Privacy Policy

ValueCommerce Co., Ltd. (hereinafter, the “Company”) provides comprehensive consulting services with a focus on affiliate marketing services, including search engine marketing services and system integration services specialized in accommodations. As a result, there are many instances where we deal with a range of information about clients, media operators, and accommodation operators, and we believe that we bear the important social responsibility to acknowledge the importance of this information and handle the information in an appropriate manner.

Regarding the protection of personal information that may make it possible to identify a private individual, we declare that we will specify, implement and maintain the following items:

  1. In acquiring personal information, the Company will specify the purpose of its use as clearly as possible, and will acquire personal information only to the extent necessary to achieve this purpose.
  2. If personal information is to be acquired directly from the individual in writing, the Company will provide the Company name, the name and the contact address of the Personal Information Protection Administrator, and the purpose of use, and will acquire only the necessary personal information.
  3. The use of personal information will be limited to the extent the individual has consented to the purpose of use. Furthermore, the Company will establish procedures for implementing the necessary measures to prevent its use outside the purpose.
  4. The Company will manage the personal information it possesses accurately and in accordance with the latest methods, in keeping with the purpose of use, only to the extent necessary, and will establish reasonable safety measures to prevent the leak, loss or damage of the personal information to and to correct any leak, loss or damage.
  5. The Company will manage the personal information appropriately and does not disclose or provide personal information to third parties without the consent of the individual.
  6. When the Company is to outsource the processing of personal information to an external contractor, the appropriate management will be undertaken by contractually obligating the contractor to protect against leaks or the provision of the information to third parties.
  7. Complaints and requests for consultation regarding the protection of personal information are handled by the Company’s inquiry section.
  8. The Company will comply with the laws and guidelines established by the government and other regulations that apply to the protection of personal information.
  9. The Company will establish a management system regarding the protection of personal information, will review it regularly, and will continuously improve it.

For the avoidance of doubt, the English version of this Privacy Policy serve only as a translation, and in the case of any conflict or inconsistency with the Japanese original, the Japanese original shall prevail.

(Japanese original: https://www.valuecommerce.co.jp/privacy_policy/)

Established: November 1, 2011
Latest revision: April 23, 2025
ValueCommerce Co., Ltd.
Jin Kagawa, Representative Director,
President and CEO

Inquiry section for matters concerning the protection of personal information

Please contact the following to complain, consult, or inquire about disclosure or other matters in person, regarding the handling of personal information and the personal information protection management system. The Company will respond promptly and appropriately.

Address:
Personal Information Protection Administrator,
ValueCommerce Co., Ltd.
21F Kioi Tower, Tokyo Garden Terrace Kioicho,
1-3 Kioicho, Chiyoda-ku, Tokyo

Purpose of Use for the Personal Information Held by the Company and the Personal Information Subject to Disclosure

Ⅰ.Name, address and representative of the entity handling personal Information

21F Kioi Tower, Tokyo Garden Terrace Kioicho,
1-3 Kioicho, Chiyoda-ku, Tokyo
Representative Director, President and CEO: Jin Kagawa.

Ⅱ.Matters Concerning the Purpose of Use for Personal Information Held by the Company

The Company uses the personal information it holds for the following purposes.

1. The personal information of individuals applying for employment at the Company in the hiring and selection process (resumes, etc.)

Disclosure: Yes

The information is used for hiring and selection procedures concerning the individual. Also note that the Company will take responsibility for the disposal of personal information such as resumes concerning any individuals who are not hired for employment.

2. The personal information of employees (resumes, etc.) when deemed necessary for the business purposes of the Company

Disclosure: Yes

The information is used for personnel,administrative and accounting procedures concerning the individual. The purpose of use will be specified at the time of collection, consent for collecting the information will be obtained from the individual, and the information will be used within that stated purpose of use.
The Company will return the personal information of an employee who has resigned to that individual, or take responsibility for disposing of the information.

3. Customer information relating to the services of the Company

(1) The Company will use the following customer information relating to its services for the purposes prescribed in (2) of 3 below.

  • ・Personal information obtained in connection with agreements on the purchase or use of or other matters related to the services of the Company
  • ・Personal information concerning people who have inquired about the Company’s services

The Company may use action history information obtained through cookies and other methods in its services by connecting it with customers’ personal information within the scope of the purpose of use.


(2) The Company will use customer information relating to its services for the following purposes.

  • 1） To contact and notify customers regarding the Company’s services (including sales activities)
  • 2） To contact customers regarding transaction evaluations
  • 3） To carry out billing and payment procedures in connection with the Company’s services
  • 4） To provide and operate the Company’s services
  • 5） To send information and notices about campaigns and questionnaires in connection with related services and products offered by partner companies
  • 6） To respond to inquiries from customers (including identity verification)
  • 7） Purposes incidental to the purposes of use above

(3) The Company uses the customer information prescribed in (1) of 3 concerning some of the services given below for the following purposes in addition to the purposes of use defined in (2) of 3.

