Handling of Personal Information

9th Floor, PMO Jimbocho, 2-10-4 Kanda-Jimbocho, Chiyoda-ku, Tokyo
Comisma Inc.
Representative Director: Koki Sato

Comisma Inc. (hereinafter referred to as “”we”” or “us”) strives to collect and use the personal information that is collected in connection with our business in an appropriate manner, and handle such information as follows. Our handling of personal information in relation to specific services or initiatives is separately defined for each such service or initiative.

1. 1. Collection of personal information
   1. (1) We collect personal information and quasi-personal information(*) (hereinafter collectively referred to as “”Personal Information””) in relation to our business in the following ways.
      1. (a) Directly from the person
         (Ex.) We collect information that is entered on written documents and online forms.
      2. (b) Indirectly from the person
         (Ex.) We collect Personal Information that is disclosed in publications, on the Internet, etc.
      3. (c) Directly or indirectly from sites we operate
         (Ex.) We automatically collect the history of actions performed on sites through tags placed on the sites we operate.
      4. (d) Indirectly from a third party
         (Ex.) We collect data from management platforms and social network services.
   2. (2) We may collect Personal Information in a manner that is not easily perceivable by the user. Please click here to learn more about the collection of Personal Information through cookies and technologies such as ad technology. This includes cases where the provider of technology such as ad technology collects information without us collecting it.

      *Quasi-personal information:
      　This refers to information that is related to an individual which does not fall under personal information, pseudonymized personal information or anonymized personal information. It does not include statistical information. Examples: postcode, email address, gender, occupation, hobbies, customer number, cookie information, IP address, device ID, advertising identifier (AAID/IDFA) and other identifier information, location information, browsing history, purchase history, and other log information related to Internet usage
      　We handle quasi-personal information as personal information if the information can be easily cross-referenced with other information to identify an individual.

2. 2. Purposes of use

   　The purposes of use of the Personal Information which we collect are as follows.

   1. (1) Entering into contracts with customers and business partners (including membership registration on sites we operate)
   2. (2) Processing requests from and performing contracts with customers and business partners
   3. (3) Communicating with customers and business partners
   4. (4) Providing information about our and our group companies’ exhibitions, seminars, products, services, etc.
   5. (5) Developing, improving and enhancing the quality of our and our group companies’ products and services
   6. (6) Marketing, selling and promoting our and our group companies’ products and services
   7. (7) Creating statistical data
   8. (8) Analyzing browsing conditions and improving our sites
3. 3. Use of quasi-personal information received from a third party and linked with personal information

   　We may use quasi-personal information which has been provided by a third party by linking it with personal information which we hold. Please check this link to confirm the details of such usage.

4. 4. Provision of personal information and consignment of handling to third parties
   1. (1) We will provide personal information to third parties only when permitted by law (including taking steps required by law, such as obtaining consent from the individual).
   2. (2) We may consign the handling of personal information to third parties to the extent necessary to achieve the purposes of use described in Section 2. In such cases, we consign the handling to contractors that satisfy our contractor selection criteria, enter into a contract with the contractors, and properly manage the contractors’ operations.
   3. (3) The recipients and contractors include third parties located outside of Japan(*).
      * We have defined a policy regarding the provision of personal information and the consignment of handling to third parties located outside of Japan.
5. 5. Shared use of personal information

   　We share the use of personal information in accordance with the following procedures.

   1. (1) Items of personal information that are shared:
      1. (a) Information collected in connection with our contracts with customers and business partners
      2. (b) Contact information of customers and business partners
   2. (2) Scope of parties we share use with:
      Our group company (https://qzil.la/)
   3. (3) Purposes of use of parties we share use with:
      1. (a) So that inquiries regarding the products and services of our group companies are responded to by the appropriate group company
      2. (b) To develop, improve and enhance the quality of our group companies’ products and services
      3. (c) To market, sell and promote our group companies’ products and services
   4. (4) Person responsible for the management of shared personal data:
      9th Floor, PMO Jimbocho, 2-10-4 Kanda-Jimbocho, Chiyoda-ku, Tokyo
      Comisma Inc.
      Representative Director: Koki Sato
6. 6. Voluntariness of provision of personal information by individuals and consequences to an individual for not providing such information

   　Although the provision of personal information to us is voluntary, we may be unable to provide the requested service or response if information is not provided.

