Privacy Policy

1. Introduction

SmartNews, Inc. (“we,” “us,” or “our”) takes protecting your privacy seriously. Our mission is to deliver quality information to the people who need it around the world, and that mission should never come at the expense of your privacy.

Scope

This Privacy Policy (the “Common Policy”) explains what information we collect, and how we use, share, and disclose it. We may provide applications and web services, and related services, under the names “SmartNews,” “SmartNews＋,” “SmartNews for docomo,” “Wanderland,” and other names (excluding advertising placement services provided to advertisers and agencies; collectively, the “Services”). In this Common Policy, “User” means a user of our Services. Please note that the specific handling of information for each service is governed by that service's individual privacy policy (a “Service-Specific Policy”). The information collected, purposes of use, disclosure recipients, and how you may exercise your rights may vary from service to service.

Changes to this Common Policy and Service-Specific Policies

We may modify and revise this Common Policy and any Service-Specific Policy from time to time. If we make a material change to this Common Policy or a Service-Specific Policy, we will notify you by posting a notice within the relevant service or by other means required by applicable law, and we will indicate when the change takes effect.

Order of Precedence

If there is any conflict between this Common Policy and a Service-Specific Policy, the Service-Specific Policy will govern.

2. SmartNews Privacy Policy

This Service-Specific Policy (the “SmartNews Privacy Policy”) applies to the applications and web services, and related services, that we provide or operate under the names “SmartNews,” “SmartNews＋,” and “SmartNews for docomo” (collectively, “SmartNews”).

Information We Collect

To provide SmartNews, we collect the following information from SmartNews users (“SN Users”).

1. Information provided by SN Users, or collected with their permission
2. Information related to SN Users' use of SmartNews
3. Information from external partners

1. Information provided by SN Users, or collected with their permission

• Information about SN Users: We may collect information about SN Users' attributes and interests to understand what content they might be interested in. We may also collect information that can identify a specific SN User (name, email address, profile image, etc.) when they set up an account or otherwise use SmartNews.
• Information related to SNS: We may allow SN Users to connect certain social networking services (“SNS”) to SmartNews, and may collect information about the SN User from an SNS that the SN User has made available through their privacy settings. For example, if an SN User links their X (formerly Twitter) account to SmartNews and wants to see what news the people they follow on X are sharing, links to those news stories will be sent to the SN User through SmartNews. Please check the privacy policy of the SNS you use for details on how your information is shared through the SNS and what information is available through your SNS account.
• Information based on interactive features: We may offer interactive features, including features that allow SN Users to submit User content. We and other SN Users of SmartNews may obtain information submitted or made available by an SN User through these interactive features. Information disclosed through these features is not covered by the privacy protections described in the SmartNews Privacy Policy.
• Information related to surveys: We may contact SN Users to invite them to participate in surveys. If an SN User participates, they may be asked to provide certain information, which may include personal information.

2. Information related to SN Users' use of SmartNews

• Device information: We and third parties we work with may automatically collect information about the device an SN User uses to access SmartNews. This may include the SN User's IP address, device-specific advertising identifiers (Google Advertising ID or Apple Advertising ID) and other device identifiers, cookie information, device name, operating system, country code, app version, and other user setting information.
• Behavioral data: We automatically collect certain data about an SN User's activity on SmartNews. This includes information about how the SN User uses SmartNews, such as the pages, content, or features viewed, the time spent using them, hyperlinks clicked from content displayed on SmartNews, and referrer information.
• Location information: SN Users may, at their own choice, provide us with location information such as postal code, city/ward information, or GPS data in order to receive weather, local news, or location-based advertising. In addition, we may estimate an SN User's location using various techniques, such as their IP address or sensor data from their device that detects nearby Wi-Fi access points or cell towers, and may use such estimated location information to deliver advertising.

3. Information from external partners

• Information from external partners: We may receive information about SN Users from partners such as publishers, advertisers, and data providers. Our partners may provide us with information about the SN User's behavior, attributes, and interests outside of SmartNews, including information about the SN User's device, device identifiers, email address, phone number, location information (including precise location such as GPS data or store visit information), websites and advertisements the SN User interacts with, browsing patterns, and how the SN User uses our partners' services.
• In particular, through the “d Account” linking service provided by NTT DOCOMO, Inc., we receive the following information about SN Users:
  • d Account and d POINT CLUB membership information
  • Article-viewing history in “My Magazine” for the past 6 months
  • d POINT CLUB-related data (d POINT balance, d POINT CLUB stage, etc.)
  • Recommendation information based on the SN User's behavior within DOCOMO services
  • Segment information for displaying ads and coupons

Purposes of Using Collected Information

Our primary purpose in handling information is to deliver quality information to SN Users. We handle SN Users' information for the following business purposes, among others.

