Vision Co., Ltd. (hereinafter referred to as "the Company") and its subsidiaries and affiliates (hereinafter collectively referred to as "the Group") acquire and utilize personal information of all persons (including shareholders, customers and employees, and hereinafter referred to as "the Customer") related to our Group, and retain such personal information. This privacy policy, which we have established, is intended to clarify the purpose and method of acquiring and handling personal information by our group companies and to deepen their understanding of the rights of individuals with respect to personal information.

This privacy policy applies to everyone in our group. In addition to this Privacy Policy, our Group may establish regulations on the handling of personal information in accordance with individual circumstances. In this case, the applicable regulations shall prevail.

Our group acquires personal information about the individual. The personal information of customers that we acquire includes information provided directly by customers, information on the use of customers' services, and information obtained from third parties.

In the event that the acquisition of personal information by our group is subject to GDPR(General Data Protection Regulation = European General Data Protection Regulation, our group shall appropriately manage such personal information in accordance with GDPR. When the handling of personal information of our group is subject to GDPR, the following item number 19 is applied in preference to item number 1 through item number 18 for the handling of personal information of our group and the right of our person. Please refer to item number 19 below.

If the EU General Data Protection Regulation (the GDPR) might apply to the Company's acquisition of personal information, the Company will manage such personal information appropriately in accordance with the GDPR. With respect to the Company's handling of personal information and the rights of the Person in cases where the GDPR applies to the Company's handling of personal information, please refer to 19 below since the provisions of 19 below will take precedence over 1 to 18.

Our group shall acquire personal information (including information on individuals) mainly by the following methods, and use and store such information as personal data.

1. Method of obtaining directly from the person
2. Methods of acquiring from a third party
3. Methods of acquiring based on the use of our group's services, etc.
4. Methods of obtaining through Cookie（ ）or web beacons (including similar techniques, etc.)
5. Method of obtaining by recording a call
6. Method of obtaining by recording with photographs, images, etc.
7. Other methods of acquiring based on engagement with our group (including, but not limited to, stock acquisitions and employment)

Our group uses the acquired personal information for the following purposes.

1. Use for which the Purpose of Use is clearly Permitted from the Perspective of the Purpose of Acquisition of Personal Information
2. To provide products and services within our group
3. Provision of after-sales service concerning the preceding item
4. Contract Examination and Credit Examination, etc.
5. Collection of bills and preservation of receivables related to our Group businesses and other related charges (including cases where the handling of personal information is entrusted for billing and collection of various charges)
6. Study and develop new products and services related to our group businesses
7. Information on the products and services described in the preceding item
8. Advertising and Advertising
9. Training in sales and solicitation methods in our group business and employee training to ensure appropriate implementation
10. Market research and other research into our group businesses
11. Implementation of Offering Prizes and Campaigns
12. Registration and Use of Personal Information Credit Agencies
    1. Referring to a personal credit information institution and using personal credit information of customers registered for proper credit judgment and post-credit management
    2. Providing and registering the facts of transactions with customers with personal credit information agencies
13. Preparation of statistics and use of analysis results for business analysis
14. Response to disclosure requests, etc. based on the Personal Information Protection Law, and monitoring and auditing of the handling of personal information
15. CSR (Corporate Social Responsibility) Activities
16. Management of contractual relationships with business partners
17. Management of Shareholders
    1. For the exercise of rights and fulfillment of obligations under the Companies Act
    2. For the benefit of our position as a shareholder
    3. In order to implement various measures to facilitate mutual relations between our shareholders and us from the perspective of the members of the association and the association
    4. Preparation of Shareholder Data Based on Prescribed Standards Based on Various Laws and Regulations, etc.
18. Employment (including recruitment) and personnel management of employees, etc.
19. Employee benefits (including benefits and other benefits and operational management)
20. Management of Facilities and Equipment
21. Joint use
22. Provision to a Third Party
23. In addition, the scope necessary for the execution of the business pertaining to each of the preceding items.

The Group complies with laws, regulations, and other norms regarding the handling of personal information. The Group's handling of personal information is for the purposes of Section 3 (Purpose of Use of Personal Information). We will obtain, use, and provide personal information as appropriate for business purposes, and will not handle personal information beyond the scope necessary to achieve the specified purposes of use, except when permitted by laws, regulations or with the prior consent of the individual, and will take measures to ensure this. The decision as to whether or not to provide your personal information to the Company is at your own voluntary discretion. However, if we are not provided with the necessary information, we may be unable to provide services appropriately.
Additionally, as provided for under Section 2 (Acquisition of Personal Information), the Company may obtain information from users through the use of cookies and web beacons, in order to ensure the security of websites you visit and improve user service.

