Privacy Policy

Progate, Inc. (the "Company" or “we”) sets forth this Privacy Policy (the "Policy") for handling the User Information (including personal information) in the service provided by dthe Company (the "Service.")

1. Personal Information

"Personal Information" under this Policy means information relating to a living individual which falls under any of the following items:

(i) information containing a name, date of birth, or other identifier or the equivalent (meaning all items made by writing, recording, sound or motion, or other means, in a document, drawing, or electronic or magnetic record which can be used to identify a specific individual) (this includes any information that can be easily collated with other information and thereby used to identify that specific individual); or
(ii) those containing an individual identification code (kojin shikibetsu fugo).

2. Purpose of Use

The Personal Information of the users will be used for the following purposes:
- To provide, maintain, protect or improve the Service, including acceptance of registration and identity verification;
- To provide guidance of the Service or to handle customer inquires;
- To handle violations of the contracts between the users and us, terms and conditions and policies (the "T&C") of the Company pertaining to the Service;
- To notify users of important announcements such as amendments of the T&C of the Service or system maintenance;
- To provide community functions within the Service;
- To distribute announcements and mail magazines about other services, seminars and schools of the Company;
- To create statistical data, in relation to the service of the company, that has been processed in such a manner that individuals cannot be identified;
- To notify users about campaigns, etc., of the Company or third parties, or to dispatch novelties;
- To distribute or present advertisements of the Company or third parties;
- To use for marketing of the services that the Company or third party provides or will provide in the future;
- To make reporting and applications to the relevant authorities in connection with the Service; and
- To use for the purposes incidental to the foregoing.

3. Use of Personal Information and Disclosure to Third Parties

The Company will not handle personal information beyond the scope necessary for achieving the purpose of use without obtaining the user's consent to do so in advance, except:

cases based on laws and regulations;
cases in which there is a need to protect the life, wellbeing, or property of an individual, and it is difficult to obtain the consent of the user;
cases in which there is a special need to improve public wellbeing or promote healthy child development, and it is difficult to obtain the consent of the user;
cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining the consent of the user is likely to interfere with the performance of those functions;
cases in which personal data is provided to an academic research institution or the equivalent, and they need to handle the personal data for academic research purposes (including cases in which a part of the purpose of handling the personal data is for academic research purposes, and excluding cases in which there is a risk of unjustly infringing on individual rights and interests).

The Company will not provide any third party with personal information without the user’s prior consent except:
- cases based on laws and regulations;
- cases in which there is a need to protect the life, wellbeing, or property of an individual, and it is difficult to obtain the consent of the user;
- cases in which there is a special need to improve public wellbeing or promote healthy child development, and it is difficult to obtain the consent of the user;
- cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining the consent of the user is likely to interfere with the performance of those functions.
- cases in which the third party is an academic research institution or the equivalent, and the third party needs to handle the personal data for academic research purposes (including cases in which a part of the purpose of handling the personal data is for academic research purposes, and excluding cases in which there is a risk of unjustly infringing on individual rights and interests); or
- cases where the third party provision of personal information is allowed under law.

4. Disclosure, Correction or Suspension of Use, etc. of Personal Information

If you request the Company to, pursuant to the Personal Information Protection Act, disclose, correct, add or delete (“Correction”), suspend the use of or remove (“Suspension of Use”) or suspend the disclosure to third parties of any personal information held by the Company, please contact:
15 Arai Building 9F, 19-20, Jingumae 6-chome, Shibuya-ku, Tokyo, 150-0001 Japan
Progate, Inc. Personal Information Contact
legal@prog-8.com
The Company will respond to the request in accordance with the Personal Information Protection Act after confirming that the request has been made by the user himself/herself. The Company may request the user to provide necessary information for user identification. The Company may not respond to the request if the Company does not have an obligation of disclosure, Correction, Suspension of Use or suspension of disclosure to third parties.
The Company will disclose the personal information by the means requested by the user ( or by paper-based document, in cases in which disclosing the personal information by that means would require a costly expenditure or prove otherwise difficult). Please note that it will take days for delivery in case of disclosure by paper-based document. We may request the user to pay the cost for delivery.