(Applicable services)

  • ・Affiliates in the affiliate program
  • ・Value Point Club
  • ・monicam, Castbook
  • ・Dynalution
  • ・Direct In

(Purposes of use)
For user analysis and advertisement delivery


(4) Provision to third parties

Unless any of the following 1) to 4) apply, the Company will not disclose or provide personal information provided by customers to a third party without the permission of the individual. The Company may provide personal information of individuals to outsourcing companies to achieve the purposes of use above.

  • 1） When required by laws or regulations
  • 2） When the provision is required for protecting human life, body or property and it is difficult to obtain the approval of the individual
  • 3） When it is especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the approval of the individual
  • 4） When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by laws and regulations, and obtaining the approval of the individual is likely to impede the execution of such affairs

4. Visitor Management Register (History of Visitors) with Information Visitors to the Company Have Entered as Part of Entry Procedures

Disclosure: Yes

The information will be used to ensure the Company security (office entry and exit control).

5. Personal Information Regarding People Who Have Sent Inquiries to the Company from its Website (History of Inquiries)

Disclosure: Yes

The information will be used to confirm the details of an inquiry and to respond to it.

6. Personal Information of Persons Who Have Applied for Investor Briefings or Meetings

Disclosure: Yes

The information will be used for the following purposes.

  • 1） To send information about the investor briefing or meeting
  • 2） To send investor materials or questionnaires
  • 3） To manage the results of IR activities at the Company

Ⅲ. Joint use

To provide Retail Linker, the Company will jointly use personal data of individuals, that is, the information as set forth in (1) of 3, II. Matters Concerning the Purpose of Use for Personal Information Held by the Company above to achieve the purposes of use set forth in (2) of 3 within the scope described below.

（１） Personal data that will be jointly used

Name, e-mail address

（２） Scope of companies making joint use

Geniee, Inc.

（３） Purpose of use by companies making joint use

Please see the purpose of use described in (2) of 3, II. Matters Concerning the Purpose of Use for Personal Information Held by the Company above.

（４） Name and address of the person responsible for management of personal data and the name of representative

ValueCommerce Co., Ltd. (For information about ValueCommerce Co., Ltd., please see matters described under “1. Name, address and representative of the entity handling personal Information” and “Overview” under Company Profile.)

Ⅳ.Matters Concerning Procedures to Respond to Requests Regarding Personal Information Subject to Disclosure Including Notification of Purpose of Use, Disclosure, Amendments, Additions, Deletions, Cessation of Use, Erasure or Cessation of Provision to Third Parties (“Disclosure, etc.,” hereafter)

– Identifying the personal information held on an individual to whom a disclosure, etc. request applies

“Personal information subject to disclosure” refers to personal information that the Company possesses and for which the Company has the authority to respond to all requests from an individual to whom the information pertains regarding its disclosure, amendment, addition, deletion, cessation of use, erasure or cessation of provision to third parties.

– Method for request for disclosure, etc.

To request disclosure, etc. please contact the inquiry desk for personal information protection.
Please note in advance that this will involve personal identification.

Ⅴ. Measures taken for the secure management of retained personal information

The Company will take necessary measures to securely manage the personal information of customers. Details are as follows.

1. Formulation of Basic Policy

To ensure that personal data is handled appropriately, the Company has a basic policy in place to cover matters such as compliance with laws and regulations and a point of contact for dealing with questions and complaints.

2. Systematic Security Measures

We have established a person responsible for the handling of personal data and we have also clarified the employees who handle personal data and the scope of personal data handled by these employees, and developed a system for reporting to and liaising with the person responsible in the event of discovery of an actual or suspected breach of laws or privacy regulations. We also carry out self-inspections on a regular basis to assess the handling of personal data and are audited by other business units and external parties.

3. Human Security Measures

The Company regularly provides training to employees on matters to be considered when handling personal data. In addition, its work rules include matters relating to the confidentiality of personal data.

4. Physical Security Measures

In areas where personal data is handled, we restrict employee access and the equipment which can be brought in and we also take measures to prevent unauthorized persons from viewing personal data. In addition, we take measures to prevent the theft and loss of equipment, electronic media and documents containing personal data. Moreover, when carrying such equipment, electronic media or documents around, such as when moving between offices, we take measures to ensure they cannot be easily accessed.

5. Technological Security Measures

We use access control to limit the scope of persons in charge of handling personal information and the scope of the personal information database they handle. Moreover, we have adopted various defenses to protect information systems containing personal data from being hacked or infected by malware.

Ⅵ.Measures for overseas outsourcing

The Company may outsource part of its operations (example: construction, operation and development of infrastructure) that are necessary for providing its services, to third parties. In doing so, all or part of personal information is entrusted to outsourcing service providers, including companies located in the following countries or regions. These outsourcing service providers access personal information to the minimum extent necessary for performing operations on the Company’s behalf and do not use personal information beyond the scope of outsourced operations. The Company complies with applicable laws, screens the eligibility of outsourcing service providers, prescribes matters regarding confidentiality in contracts, and creates a system under which outsourcing service providers comply with frameworks for personal information protection in their respective counties of domicile and which ensures proper management of personal information.

Transfer destination: Vietnam

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