In order to improve the convenience of our website and our Group's services, maintain and improve the quality of our services, our Group may acquire personal information from business operators handling personal information, such as Cookie information, IP addresses, identifier information such as individual terminal IDs, and log information related to Internet use such as location information, browsing history and purchase history, as personal data. The purpose of use of personal information obtained as personal data shall be as described in Item 3 "Purpose of Use of Acquired Personal Information".

When acquiring Personal Information requiring Consideration, our Group shall obtain the prior consent of the Person. Provided, however, that this shall not apply where permitted by law.

The Group endeavors to grasp external factors regarding acquisition, use, storage, provision, deletion, and disposal, etc., and complies with the Act on the Protection of Personal Information, guidelines in the field of economic and industrial affairs concerning the Act, and other related laws and regulations. The Group also formulates rules concerning the handling of personal data, responsible persons and other persons in charge of handling personal data, and their duties, etc. in order to satisfy the requirements of these laws, regulations and guidelines. In addition to ensuring that Group employees comply with these rules, we take organizational, personal, physical, and technical safety management measures for the personal data, etc., we retain.

Our group may provide personal data to third parties only in the following cases:

1. You agree to this Privacy Policy. The details of our group's provision to a third party in the event of agreement are as follows.
   1. Items of Personal Data Provided by Third Parties
      All or part of the personal information obtained by our group
   2. Method of Provision to a Third Party
      1. Electromagnetic recording (including the method of delivering it by hand or sending it by mail using a recording medium, in addition to the case where it is provided in an intangible form by e-mail, etc.)
      2. In writing
   3. Methods of accepting the suspension of provision to a third party
      How to contact the reception desk described in Item 17 "How to accept disclosure, etc."
2. A warrant or other court decision, order or statute issued by a court
3. When it is necessary for the protection of life, body, or property of a person and it is difficult to obtain the consent of the person
4. Cases in which it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children and in which it is difficult to obtain the consent of the person in question.
5. Cases in which it is necessary to cooperate with a state organ, a local government, or a person entrusted thereby in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person in question is likely to hinder the execution of the affairs in question.

6. In order to display online advertisements tailored to customers on other companies' websites, we may disclose or provide personal information to entrusted advertising distribution providers through secure means.

   These providers may include businesses located in the states of California and Washington, USA (For information on the protection of personal information, please see the following link: USA (Federal, California, Washington)).

   Please note that advertising delivery by advertising distribution providers can be halted by opting out through the opt-out page of the advertising distribution provider.

Our Group may entrust the handling of personal data (excluding personal data including personal information requiring consideration; the same shall apply hereinafter in this section) to a third party to the extent necessary for the achievement of the Purpose of Use. In this case, our group will select an appropriate counterparty, conclude an appropriate agreement to ensure that such personal data is handled appropriately by the outsourcee, and grasp the status of the handling of personal data at the outsourcee in a timely manner.

All or part of the personal data held by any of our groups is for the purpose of safer personal data management and cross-sectional service provision by our group, and we are consolidated with us as the person responsible for personal data management and shared among our groups.
Please refer to Item 18 "Overview of Our Company and Our Group Companies" for information on our Group companies.

1. The items of personal data to be used jointly are as follows.
   1. Name, address, date of birth, gender, telephone number, e-mail address, place of work, etc.
   2. Address, Financial Institution Account Number, Name, Credit Card Number, etc. Required for Charge Billing
   3. Contents of application services and inquiries, etc.
   4. Service usage fees, invoices, payment status, payment methods, etc.
   5. Information on the main body of the communication device (serial number, model name, model number, terminal-specific ID, etc.)
2. The scope of joint users is the parent company, subsidiaries and affiliates of the Company, as listed under Section 18.
3. The purpose of use of personal information to be shared is as described in Item 3 "Purpose of use of acquired personal information".
4. The method of obtaining personal information for shared use is as described under Section 2 (Acquisition of Personal Information).
5. The entity responsible for the management of personal data to be used shall be Vision Inc. For details, please refer to the bottom of this Privacy Policy.

When preparing anonymized processing information, our group processes and handles it appropriately in accordance with relevant laws and regulations. In addition, when the anonymized processing information is created, the items of personal information included and the safety measures taken shall be announced.

When our group receives anonymized processing information, we do not collate other information and take appropriate safety management measures while appropriately handling anonymized processing information.