5. External Transmission Regulations

(1) We send user information to external parties as follows:
(i) For targeted advertising:
To implement targeted advertising (i.e., advertising methods that distribute advertisements following the needs, interests, and interests of users) by us or third parties such as advertising service providers, we collect, use, and provide advertising service providers with the information outlined in the following paragraphs in connection with the provision of the Service or related services. We use the services of the advertising service providers to distribute advertisements when Service users visit a specific page. Cookie is also used to obtain the activity history through advertisements.
(ii) For the improvement of the Service:
To understand the usage of the Service, we use Cookie to obtain information about the history of user visits. We track users' usage of the Service and send the visit history information to external analyzers to improve our service and provide services that are more appropriate for the user's interests and needs.
(iii) For the proper and safe provision of the Services:
We use Cookie to obtain the history of visits to detect and correct bugs, errors, and security-related issues in the Service. We assess the usage of the Service by users and send it to external service providers.
(2) The details of the information that we obtain and transmit externally are as follows:
(i) Browsing History:
History of the Service browsing (browsing date and time, URL, categorization, linking source URL, etc.)
(ii) Location information:
Location information of the equipment (e.g., IP address, GPS information) by which the user accesses the Service.
(iii) Identifiers:
Information that identifies the user and the device used (user ID, browser identifier, device identifier, etc.)
(iv) Attribute/action information:
Attribute information (gender, generation, etc.) associated with information that identifies a user or their device, and behavior information such as a request for information (date and details of a request for information, etc.)
(v) Tags:
Information on the external transmission program (tags.)
(3) We retain the collected user information only for a period that is lawful and legitimately required for business.
(4) If you wish to turn off the external transmission, please access the opt-out URL of the relevant destination and configure opt-out settings. Please note that if you are using multiple web browsers or devices, you must configure the settings for each browser or device.
(5)Details of external transmissions for each destination are as follows:
Please see (2) above for the details of the information to be transmitted, and see (1) above for the details of the purpose of use.

Service Name	Information to be transmitted	Destination	Purpose of Use	Opt-out URL
Microsoft Clarity	Browsing history, location information, and identifiers	Microsoft Corporation	For the improvement of the Service	https://go.microsoft.com/fwlink/?LinkID=286759
Google Analytics	Browsing history, location information, identifiers, attribute/action information	Google LLC	For the improvement of the Service	https://tools.google.com/dlpage/gaoptout?hl=ja
Google Tag Manager	Browsing history, location information, identifiers, attribute/action information, tags	Google LLC	For the improvement of the Service	https://support.google.com/My-Ad-Center-Help/answer/12155451
Yahoo! Tag Manager	Browsing history, location information, identifiers, attribute/action information, tags	Yahoo Japan Corporation	For the improvement of the Service	https://btoptout.yahoo.co.jp/optout/index.html
Google Ads	Browsing history, location information, identifiers	Google LLC	For targeted advertising	https://myadcenter.google.com/?sasb=true
Facebook	Browsing history, location information, identifiers	Meta Platforms, Inc.	For targeted advertising	https://www.facebook.com/help/109378269482053
Twitter	Browsing history, location information, identifiers	X Corp.	For targeted advertising	https://help.twitter.com/ja/rules-and-policies/twitter-cookies-japan
Instagram	Browsing history, location information, identifiers	Meta Platforms, Inc.	For targeted advertising	https://www.facebook.com/help/instagram/2885653514995517
TikTok	Browsing history, location information, identifiers	Bytedance Kabushiki Kaisha	For targeted advertising	https://support.tiktok.com/ja/account-and-privacy/personalized-ads-and-data
LinkedIn	Browsing history, location information, identifiers	LinkedIn Corporation	For targeted advertising	https://www.linkedin.com/help/linkedin/answer/a1342443/manage-advertising-preferences?lang=ja
ADMATRIX DSP	Browsing history, location information, identifiers	CRAID INC.	For targeted advertising	https://www.admatrix.jp/dsp/optout/
UZOU	Browsing history, location information, identifiers	Speee, Inc.	For targeted advertising	https://uzou.speee-ad.jp/optout/
New Relic	Browsing history, location information, identifiers	New Relic, Inc.	For the proper and safe provision of the Services	https://newrelic.com/jp/termsandconditions/privacy
BugSnag	Browsing history, location information, identifiers	SmartBear Software	For the proper and safe provision of the Services	https://smartbear.com/privacy/
Firebase	Browsing history, location information, identifiers	Google LLC	For the proper and safe provision of the Services	https://firebase.google.com/docs/perf-mon/disable-sdk?hl=ja&platform=ios
Expo	Browsing history, location information, identifiers	Industries, Inc.	For the proper and safe provision of the Services	https://expo.dev/privacy
ReCAPTCHA	Browsing history, location information, identifiers, attribute / action information	Google LLC	For the proper and safe provision of the Services	https://policies.google.com/privacy?hl=ja#infodelete

