当社のプライバシー ポリシーをお読みください - xFrenchies

2. How we collect your personal data

1. when you visit and/or use our Website;
2. when you complete our registration form,
3. when you post materials or upload content;
4. when you take part in surveys or report a problem with our Website; or
5. when you contact with us via email, post or other ways of communication.

3. If you fail to provide personal data

4. Personal data that we collect and process

1. Personal data we collect and process from Browsers
   1. Technical Data, including your Internet Protocol (IP) address,
      your browser type and version, time zone setting and location, browser plug-in
      types and versions, smart device information, mobile phone network information,
      operating system and platform and other technology on the devices you use to
      access this Website;
   2. Usage Data, including your communication preferences and
      information about how you use our Website including the services you viewed or
      searched for, page response times, download errors, length and number of visits
      and page interaction information (such as scrolling, clicks and mouse-overs) as
      well as the links you clicked on or used.
   3. User Submitted Data, including data collected for a specific
      function, for instance a contest or a survey; and
   4. Consents, including any permissions, consents or preferences
      that you give to the Website.
2. Personal data we collect and process from Members
   1. All personal data we collect from Browsers, set out in paragraph 4(a) above;
   2. Identity and Contact Data, including username or similar
      identifier, password and email address. We may also collect a Member's photo or
      video, if such is uploaded to a Member's profile;
   3. User Submitted Data, including data collected at your
      discretion for a specific function, for instance your username and password,
      your interests, preferences, feedback and survey responses, or any text, images,
      videos, blog posts, forum comments or other content or media you choose to
      upload on the Website;
   4. Marketing Data, including preferences in receiving marketing
      from us and third-parties; and
   5. Communications, including information on how and what methods
      we use in order to communicate with you through electronic and verbal
      correspondence.

5. Automated personal data collection

6. Why we need your personal data and how we use it

1. where we need to perform our services to you, as necessary in accordance with
   our Website's Terms of Use;
2. where it is necessary for our legitimate interests (or those of a third party)
   and your interests and fundamental rights do not override those interests;
3. where we need to comply with a legal obligation; and/or
4. where you have given us your consent.

1. Performance of our services to you
   1. Provision of services (Members Only)
      We may collect and process your personal data where it is necessary in order to present our Website and
      its contents to you, including any interactive features on our Website and to provide you with
      information or services that you request from us.
      Please note that if you do not agree to provide us with the requested information, it may not be
      possible for us to continue to operate your account and/or provide you with the services we provide to
      our Members.
   2. Customer management (Members Only)
      We may collect and process your personal data where it is necessary in order to manage a Member's
      account, to provide customer support and notices to Members about their account and subscription,
      including expiration and renewal notices, and notices about changes to our Website or any services
      we offer or provide through it.
2. Legitimate interests
   1. Customization of content (Members Only)
      We may collect and process your personal data where it is necessary in order to perform
      research and analysis about your use or, or interest in, our Website content and/or
      services, so as to develop and display content and advertising tailored to your interests on
      our Website.
   2. Analytics
      We may collect and process your personal data where it is necessary in order to determine
      whether users of the Website are unique, or whether the same user is using the Website on
      multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages
      viewed and demographic patterns.
   3. Functionality and security
      We may collect and process your personal data where it is necessary in order to diagnose or
      fix technology problems, and to detect, prevent and respond to actual or potential fraud,
      illegal activities, or intellectual property infringement.
   4. Other legitimate interests
      In addition to the above, we may process your data, to the extent required for our business
      needs in order to:
      1. develop new services on our Website as well as analyze and target new markets;
      2. protect our legal rights and interests (including legal claims and preparing our defense
         in litigation);
      3. monitor, maintain and improve internal business processes, information and data,
         technology and communication solutions and services;
      4. ensure network information security, including monitoring Browsers' and Users' access to
         our information technology for the purpose of preventing cyber-attacks, unauthorized use
         of Website and prevention or detection of crime;
      5. send you relevant marketing information (including details of other services provided by
         us which we believe may be of interest to you), but only where you are a Member of the
         Website;
      6. monitor the performance and effectiveness of our services and the Website; and
      7. assess the quality of our customer services.
3. For compliance with legal obligations
   When you visit and/or use and/or register in our Website (and throughout your relationship with us),
   we are required to comply with certain legal and regulatory obligations which may involve the
   processing of your personal data. This may include processing to:
   1. perform checks and comply with laws relating to fraud;
   2. identify other infringements of our Terms of Use; and
   3. manage contentious regulatory matters, investigations and litigation.
4. You have provided your consent
   We will only ask for your consent when we wish to provide marketing information to you in relation
   to our services which we believe may be of interest and of benefit to you, but only where you are a
   Browser.
   You have the right to revoke your consent at any time. However, any processing of personal data
   prior to the receipt of your revocation will not be affected.