1. To provide services and information
2. To measure performance and conduct research
3. For customer support
4. To deliver advertising
5. For administrative or legal purposes

1. To provide services and information. This includes handling SN Users' information to:

• Fulfill our contract with the SN User
• Customize and deliver content tailored to interests we infer from data we have collected
• Provide access to specific SmartNews features, such as local news or weather forecasts
• Create, authenticate, and update SN User accounts
• Manage SN User information

2. To measure performance and conduct research. This includes handling SN Users' information to:

• Measure usage such as interests and time spent on SmartNews
• Pursue our legitimate interests, such as R&D (including marketing research), network and information security, and fraud prevention
• Improve our products and SmartNews
• Develop new products and services
• Conduct certain analyses. For example, we may use personal information and other data to create de-identified statistical information, such as de-identified demographic information, de-identified location information, and information about the computer or device an SN User used to access SmartNews.

3. For customer support. This includes handling SN Users' information to:

• Respond to SN Users' questions, comments, and other requests
• Investigate and respond to SN User or technical support requests
• Communicate with SN Users about activity on SmartNews or changes to our Terms of Service
• Conduct certain analyses, as described above

4. To deliver advertising. This includes handling SN Users' information to:

• Provide personalized advertising to SN Users (including for the purpose of measuring and improving advertising effectiveness, such as measuring store visits). We and our partners may provide personalized advertising to the extent permitted by applicable law, for example, based on an SN User's attributes or location, or based on inferred information (such as places of interest or place of residence) derived from behavioral or location data.
• Perform cross-device tracking to match an SN User's browsing history across different websites, devices, or apps. For example, we may attempt to match an SN User's browsing history on a mobile device with that on a tablet. To do this, our partners may share data such as behavioral patterns, location information, and device identifiers to match browsers or devices likely used by the same SN User.

5. For administrative or legal purposes

• To ensure quality control and safety
• To verify identity in response to specific requests or claims
• To conduct audits
• To prevent and report prohibited or potentially unlawful conduct
• To enforce our agreements
• To comply with our legal obligations. For example, we may disclose SN User information to specific judicial or administrative authorities regarding certain claims or disputes related to the use of SmartNews.

Sharing of Information

We may share information collected from SN Users in the following circumstances.

1. Sharing with advertising partners
2. Sharing with media partners
3. Sharing with service providers
4. Where the SN User has consented or requested it
5. Outsourcing to affiliated companies
6. Where required by law
7. In connection with business transfers

1. Sharing with advertising partners

• We may provide information we have collected about SN Users to ad-serving companies, advertising agencies, and other advertising partners (“Advertising Partners”) to deliver advertising within SmartNews that is personalized to SN Users' interests. We may also provide such information to Advertising Partners to measure the effectiveness of ads served within SmartNews (including measuring store visits) and of our ads served by Advertising Partners on other services. Information we provide to Advertising Partners is limited to information that cannot, on its own, identify an SN User, such as a hashed email address. However, Google, Meta, and Amazon, as Advertising Partners, may match the information we provide against personal information they hold about the SN User for the purpose of delivering advertising personalized to the SN User's interests. In such cases, Google, Meta, and Amazon handle the matched information as personal information in accordance with their own standards.
• When an SN User uses SmartNews, these Advertising Partners may collect information about the SN User's activity and device (e.g., IP address, device identifiers, pages visited, location, time of day). Advertising Partners may use this information (together with similar information collected from other services) to deliver personalized advertising to the SN User when they access SmartNews and other services within the Advertising Partner's network. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
• If you do not want your personal information shared with third-party Advertising Partners, please follow the method described later in this policy.
• We may match information about SN User behavior and devices provided by Advertising Partners against personal information about the SN User that we hold. This matching is performed to deliver personalized advertising and measure advertising effectiveness. In such cases, we handle the matched information appropriately as personal information.

2. Sharing with media partners

We contract with numerous media partners to provide quality content through SmartNews. We may provide media partners with statistical information that does not identify individual SN Users, such as attribute information and view counts related to each piece of content, to help them create better content.

We also carry out part of SmartNews' content distribution jointly with NTT DOCOMO, Inc. In connection with this distribution, we may provide information collected about SN Users (identifiers, in-app settings, and in-app behavioral data) in the same way as described above for Advertising Partners.

