Privacy Policy

PT. FreakOut dewina Indonesia (hereinafter the “Company”) uses the advertising delivery system “Hike,” to display advertising estimated to have high relevance to users, based on user information. The Company recognizes the importance of Personal Information, and, in addition to complying with the Personal Information Protection Act and other related laws, regulations, and guidelines, the Company takes the following measures to ensure the protection of Personal Information and Informative Data.

Section 1. Basic Policy on the Protection of Personal Information

1. Definition of Personal Information
Personal Information is information about a living individual, including name, date of birth, and other descriptors, which can be used to identify a specific individual. This includes information, which in itself is able to identify a specific individual, as well as information that can be combined with other information to easily identify a specific individual (Personal Information Protection Act Article 2 paragraph 1).

2. Purpose of Use of Personal Information
The Company shall use Personal Information within the scope necessary to accomplish the following purposes. Consent shall be obtained in advance prior to using Personal Information for any purposes other than those below:

(1) Providing for the smooth use of the Company’s services by users (advertising-related services, media management, other related business)
(2) Creating statistical data related to the Company’s services
(3) Responding to user inquiries
(4) Planning new services in relation to the Company’s future services
(5) Providing information related to the Company’s services
(6) Other purposes set out separately in the Company’s various services

3. Limitations on Use of Personal Information
The Company shall not use Personal Information for any use other than the accomplishment of the purposes of use without prior consent from the individual. Even in the event that Personal Information is acquired in the course of a merger or other reasons, this shall not be handled outside of the scope of the purposes of use before the handover without prior consent from the individual. However, this shall not apply in the following cases:
(1) When prescribed by laws and regulations
(2) When necessary for the protection of human life, body, or property and where obtaining the consent of the individual in question is difficult
(3) When particularly necessary for the improvement of public health or the promotion of healthy child development and where obtaining the consent of the individual in question is difficult
(4) Where necessary in order to cooperate with the exercise of the duties of national agencies, local governments, or delegated parties in accordance with the law and where obtaining the consent of the individual in question may hinder the exercise of the said duties

4. Appropriate Acquisition of Personal Information
The Company shall acquire Personal Information by appropriate means and shall not obtain Personal Information by deceitful or wrongful means. The Company shall also take care to not indiscriminately collect information concerning children younger than 15 years of age without the consent of their guardian.

5. Notification of Purpose of Use of Personal Information at the Time of Acquisition
The Company shall publish the purpose of use prior to the acquisition of any Personal Information. However, this shall not apply in the following cases:
(1) Where there is a risk of damage to the life, body, or property or other rights and interests of the user or other third party, by notifying the user or publishing the purpose of use
(2) Where there is a risk of damage to the rights or legitimate interests of the Company by notifying the user or publishing the purpose of use
(3) Where necessary, to cooperate with the exercise of the duties of national agencies, local governments, or delegated parties in accordance with the law, and where notifying the user or publishing the purpose of use may hinder the exercise of said duties
(4) Where it is deemed that the purpose of use is clear based on the circumstances surrounding the acquisition

6. Changes to the Purpose of Use of Personal Information
Where the Company makes changes to the purpose of use of Personal Information, these changes shall not exceed a reasonable range in terms of considerable relevance with the prior purpose of use. Users shall be notified of the said changes to the purpose of use, and they shall be published.

7. Secure Management of Personal Information and Employee Supervision
The Company shall establish regulations for the protection of Personal Information so as to securely manage Personal Information against leak, loss, or other damage and shall provide necessary supervision of employees.

8. Supervision of Subcontractors
Where the Company subcontracts all or part of the handling of Personal Information, the Company shall enter into a contract with the subcontractor, which includes confidentiality, or shall obtain an agreement on the terms and conditions set by the Company and shall provide appropriate and necessary supervision to ensure that the subcontractor exercises appropriate management of Personal Information.

9. Limits on Provision to Third Parties
The Company shall not provide Personal Information to any third party without the prior consent of the user, except in the following cases:
(1) When prescribed by laws and regulations
(2) When necessary for the protection of human life, body, or property and where obtaining the consent of the individual in question is difficult
(3) When particularly necessary for the improvement of public health or the promotion of healthy child development and where obtaining the consent of the individual in question is difficult
(4) Where necessary in order to cooperate with the exercise of the duties of national agencies, local governments, or delegated parties in accordance with the law and where obtaining the consent of the individual in question may hinder the exercise of the said duties
(5) When the following have been announced or published in advance:
Purpose of use includes disclosure to third parties
Data provided to third parties
Means or methods of providing to third parties
Suspension of the provision of Personal Information to third parties at the request of the user
However, in the following cases, the above shall not apply to third parties:
Where the Company outsources the handling of all or part of the Personal Information within the scope of accomplishing the purpose of use
When Personal Information is provided for the purpose of business continuity in the event of a merger or other reasons
When Personal Information is used in association with specific parties and when, regarding the items of Personal Information used in association, the fact that such use will take place, the scope of the cooperative users, the purpose of use for the cooperative user, and the management of said Personal Information, the user is notified in advance or be provided with the opportunity to easily know the name and corporate names of the responsible parties.
When Personal Information is used in association with specific parties, in the event of a change to the purpose of use or the name and corporate name of the responsible managers, users shall be notified in advance or be provided with the opportunity to easily know about the details of the change.

10. Publication of Matters related to Personal Information
The Company shall make users aware of the following in relation to Personal Information and shall respond to requests from users without delay.
The purpose of use of Personal Information (except when no obligations exist under the Personal Information Protection Act. When a decision is made to not respond, this shall be made known to the user without delay.)