7. Who we share your personal data with

1. members of our corporate group which operate partner websites such as xfrenchies.com,
   to the extent this is necessary for the purposes set out in this privacy
   policy and to enable you to have access to certain features;
2. service providers;
3. governmental and regulatory bodies, including law enforcement authorities, in connection with
   enquiries, proceedings or investigations by such parties or in order to enable the Company to
   comply with its legal and regulatory requirements. We specifically reserve the right to disclose
   any and all information to law enforcement in the event that a crime is committed or suspected
   or if we are compelled to do so by lawful criminal, civil or administrative process, discovery
   requests, subpoenas, court orders or writs;
4. buyers or other legal successors in the event of a merger, divestiture, restructuring,
   reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a
   going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal
   information held by us about our Website Members and Browsers is among the assets transferred.
   Should such a sale or transfer occur, we will use reasonable efforts to ensure that the entity
   to which we transfer your personal data uses it in an manner that is consistent with this
   privacy policy; and/or
5. legal or other professional consultants.

8. Members' Profile

9. Security of your personal data

10. Information we transfer

1. We will only transfer your personal data to countries that have been deemed to provide an
   adequate level of protection for personal data by the European Commission.
2. Where we use service providers outside the EEA, we may use specific contracts approved by the
   European Commission which give personal data the same protection it has in the European Union.
3. Where we use providers based in the US, we may transfer data to them if they are part of the
   Privacy Shield which requires them to provide similar protection to personal data shared between
   the European Union and the US.

11. Marketing information

12. How long we keep your personal data for

13. Your data protection rights

1. Access: This enables you to get access or receive a copy of the personal data
   that we hold about you and to check that we are lawfully processing it.
2. Correction: If you believe that any of the information that we hold about you
   is inaccurate or incomplete, you have a right to request that we correct the inaccurate personal
   information.
3. Erasure: You may request that we delete your personal information if you
   believe that:
   1. we no longer need to process your information for the purposes for which it was
      provided;
   2. we have requested your permission to process your personal information and you wish to
      withdraw your consent; or
   3. we are not using your information in a lawful manner.
   As a result of deleting your personal information, you will lose access to most of our
   services.
   Grace period: There is a 45 day grace period
   before we proceed with erasure. During this Grace Period you will be allowed to restore your
   account. The grace period functionality allows you not to lose any important information and
   options by mistake. After the expiration of the grace period however, your account will be
   deleted.
4. Right to object: You have the right to object to the processing of your
   personal data where we are relying on a legitimate interest and there is something about
   your particular situation which makes you want to object to processing on this ground. If
   you exercise your right to object, we will no longer process your personal data unless we
   can demonstrate compelling legitimate grounds for the processing which override your
   interests, rights and freedom or for the establishment, exercise and defense of legal
   claims.
   If you object to processing for direct marketing purposes, then we
   shall stop the processing of your personal data for such purposes.
   Depending on the circumstances, we may need to restrict or cease
   processing your personal data altogether or, where requested, delete your personal data.
   Please note that if you object us processing your personal data, we may have to suspend the
   services we provide to you.
5. Restriction: You have the right to request the restriction of processing of
   your personal data. This enables you to ask us to restrict the processing of your personal
   data if:
   1. it is not accurate; or
   2. it has been used unlawfully but you do not want us to delete it; or
   3. it is not relevant any more, but you want us to keep it for use in possible legal
      claims; or
   4. you have already asked us to stop using your personal data but you are waiting for us to
      confirm if we have legitimate grounds to use your personal data.
   Please note that if you request us to restrict processing of your personal data, we may have
   to suspend the services we provide to you.
6. Right to portability: Where we have requested your permission to process
   your personal data or you have provided us with information for the purposes of entering
   into a contract with us, you have the right to receive the personal data you provided to us
   in a portable format. You may also request us to provide it directly to a third party, if
   technically feasible. We are not responsible for any such third party's use of your account
   information, which will be governed by their agreement with you and any privacy statement
   they provided to you.

15. Our communication with you

16. Right to complain

17. Our policy towards minors

18. Third-party links

19. Changes to this privacy policy

20. Cookies