If a person wishes for us to disclose his or her own information (or be notified of the purpose of use of retained personal data) with regard to personal data retained by the Group, or records of provision to third parties, we respond to such requests within a reasonable period and to a reasonable extent, after first confirming that the request was made by the individual. In some cases, we may not be able to respond to requests for disclosure due to applicable laws and regulations.

In the event the Company wishes to correct, add, or delete personal data in the possession of the Group, the Company will correct, add, or delete such information within a reasonable period and within the scope of time if there are any matters that differ from the facts after confirming the identity of the applicant.

In the event you wish to discontinue using or delete personal data in the possession of our Group and fall under any one of the following items, we shall confirm that the person who has made the request is the identity of the person and, in principle, suspend or delete the use of the personal data to the extent necessary to prevent the infringement of the rights and interests of the person. Provided, however, that the Company may not comply with the request for suspension of use or elimination pursuant to laws or may substitute for suspension of use or elimination due to the implementation of alternative measures permitted by laws and regulations.

If personal data is suspended or deleted in whole or in part, service that meets your request may not be able to be provided unnecessarily.

1. When our group uses personal information beyond the scope of the Purpose of Use stated in Item 3 "Purpose of Use of Acquired Personal Information" without the consent of the Person
2. In the event our Group acquires such Personal Information in an unlawful or fraudulent manner
3. When our group improperly provides personal information to a third party
4. Use of Retained Personal Data in a manner that encourages or threatens to induce illegal or unjust conduct
5. When it is no longer necessary to use retained personal data
6. In the event of any leakage, loss, or damage to the retained personal data
7. Otherwise, the rights or legitimate interests of the Principal may be impaired.

We may provide action targeting advertising services in conjunction with personal information in order to effectively distribute advertisements in application services (hereinafter referred to as "Applications") provided by us on smartphones and other devices. If you want to disable event-targeting advertising, visit the following page and follow the instructions.

1. Opt-out on iOS terminals
   Our application uses Identification For Advertisers (hereinafter referred to as "IDFA") as advertising IDs.
   If you want to restrict advertising using IDFA, please refer to the following page and set up according to the description.
   https://support.apple.com/ja-jp/HT202074
2. Opt-out in Android terminal
   Our application uses Advertising ID (hereinafter referred to as "AAID") as advertising IDs.
   If you want to restrict advertising using AAID, please refer to the following page and set up according to the description.
   https://support.google.com/googleplay/answer/3405269?hl=ja

The following apps are used by us as advertising IDs, and the following businesses are used for advertising services based on the use of advertising IDs. If you want to restrict advertisements using advertisement IDs, you must also perform the following settings and procedures in addition to the above.

Application name: Global WiFi

Company name: Repro Corporation
Explanation: The Global WiFi Application has the function of acquiring system log information, terminal-specific information, advertising ID, etc. using Repro which is a push notification analysis and delivery service provided by Repro Corporation ("Repro").
In order to provide information that we consider beneficial to our customers, we transmit system log information, terminal-specific information, advertising ID, and other information to Repro companies. However, it is not possible to identify individuals by the terminal's system log information, terminal-specific information, advertising IDs, and others. Under Repro's responsibility, Repro manages terminal system log information, terminal-specific information, advertising IDs, and so on, in accordance with Repro's policy.

For more information, see the following pages:

Repro Privacy Policy https://repro.io/company/legal/privacy/
You can opt out for Repro to collect data about your use (terminal system log information, terminal-specific information, advertising IDs, etc.) and process the data. To do so, contact the e-mail address listed on Repro's website.

To ensure that personal information is handled appropriately, the Company will educate all officers and employees on the protection of personal information and conduct regular audits on the state of handling of information, put this Privacy Policy (Personal Information Protection Policy) into practice, and work to continuously improve its personal information protection management system in a timely and appropriate manner, based on actual conditions and changes in the environment surrounding the Group and the actual situation. The Company will establish and work to continuously improve rules and systems to prevent risks such as leaks, loss, and damage to personal information, by taking reasonable safety measures. In the event of such a risk occurrence, we shall take corrective actions immediately.

The Group has appointed an Information Manager for the management of personal information. For inquiries, complaints, and consultations, etc., regarding the contents of this Privacy Policy and the handling of personal information, etc., with regard to Sections 12, 13, and 14, please contact the following inquiry desk.

≪ Contact ≫
Address: SHINJUKU EASTSIDE SQUARE 8F 6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan
Vision Group Personal Information Contact
Tel. 03-6834-5845
Shinichi Nakamoto, Information Manager
The reception time shall be from 9:00 a.m. to 6:00 p.m. on weekdays (*) for any contact point.
※Excluding weekends, holidays, and year-end and New Year holidays.

