Privacy Policy

Handling of Personal Information for “Ocean Dict.”

8-17-1 Nishishinjuku, Shinjuku-ku, Tokyo
SEPTENI INCUBATE, INC.
Tadahiro Matsuda, President

SEPTENI INCUBATE, INC. (the "Company," "we" or "our") is committed to the appropriate acquisition and use of information relating to End User ("End User", "you" or "your" ) of "Ocean Dict." (the "Service") and will handle it as follows. Any matters not stipulated in these handling rules shall be in accordance with the "Handling of Personal Information".

1. Acquisition on Personal Information

(1) The Company shall acquire personal information or personally referable information* (hereinafter referred to, collectively, as "personal information, etc.,") in relation to its business operations using any of the following methods.

The acquisition methods	Applicable or not
a. Direct acquisition, from the individual in question E.g.: We acquire personal information from the individual by them filling out a paper form, or by direct entry into a website form.	✔
b. Indirect acquisition, from the individual in question E.g.: We acquire personal information, etc., published in a publication or on the internet.	✔
c. Direct or indirect acquisition, from a website operated by the Company E.g.: We acquire site usage history automatically via tags set on a website operated by the Company.	✔
d. Indirect acquisition from a third party E.g.: We acquire personal information via a data management platform or social media.	✔

(2) The Company may acquire personal information, etc., by methods that may not be easily perceived by the individual in question. Please click here for information regarding the transfer of End User information to third party server* and use of cookies on our website(s) and application(s) (if any) related to the Service.

*About personally referable information
“Personally referable information” means information relating to an individual which does not fall under the categories of personal information, pseudonymously processed information and anonymously processed information. It does not include statistical information.

E.g.: Postal (zip) codes, email addresses, gender, occupation, hobbies and interests, customer ID numbers, information stored in cookies, IP addresses, device ID numbers, advertisement identifiers (AAID/IDFA), other identifiers and location data, browsing histories, purchasing histories and other log data pertaining to Internet usage, etc.

The Company acquires (and handles) any personally referable information as personal information if it can be readily collated with other information and thereby identify a specific individual.

*What is "transfer of End User information to third party server"?
"Transfer of End User information" means that End User information is transferred to the third party’s server without End User’s intent when End User visits or uses the website(s) and the application(s).

2. Purpose of Utilizing Personal Information

Personal information, etc., that the Company acquires and the purpose(s) of utilizing such personal information, etc. are as follows.

Personal information, etc.	The purposes of utilizing personal information, etc.
Account name and ID of the SNS (X (formerly Twitter)/Discord, etc.) account associated with the Service and information relating to the SNS account.	To take action to resolve End User’s login problems or problems with the Service. To perform maintenance of the Service, such as troubleshooting. To contact End User as necessary in relation to the contents of the Service and the amendment or abolition of rules and regulations such as the Terms of Use. To identify End User who have violated the Terms of Use or used the Service for other unauthorized and unreasonable purposes, and to take necessary measures in accordance with the Terms of Use, such as refusing their use of the Service. To record, confirm and reply to enquiries. To analyze the information obtained and to improve the Service and develop new functions in accordance with interests and preferences. To monitor and improve the effectiveness of campaigns and to optimise the distribution of campaigns. To provide information about events and campaigns organised or sponsored by the Company or its group companies. To compile statistical information and to prepare marketing materials using such statistical information.
Wallet address on the blockchain and information related to the wallet address.
Mail address
The time zone of the browser.
Action histories, including browsing histories, etc. on the site relating to the Service.
Campaign details and other information that you enter.

3. Use of Personally referable Information Provided to the Company by Third Parties in Conjunction with Personal Information

The Company may make use of personally referable information provided to it by third parties in conjunction with personal information already in the possession of the Company. Please click here for details regarding such cases.