11. Disclosure of Personal Information
When the Company is requested by users to disclose their Personal Information, the Company shall do so without delay. However, where the said disclosure falls under any of the following items, all or part of said Personal Information may not be disclosed, and when the decision is made to not disclose, the user shall be notified to this effect without delay:
(1) When it may result in damage to the life, body, property, or other rights and interests of the user or a third party
(2) When it may result in significant obstacles to the proper implementation of the Company’s business
(3) When it would result in the violation of other laws and regulations
In principle, information other than Personal Information, such as access logs, shall not be disclosed.

12. Correction of Personal Information
Where a user requests the Company to make corrections, additions, or deletions (hereinafter “make corrections etc.”) to the contents of Personal Information because it is incorrect, except where other specific procedures have been set out by other laws or regulations, the Company shall conduct the required examination of the situation without delay within the scope necessary to accomplish the purpose of use, and based on the results of said examination, shall make corrections etc. to the Personal Information and so notify the user.

13. Suspension of Use of Personal Information
Where a user requests the Company to suspend the use of or delete (hereinafter “suspend use etc.”) the user’s Personal Information for the reason that it has been used outside of the scope of the purpose of use published beforehand or that it was acquired by deceitful or wrongful means, the Company shall make the required examination of the request without delay and based on the results shall suspend use of the Personal Information and so notify the user. However, in the event that the suspend use etc. of the Personal Information would be excessively costly or otherwise difficult, the Company shall take alternative measures to protect the rights and interests of the user.

14. Explanation of Reasons
The Company shall work to explain reasons when notifying users of any of the following decisions despite a request from the user.
(1) Notification of purpose of use is not given
(2) All or part of Personal Information is not disclosed
(3) Use of Personal Information is not suspended
(4) Provision of Personal Information to third parties is not suspended

Section 2. Use of Informative Data

1. Definition of Informative Data
Informative Data refers to information such as gender, information related to personal hobbies etc., cookies, and IP address information, etc., and it is log information related to Internet use, which cannot identify an individual.

2. Acquisition of Informative Data
The Company shall issue a random ID composing a unique string for every browser used by the user for browsing (hereinafter “Unique ID”), which shall be stored as a cookie by the browser.
Further, in the case of smartphone apps, which do not use cookies, the smartphone ad identifier provided by the smartphone OS for the identification of users (IDFA or Google Advertising ID) shall be used as the Unique ID. The following informative data shall be acquired using the cookie, IDFA, or Google Advertising ID:

(1) User agent
(2) IP address
(3) Device information (Nexus 7, sc-03g, etc.)
(4) Site URL
(5) Access date
(6) Site browsing behavior information and conversion information defined separately for each advertiser
(7) Advertising identifier

The informative data acquired by the Company is not deemed to be Personal Information, as it cannot identify a specific individual, and this cannot be easily done even when combined with other information.

In addition to the above, the Company may obtain from cooperating businesses (third parties) data such as segment information strung to Unique IDs issued by the Company. This data does not include data that can be used to identify an individual, as Unique IDs are issued randomly in relation to the browser.

3. Purpose of Use of Informative Data
The informative data acquired by the Company is used for the delivery of online advertising, to measure the effectiveness of advertising delivery and specifically for the following applications.
(1) The classification of users based on their behavioral histories, as defined by advertisers, advertising agencies, and other media that use the Company’s service and the delivery of targeted ads based on these classifications
(2) The measurement of advertising effectiveness, market analysis, and the creation of market research reports
(3) Ensuring smooth use of the Company’s services by businesses cooperating with the Company
(4) The creation of statistical data related to the use of the Company’s services
(5) For use in the planning of new services related to future services of the Company

4. Changes to the Purpose of Use of Informative Data
Where the Company makes changes to the purpose of use of informative data, said changes shall not exceed the reasonably accepted scope of the purpose of use prior to the change, and said changes to the purpose of use shall be made public.

5. Secure Management of Informative Data and Employee Supervision
The Company shall provide necessary and appropriate supervision of employees for the protection of Personal Information against leak, loss, or other damage and to ensure the secure management of other user information.

6. Supervision of Subcontractors
Where the Company subcontracts all or part of the handling of informative data, the Company shall enter into a contract with the subcontractor that includes confidentiality and shall provide appropriate and necessary supervision to ensure that the subcontractor exercises appropriate management of the informative data.

7. Provision to Third Parties
In the following circumstances, the Company shall provide informative data to third parties.
(1) When prescribed by laws and regulations
(2) When necessary for the protection of human life, body, or property and when obtaining the consent of the individual in question is difficult
(3) When particularly necessary for the improvement of public health or the promotion of healthy child development and where obtaining the consent of the individual in question is difficult
(4) Where necessary in order to cooperate with the exercise of the duties of national agencies, local governments, or delegated parties in accordance with the law and where obtaining the consent of the individual in question may hinder the exercise of said duties
(5) Where businesses cooperating with the Company require informative data
(6) For the continuation of business in the case of merger or other reasons

8. Changes to Privacy Policy
The Company may change the content of this Privacy Policy at any time, and the content following the change shall then be deemed to apply.

9. Opt-out
Enabling the opt-out option will stop your browser or smartphone app from accumulating browsing information and will suspend the use of such information (including provision to third parties).
The opt-out function needs to be set for each browser, and after opting-out, information on visits to the site by the user will no longer be collected; however, in the event of the deletion of the cookie or changes to terminal devices disabling this setting, the accumulation, use, and provision of information to third parties may recommence in some cases.
Please see the following link to enable the opt-out function:
http://id.foutap.com/privacy_policy/opt_out
(enabled as soon as the retargeting function is requested for)

Inquiries regarding this Privacy Policy:

PT. FreakOut dewina Indonesia E-mail:id@foutap.com

Mar 1, 2016

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