Privacy Policy

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

1. User Information to be Collected and Manner of Collection

The "User Information" under this Policy shall mean the information about the identity of users, users action history on the telecommunication service, or any information created or stored in the users devices in relation to the users or users’ devices, and that is collected by the Company pursuant to this Policy.
The User Information in the Service that is collected by the Company shall include, as for each manner of collection, the following:

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

(2)	Information that, by way of the user’s permission of linking the Service with another service in using the Service, is 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.

(3)	Information that is collected by the Company of the 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 user’s action history by using Cookies, JavaScripts and other technology. However, these do not include personal information.

(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.
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.

2. Purpose of Use

The User Information collected from 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 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

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 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 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. Correction and Suspension of User’s Personal Information

If any user requests the Company to correct or suspend the use of any personal information, the Company will verify that the request has been made by the user himself/herself, and conduct necessary investigation without delay.  The Company will then correct or suspend the use of the personal information, and notify the user. If the Company determined not to correct or suspend the use of the personal information on a reasonable ground, the Company will notify the same to the user.
If any user requests the Company to delete any personal information of the user, and the Company deems it necessary to comply with the request, the Company will verify that the request has been made by the user himself/herself. The Company will then delete the personal information, and notify the user.

5. 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;
-	The user is identified by chance, based on any information the user input on the Service, or activity information, etc.;
-	The third party acquired the personal information or any other User Information through a means outside the Service; or
-	Any person other than the user himself/herself obtained any information that identifies the user (including IDs, passwords, etc.).

6. Procedure of Amendment of Privacy Policy

The Company from time to time reviews the handling of User 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.

7. Contact

For inquiry about this Policy and User Information, please contact us from the contact form.
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.

(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.

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 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 compliant 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. 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.

(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.

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 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;
-	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.

Progate, Inc.
6-19-20 Jingumae, Shibuya-ku, Tokyo, Japan
Email: info@progate.com
Phone: +813-6455-0950
Ver. 2: October 2, 2019
Ver. 1: Feburary 28, 2019