Personal Information Protection Policy
Established on August 16, 2023

Too Marker Products Inc. (hereinafter referred to as the “Company”) shall establish the Personal Information Protection Policy as follows.

Ⅰ. Definition and the Method of Collecting Personal Information

1. Definition of terms

(1) “Personal information,” “Personal data” and "Personal data the business holds" used in this Personal Information Protection Policy are used for the same meaning as that in the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003) (including the subsequent revisions; hereinafter referred to as the “Personal Information Protection Act”).

(2) “Historical information and characteristic information” shall refer to those other than the above “Personal information,” including used services; history of viewed pages and advertisement; search key words searched by customers; dates and times, methods and environment of using services (including the communication status of mobile terminals, various setting information, etc. for the use when using through the terminals), postal codes, gender, job, age, customers’ IP addresses, Cookie information, location information and individual identification information of terminals.

2. Method of collecting personal information

(1) When providing various web services (including the provision through the website and via smartphone applications), the Company may ask information, including customers’ name, birth date, address, telephone number and email address. Moreover, the Company may collect from its business partners (including information providers, advertisers and advertisement distribution targets; hereinafter referred to as the “Business Partners”), etc. records of transactions, etc., including customers’ personal information, conducted between customers and its Business Partners, etc.

(2) The Company may collect customers’ historical information and characteristic information when they use the services of the Company or its Business Partners or view the pages of the Company or its Business Partners.

(3) The Company may collect personal information through the exchange of business cards between its officials/employees and customers among others.

Ⅱ. Matters concerning the Purposes of Using Personal Information

The Company shall handle customers’ personal information to the extent necessary to achieve the following purposes of use:

・To respond to the inquiry from customers concerning products and services of the Company;
・To provide customers with products and services of the Company;
・To provide information that is deemed to be useful and necessary for customers, including introduction, advertisement and promotion of products and services of the Company and third parties;
・To conduct and analyze questionnaire surveys for the improvement of services;
・For the purposes of use separately listed for each service; and
・Otherwise, to perform appropriately and smoothly operations which are incidental or related to the above purposes of use.

Ⅲ. Matters concerning Joint Use of Personal Information

The Company shall jointly use customers’ personal information as follows.

1.Items of personal data to be used jointly

・Information on customers, including name, birth date, address, telephone number, email address, contacts such as SNS accounts, information on family members, and information on place of employment

・Separately listed information to be used jointly in each service

2. Scope of joint users

Group companies of Too Corporation (Too Group) shown in the following:
https://www.too.com/company/group.html

3. Purposes of use

・For proposals, introduction and development of products and services as the Too Group

4. Name, address, name of representative of the person responsible for the management of personal data

Too Marker Products Inc.
Meguro-Higashiyama Bldg. 1-4-4 Higashiyama, Meguro-ku, Tokyo 153-0043
Chief Executive Officer: Gota Ishii

Ⅳ. Matters concerning Personal Data the Business Holds

1. Name, address, name of representative of the business handling personal information

Too Marker Products Inc.
Meguro-Higashiyama Bldg. 1-4-4 Higashiyama, Meguro-ku, Tokyo 153-0043
Chief Executive Officer: Gota IshiiResponsible Department: Product Planning Department
For inquiry: https://form.too.co.jp/form/pub/fm01/copic_inquiry/

2. Purposes of using personal data the business holds

The purposes of using personal data the Company holds shall be the same as the purposes of using personal information stated in II. above and the purposes of use for jointly using personal data stated in III.3. above

