comcom Analytics Privacy Policy

1.Personal Information

"Personal information" means "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter the "Personal Information Protection Act"), and refers to information about a living individual that can identify a specific individual by name, date of birth, or other descriptions, etc. contained in such information, or that contains an individual identification code.

1-2.Information Acquired from Discord

In providing the Service, the Company acquires the following information from Discord servers into which the bot program has been introduced.

1. Information relating to messages (including metadata such as the date and time of posting, the channel, and the poster, as well as reactions and mentions, and including the content of messages to the extent necessary for the provision of the functions)
2. Information relating to members (joining and leaving servers, roles, display names, etc.)
3. Usage status of voice channels
4. Presence information (meaning online status, the type of connected device, and the activity in progress (the game being played, streaming, the music being played, the status set by the user, etc.))

The Company handles presence information to the extent necessary for the creation of statistical information and for otherwise providing the functions of the Service, and does not retain it in a form that can identify a specific individual beyond the period necessary for these purposes.

2.Acquisition and Use of Personal Information

The Company acquires Users' personal information to the extent necessary for the following purposes, and uses the acquired information. The Company may change the purposes of use within a scope reasonably deemed to have relevance to the purposes of use before the change, and in the event of such a change, will make it known by way of a revision of this Policy or by other appropriate methods. In the event the Company uses personal information beyond the scope of the purposes of use set forth in the preceding sentences, it shall obtain the User's consent in advance in accordance with laws and regulations.

1. To provide the Service and other products and services of the Company (hereinafter collectively the "Company Services")
2. To improve and enhance the contents of the Company Services, or to develop new services
3. To provide information about new features, updates, campaigns, etc. of the Company Services and about Company Services other than the Service (including the sending of e-mails, flyers, and other direct mail)
4. To make necessary contact such as maintenance and important notices
5. To respond to inquiries from Users regarding the Company Services (including identity verification)
6. To report the usage status of the Company Services to Users
7. To request Users' cooperation with surveys, interviews, etc. regarding the Company Services and their participation in various events, or to report the results thereof
8. To investigate and analyze the usage history, etc. of the Company Services and to use the results for the improvement and development of the Company Services and for the delivery of advertisements
9. To identify Users who have violated the Terms of Service or who attempt to use the Company Services for fraudulent or improper purposes, and to refuse them use
10. To conduct joint research between the Company and universities in Japan
11. To aggregate and analyze information acquired from Discord and other information handled in the Service, and thereby create statistical information from which a specific individual cannot be identified
12. To provide the statistical information set forth in the preceding item to Users as a function, report, etc. of the Company Services, or to provide it to third parties (including provision for a fee)

3.Joint Use

For the purpose of achieving the purpose of use stated in 2.(10) above, the Company jointly uses Users' personal information within the following scope.

The joint use under this Article is limited to Users who have completed user registration, and does not cover the personal information of members participating in Discord servers into which the bot program of the Service has been introduced.

1. Items of personal data to be jointly used

   All personal information of the User themselves, except where there is a specific request from the User

2. Scope of those who jointly use the information

   (i) Kyoto University of Advanced Science

   (ii) Kyoto University

3. Purpose of use by those who jointly use the information

   Same as 2.(10) above

4. Name and address of the party responsible for the management of the relevant personal information, and the name of its representative

   Same as 13. Contact Point for Inquiries

4.Provision to Third Parties and Management and Protection of Personal Information

To the extent necessary to provide payment services to Users, the Company may provide a User's e-mail address and other information necessary for payment to the payment service providers used by the Company.

Except in the following cases, the Company will not disclose or provide data to third parties without the User's consent. In addition, with safety in mind, the Company takes measures to prevent and correct risks such as unauthorized access to personal information, and the loss, destruction, alteration, and leakage, etc. of personal information.

1. When it is necessary for the protection of the life, body, or property of a person, and it is difficult to obtain the User's consent
2. When it is particularly necessary for improving public health or promoting the sound development of children, and it is difficult to obtain the User's consent
3. When it is necessary to cooperate with a national government organ or a local public entity, or a party entrusted by either of them, in carrying out affairs prescribed by laws and regulations, and obtaining the User's consent is likely to impede the performance of such affairs
4. When all or part of the handling of personal information is entrusted within the scope necessary to achieve the purpose of use, in order to carry out business smoothly
5. When personal information is provided in association with the succession of business due to a merger or other reason
6. When, as provided in 3, personal information is jointly used with a specific party, and the fact of such use, the items of personal information to be jointly used, the scope of those who jointly use it, the purpose of use by those who use it, and the name of the party responsible for the management of the relevant personal information are notified to the User in advance, or placed in a state where the User can readily know them
7. Other cases permitted by laws and regulations

Notwithstanding the provisions of this Article, statistical information that has been aggregated and analyzed in a form in which a specific individual cannot be identified and from which the personal information used as the basis for its creation cannot be restored does not constitute personal information. The Company may provide such statistical information to third parties (including provision for a fee), regardless of whether the recipient is a corporation or an individual.