7. 7. Procedure for requests for disclosure, etc.
   1. (1) An individual may request the following matters (hereinafter “Disclosure”) to the extent permitted by law regarding the personal information which we handle.
      1. (a) Notification of purposes of use
      2. (b) Disclosure of personal information or records of provision to third parties
      3. (c) Correction, addition or deletion of personal information, or cessation of use, erasure or cessation of provision to third parties
   2. (2) The procedure for requesting Disclosure is as follows.
      1. (a) Requests are to be sent to the personal information hotline listed under “”Inquiries””.
      2. (b) Send the prescribed application form, identification documents and other necessary documents by postal mail. Regarding the disclosure of personal information, please inform us if you wish to receive the disclosure via electronic records. We will provide you with specific instructions regarding the process.
      3. (c) A designated fee will be charged for each request for notification of purposes of use and the disclosure of personal information or records of provision to third parties.

      * Please click here for details regarding the procedure.

8. 8. Security control measures

   　We endeavor to keep personal information accurate and current, and take the necessary and appropriate security control measures as described below to protect personal information from unauthorized access, alteration, leakage, loss, and damage.

   1. (1) Formulation of basic policies
      In order to ensure the proper handling of personal information, we have established basic policies regarding “”Compliance with applicable laws, regulations, guidelines, etc.”” and “”Hotline for handling questions and complaints”.
   2. (2) Establishment of personal information handling rules
      We have established rules for handling personal information at each stage of collection, use, storage, provision, deletion/disposal, etc., including handling methods, responsible persons, persons in charge, and their duties.
   3. (3) Organizational security control measures
      1. (a) We appoint an administrator of personal information handling, identify the employees who handle personal information and the scope of personal information handled by such employees, and maintain a system for reporting to the administrator in the event that an employee becomes aware of any fact or indication of a violation of the law or our handling rules.
      2. (b) We conduct periodic self-inspections of the status of personal information handling.
   4. (4) Human security control measures
      1. (a) We provide regular training to our employees on precautions regarding the handling of personal information.
      2. (b) We have defined rules regarding maintaining the confidentiality of personal information in our employment regulations.
   5. (5) Physical security control measures
      1. (a) For areas where personal information is handled, we control employee access, restrict the equipment that can be brought into the area, and implement measures to prevent unauthorized persons from accessing personal information.
      2. (b) We take measures to prevent the theft and loss of equipment used to handle personal information, electronic media, documents, etc., and implement measures to prevent personal information from being easily discovered if such equipment, electronic media, etc. are carried around, including transfer within the workplace.
   6. (6) Technical security control measures
      1. (a) We implement access control to restrict the scope of persons who handle personal information and the databases, etc. they can handle.
      2. (b) We implement mechanisms to protect information systems that handle personal information from unauthorized external access and unauthorized software.
   7. (7) Ascertaining the external environment

      When handling personal information outside of Japan (including cases where we consign the handling of personal information to a third party located outside of Japan), we implement security control measures after ascertaining the systems for the protection of personal information in the country where the personal data is stored.

9. 9. Responding to incidents such as leaks

   　In the event of an incident such as a leakage of personal information, we will report the incident to the regulatory authorities in accordance with the Act on the Protection of Personal Information and related guidelines, and take necessary measures to prevent similar incidents from occurring or recurring, in accordance with the instructions of the relevant regulatory authorities.

10. 10. Personal information protection manager

    　Director of the Information Security Office

11. 11. Inquiries

    　Please contact our Personal Information Hotline below for inquiries or complaints regarding the handling of personal information, and requests for Disclosure.

[Personal Information Hotline]
Company: Comisma Inc.
Contact: Director of Information Security Office
Address: 9th Floor, PMO Jimbocho, 2-10-4 Kanda-Jimbocho, Chiyoda-ku, Tokyo
E-mail：pms@comicsmart.co.jp

Established: February 1, 2013
Revised: January 1, 2016
Revised: February 1, 2017
Revised: January 1, 2018
Revised: January 1, 2020
Revised: April 1, 2022