1.1 Personal Information. “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. In addition, for the purpose of this Policy, Personal Information also refers to “Personal Information” as defined in the “Act on the Protection of Personal Information” of Japan. In addition, we will also treat, as part of Personal Information, IP address and terminal device information acquired from the User’s browser. The following are categories (with non-exhaustive examples) of personal information we may collect about you:
Solely for the purposes of the California Consumer Privacy Act (CCPA), Personal Information does not include:
1.2 Sources of Personal Information. We obtain the categories of personal information listed above on or through our Platform from the following categories of sources:
1.3 Acquisition of Personal Information. Personal Information necessary for business activities will be acquired by us directly from Users and other parties, from the browser or mobile application environment, or via our partners. Additionally, when we acquire Personal Information, we will let you know or publicly announce the purpose of use thereof in advance (hereinafter referred to as “Public Announcement, etc.”) except in the following circumstances:
2.1 User Information. Spider Labs’s primary purpose in collecting personal information is to provide the Services and Content that you request on the Platform. Spider Labs may also use personal information for various purposes, including without limitation to:
2.2 Use of Client Information. Spider Labs may also use Personal Information pertaining to contact persons, etc., of our client corporations and self-employed business owners as follows:
2.3 Job Applicant Information. We may use Personal Information pertaining to individuals who desire to join Spider Labs and apply for job openings for the following purposes
With regard to Section 2.1 (User Information), we may prepare anonymously processed data and provide the same to a third party upon taking appropriate protective measures to ensure that Users will not be identified or specified and that Personal Information used for the preparation of such data cannot be restored. Additionally, anonymously processed data to be prepared by us may include User Agent information (such as IP addresses, terminal device information and referrer), behavioral information such as clicks, viewing and installation, server domain information, text, image, audio and html information, and such provision will be prepared in data files and by data transmission in a secure manner.
In addition to the specific situations discussed elsewhere in this Policy, Spider Labs may share your personal information in the following circumstances:
3.1 Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
3.2 Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this policy, and we may do so with your consent.
3.3 Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service.
3.4 Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Platform. Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Policy. Access to your personal information by these service providers is limited to the information reasonably necessary for the service provider to perform its limited function. We require our service providers to keep the personal information that they are provided with confidential and to comply with all applicable laws.
3.5 Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites.
3.6 Partner or Client Offerings. We may jointly offer events, promotions, or any other product or service offerings with third party partners or our clients, which may be your employer. The personal information that you submit through an event, promotion, or other product or service offering may be combined and transmitted with the Registration Information related to your Account. Third party partners or clients may collection information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a third-party partner or client, the information that you provide may be shared with us and with that identified third party.
3.7 Social Networking. The Platform may offer you the ability to share your personal information through a social networking website (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
3.8 Public Forum and Messaging. The Platform may provide you with the opportunity to post comments, messages, or reviews in a public forum. If you decide to submit personal information at these locations, that information will be available to other Users of the Platform.
3.9 Referrals. Users may recommend other Users to join the Platform by providing their contact information or selecting friends from a social networking site. Users may also provide information about other Users of the Platform such as reviews of the services or products that he or she received, booking or scheduling information, or reference information.
We strive to protect Personal Information. For instance, when transmitting Personal Information and other confidential information (such as credit card numbers), we encrypt such information by using SSL (Secure Socket Layer) to protect such information. No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
5.1 Access to Your Personal Information. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law.
5.2 Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your Account. Note that we may keep historical information in our backup files as permitted by law. If our Platform does not permit you to update or correct certain personal information, please contact us as described below.
7.1 Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Platform, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your Account, to fulfill orders for products and service you have requested or deliver notifications directly to you through the Platform.
7.2 Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites. If you wish to limit third parties’ collection of information about your use of our Platform, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE PLATFORM. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
7.3 Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, we do not modify your experience based upon whether such a signal is broadcast.
9.1 When a User uses our service or views our website, we may automatically acquire the User’s cookie, IP address, IDFA, AAID and other information from the User’s browser. We may use such information for the purpose of identifying the User, delivering optimal advertisement, analyzing for delivery of optimal advertisement, developing a new service, and optimizing our services for Users.
9.4 Additionally, for the steps to activate or inactivate cookies, IDFA, AAID, or other information or to delete such information, please see the manuals or Help pages for your OS or browser (with regard to advertising identifiers of third parties such as Google and Apple, please see the privacy policies of such parties).
9.5 For any question regarding the identification document, fees, and other specific procedures, please also make an inquiry to our contact indicated below.
12.1 Lawful bases for processing. Spider Labs is required to inform you of the lawful bases of our processing of your personal information, which are described in the table below. If you have questions about the lawful basis of how we process your personal information, contact us at the address listed in the section titled “CONTACTING US” below.
13.1 Categories of Personal Information Disclosed for a Business Purpose or Valuable Consideration. California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 require that a business disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those term is defined under California law. Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. In the proceeding twelve months, we have disclosed the following categories of personal information in the manner described.
13.2 Your Rights. If you are consumer as defined in the California Consumer Privacy Act (CCPA), i.e., a resident of California as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in relation to your personal information under the CCPA. Under the CCPA, you have the following rights:
To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by visiting the following Internet Web page link: https://spideraf.com/
Once You make an opt-out request, We will wait at least twelve (12) months before asking You to reauthorize personal information sales. However, You may change Your mind and opt back in to personal information sales at any time by visiting the following Internet Web page link: https://spideraf.com/
13.3 Additional California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Oaklo are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If You are a California resident and would like a copy of this notice, please submit a written request to us at the addresses listed below.
14.1 No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
14.2 What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
14.3 Time to Respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
14.4 No discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.
Spider Labs, Ltd.
Attention: Data Processing Officer
Minamiaoyama ST Bldg. 4F, 7-10-3 Minamiaoyama, Minato-ku, Tokyo 107-0062
Last Revised: [December 5, 2022]
Amended on October 11, 2012
Amended on July 5, 2013
Amended on April 1, 2019
Amended on October 15, 2019