LOOP, Inc. (hereinafter the “Company”) is the operator of “OR NOT,” a fashion EC platform service, and “the Door,” an online salon (hereinafter collectively the “Services”), and collects, uses and keeps personal information of users using the Services.
The Company does not have a personal data controller or processor in EU countries, and does not deploy services for users in EU countries or monitor their behavior; accordingly, the application of the EU General Data Protection Regulation (GDPR) is precluded.
1. Name and location of the business operator handling personal information
Name: LOOP, Inc.
Location: 3F Miyata Bldg 2, 1-38-17 Yoyogi, Shibuya-ku, Tokyo
2. Items of personal information collected from users and manners of collection
The Company will collect the following personal information in the following manner:
(1) Personal information of OR NOT users
|Manner of collection||Items collected|
|At the time of membership registration and change of membership information||Name, sex, birth date, country of residence, address, telephone number, e-mail address, and password|
|At the time of purchase of an item||Delivery address, payment information (credit card information or information on other means of payment), ordering date/time, and purchase data (details and size of an item, etc.)|
|At the time of a visit to the site||Access history and information collected using cookies, web beacons and other similar technology|
|At the time of acceptance of/response to inquiries/complaints||Contents of inquiries/complaints|
|Information provision from credit card companies, payment agents, etc.||Information of users provided by credit card companies, payment agents or payment-related companies to the Company|
|Information of which provision is requested by the Company(through questionnaires, surveys, etc.)||Requested information|
(2) Personal information of the Door users
|Manner of collection||Items collected|
|At the time of purchase||Information of a user’s account|
|Information posted on the Door (excluding information intended for limited publication)||Information posted on the Door|
3. Purposes of using collected personal information
The personal information set forth in paragraph 2 above will be used for the following purposes, unless consent is obtained on a purpose of use separately, or it is permitted under laws and regulations. The Company collectively manages personal information of users collected from the services of OR NOT and the Door, and personal information collected from either service may be used for both of the services.
|Purpose||Personal information used for the purpose|
|To manage and register an account of a user on the Services||Name, sex, birth date, country of residence, address, telephone number, e-mail address, and password|
|To confirm the identity of a user on the Services|
|To complete the procedure under a sales contract formed between a user and the Company on the Services (ordering, delivery, receipt of an item charge, return, etc.)||Name, country of residence, address, telephone number, e-mail address, payment information, and information of the user’s account|
|To complete the procedure under a sales contract formed between a user and the Shop on the Services (ordering, delivery, receipt of an item charge, return, etc.)||Name, country of residence, address, telephone number, e-mail address, payment information, and information of the user’s account|
|To provide customer service on the Services (to respond to/manage inquiries and complaints and notify a change to a service)||Name, sex, birth date, country of residence, address, telephone number, e-mail address, contents of inquiries/complaints, and information posted on the Door|
|In addition to the foregoing, to improve services on the website operated by the Company and manage their appropriate operation (including correction of violations)|
|To operate and manage a royalty program||Name, sex, birth date, country of residence, address, telephone number, e-mail address, access history, purchase data, cookies, web beacons, and information posted on the Door|
|To contact a user for marketing purposes and provide a user with relevant offers|
|To conduct research, analysis, a survey or questionnaire about a user’s usage of the Services|
|To analyze a user’s usage of the Services, develop a new service or improve an existing service|
|To publicize items and services of the Company or a shop or carry out targeted advertising|
|To distribute e-zines, run a lottery in an advertising/campaign, send prizes, conduct a questionnaire, or provide information (including information on a service)||Name, country of residence, address, e-mail address, and information posted on the Door|
4. Provision/entrustment of personal information
Based on the entrustment of a user, the Company will provide the necessary personal information of the user to achieve the purpose of a sales contract made by the user on the Site (defined in item 6 below) (including both a sales contract with the Company formed on OR NOT and a sales contract with a shop formed on the Door) to a necessary third party (shops, delivery companies, payment service providers, etc.) to fulfill the sales contract.
Outside the foregoing, the Company will not disclose or provide personal information to any third party unless the Company obtains the advance consent of the person concerned, or it is permitted under laws and regulations.
5. Management/protection of personal information
The Company will keep collected personal information during a necessary period to achieve the purpose of use.
To prevent unauthorized access, loss, damage, alteration, leakage and other accidents involving personal information, the Company will securely manage personal information, and endeavor to secure, enhance and rectify the security.