6. Measures to Ensure the Safe Management of Personal Information

The Company will provide necessary and appropriate supervision to our employees to ensure the safe management of personal information against the risks of loss, destruction, alteration, and leakage of personal information. In addition, in the event the handling of personal information is entrusted in whole or in part, the Company shall exercise necessary and appropriate supervision to ensure the safe management of personal information by the outsourcee.

The Company mainly implements the following safety management measures:
・Systematic security control measures;
・Human security control measures;
・Physical security control measures;
・Technical security control measures; and
・Understanding of the external environment

7. Exclusion of Liability

The Company shall have no responsibility in relation to acquisition of personal information by a third party if:
- The user by himself/herself provides the personal information to the third party by using any function of the service or any other means; or
- The user is identified by chance, based on any information the user input on the Service, or activity information, etc.

8. Procedure of Amendment of Privacy Policy

The Company from time to time reviews the handling of personal information and endeavors improvement on a continuing basis. The Company may, if it deems necessary, amend this Policy at any time. If the Company amends this Policy, it will be announced on this website.

9. Contact

For inquiry about this Policy and personal information, please contact:
15 Arai Building 9F, 19-20, Jingumae 6-chome, Shibuya-ku, Tokyo, 150-0001 Japan
Progate, Inc. Personal Information Contact
Masanori Kato, Representative Director
legal@prog-8.com

Ver. 6: July, 31, 2023
Ver. 5: October, 24, 2022
Ver. 4: April, 13, 2022
Ver. 3: December, 6, 2021
Ver. 2: November 13, 2017
Ver. 1: April 1, 2017

Privacy Policy (for EEA)

Progate, Inc. (the "Company") sets forth this Privacy Policy (the "Policy") for processing the Personal Data of the users in the service provided by the Company (the "Service.")
This Policy shall apply only to the users who are individuals located within the European Economic Area (EEA.)

1. Personal Data and Processing

The "Personal Data" under this Policy shall mean any information relating to an identified or identifiable natural person (data subject.) Personal data shall not include information relating to a legal person or the dead.

The Personal Data in the Service that are collected and processed by the Company shall include, as for each manner of collection, the following:

(1) Personal Data provided by the user:
- Name;
- E-mail address; and
- Other information input by the user in the form designated by the Company.

(2) Personal Data that, by way of the user’s permission of linking the Service with another service in using the Service, are provided by such other service:
- ID used by the user at the third-party service; and
- Information that the user authorized provision to the linked service under the privacy preference of the third-party service.
- These Personal Data are ones provided by the user to such another service.

(3) Personal Data that are collected by the Company of the user in using the Service:
- Browser information;
- Log information;
- Device information;
- Location information;
- Cookies and anonymous IDs; and
- Other online identifiers.
The Company will, to improve usability of the Service, store and use Cookies, access analytics, statistical data, etc. The Company may collect the user’s action history by using Cookies, JavaScripts and other technology.
For behavioral targeting advertising using Cookies, please see this page.
(4) User attributed information collected from Google Analytics
The following user attributed information will be collected from Google Analytics used by the Service for collecting traffic data on the users:
- Age;
- Gender; and
- Interests.
These data will be collected after processing so that individuals cannot be identified from the data. For more details on Google Analytics, please see the Terms of Service of Google Analytics.

(5) Information collected through Microsoft Clarity
The following information collected through Microsoft Clarity used by the Service to statistically analyze the usage trends of the site:
- Cookie and anonymized IDs; and
- User’s action history.
We will use the data collected through the use of Microsoft Clarity only for statistical analysis of the usage trends of sites, and such data will not be used to identify individuals.
For more information about Microsoft Clarity, see Microsoft Clarity terms and conditions.