Please refer to the following for the company outline of our company and our group companies, such as name, address, and representative.

• VISION INC.（Our) : https://www.vision-net.co.jp/company/com_data.html
• BEST LINK INC. : https://bestlink-net.co.jp/#company
• MEMBERS NET INC. : http://membersnet.co.jp/information/
• ALPHA TECHNO INC. : https://alphatechno.jp/company/
• BOS INC. : https://b-os.co.jp/#company
• Vision Ad INC. : https://visionad.co.jp/#company
• Vision Technologies Inc. : https://vision-dm.co.jp/company/
• Adval Inc. : https://adval.jp/company
• Koshikano Onsen Inc. : https://koshikano-onsen.com/

If you have your habitual residence in the European Economic Area, this Chapter VIII shall prevail against Chapters I to VII above with respect to our processing of personal data and data subject rights.

Summary of PRIVACY NOTICE

This summary Privacy Notice ("Summary Notice") will provide you with a summary of the accompanied, detailed Privacy Notice (hereafter "Full Notice", together "Summary and Full Notice") on the data processing activities of Vision Inc., located at SHINJUKU EASTSIDE SQUARE 8F 6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan ("Vision", „our", "we" or "us") with respect to individually identifiable information ("Personal Data") about users of our site (https://www.vision-net.co.jp/) ("Website").

Scope of applicability
This Summary and Full Notice applies to you if you are a user of our Website.

Processing of your Personal Data (categories of Personal Data)
We process the following of your Personal Data collected during your visit of our Website: your full name, your date of birth, your gender, your country, your postal address including your street and number, city, zip code, phone number, e-mail address, your IP-address, host name, user agent, browser identification, referrer, the date/time of your access to the Website, and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you. For more details see 1. of the Full Notice or click here.

Processing purposes
We process your Personal Data for the following purposes: providing WiFi router rental services, billing and collecting fees for our services, granting prizes and conducting campaigns, introducing goods or services of us or our business partners, managing and administrating your account, get in contact with you concerning your queries, security and fraud prevention, conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and service. For more details see 2. of the Full Notice or click here.

Legal justifications for the processing of your Personal Data
One of the key privacy law requirements is that any processing of Personal Data has to have a legal justification. We generally use the following legal justifications: (1) You have given your consent to the processing (Art. 6(1)(a) GDPR; "Consent Justification"), (2) the processing is necessary for (a) the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR; "Contract Performance Justification") (b) compliance with a legal obligation (Art. 6(1)(c) GDPR; "Legal Obligation Justification") and (c) realizing a legitimate interest (Art. 6(1)(f) GDPR; "Legitimate Interest Justification"). For more details and the matching of purposes and corresponding legal justifications see 3. of the Full Notice or click here.

Data transfers and recipients and legal justification for such transfers
We transfer your Personal Data to our service providers, and, in accordance with applicable law, other governmental authorities, courts, external advisors, and similar third parties, some of the aforementioned recipients located in jurisdictions outside the EU. For more details see 4. of the Full Notice or click here.

Retention periods for and deletion of your Personal Data
Your Personal Data will be deleted once they are not any longer needed for the purposes motivating their original collection or as required by applicable law. For more details see 5. of the Full Notice or click here.

Your statutory rights
You have a number of rights with regard to the processing of your Personal Data, each as per the conditions defined in applicable law, such as the right to have access to your Personal Data, to have them corrected, erased or handed over. Please refer any of your questions to [email protected]. For more details see 6. of the Full Notice or click here.

Changes of this Summary and Full Notice as well as further notices
This Summary and Full Notice are subject to change. You will be notified adequately of any such changes. Further, you will be notified adequately through further relevant privacy notices (e.g. for specific purposes) in case such is not covered by this Summary and the Full Notice.

• How to contact us

If you wish to exercise your data subject rights or if you have any other questions concerning this Summary and Full Notice, please address your request to us, who can be contacted at:
Vision Group Personal Information Contact,
SHINJUKU EASTSIDE SQUARE 8F 6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan,
Email: [email protected]
Tel: 03-5325-0200.

The reception time for all counters is from 9 AM to 5 PM on weekdays except for national holidays in Japan.

• Full Notice

We are delighted about your interest in our Website. Your privacy is important to us. Hereafter, we provide you with detailed information on dealing with your personal data on this Website.

This Full Notice is applicable for the Website only. Other Vision websites may be governed by other privacy policies. Please also note that parts of the Website may contain links to such other Vision websites or third party websites which may be governed by other privacy policies.