3. Procedures for responding to the request for disclosure, etc.

The Company shall appropriately and promptly respond in accordance with laws and regulations if customers request notification of the purposes of use, disclosure (including disclosure of the records on provision of personal data to third parties), correction/addition/deletion, suspension/erasure of use, and suspension of provision to third parties (hereinafter referred to as the “Request for Disclosure, etc.”). For the Request for Disclosure, etc., prescribed fees may be charged.
If the customers themselves cannot be confirmed, or authority of representation cannot be confirmed for the request by an agent, and there is any deficiency in documents such as the prescribed request form, etc. among others, the Company may not accept the Request for Disclosure, etc.; and therefore, it would be appreciated if information required for identifying personal data the business holds subject to disclosure, etc. would be provided.
Moreover, the Company may not respond to the Request for Disclosure, etc. due to the provisions of laws and regulation, for which the Company would appreciate customers’ understanding in advance.
Notwithstanding the above, the Company shall not disclose in principle information other than personal information such as historical information and characteristic information.

4. Safety management measures for personal data

For the prevention of leakage, loss, damage of personal data (hereinafter referred to as the “Leakage, etc.”) and other safety management of personal data, the Company shall take the following necessary and appropriate measures and strive to improve them. Moreover, when its employees handle personal data, the Company shall conduct necessary and appropriate supervision on its employees so that safety management of such personal data shall be conducted.

・Formulation of the basic policy ・Establishment of the discipline for handling personal data
・Organizational safety management measures (Establishment of organizational structure for taking safety measures, operation in accordance with the discipline for handling personal data, establishment of means to confirm the status of handling personal information, establishment of the system to respond to cases of Leakage, etc., grasping of the handling situation and review of safety management measures)
・Human safety management measures (Education of employees, etc.)
・Physical safety management measures (Management of areas for handling personal data, prevention of theft, etc. of devices, electronic media, etc., prevention of leakage in the case of carrying electronic media, etc., deletion of personal data and disposal of devices, electronic media, etc.)
・Technical safety management measures (Access control, identification and authorization of accessors, prevention of unauthorized access from outside, prevention of Leakage, etc. due to the use of information systems)
・Grasping of external environments

Ⅴ. Entrustment of Handling of Personal Data

The Company may entrust third parties with all or part of operations of handling personal data to the extent necessary for the achievement of the purposes of use. In this case, the Company shall select appropriate parties to be entrusted to ensure safety management of personal data at the entrusted parties, conclude with the entrusted parties agreements on confidentiality and personal information protection, and conduct necessary and appropriate supervision on the entrusted parties, including confirmation on the status of handling personal data at the entrusted parties.

Ⅵ. Contact for Complaints about Handling of Personal Data the Business Holds

• For opinions and requests concerning the handling of personal data the Company holds, please contact the Company’s reception window (Responsible department stated in IV.1. above).
• Reception hours: 10:00 a.m.-noon and 1:00-5:30 p.m. except for Saturdays, Sundays, public holidays and year-end and new year holidays

Ⅶ. Other Matters

1. Access analysis tool

The Company’s website uses an access analysis tool by Google “Google Analytics.” Google Analytics uses Cookie to collect data. These data are collected anonymously, which will not identify individuals.
Regarding this function, customers can reject the collection by nullifying Cookie: Please check the setting of the browser used. For details of these Rules, please see pages for Google Analytics Service Terms of Use, and Google Policy and Rules.

2. Advertisement

The Company’s blog uses advertisement services distributed by third parties (Google AdSense, A8.net), using Cookie to display advertisement of products and services according to customers’ interest.
With the use of Cookie, this site becomes able to identify customers’ computers but cannot specify customers themselves.

For the method of nullifying Cookie and details of Google AdSense, please check “Advertisement – Policy and Rules – Google.”

If you wish to nullify the distribution of advertisement using Cookie (Remarketing advertisement, etc.), please access to the opt-out page of advertisement media below, and follow the procedures.

Yahoo!
http://btoptout.yahoo.co.jp/optout/preferences.html

Google
https://www.google.com/intl/ja/policies/technologies/ads/

Facebook
https://www.facebook.com/legal/terms

3. Compliance with laws and regulation and continuous review

The Company shall comply with laws, regulations and other norms in Japan applicable to personal information it holds, continuously review the content of this Policy, and strive to improve it.