2. Purpose of Collection and Processing of Personal Data

The Personal Data of the users will be collected and processed for the following purposes:

For the performance of a contract to which the user is party or in order to take steps at the request of the user prior to entering into a contract:
- To provide, maintain, protect or improve the Service, including acceptance of registration and identity verification;
- To provide guidance of the Service or to handle customer inquires;
- To handle violations of the terms and conditions and policies (the "T&C") of the Company pertaining to the Service;
- To notify users of important announcements such as amendments of the T&C of the Service or system maintenance; and
- To provide community functions within the Service.

For compliance with a legal obligation to which the Company is subject:
- To respond to disclosure and other requests under the law.

3. Disclosure of Personal Data

The Company may, for the purposes set forth in 2 above, disclose the Personal Data to third persons if:
- The Company entrusts a whole or part of the processing of the Personal Data;
- The Personal Data is provided accompanied with business succession caused by a merger or other reason; or
- There is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a user's consent would interfere with the performance of the said affairs.

4. Transfer of Personal Data to Third Countries

The Company may, for the purposes set forth in 2 above, transfer Personal Data to one or more locations of the Company outside the EEA. In such case, the Company will ensure that the country to which the Personal Data is transferred is given an “adequacy decision,” or implements appropriate safeguards.
The Company may have one or more server operators outside the EEA to process the Personal Data. In such case, the Company will ensure that the transferee has been given the certification of EU-US Privacy Shield, or otherwise satisfies the requirements under the law.
For details, please ask the contact in 9 below.

5. Failure to provide Personal Data

In case the Company needs to collect Personal Data by law or under the terms of a contract with the user and the user fails to provide the requested Personal Data to the Company, the Company may not be able to perform the contract with the user. In such case, the Company may decline to provide the relevant services to the user. The Company will notify the user if this is the case at the time the Personal Data is collected.

6. Retention of Personal Data

The Company retains the Personal Data of the users for as long as necessary to fulfill the purposes of collection. To determine the appropriate retention period for the Personal Data, the Company considers, among other things, whether the contract with the user is continued, and the necessity to respond to inquiry from the users.

7. User’s Legal Rights

The user has the following rights in relation to the Personal Data:

Information about Use of Personal Data:
The user has a right to be informed about how the Company uses and discloses his/her Personal Data. When requested by the user, an explanation will be provided by the Company in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language.
Access to Personal Data:
The user has a right to obtain confirmation of whether the Company is processing his/her Personal Data, access to his/her Personal Data and information regarding how his/her Personal Data is being used by the Company.
Rectification:
The user has a right to have any inaccurate or incomplete Personal Data rectified.
Erasure:
In certain circumstances, the user has a right to request that certain Personal Data controlled by the Company is erased.
Restricting Processing:
In certain circumstances, the user has a right to block the processing of his/her Personal Data controlled by the Company.
Data Portability
In certain circumstances, the user has a right to receive his/her Personal Data in a structured, commonly used and machine-readable format, and has a right to transmit those data to another controller.
Objection to Processing of Personal Data:
In certain circumstances, the user has a right to object to processing being carried out by the Company.

Users may exercise any of these rights using the contact details set out in Article 10 below. In principle, the user will not have to pay a fee. However, the Company may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive. Alternatively, the Company may refuse to comply with the exercise of the rights.
The Company may need to request additional documentation and any other necessary information to confirm the user’s identity.
The Company tries to respond to all legitimate requests within one (1) month.

8. Procedure of Amendment of this Policy

The Company from time to time reviews the handling of Personal Data and endeavors improvement on a continuing basis. The Company may, if it deems necessary, amend this Policy at any time. If the Company amends this Policy, it will be announced on this website. The history of amendment of this Privacy Policy is described at the bottom of this Privacy Policy.

9. Inquiries and Complaints

For inquiry and complaint about this Policy and Personal Data, please contact us via the contact form.
The user also has a right to file complaints with the supervisory authority.

10. Controller

The controller of processing of Personal Data is the Company, the details of which are as follows:

Progate, Inc.
6-19-20 Jingumae, Shibuya-ku, Tokyo, Japan
Email: info@progate.com
Phone: +813-6455-0950

Ver. 5: July, 31, 2023
Ver. 4: October, 24, 2022
Ver. 3: December, 6, 2021
Ver. 2: October 2, 2019
Ver. 1: Feburary 28, 2019

Privacy Policy (for United States)

The following description applies only if the user is located in the United States, and is known to the Company to be under 13 years old (the “Child User”). For the matters not stipulated in the following, the general Privacy Policy of the Company applies.

