Privacy Policy

CardealPage Co., Ltd. (the "Company") sets forth this Privacy Policy (this "Policy") with regard to the treatment of buyers’ information, including but not limited to personal information, during the performance of services (https://www.cardealpage.com/) provided by the Company (the "Services"), as follows.

All the definition in this Policy will have the same meaning as the CardealPage Buyer Terms of Use unless otherwise provided in this Policy.

• Buyer’s Information to be Collected and Method of Collection
For purpose of this Policy, "Buyer’s Information" means information that identifies buyers, history of actions on communication services and other information created or accumulated in relation to buyer or buyers’ devices, which shall be collected by the Company pursuant to this Policy.
Depending on the method of collection, the Buyer’s Information that we may collect for a buyer to use the Services is as follows:
(i) information provided by the buyer, including:
・name;
・telephone number;
・e-mail address;
・bank account information;
・Sold Vehicle information;
・credit card information;
・information for past inquiries about Posted Inventory;
・communication between buyer, and seller and the Company;and
・other information entered by the buyer into such form as specified by the Company;
(ii) information provided from services outside the Services to the extent that the buyer permits for use with the Services;
The Company may collect the following information from services outside the Services, including but not limited to social network services, to the extent the buyer permits for use with the Services at that time:
・ID used by the buyer for such outside service; and
・other information that the buyer has authorized the other service provider to disclose through its privacy settings in such outside service;
(iii) information collected by the Company for the use by the buyer of the Services
The Company may collect information upon access to or use of the Services, including:
・terminal information;
・log information;
・cookies and anonymous ID; and
・location information.
• Purpose of Use
2.1 The Buyer’s Information may be used not only for provision of the Services as provided in Section 2-2, but for other purpose as provided in Section 2-3.
2.2 Specific purposes of the Buyer’s Information for the provision of the Services shall include the following.
(i) provision, maintenance, protection, and improvement of the Services, including but not limited to acceptance of registration for the Services and identification of individuals;
(ii) guidance or response to inquiries relating to the Services;
(iii) addressing a violation of rules, regulations or policies relating to the Services (the "Rules");
(iv) notice of any modification to the Rules; and
(v) other purposes incidental to the foregoing.
2.3 Purposes other than those specified in Section 2.2 above shall be as indicated below:

Purpose of Use	Corresponding Buyer’s Information
(1) creating statistical data relating to the Services, in a form that cannot identify an individual;	・device information ・log information ・Cookies and anonymous ID ・location information ・Sold Vehicle information ・information for past inquiries about Posted Inventory
(2) delivering or displaying advertisements, including e-mail newsletter, of the Company or third parties; And	・log information ・Cookies and anonymous ID ・location information ・name ・address ・e-mail address ・Sold Vehicle information ・information for past inquiries about Posted Inventory
(3) other marketing.	・name ・address ・e-mail address ・Sold Vehicle information ・information for past inquiries about Posted Inventory ・other information input by buyers in the form specified by the Company

• Method of Notice, Publication and Permission; Method of Discontinuance of the Use
3.1 The buyer’s permission must be obtained before collecting the following Buyer’s Information;
(i) terminal information; and
(ii) location information.
3.2 If the buyer specifies a certain setting, the buyer is entitled to require the Company to, and the Company shall immediately, discontinue the use of any or all of the Use’s Information, in accordance with such rules as may be from time to time prescribed by the Company. Depending on the item of the Use’s Information, if such collection or use is required for the Services, the Company may not be able to discontinue such collection unless the buyer withdraws from the Services pursuant to the procedures as determined by the Company.
• Outside Transmissions; Provision to Third Parties; Information Collection Modules
In order to distribute targeted advertisements using the Buyer’s Information, the following information collection module is incorporated into the Services. Thus, the Company provides the Buyer’s Information to the provider of such information collection module in accordance with the following:

(i)	Name of Information Collection Module:	Criteo
(ii)	Provider of Information Collection Module:	Criteo
(iii)	Items of Buyer’s Information to be Provided:	・device information ・log information ・Cookies and anonymous ID ・location information ・Sold Vehicle information ・information for past inquiries about Posted Inventory
(iv)	Means and the Methods of Provision:	by Cookie
(v)	Purpose of Use by Provider:	advertisement
(vi)	Whether or not Provider Intends to Provide Information to Third Parties:	Yes
(vii)	URL of Provider’s Privacy Policy:	http://www.criteo.com/privacy/