4. Provision and Entrusting the Handling of Personal Information to Third Parties

(1) The Company may provide personal Information to third parties within the extent permitted by law (including when obtaining the consent of the individual in question, and performing procedures required by law.)
(2) The Company may entrust the handling of personal information to third parties ("contractors"), within the necessary scope to achieve the purpose(s) of utilizing Personal Information described in Section 2. In such cases, the Company shall enter into an agreement with the contractor, who must meet selection criteria for contractors, and appropriately manage work performed by the contractor.
(3) Third-party providers and contractors may include third parties located outside of Japan (*).
*The Company provides details regarding cases where we provide, or entrust the handling of, personal information to third parties located outside of Japan.

5. Others

Any matters not provided in these handling rules are governed by the "Handling of personal data etc.". If there is any conflict between the said handling rules and these handling rules, these handling rules will take precedence.

Established November 7th, 2022

Revised October 27th, 2023

Revised December 21th, 2023

This English translation is for reference purposes only and not a legally definitive translation of the original Japanese texts. If a difference arises regarding the meaning herein, the original Japanese version shall prevail as the official authoritative version.

Use of cookies and transfer of End User information to third party

1. Use of Cookies

The Company may use cookies (information that is sent from the server to the browser of End User and is stored on the computer of End User so the server can identify End User) and access logs to improve the convenience of users, enhance the website, and prevent unauthorized access. The information that is obtained and used includes the IP address, the type of the browser, and the pages that are viewed. End User can set their browser to refuse cookies. If End User refuses cookies, it may not use all or part of the Company’s services that it wants to receive.

2. Transfer of End User information to third party server

Ad technologies are used on the website(s) and application(s) (if any) associated with the Service. The information collected by such ad technologies will be transferred to the vendor that provides such ad technologies and will be handled and managed in accordance with the vendor’s privacy policy. The Service name/vendor name, End User information collected and transferred to the third party, purpose of use and privacy policy, etc. for each technology follows. Such ad technologies may include those with an opt-out feature. We are not responsible for any damages that you may suffer as a result of these ad technologies.

Website(s)

Service Name/ Vendor Name	End User information	Purpose of use	Privacy Policy	Opt-Out
Google Analytics/ Google LLC and its affiliate companies	Information on systems, devices, networks, and communications normally used for Internet communications Location information Data related to the behavior of the user on the website/application Data related to pages viewed User identifiers (cookies, device identifiers, etc.)	To analyze browsing trends and history by users.	Google Analytics Terms of Service Privacy Policy	Google Analytics Opt-Out Google Ad Settings

Use of Personal-related Information Provided to the Company by Third Parties in Conjunction with Personal Information

The Company receives personally referable information from DMP service providers, media companies and other business partners of ours, which we link to the personal information we hold. The items of personally referable information that we receive and purposes of using it are described below:

The items of personally referable information that we receive.	The purposes of using personally referable information after it has been linked to personal information.
Advertising ID and terminal system log information, device type / OS type, wallet address etc.	To monitor and improve the effectiveness of campaigns and to optimise the distribution of campaigns.

Provision and Entrusting the Handling of Personal Information to Third Parties Located Outside of Japan

(1) When providing personal information or entrusting the handling of personal information to third parties located outside of Japan (excluding third parties located in the United Kingdom or EEA member countries; hereinafter referred to as "third parties located overseas"), the Company shall provide the name(s) of the relevant overseas countries and information regarding systems for the protection of personal information in those overseas countries, except in cases where they cannot be identified for operational reasons of third parties located overseas (such as enabling effective operation, improving performance and ensuring redundancy). When there are other reasons why the country cannot be identified, the Company shall clearly state those reasons. (2) The Company confirms that third parties located overseas to which it provides personal information or entrusts the handling of personal information take measures in response to the eight OECD Privacy Principles (part of the OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data). When third parties do not take such measures, the Company shall provide information to that effect. (3) The Company may provide personal information or entrust the handing of personal information to third parties located in the United Kingdom or EEA member countries.