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RUNNET GLOBAL PRIVACY POLICY RUNNET GLOBAL PRIVACY POLICY RUNNET GLOBAL PRIVACY POLICY

R-bies, Inc. and its Group companies (RECS Co., Ltd.) (hereinafter referred to as the “Companies”) shall recognize the importance of personal information, strictly comply with the Act on the Protection of Personal Information and related laws and regulations, etc., and endeavor to properly manage, protect, and appropriately handle personal information based on the following policies:

1.  Acquisition of personal information
The Companies shall acquire personal information by lawful and fair means.

2.  Use of personal information
・ The Companies shall use personal information within the scope of the purpose of use which is indicated at the time of acquisition and to the extent necessary to perform operations. The acquired personal information shall be used primarily for the following purposes:
[To confirm or send the services relating to the goods, events, tours, etc.]
1) Confirm the purchases of and/or send magazines, books or goods;
2) Confirm applications for events or tours and/or send notices on the invitation for participation;
3) Confirm registrations for membership services and/or send related notices;
4) Confirm subscriptions of magazines and/or send related notices;
5) Confirm presents/questionnaires and/or send related notices;
6) Confirm the registration for email delivery service and/or deliver messages;
7) Confirm applications for events, seminars, campaigns, etc. and/or send related notices;
[To provide, improve and/or develop the services relating to the goods, events, tours, etc.]
1) Notices on the introduction of new products, new magazines or new websites;
2) Notices on the events /tours to be held;
3) Notices on the services provided by cooperating companies in terms of events, tours, etc.;
4) Questionnaire about magazines/goods/events/tours, etc.;
5) Totalization of the records and announcement of the ranking;
6) Totalization of first-aid activities/accident and sickness data.
・The Companies shall use personal information jointly with a third party or, when entrusting the handling of the acquisition of personal information to a third party, after running a rigorous investigation of the relevant third party, shall conduct an appropriate audit to make such third party maintain confidentiality.

3.  Provision of personal information to a third party

Unless otherwise provided for by laws or regulations, the Companies shall not provide personal information to any third party without obtaining prior consent from the relevant person.

4.  Management of personal information
・The Companies shall maintain the accuracy of personal information and safely manage the same;
・To prevent personal information from being lost, destroyed, falsified or leaked, the Companies shall take appropriate security measures against unauthorized accesses, computer viruses, etc.

5.  Disclosure/correction/suspension of use/erasure of personal information
The Companies shall recognize that the relevant person has a right to demand disclosure/correction/suspension of use/erasure, etc. in terms of his/her own personal information, and when such demand is made, after confirming that the person who makes a demand is the relevant person, the Companies shall promptly deal with the case. Please be sure to use the prescribed form and contact “the Companies’ Counter for Inquiries about Personal Information” set out below:
Contact for disclosure/correction/suspension of use/erasure:
Customer Service, R-bies, Inc.
1-31-9, Hara-machi, Meguro-ku, Tokyo 152-8532

6.  Organization/structure
The Companies shall recognize that the relevant person has a right to demand disclosure/correction/suspension of use/erasure, etc. in terms of his/her own personal information and when such demand is made, after confirming that the person who makes a demand is the relevant person, the Companies shall promptly deal with the case. Please be sure to use the prescribed form and contact “the Companies’ Counter for Inquiries about Personal Information” set out below:

7.  Formulation/implementation/maintenance/improvement of the Personal Information Protection Compliance Program
To put this policy in action, the Companies shall formulate the Personal Information Protection Compliance Program (including this policy, the “Personal Information Protection Rules” and other rules and regulations) and, after making the program universally known to the employees of the Companies and other persons concerned, shall implement, maintain and improve such program on a continuous basis.

8. How We Use Your Personal Data.
We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may use the Personal Data as follows:

8.1 Specific Reason.
If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.

8.2 Access and Use.
If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.

8.3 Internal Business Purposes.
We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.

8.4 RUNNET GLOBAL Marketing Communications.
Where it is in accordance with your marketing preferences, we may use your Personal Data to contact you in the future for our marketing and advertising purposes, including without limitation, to inform you about services or events we believe might be of interest to you, to develop promotional or marketing materials and provide those materials to you, and to display content and advertising on or off the Services that we believe might be of interest to you.