3. Sharing with service providers

We may contract with service providers for the provision and management of SmartNews. The types of service providers to whom we outsource the handling of information include those for: (i) providing SmartNews; (ii) providing information, features, or other services requested by SN Users; (iii) analytics; (iv) marketing and advertising; (v) customer service; and (vi) IT-related services.

For example, we use MailChimp to send SN Users notifications related to SmartNews, including but not limited to our newsletters and emails. For details, please see MailChimp's privacy policy (https://mailchimp.com/legal/privacy/).

We also use Google analytics services, including Google Analytics for Firebase, to obtain analytics information about SmartNews, and we use the YouTube API to provide YouTube videos within our content. For details on how Google handles SN User information, please see Google's privacy policy (https://www.google.com/policies/privacy/partners/). For details on how to opt out of Google Analytics' handling of your information on our website, please visit https://tools.google.com/dlpage/gaoptout.

4. Where the SN User has consented or requested it

We may share an SN User's information with third parties where the SN User has given consent, or where the SN User has expressly requested that we share their information.

5. Outsourcing to affiliated companies

We may outsource the handling of personal information to our group companies in compliance with applicable law.

6. Where required by law

We cooperate with judicial authorities, administrative authorities, and private organizations to enforce and comply with the law. We may, at our discretion, disclose information about SN Users to judicial authorities, administrative authorities, or private organizations, based on applicable law, where we consider it necessary or appropriate: (i) to respond to claims or legal process (including subpoenas); (ii) to protect our property, rights, and safety, or the property, rights, and safety of a third party or the public; and (iii) to prevent activity that we determine may be illegal, unethical, or subject to legal action.

7. In connection with business transfers

If we are involved in a merger, acquisition, due diligence for financing, corporate reorganization, bankruptcy, receivership, purchase or sale of assets, or transfer of services to another business, SN User information may be shared as part of that transaction to the extent permitted by law or contract.

Special Provisions for SmartNews＋ Users

In addition to the above, for SmartNews＋ subscribers, we collect information necessary to process payment and share it with our designated payment processor. However, we do not collect or retain billing addresses, credit card numbers, bank account information, or identity verification information (identification documents, photos, etc.); these are processed by the payment processor. In addition, where the payment processor collects information directly through its own website separately from our payment processing, that collection is subject to the payment processor's own privacy policy and terms, which you should review.

Personal Settings

Overview

SN Users may be able to opt out of certain uses of their information.

Email communications

If you receive an unwanted email from us, you can use the unsubscribe link at the bottom of the email to stop receiving future emails. Emails related to SmartNews that the SN User has requested will continue to be sent. We may also send SN Users certain non-promotional notices about us and SmartNews (such as communications about SmartNews or updates to our Terms of Service, the SmartNews Privacy Policy, or this Common Policy), and SN Users cannot opt out of these.

Mobile device settings

We may send push notifications through our apps. SN Users can stop these notifications by changing their mobile device settings.

If an SN User has enabled precise location collection through our app, we may collect it. In this case, we may use GPS and other location information to deliver advertising suited to the SN User (for example, coupons or deals for nearby stores when precise location is enabled in the app). SN Users can stop the use of precise location by changing their mobile device settings.

Note that we may also obtain precise location information from external partners where the SN User has enabled precise location in an app operated by that partner. Even after opting out of precise location use, we may still estimate an SN User's location using various techniques, such as IP address or sensor data detecting nearby Wi-Fi access points or cell towers, and may use this estimated location for advertising delivery or measuring advertising effectiveness such as store visits (for details, see here). If you do not want location-based advertising, you can opt out using the method described under “Personalized Advertising” below.

Personalized advertising

If you want to opt out of the advertising technologies and similar technologies (e.g., cookies) we use on SmartNews, you can do so by blocking, disabling, or deleting them in your browser or device. You can also opt out using the steps below. Note that this will stop personalized advertising, but non-personalized online advertising will still appear on SmartNews.

• To stop personalized advertising delivered directly by SmartNews: long-press a displayed ad and tap “About SmartNews Ads.” The next screen will show a link to stop personalized advertising on SmartNews.
• To restrict advertising through Apple, Google, or other mobile OS settings: follow the instructions for Android, iOS, and other mobile operating systems, which may describe how to opt out of personalized advertising.
• To stop personalized advertising provided by third parties other than SmartNews within the SmartNews app: opt out of personalized advertising in your account settings for each applicable service. If you do not have an account with a particular service, you likely will not see personalized ads from that service.
  • https://adssettings.google.com/authenticated
  • https://www.facebook.com/ads/preferences/

The online advertising industry also offers websites where you can opt out of receiving targeted ads from advertisers participating in self-regulatory programs. You can visit these sites to learn more about targeted advertising and your choices regarding privacy.