6. Collection of personal information in a method where users cannot easily recognize it
For the Services (OR NOT: or-not.com / the Door: [link]), cookies or web beacons (hereinafter collectively “Cookies”) are used to enhance the smooth provision of services. The Cookies are a technology that stores certain information in the Internet browser software (web browser) in the PC or other terminals of a user who accesses the website of OR NOT or the Door (hereinafter collectively the “Site”), which records the day, time and other information concerning the user’s visits to the Site, making it easier for the user to use the Site at future visits.
Information collected by Cookies may not identify the user by itself. Information of a user collected by Cookies will be used only to the extent of analyzing the browsing habits of the user to provide him/her with better services, and providing services of the Company, and it will under no circumstances be used for any other purposes.
7. Implementation of targeted advertising
(1) Purpose of using information, and items collected, accumulated and used
To provide more relevant offers to a user, the Company may implement targeted advertising by itself or a third party such as an ad serving company. When this is the case, the Company will use the following information kept by the Company (hereinafter collectively “Action History Information”). Action History Information may not identify the user by itself.
① Demographic attributes of a user (sex, age, country of residence, address, etc.)
② Access history (the usage history of the Site and other information that may be used, when accumulated, for analyzing the needs, interests and concerns of a user, which may not identify the specific individual))
③ Purchase data (items, categories, amounts, and days/times of purchases by a user)
(2) Provision of Action History Information
The Company may provide Action History Information to a company distributing targeted ads (hereinafter an “Ad Serving Company”) so that more beneficial information will be delivered to the user by means of optimal ad serving meeting the needs and interests of the user and other marketing activities including recommendations.
(3) Period of use and retention
The Company will keep Action History Information collected from a user during a necessary period to achieve the purpose.
(4) Procedure for invalidation
9. About procedures for disclosure, correction and discontinuation of use of user information
(1) Request for disclosure
A user who provides personal information to the Company may request from the Company (i) notice of purpose of use, (ii) disclosure, (iii) correction, addition and deletion of contents or (iv) discontinuation of use, erasure and discontinuation of provision to third parties of the personal information (items (i) through (iv) are hereinafter collectively referred to as “Disclosure”). Personal information subject to a request for Disclosure is personal information of which the Company has the authority for Disclosure.
(2) Request procedure
You can make a request by completing an inquiry form or sending a written request by post.
■ In the case of a request by an inquiry form
Please make a request by entering the details of the disposition to request (notice of purpose of use; disclosure; correction, addition or deletion of contents; or discontinuation of use, erasure, or discontinuation of provision to third parties) in the inquiry form. The Company may confirm that it is a request by the user concerned with information that may identify the individual (his/her name, address, telephone number, birth date, e-mail address, password, etc.)
■ In the case of a written request by post
In this case, please enter the items in (a), enclose the documents in (b), and send it to the address in (c)
(a) Items entered
Your name, address, contact point, e-mail address, details of the disposition to request, and reason for the request
(b) Documents enclosed
■ In the case of a request by the person concerned
|(A) One of the following documents||・運転免許証の写し
・Copy of driver’s license
・Copy of passport
・Copy of health insurance card
・Copy of pension handbook
・Copy of Basic Resident Registration Card with a photograph
・Copy of foreigner registration certificate
・Copy of disabled person notebook
|(B) One each of the documents in (a) and (b)||a||・Family register or its extract (prepared within 6 months)
・Residence certificate (prepared within 6 months)
・Copy of a utility bill
・Copy of student’s card or handbook
■In the case of a request by proxy
Documents of the person concerned listed in (A) or (B) of the above (b)
Documents of the proxy listed in (A) or (B) of the above (b)
*For a legal proxy (parents, adult guardian, etc.), a letter of proxy will not be required when one document proving that the person is a legal proxy of the person concerned is submitted (family register or its extract, certificate of a family court, etc.)
3F Miyata Bldg 2, 1-38-17 Yoyogi, Shibuya-ku, Tokyo 151-0053
Attn: Person in charge of personal information protection of LOOP, Inc.
o When the above request is made, the Company will respond to it without delay. Please note that depending on the contents of a request, the Company may take time to respond to it.
o If the Company finds that we cannot accept a request, the Company will respond to it with the reason attached.
o Documents submitted for a request will be used within the limits necessary for responding to the request of the user. The Company is unable to return the submitted documents.
o Even in the case of a request for deletion or erasure of personal information, the Company will retain for a certain period the documents submitted for the request and a copy of our answer (however, identification documents will be destroyed immediately after confirmation)
o Please note in advance that as a result of a request for discontinuation of use, erasure or discontinuation of provision to third parties of personal information, you may be unable to use services of the Company involving personal information.
10. Point of contact for inquiries about personal information
[Point of contact for inquiries about personal information]
Enacted on：Oct 11st, 2018
Yoshinobu Masushio, Representative Director