as corporate mergers, split ups, or a reassignment of operations.
2 In order provide Customer Information to services joined with SERVICE ("Joint Service"), COMPANY will, upon receiving the agreement of the customer, provide this information to the operator of the Joint Service ("Joint Partner").

Article 6 (Entrusting the Handling of Personal Information)

COMPANY may entrust to third parties the handling of all or part of the personal information collected from customers (in cases where the management of data including personal information is entrusted to another party). In such cases, COMPANY will enter into agreements including non-disclosure agreements with the relevant entrusted parties based on this privacy policy as well as conduct necessary supervision and guidance of the entrusted parties' safe and appropriate handling of the information.

Article 7 (Shared Use)

COMPANY may engage in shared use of the customer's personal information with Joint Partners and other third parties in the capacity that is necessary to provide the Joint Service. In such cases, COMPANY will publicly announce the name of Joint Partner, the purpose of the shared use, and type of information that will be shared.

Article 8 (Information Collection Modules)

In order to analyze the status of utilization of SERVICE, the following modules are built into SERVICE for the collection of information. As a result, COMPANY may share user information with the following providers of information collection modules. These information collection modules utilize cookies and gather user information--not including information that can identify the individual--and manage this information in accordance with the provisions set out in their respective privacy policies.
Name of Service: Google Analytics
Provider:Google Inc.
Privacy Policy: http://www.google.com/intl/ja/policies/privacy/

Article 9 (Safety Management System)

1 COMPANY, in order to prevent leakage of, loss or damage of, and otherwise protect Customer Information, will take the necessary measures for the safe management of Customer Information. This will include conducting access restrictions to personal information files, keeping a record of access to such files, and introducing security measures to prevent external illegal access to such files.
2 COMPANY will have its president as the chief administrator of Customer Information and will properly conduct and continuously improve the management of Customer Information.

Article 10 (Disclosing and Revising Customer Information)

１ For information regarding the disclosure, revision, addition, deletion or suspension in use of information provided by the customer, please reference "Guidelines for the Disclosure Application" (PDF). However, these procedures may not be able to be conducted depending on the nature of the information.
2 If an application is submitted based on the prior items and with identify verification, COMPANY will disclose personal information within a reasonable capacity. However, in accordance with the Personal Information Protection Law and other related laws and ordinances, COMPANY may not be obligated to disclose certain information.

Article 11 (Changes to THIS POLICY)

1 In working towards continuous improvement, COMPANY may make changes to this privacy policy in accordance to necessity after reevaluating the operational status of the handling of Customer Information.
2 Changes to THIS POLICY will be added to THIS POLICY itself, posted on the website operated by COMPANY, and made available in other easy to access locations. However, if there is a change in content that requires additional customer agreement in accordance with the law, customer agreement will be obtained through a separate means as established by COMPANY.

Article 12 (Inquiries)

Please contact the following for opinions, questions, complaints or other concerns regarding COMPANY's use of Customer Information.

Helixes Inc.
REClike Personal Information Service Desk
E-mail ：info@reclike.com

【Oct/4/2016 Revised】