• https://optout.networkadvertising.org/
• https://www.youronlinechoices.com/
• https://optout.aboutads.info/

Please note that cookie-based opt-outs are not effective within mobile applications, and must be set separately for each browser and each device.

Your Rights Regarding Personal Information

Depending on applicable law, SN Users may have the following rights.

• The right to confirm whether we are processing your personal information
• The right to access your personal information and obtain a copy of related detailed information
• The right to receive an electronic copy of personal information you provided to us, or to request that we transmit it to another company (the “right to data portability”)
• The right to change, update, or correct your personal information
• The right to withdraw consent to the handling of personal information
• The right to request that we restrict the use of personal information
• The right to opt out where we handle your personal information for purposes such as targeted advertising (as defined by applicable law)
• The right to request deletion of personal information we hold about you
• The right to object to our handling of your personal information
• The right to challenge our decision to decline your request

To exercise these rights, please open the “Settings” menu in the SmartNews app, then tap “Help Center.” The Help Center provides a form for submitting inquiries — please specify your request in the form. The Settings menu also includes a feature for deleting personal information used to provide account features and your news feed (for details, see here). If you have any questions, please contact us using the details at the bottom of this page. Please note that technical limitations may prevent us from fulfilling certain requests. We may respond to deletion requests by de-identifying or anonymizing information instead.

We will process the exercise of these rights in accordance with applicable law. To protect your privacy, we will verify your identity before responding to your request.

To verify your request, we use a unique identifier assigned to your device by our app. When you submit a request following the instructions above, we automatically receive this identifier. If we do not receive this identifier when you make a request, we may be unable to verify your identity and may not be able to respond to your request.

Where applicable law grants SN Users a right to appeal, if an SN User wishes to appeal our decision regarding their request, they may do so by notifying us and providing information supporting their appeal.

Retention Period

We retain the personal information described in the SmartNews Privacy Policy for as long as the SN User uses SmartNews, or as necessary to achieve the purpose for which it was collected, provide SmartNews, resolve disputes, establish legal defenses, pursue legitimate business interests, fulfill our contracts, and comply with applicable law.

Managing Information

We take reasonable measures to protect information we collect from or about SN Users from unauthorized access, use, or disclosure. Specifically, we maintain unified rules and manuals for handling SN User data and define policies and specific handling procedures to be followed throughout the SN User data lifecycle. We share these across all group companies involved in developing our apps, conduct regular training, and carry out periodic audits by a dedicated department.

By using SmartNews or providing us with personal information, SN Users agree that we may communicate with them electronically regarding security, privacy, and administrative matters related to their use of SmartNews. If we become aware of a security system breach, we may notify SN Users by posting a notice within SmartNews, sending an email, or other electronic means.

Links to Other Services

SmartNews may include links to other websites and services, including news content. Information provided on or collected by a third-party website or service is provided directly to the owner of that website or service and is subject to that third party's privacy policy. The SmartNews Privacy Policy does not apply to such websites or services, and we are not responsible for their content, privacy, security practices, or policies. To protect your information, we recommend carefully reviewing the privacy policy of any other website or service you access. Visiting these other websites or services is at your own risk.

International Transfers

We may provide information collected about SN Users to third parties in the following foreign countries.

• United States of America

For information about the personal information protection systems of that country, please see the following link.

https://www.ppc.go.jp/enforcement/infoprovision/laws/

Recipients implement measures in accordance with the applicable personal information protection laws of that country and their own privacy policies. We may also provide information collected about SN Users to third parties in foreign countries that have implemented appropriate measures under Japan's Act on the Protection of Personal Information, and we take necessary measures to ensure such measures continue to be implemented.

Creation and Provision of Anonymized Information

In accordance with applicable law, we may continuously create anonymized information from which specific individuals cannot be identified and personal information cannot be restored or re-identified, and provide it to third parties for the purpose of analyzing and improving SmartNews usage.

Categories of personal information included in anonymized information: information necessary for analyzing SmartNews usage (usage status, behavioral data, device information, etc.) among the information described under “Information We Collect” in the SmartNews Privacy Policy.

When we provide anonymized information we have created to third parties, we do so using methods such as encrypted electronic transmission or server transfer, after ensuring an appropriate level of security, including data encryption and access restrictions.

Contact

For inquiries about the SmartNews Privacy Policy or the SmartNews app, please go to “Settings” → “Help Center” → “Contact Us” within the SmartNews app.

3. Wanderland Privacy Policy

This privacy policy (the “Wanderland Privacy Policy”) applies to the applications and related services that we provide or operate under the name “Wanderland” (“Wanderland”).

