Action History Information Protection Policy

What is action history information?

As used herein, the term “action history information” is information about the history of user actions including the browsing of websites or the use of applications related to the various services ValueCommerce Co., Ltd. operates (the “Company’s sites” hereafter) and information about the attributes of individuals (“action history information, etc.” hereafter) that does not make it possible to identify any specific individual.
Note that action history information is not information that in itself enables the identification of a specific individual; however, ValueCommerce Co., Ltd. (hereinafter, the “Company”) will handle information that can be readily collated with other pieces of information and by doing so it is possible to identify a specific individual as personal information.

For the avoidance of doubt, the English version of this Action History Information protection 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/privacy_action/)

About the use of identifiers

The Company uses identifiers including cookies (hereafter “Cookies, etc.”) with the aim of analyzing the behaviors of users visiting its services to increase the convenience of the services, measure the effectiveness of advertisements distributed by the Company, and display content tailored to users.
Users can disable cookies by configuring the settings of their browser software. Please check with the company that provides your browser software for more details.

【Action history information, etc.】

(1) Website browsing history and history of user actions on the Company’s sites or applications
(2) Advertisement display/click history
(3) Product purchase history
(4) Information and the like concerning fields of individual interests classified by unique criteria
(5) Information about personal attributes or devices used

Purposes for acquiring action history information, etc.

The Company will acquire, store, and use action history information, etc. for the following purposes. In accordance with the regulations of the Company, the acquired information will not be used for any purpose other than the following.

【Purposes of use】

(1) Analysis of user attributes, actions, and the like
(2) Display of content and the like in accordance with user attributes and actions
(3) Measurement of effects of the Company’s services and their functions
(4) Provision and development of our services and functions
(5) Provision of results of the analysis to third parties and the like
(6) Optimization of advertisement delivery for promotional uses

Provision of action history information, etc. to third parties

The Company is entitled to provide action history information to any third party. The Company will request these third parties enter into an agreement including a non-disclosure clause with the Company or agree to regulations or other matters stipulated by the Company, and will perform the necessary and appropriate supervision to ensure the third party manages the personal information to ensure its security.

Sending User Information Outside the Company

1. About the analysis services using action history information, etc.

The Company uses the analysis services stated below. For the data collected by each service, please refer to the following page：

(1) Google Analytics

Sent to: Google LLC

Handling of collected data：
Service name	Information to be sent to	Details of information to be sent	Purposes of use
Google Analytics	Google LLC and its affiliates	Information about systems, devices, networks, and communications that are usually used for Internet communications Location information Data on behaviors on websites/applications Data on viewed pages User identifiers (e.g., cookies and device identifiers)	To analyze trends and history of viewing by users

（source）https://business.safety.google/intl/ja/tba-jp/

Click here to stop information transmission：
https://support.google.com/analytics/answer/181881?hl=ja

(2) Microsoft｜Clarity

Sent to: Microsoft
Handling of collected data：https://privacy.microsoft.com/ja-jp/privacystatement

2. Evaluation of distributed advertising using action history information, etc.

The Company shares action history information, etc. with the ad verification vendors stated below in the ValueCommerce affiliate program that the Company operates.

Shared with：
・Spider Labs, Inc.
・Momentum Inc.

3. Action history information, etc. on the Company’s website

(1) The Company links action history information, etc. collected through its websites with services provided by the following companies.

① SATORI Inc

The Company uses the marketing activity support service of SATORI Inc.
Of the customer’s action history information, etc. obtained on the Company’s website, the accumulation of action history information, etc. obtained via SATORI, a service of SATORI Inc., can be disabled (opted out of) on the opt-out page below.

Opt-out page of SATORI：https://satori.marketing/optout/
Purpose of use of information on SATORI: providing a service that makes possible the measurement of advertising effectiveness and improvement of advertising, etc.
Detailed purpose of use：https://satori.marketing/privacy-policy/

② Cloud CIRCUS Inc.

On its websites, the Company uses BowNow, the marketing automation tool provided by Cloud CIRCUS Inc.
For more information, click the link below to read the pages regarding the handling of collected data.
If users wish to disable measurement by BowNow, they have only to click the URL below. This completes the opt-out process. Users will need to set this option again after changing their usage environment, for example, changing their browser, deleting cookies or replacing their computer with a new one.

Purposes of use by Cloud CIRCUS Inc.：

(1) To generate statistical data
(2) To implement various analyses, conduct questionnaire surveys, and analyze survey results for product development, the improvement of functions, and/or the improvement of service quality
(3) Collaborative industry-academia research

Details of the handling of collected data：https://cloudcircus.jp/bownow_privacy/
The opt-out page：https://bow-now.jp/optouted/?bownowtrace=optout

(2) If you do not want content to be displayed based on the action history information, etc. collected and accumulated by the Company, execute the procedure set out in the website below. If the procedure to stop the display of content based on action history information, etc. is invalidated due to the deletion of cookies or changes to PC settings or browser settings, etc., content reflecting action history information, etc. may be displayed again.
https://www.valuecommerce.ne.jp/ecsite/ipush/optout.html

Ⅳ.Use of action history information, etc. in the Company’s media business

The Company uses action history information, etc. in its media business, Value point club and Vlink, for the ValueCommerce affiliate program.
In addition, Vlink uses information about action history, etc. to display users’ favorites.

Ⅴ.About advertisement delivery

The Company conducts targeted advertising that displays advertising based on website browsing information and other data using the services provided by the following affiliates. If you wish to stop such advertising, suspend (opt out of) the targeted advertising for each of the affiliates’ services.

Affiliates

Google LLC: Handling of information： https://policies.google.com/technologies/partner-sites?hl=en
About stopping information transmission：https://adssettings.google.com/anonymous?hl=en&ref=mac-hub
Yahoo! JAPAN: Handling of information：https://www.lycorp.co.jp/en/company/privacypolicy/
About stopping information transmission：http://btoptout.yahoo.co.jp/optout/preferences.html
LINE Advertising: Handling of information：https://www.lycorp.co.jp/en/company/privacypolicy/
About stopping information transmission：https://optout.tr.line.me/
Facebook Japan K.K. (FacebookUPPA): Handling of information：https://www.facebook.com/privacy/center/?locale=en_EN
About stopping information transmission：https://www.facebook.com/about/ads
Facebook Japan K.K. (Instagram): Handling of information：https://www.facebook.com/privacy/center/?locale=en_EN
About stopping information transmission：https://www.instagram.com/about/legal/privacy/
X Advertising: Handling of information：https://business.x.com/en/help/ads-policies/product-policies/interest-based-opt-out-policy
About stopping information transmission：https://help.x.com/en/safety-and-security/privacy-controls-for-tailored-ads

The Company delivers advertising using the services provided by the above affiliates based on customers’ email addresses that are encrypted and user identification information verified by each affiliate. Email addresses subject to verification are encrypted and are not provided to the affiliates and other third parties. If you wish to stop the services, suspend (opt out of) each of the affiliates’ services.

VALUE COMMERCE