8.5 Organizer Emails.
We allow Organizers to use our email tools to contact Consumers for their current and past events, so you may receive emails from our system that originate with such Organizers and that we send on their behalf. If you registered for an event on the Services, your email address is available to that Organizer. However, Organizers may also import the email addresses they have from external sources and send communications through the Services to those email addresses, and we will deliver those communications to those email addresses on the Organizer's behalf. The Organizer and not RUNNET GLOBAL is responsible for sending these emails.

8.6 Other Purposes.
If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use.

8.7 Aggregated Personal Data.
In an ongoing effort to understand and serve our Users better, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.

9. How We Disclose And Transfer Your Personal Data.

9.1 No Sale.
We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below.

9.2 Parent Companies, Subsidiaries and Affiliates.
We may also share your Personal Data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Policy. Our parent companies, subsidiaries and affiliates will be bound to maintain that Personal Data in accordance with this Privacy Policy.

9.3 Agents, Consultants and Service Providers.
We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of RUNNET GLOBAL to perform certain business-related functions. These companies include our marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.

9.4 Organizers.
When you purchase tickets to, register for or donate to an event through the event page on the Services, we provide the Personal Data entered on the applicable event to the Organizers of such event. It is important that you review the applicable policies of the Organizers event before providing Personal Data or other information in connection with that event.
Similarly, if you are a member of an Organizer's organization within RUNNET GLOBAL, your Personal Data will be available to the Organizer and shared with those.

9.5 Legal Requirements.
We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.

10. EEA, SWITZERLAND AND UK ONLY
The EU General Data Protection Regulation (GDPR)

In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the "GDPR") becomes effective. The GDPR requires RUNNET GLOBAL and Organizers using the Service to provide Users with more information about the processing of their Personal Data.

Here is what you need to know:
Legal grounds for processing your Personal Data
The GDPR requires us to tell you about the legal ground we're relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out in Policy 8 and 9 above will typically be because:
・you provided your consent;
・it is necessary for our contractual relationship;
・the processing is necessary for us to comply with our legal or regulatory obligations; and/or
・the processing is in our legitimate interest as an event organising and ticketing platform (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.).

Transfers of Personal Data
As RUNNET GLOBAL is a registration website, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland and the UK which have no data protection laws or laws that are less strict compared with those in Europe.

Personal Data retention
We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

If you have an account with us, we will typically retain your Personal Data for a period of 90 days after you have requested that your account is closed.

Your rights.
Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications.

If you have a complaint about how we handle your Personal Data, please get in touch with us R-bies, Inc. (2-4-12, Jinguumae, Shibuya-ku, Tokyo) privacy@runners.co.jp to explain. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.

RUNNET GLOBAL as a data controller and a data processor
EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process personal data on behalf of other organizations (known as "data processors"). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.

RUNNET GLOBAL may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.
For example, if you create an account with us to organize your events, RUNNET GLOBAL will be a data controller in respect of the Personal Data that you provide as part of your account. We will also be a data controller of the Personal Data that we have obtained about the use of the Applications or RUNNET GLOBAL Properties, which could relate to Organizers or Consumers. We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform and provide you with more targeted recommendations about events we think may be of interest to you.
However, if you register for an event as a Consumer, we will process your Personal Data to help administer that event on behalf of the Organizer (for example, sending confirmation, promotional and feedback emails, processing payments, etc.) and to help the Organizer target, and understand the success of, their event and event planning (for example, providing event reports, using analytics to gain insights into the effectiveness of various sales channels, etc.). In these circumstances, RUNNET GLOBAL merely provides the "tools" for Organizers; RUNNET GLOBAL does not decide what Personal Data to request on registration forms, nor is it responsible for the continued accuracy any Personal Data provided. Any questions that you may have relating to your Personal Data and your rights under data protection law should therefore be directed to the Organizer as the data controller, not to RUNNET GLOBAL.

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