(i)	Name of Information Collection Module:	Google
(ii)	Provider of Information Collection Module:	Google
(iii)	Items of Buyer’s Information to be Provided:	・device information ・log information ・Cookies and anonymous ID ・location information ・Sold Vehicle information ・information for past inquiries about Posted Inventory
(iv)	Means and the Methods of Provision:	by Cookie
(v)	Purpose of Use by Provider:	advertisement
(vi)	Whether or not Provider Intends to Provide Information to Third Parties:	Yes
(vii)	URL of Provider’s Privacy Policy:	https://www.google.com/intl/en/policies/privacy/

• Provision of Personal Information of Third Parties
Unless required by the Personal Information Protection Act or other applicable laws and regulations, the Company shall not provide to any third party personal information contained in the Buyer’s Information without the prior consent of the buyer, unless:
(i) The personal information is provided to the Company’s member stores and business associates, such as custom agent, land cargo carrier, shipping agent and vehicle maintenance agent in Japan or abroad for the purpose of providing the Services to the Buyer;
(ii) The Company authorizes such third party to handle the personal information in whole or in part to the extent necessary to accomplish the purpose of the use;
(iii) The personal information is provided through a business transfer by way of merger or other similar transactions;
(iv) The personal information is provided to a provider of an information collection module pursuant to Section 4 hereof:
(v) The Company is required to cooperate with state or local governmental organizations or their agents to perform their duties or obligations pursuant to applicable laws and regulations, and such performance is likely to be precluded if the consent of the buyer must be obtained; and
(vi) In addition to the foregoing, the Company is entitled to disclose information pursuant to the Personal Information Protection Act or other applicable laws and regulations.
• Disclosure of Personal Information
Upon request from the buyer to disclose its personal information under the Personal Information Protection Act, the Company shall, without delay, disclose to the buyer such information after confirming its identity (or notify it of the non-existence of such personal information), to the extent required to do so pursuant to the Personal Information Protection Act and other applicable laws and regulations. Please not that you must pay a commission (10 USD per application. Remittance charge shall be borne by the Buyer) for disclosure of personal information.
• Correction and Suspension of Use of Personal Information
7.1 If the Company is required by the buyer to (1) correct the content of personal information under the provisions of the Personal Information Protection Act because such information is false, or (2) suspend use of personal information because such information is being handled beyond the scope of the purpose of the use previously made public, or has been collected in a fraudulent or otherwise illicit manner, then the Company shall, without delay, conduct an appropriate investigation after confirming the requesting party’s identity, and based upon the results, correct the content of suspend the use of such personal information, and notify the party to that effect. The buyer shall also be notified of any determination, if applicable, not to correct or suspend the use of such information, together with the justification for such determination.
7.2 In the event that the Company is required by the buyer to delete its personal information and has determined that it is necessary to accept such request, the Company shall delete such personal information confirming the requesting party’s identity and shall notify the party to that effect.
7.3 Should the Company not be obligated to correct, or suspend use of, information pursuant to the Personal Information Protection Act and other applicable laws and regulations, the preceding paragraphs shall not apply.
• Inquiries
Any suggestions, questions, complaints, or other inquiries on the handling of the Buyer’s Information must be submitted to:
Address: 4F Masumoto Bldg., 7-4-3, Nishishinjuku, Shinjuku-ku, Tokyo 160-0023, Japan
Tel:+81-3-5937-4554
CardealPage Co., Ltd buyer support center
E-mail Address: partner@cardealpage.com
• Procedure to Amend this Privacy Policy
The Company shall from time to time review how the Buyer’s Information is being handled, and use its best efforts to continuously improve the operation, and make such modifications to this Privacy Policy as may be necessary. Any modification to this Privacy Policy shall be notified to you by posting in the Company’s website; provided that for any modification requiring consent from the buyer pursuant to applicable laws and regulations, such consent from the buyer must be obtained subject to the procedures as separately established by the Company.