4-2.Retention Period of Personal Information

The Company retains personal information only for the period necessary to achieve the purposes of use, and where it is no longer necessary to retain it, endeavors to erase it without delay or to process it into statistical information from which a specific individual cannot be identified. With respect to presence information, after the lapse of the period necessary for the creation of statistical information and for otherwise providing the functions, the Company erases without delay any data in a form in which a specific individual can be identified or restored.

5.Entrustment of the Handling of Personal Information

The Company may entrust all or part of the handling of personal information within the scope necessary to achieve the purpose of use. In such cases, the Company sufficiently examines the suitability of the entrustee, establishes matters concerning confidentiality obligations, etc. upon contracting, and provides necessary and appropriate supervision of the entrustee.

6.Disclosure of Personal Information

When requested by a User to disclose personal information, the Company will disclose it to the User without delay. However, if disclosure falls under any of the following, the Company may decline to disclose all or part of it, and in the event a decision is made not to disclose, the Company will notify the User to that effect without delay.

1. When there is a risk of harming the life, body, property, or other rights or interests of the User or a third party
2. When there is a risk of significantly impeding the proper conduct of the Company's business
3. When it would otherwise violate laws and regulations

7.Correction and Deletion of Personal Information

1. If the personal information held by the Company is incorrect information, the Company will correct or delete the personal information at the User's request, in accordance with the procedures prescribed by the Company.
2. If the Company receives a request from a User under the preceding paragraph and determines it necessary to comply with such request, the Company will correct or delete the relevant personal information without delay and notify the User thereof.

8.Suspension of Use, etc. of Personal Information

If a User requests the suspension of use or the erasure of personal information (hereinafter "Suspension of Use, etc.") on the grounds that it falls under any of the cases set forth in the following items, the Company will conduct the necessary investigation without delay, and based on the results thereof, will carry out the Suspension of Use, etc. of the personal information in accordance with laws and regulations and notify the User thereof. However, in cases where the Suspension of Use, etc. of personal information requires a large expense, or where it is otherwise difficult to carry out the Suspension of Use, etc., and alternative measures necessary to protect the User's rights and interests can be taken, the Company will take such alternative measures.

1. When it is being handled beyond the scope of the purpose of use
2. When it is personal information acquired by improper means
3. When it is being used in a manner that is likely to encourage or induce illegal or improper acts
4. When the Company no longer needs to use the User's personal information
5. When a leakage, loss, or damage (hereinafter "Leakage, etc.") of personal information containing special care-required personal information has occurred, or is likely to have occurred
6. When a Leakage, etc. of personal information that is likely to cause property damage through improper use has occurred, or is likely to have occurred
7. When a Leakage, etc. of personal information that is likely to have been carried out for an improper purpose has occurred, or is likely to have occurred
8. When a Leakage, etc. involving more than one thousand individuals whose personal information is concerned has occurred, or is likely to have occurred
9. When the handling of the relevant personal information is likely to harm the rights or legitimate interests of the User

9.Procedures for Changing the Privacy Policy

The Company reviews the contents of this Policy as appropriate and endeavors to improve it. The contents of this Policy may be changed at the Company's discretion, except for matters separately provided for by laws and regulations or by this Policy. In the event the Company changes this Policy, it will determine the time at which the changed contents take effect and will, by that time, make known or notify Users of the contents of the change and the time at which it takes effect, by posting on the Company's website or by other appropriate methods (such publicity shall be deemed to have been completed upon posting on the Company's website). If a User uses the Service on or after the time at which the change takes effect, the User shall be deemed to have agreed to this Policy as changed.

10.Regarding Access Analysis

The Company uses Google Analytics, provided by Google, for the analysis of usage status in the Service. Google Analytics uses cookies, etc. (meaning device identifiers such as cookies, web beacons, SDKs, and collection tags) to automatically collect information such as your access information, without including information that identifies an individual, and transmits it to Google. The collected information is managed in accordance with Google's privacy policy.

If you wish to stop the collection of information using Google Analytics, please change your browser settings. This can be done by downloading and installing the "Google Analytics Opt-out Add-on" from Google's opt-out add-on download page, and changing your browser's add-on settings.

• Google Analytics Terms of Service: https://www.google.com/analytics/terms/jp.html
• Google Privacy Policy: https://www.google.com/intl/ja/policies/privacy/
• Google Analytics Opt-out Add-on: https://tools.google.com/dlpage/gaoptout?hl=ja

11.Compliance with Laws and Norms

The Company complies with the Japanese laws and regulations and other norms applicable to the personal information it holds.

12.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 such as the disclosure, correction, addition, or deletion of the relevant personal information, or the refusal of its use or provision.

13.Contact Point for Inquiries

For inquiries regarding the Company's handling of personal information, or to exercise your rights, please contact the following.