Information We Collect

To provide Wanderland, we may collect the following information from Wanderland users.

• Information provided by Wanderland users, or collected with their permission: this includes information related to a Wanderland user's account and profile, content the user posts or submits (videos, images, comments, etc.), and related information. Content that a Wanderland user publishes on Wanderland, such as videos or posted spots, becomes viewable by third parties, including other users. To protect your own privacy and the privacy of others, please be mindful of your surroundings when filming or posting videos.
• Information collected automatically through use of Wanderland: this includes information about usage, such as a Wanderland user's actions and browsing history within Wanderland, access logs, and technical information about the device the user uses.
• Wanderland users' location information: this includes device location information based on the user's choice or permission (GPS data or selected region), as well as location information related to posts and usage activity.
• Information obtained from external partners: this includes login information from linked external services (SNS) and information about Wanderland users provided by partners.

Purposes of Using Collected Information

We use collected information for the following purposes.

• Providing services and information: including account management, displaying maps and spot information, providing various features (notifications, saving, etc.), and delivering content tailored to a Wanderland user's interests.
• Quality improvement and R&D: including analyzing Wanderland usage, improving features, and developing new services.
• Ensuring safety: including support, appropriate management of posted content, and preventing and investigating fraud or violations of our terms.
• Delivering and measuring the effectiveness of advertising: where advertising delivery or related services are provided, this includes displaying advertising or information suited to Wanderland users and measuring its effectiveness.
• Administrative and legal purposes: including complying with legal obligations and responding to disputes or legal proceedings.

Sharing of Information

We may share or provide information in the following circumstances.

1. Sharing with service providers

We may outsource the handling of information to service providers to the extent necessary to achieve the purposes described above.

2. Sharing with advertising partners

Where advertising delivery features are provided, we may provide advertising identifiers and usage information to advertising partners, or allow advertising partners to collect such information, for advertising optimization and effectiveness measurement.

3. Sharing with other partners and business collaborators

We may share information with business partners or external partners to the extent necessary for providing our services, expanding features, or joint planning or service development.

4. Where the Wanderland user has consented or requested it

We may share information with third parties where a Wanderland user has consented or made an explicit request.

5. Where required by law

We may disclose information to respond to legal claims or proceedings, to protect our rights or safety or those of third parties, or as required by law to judicial or administrative authorities.

6. In connection with business transfers

Information may be shared in connection with a merger, acquisition, corporate reorganization, or business transfer transaction (including due diligence for financing).

Relationship with the SmartNews App and Our Other Services

We may use information collected through Wanderland in conjunction with SmartNews and our other services, to improve our services, prevent fraud, and provide users with optimal information (including advertising) tailored to their interests across our services.

Mobile Device Settings

We may send push notifications through Wanderland. Wanderland users can stop these notifications by changing their mobile device settings.

Use of Location Information

Wanderland may use precise device location information, such as GPS data, to display information near the user's current location or to enable posting near a specific spot. Wanderland users can stop the collection of precise location at any time through their device settings, though this may make some features unavailable.

When a Wanderland user makes a post, location information may be inferred from the location associated with that post. If you do not want this information used, please request deletion of the relevant post.

Inquiries and Requests for Disclosure or Deletion of Personal Information

For requests regarding disclosure, correction, restriction of use, or deletion of personal data we hold, as well as inquiries about deleting a Wanderland account or posts, please contact us via the contact form. We will respond individually in accordance with applicable law and our own procedures. (Note: procedures available within the SmartNews app do not apply to Wanderland.)

Contact

For other inquiries about Wanderland, please contact us via the contact form.

4. Cookie Policy

Cookies and Pixel Tags

We may use cookies, pixel tags, and other similar technologies. Cookies are small text files placed in your device's browser that store preferences and make your experience easier and better. Pixel tags (also known as web beacons) are pieces of code that may be embedded in our services to collect information about your use of them. We may also include web beacons in emails to determine whether a message has been opened, acted on, or forwarded.

Our use of cookies and similar technologies falls into the following general categories: (i) those operationally necessary for our services; (ii) those related to the performance of our services; (iii) those related to the functionality of our services; and (iv) those related to advertising.

For other matters set forth under the Telecommunications Business Act, please see here.

Software Development Kits

We may use third-party software development kits (“SDKs”) as part of the functionality of our services. SDKs typically collect a user's device identifier and information related to their use of our services. SDKs may send user information to third parties, including analytics and advertising partners, for various purposes, including analytics services and personalized advertising. For details about the SDKs we use, please contact us using the information below.