This Website uses cookies. For further information please read our cookie policy - which you will find here.

1. Categories of Personal Data
   We process the following Personal Data about you (hereinafter jointly "Your Data"):
   1. Your full name, your date of birth, your gender, your country, your postal address including your street and number, city, zip code, phone number, e-mail address (hereinafter jointly "Contact Data");
   2. Your IP-address, host name, user agent, browser identification, referrer, and the date/time of your access to the Website(hereinafter jointly "Technical Data"); and
   3. Any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you (hereinafter jointly "Form Data").
2. Processing purposes
   We process Your Data to the extent permitted or required under applicable law, for the following purposes:
   • to perform a contractual obligation under contracts between you and Vision or to take steps at your request prior to entering into a contract with us (hereinafter "Contract Purposes");
   • to provide the Website in an optimized way for you and to currently enhance the user experience of the Website (hereinafter "Quality Purposes");
   • to send you marketing materials, such as newsletters to provide you with the latest information about our products and services which might be of interest to you (hereinafter jointly "Marketing Purposes").
3. Legal justification for the processing of Your Data
   Generally, the provision of Your Data is voluntary. However, if you do not provide Your Data, the use of the Website may be different.
   Particularly, if you do not provide Contact Data, we do not provide our Wi-Fi router rental services to you.

   Furthermore, We rely on the following legal justifications for the processing of Your Data:

   YOUR DATA

   • Processing purposes

     Contract Purposes
     Quality Purposes
     Marketing Purposes

   • Categories of Your Data involved

     Contact Data
     Form Data
     Technical Data
     Contact Data
     Marketing Data
     Form Data

   • Legal basis

     Contract Performance Justification
     Legitimate Interest Justification
     Consent Justification

4. Data transfers and recipients and legal justification for such transfers
   1. Recipients
      1. Third parties: We may transfer Your Data to governmental agencies and regulators, courts, and government authorities, all in accordance with applicable law based on Legal Obligation Justification and to external advisors acting as controllers (e.g., lawyers, accountants, auditors etc.) based on Legitimate Interest Justification.
      2. Service providers: We contract with third party service providers as part of our normal business operations to provide the Website and related services to you (i.e., cloud service providers, call center service providers, and logistic companies).
   2. Cross-Border Data Transfers
      1. We may transfer Your Data outside of the country you are located. Some recipients of Your Data are also located in another country for which the European Commission has not issued a decision that this country ensures an adequate level of data protection as of the date of this Privacy Notice, namely: Japan.
      2. By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Art. 46(5) GDPR, we have established that all recipients located outside the EEA will provide an adequate level of data protection for Your Data and that appropriate technical and organizational security measures are in place to protect Your Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law. Such agreements are accessible upon request from [[email protected]].
5. Retention periods for and deletion of Your Data
   1. Your Data processed for the purposes hereunder will be stored only to the extent necessary. If a judicial or disciplinary action is initiated, Your Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
   2. In principle, we will retain Your Data as long as required or permitted by applicable law. Afterwards, we will remove Your Data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.
6. Your statutory rights
   Under the conditions set out under applicable law (i.e., the GDPR), you have the following rights:
   1. Right of access: You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes - inter alia - the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed.
      You have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, wemay charge a reasonable fee based on administrative costs.
   2. Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
   3. Right to erasure (right to be forgotten): You have the right to ask us to erase your Personal Data.
   4. Right to restriction of processing: You have the right to request the restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
   5. Right to data portability: You have the right to receive the Personal Data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another entity without hindrance from us.
   6. Right to object:

      You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by Us and We can be required to no longer process your Personal Data. In general, you have the right to object to our processing of your personal data for direct marketing purposes. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by Us. Exercising this right will not incur any costs. Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

      Please note that the aforementioned rights might be limited under the applicable national data protection law. We remain the universal point of contact for your execution of these rights.

      Please refer any of your questions to [email protected]

      In case of complaints you also have the right to lodge a complaint with the competent supervisory authority, in particular in the member state of your habitual residence or alleged infringement of the GDPR.

The Privacy Policy is effective from [2018/5/26].
Incidentally, we may change the Privacy Policy along with the establishment and amendment of laws, regulations and various guidelines. We will publish any changes to the Privacy Policy on our website.

Name, Location and Representative of the Company
Vision Inc.
Shinjuku Eastside Square 8F, 6-27-30, Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan
Representative Director COO　Kenji Ota

Personal information manager
Shinichi Nakamoto, Vision Inc.
0120-322-440