Behavioral Targeting Advertising Policy

Section I: General Provisions

1. Purpose

The purpose of this policy is to allow FAN Communications, Inc. (hereinafter “the Company”) to acquire information on the websites, applications (hereinafter “apps”), and other behavior history (regardless of the devices involved in browsing or using the Internet) of Internet users (hereinafter “users”), and, with regard to behavioral targeting advertising that uses said information to display advertising, to gain the correct understanding of users and advertisers and allow users to make use of Internet advertising with peace of mind.

2. Scope of Applicability

(1) This policy applies to services operated by the Company.
(2) This policy addresses advertising in the Internet advertising business, and does not apply to distribution businesses for content other than advertising, such as recommendations.
(3) With respect to behavioral targeting advertising, the Company, when having acquired personal information as provided for in the Act on the Protection of Personal Information, will handle the information in accordance with the “Privacy Policy” established by the Company. The URL of the “Privacy Policy” is as follows:
https://www.fancs.com/en/privacypolicy
(4) Unless otherwise stipulated in this policy, the definitions of terms used in this policy will follow the Behavioral Targeting Advertising Guidelines (hereinafter “the Guidelines”) established by the Japan Interactive Advertising Association (hereinafter “JIAA”).

3. Definitions

The definitions of the terms in the following numbered items will be as stipulated in each item.

(1) Behavioral history information
This refers to information such as website browsing history and purchase history on electronic commerce sites, which can be accumulated for use in the analysis of users’ interests and preferences.
(2) Behavioral targeting advertising
This refers to a service, associated with the collection of behavioral history information, that analyzes users’ interests and preferences from behavior history information to categorize users into clusters, and, for each cluster, to segregate Internet advertising.

Section 2: Handling of Behavior History Information

4. Notifications

The Company provides for the “Notifications” provided for in the Guidelines as follows.

(1) Confirmation of acquisition
The Company acquires behavior history information and engages in behavioral targeting advertising when users browse websites or apps that implement the services that the Company operates.
(2) Name of the business operator that acquires the information
FAN Communications, Inc.
(3) Examples of acquired behavior history information
Cookie information, pages browsed (URLs and time), ad displays and click history, IP address, and other behavior history information which cannot be used to identify individuals
(4) Acquisition method
Behavior history information is temporarily created and acquired when transactions take place between servers and web browsers or apps.
(5) Purposes of use
・Regional targeting advertising: Segregation of advertising by region
・Behavioral targeting advertising: Segregation of advertising according to interests and concerns
・Advertising distribution reports: Number of ad displays and number of clicks
・Optimization of advertising distribution: Segregation of advertising according to usage environment and conditions
(6) Retention period
Maximum 2 years
(7) Opt-out procedures or other available user involvement methods
The Company provides opt-out procedures via the method indicated in the following Article.

5. Opting Out

A user who does not wish for the display of behavioral targeting advertising can suspend the display of behavioral targeting advertising for services that the Company operates by opting out.

6. Behavioral Targeting Advertising Guidelines

As a JIAA member firm, our company complies with these Guidelines.

7. Acquisition through Fair Means

The Company will acquire behavior history information fairly, in accordance with the internal rules of the Company.

8. Appropriate Safety Management

Advertising providers will enact and maintain appropriate safety management measures concerning behavioral targeting information, in accordance with the internal rules of the Company. The acquired information will be used only for advertising distribution and will not be provided or disclosed to third parties without the consent of users. However, behavior history information acquired through specified services of the Company may be used by other services of the Company.

9. Transmission of behavior history information to external parties

(1) The Company transmits behavior history information to external business operators’ services for the purposes below. The information that is transmitted shall be managed and used on the basis of the privacy policy for the recipient’s external business operator’s services.

Service	Name of the recipient's business	Information sent to the recipient	Purpose of use	Privacy Policy	Opt-out link
Google Ads	Google LLC	- Identifier information, such as cookie IDs, IP addresses, and advertising IDs - URLs of the pages browsed, referrers, dates and times of access, and operation history within sites (clicks, amount of time spent visiting sites, etc.) - An association may be made with the user’s attribute information (age, gender, interests, etc.) that Google possesses.	For advertising distribution and optimization	https://policies.google.com/privacy	https://policies.google.com/technologies/ads?hl=ja
Google Analytics	Google LLC and its affiliates	- Information concerning the systems, devices, networks, and communication that are usually part of Internet communication - Location information - Data concerning behavior on sites and apps - Data concerning pages browsed - User identifiers (cookies, terminal identifiers, etc.)	For analyzing the tendencies and history of browsing by the user	https://policies.google.com/privacy?hl=ja#infocollect	https://support.google.com/analytics/answer/181881?hl=ja
Yahoo Ads	LY Corporation	- Browser information (cookie IDs, IP addresses, browser type, user agent, etc.) - Browsing information (URLs of the pages browsed, referrers [URLs of source links], dates and times of access, etc.) - An association may be made with the user’s attribute information (age, gender, interests, etc.) that LY Corporation possesses.	For advertising distribution and optimization	https://www.lycorp.co.jp/ja/company/privacypolicy/	https://btoptout.yahoo.co.jp/optout/index.html
Microsoft Ads	Microsoft Corporation	- Identifier information, such as cookie IDs, IP addresses, and advertising IDs linked to Microsoft accounts - URLs of the pages browsed, referrers, dates and times of access, and operation history within sites (search keywords, advertisements on which the user clicked, etc.) - An association may be made with the user’s attribute information (age, gender, interests, etc.) that Microsoft possesses.	For advertising distribution and optimization	https://www.microsoft.com/ja-jp/privacy/privacystatement	https://www.microsoft.com/ja-jp/privacy/privacystatement
Meta ads	Meta Platforms, Inc.	- Browser information (cookie IDs, IP addresses, browser types, user agent, etc.) - Browsing information (URLs of the pages browsed, referrers [URLs of source links], dates and times of access, etc.) - Information concerning the history of operation on websites (information about specific actions by the user on websites, such as browsing of products, addition of products to shopping carts, purchases, member registration, and search behavior)	For advertising distribution and optimization	https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0	https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

(2) For the external business operators’ services that are stated in an opt-out item, it is possible to stop transmission of information and use by the recipient.

(3) Details shall be according to the page of the linked external business operator’s services.

10. URL of the Guidelines

The URL of the Guidelines is as follows.
https://www.jiaa.org/wp-content/uploads/2019/11/JIAA_BTAguideline.pdf

11. Inquiries

The contact desk for claims and questions concerning the handling of behavior history information is as follows.

Personal Information, etc. Complaints and Advice Desk
FAN Communications, Inc.
Contact desk for personal information claims and consultation
Aoyama Diamond Building 2F, 1-1-8 Shibuya, Shibuya-ku, Tokyo 150-0002

Section 3: Other

12. Revision of These Policies

These policies may be revised as necessary in accordance with changes in the environment, including changes in social conditions, public awareness and technical trends.

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