1. Child User Information to be Collected

(1) Information provided by the Child User:
- Name;
- E-mail address; and
- Other information input by the Child User in the form designated by the Company.

(2) Information that, by way of the Child User’s permission of linking the Service with another service in using the Service, is provided by such other service:
- ID used by the Child User at the third-party service; and
- Information that the Child User authorized provision to the linked service under the privacy preference of the third-party service.

(3) Information that is collected by the Company of the Child User in using the Service:
- Browser information;
- Log information;
- Device information;
- Location information; and
- Cookies and anonymous IDs.
The Company will, to improve usability of the Service, store and use Cookies, access analytics, statistical data, etc. The Company may collect the Child User’s action history by using Cookies, JavaScripts and other technology. However, these do not include personal information.
For behavioral targeting advertising using Cookies, please see this page.
(4) Child User attributed information collected from Google Analytics
The following user attributed information will be collected from Google Analytics used by the Service for collecting traffic data on the Child Users:
- Age;
- Gender; and
- Interests.
This data will be collected after processing so that individuals cannot be identified from the data. For more details on Google Analytics, please see the Terms of Service of Google Analytics.

(5) Information that is collected through Microsoft Clarity of the Child User
The following information collected through Microsoft Clarity used by the Service to statistically analyze the usage trends of the site:
- Cookie and anonymized IDs; and
- User’s action history.
We will use the data collected through the use of Microsoft Clarity only for statistical analysis of the usage trends of sites, and such data will not be used to identify individuals.
For more information about Microsoft Clarity, see Microsoft Clarity terms and conditions.

2. Purpose of Use of the Information Collected from Child Users

To provide, maintain, protect or improve the Service, including acceptance of registration and identity verification;
To provide guidance of the Service or to handle customer inquiries;
To handle violations of the terms and conditions and policies (the "T&C") of the Company pertaining to the Service;
To notify users of important announcements such as amendments of the T&C of the Service or system maintenance;
To provide community functions within the Service;
To distribute announcements and mail magazines about other services, seminars and schools of the Company;
To create statistical data, in relation to the service of the company, that has been processed in such a manner that individuals cannot be identified;
To notify users about campaigns, etc., of the Company or third parties, or to dispatch novelties;
To distribute or present advertisements of the Company or third parties;
To use for marketing of the services that the Company or third party provides or will provide in the future; and
To use for the purposes incidental to the foregoing.

3. Disclosure to Third Parties of the Information Collected from Child Users

The Company will not, unless it is authorized under the Personal Information Protection Act or any other law, disclose any personal information (which comprises User Information) to third person without obtaining prior consent form the Child User. However, the foregoing shall not apply if:
- The Company entrusts a whole or part of the handling of the personal information within the necessary scope to achieve the purpose of use;
- The personal information is provided accompanied with business succession caused by a merger or other reason;
- There is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a Child User's consent would interfere with the performance of the said affairs; or
- In addition to the foregoing, the disclosure is authorized under the Personal Information Protection Act or any other law.

4. Consent of Parents

Before collecting, using or disclosing personal information from a Child User, the Company will obtain their parent’s verifiable consent. The Company will, by email, notify the parent of the personal information to be collected, disclosure to third parties, link to the privacy policy, method of consent and method of revocation of consent. If the parent does not consent within a reasonable time, the Company will delete the parent’s contact information as well as any information the Company collected from the Child User in relation thereto, from the Company’s records.

5. Rights of Parents

The parents of the Child Users have the following rights:
- The Company does not require a Child User to disclose more information than is reasonably necessary for the provision of the Company’s service;
- The parents may review the Child User’s personal information, direct the Company to delete it, and refuse to allow any further collection or use of the Child User’s information, in which case, however, the Child User may not be able to use the Company’s service;
- The parents may agree to the collection and use of the Child User’s information; however, the parents may not allow disclosure to third parties unless it is a part of the service; and
- To exercise the rights, the parents may contact the following. The Company may need to request additional documentation and any other necessary information to confirm the Child User’s or the parent’s identity.