This is a translation from the Japanese original and Japanese version shall in any event prevail. <https://www.sixapart.jp/privacy/>

Privacy Policy

Business Operator: Six Apart Ltd.
Address: 5th Fl., Yoshida FG Bldg., 3-17-15, Kanda Jimbo-cho, Chiyoda-ku, Tokyo
Representative: Hajime Koga, Representative Director

Six Apart Ltd. (“Six Apart”) may acquire and retain your personal or other information through its websites and services to ensure a stable supply of its products and services or to develop new products and services. Recognizing the importance of personal information protection, Six Apart handles and strives to protect personal and other information in accordance with the following information protection policy:

Article 1. Acquisition of Personal Information

Six Apart will acquire your personal information (as defined in the Act on the Protection of Personal Information of Japan (the “Personal Information Protection Act”); hereinafter the same) to the extent necessary to achieve the purpose of its use, and by lawful and fair means. Six Apart may collate your personal information with information obtained by lawful and fair means from Six Apart’s business partners and/or other companies (including users of Six Apart’s services (the “Service Users”)).

Article 2. Scope of Personal and Other Information to be Acquired

Six Apart will acquire the following personal and other information from you:
1) Your name, contact information (email address, address, and telephone number), and credit card information:
2) Other information that you may voluntarily register, including your date and place of birth, your mother’s maiden name, your gender, postal code, background, user names for instant messaging services (ICQ, AIM, Yahoo, and MSN), associate codes for U.S. Amazon.com and its subsidiaries, occupation, job type, and hobbies;
3) Information relating to transactions between you and any corporation or individual with whom Six Apart jointly conducts advertising, sales promotional activities, sales, or customer services (the “Partners”); and
4) Information and data sent from your browser that reside on Six Apart’s servers, or are automatically received and recorded by Six Apart, including your IP address, cookies, web beacons, scripts, and a history of the pages you have viewed.

Article 3. Use of Personal Information

Six Apart will use your personal information for the purposes specified below. Six Apart will not change the purposes of use of personal information beyond the extent that is reasonably recognized to be related to the purposes of use before the change.
Six Apart will not use personal information in a manner that may encourage or induce illegal or wrongful acts or activities.

1) Supply of products and services as well as provision of related information;
2) Billing process;
3) Identification and authentication of you;
4) Marketing, sales, and advertising activities to be conducted individually or jointly with any Partner;
5) Improvement of Six Apart’s websites and services; and
6) Communication of other important matters, and research related to the development of products and services.

Six Apart will use personal information obtained under entrustment from the Service Users for the following purposes:
Secure operation and provision of the services;
Support for the Service Users (only when so requested by the Service Users);
Prevention or resolution of system problems with identification/authentication services or other services; and
Assessment of usage status and compilation of statistical data.

Article 4. Handling of Sensitive Information

Six Apart will not acquire, use or provide to third parties any special care-required personal information (as defined in the Personal Information Protection Act) without the consent of the data subject, except for the cases specified by the said Act or other related laws, regulations, guidelines, etc.
In addition, when handling pseudonymized information, anonymized information, or personal-related information (as defined in the Personal Information Protection Act), Six Apart will comply with its obligations provided in the relevant laws, regulations, guidelines, etc

Examples of information that Six Apart collects and specific handling thereof are as follows:

1.IP Addresses
Six Apart receives the IP address information automatically sent from each user’s browser to Six Apart’s web pages. When you register with Six Apart, your IP address will be stored in Six Apart’s user registration database. Six Apart uses IP addresses for the following purposes:
1) To diagnose service or technology problems reported by Six Apart’s users or engineers that are associated with the IP addresses controlled by a specific web company or ISP (Internet service provider);
2) To place exclusive advertisements based on geographical areas or other information derived from the IP addresses;
3) To report to advertisers on the information obtained from the IP addresses;
4) To estimate the number of Six Apart users in a particular area or category; and
5) To determine the users who have access rights to specific content or services.

2. Cookies
1) A cookie, or a small amount of data that may contain an anonymous unique authentication code, is sent from the computer running a website to your browser and stored on your computer’s hard drive. By setting your browser configuration, you can accept all cookies, reject all cookies, or receive notice when a cookie is set on your device. If you reject all cookies, you may not be able to use certain of Six Apart’s products or services that require you to log in. However, many of Six Apart’s products and services do not require you to accept cookies

2) Six Apart uses its own cookies for the following purposes:
i. To access your information when you log in;
ii. To record and track preferences that you specify while using Six Apart’s services;
iii. To display the most suitable banner advertisements on Six Apart’s web pages based on your interests and behavior;
iv. To estimate and research Six Apart’s total audience size and traffic;
v. To conduct research to improve Six Apart’s contents and services; and
vi. To require you to re-enter your password in order to prevent third parties from accidentally accessing your account contents after the elapse of a certain period of time since your last visit to Six Apart’s website.

3) Six Apart allows business operators such as its online advertisers, access analysis service providers, and credit card processing service providers to set cookies on your computer and access them. Such business operators use their cookies in accordance with their own privacy policies. None of such business operators has access to Six Apart’s cookies. Specifically, Six Apart uses the following third-party cookies, but Six Apart itself does not collect browsing information directly from you through such cookies, and the browsing information collected will be managed in accordance with the privacy policy and other rules of each relevant company. If you wish to opt out of the cookies of any company, please do so in the manner specified by the relevant company (The following URLs are examples of links to the privacy policies and other rules of the relevant companies, but they are for reference only. Please do your own checking of each company’s cookie handling practices and the like.).
Google Analytics: https://support.google.com/analytics/answer/6004245?hl=ja
Stripe: https://stripe.com/jp/legal/cookies-policy (For the setting of cookies, https://stripe.com/jp/cookie-settings)
Twitter: https://help.twitter.com/ja/rules-and-policies/twitter-cookies
Facebook: https://ja-jp.facebook.com/policies/cookies/
Hatena Bookmark: https://policies.hatena.ne.jp/privacypolicy-ja#policy07

4) Six Apart will collect your browsing information using Six Apart’s own cookies described in 2) above. Six Apart will use such browsing information that does not contain personally identifiable information (which is not treated as personal information) or provide it to third parties.

3. Web Beacons
A web beacon is an electronic file that sends a signal when a website, advertisement, video, or other types of content, email, newsletter, etc. is viewed. Six Apart uses web beacons on its websites or third parties’ websites, or in Six Apart’s services and products for the following purposes:
1) To survey the number of visitors to such websites;
2) To recognize and access cookies;
3) To record information on pages viewed;
4) To record the Internet protocol addresses of the computers that have downloaded a web beacon;
5) To record the types of browsers used to view the web pages containing a web beacon;
6) To track the delivery, viewing, and responses to emails and newsletters;
7) To estimate and research the total audience size and traffic; and
8) To conduct research to improve Six Apart’s websites, services, and products.

4. Scripts
A script is a short section of computer code included in a web page or other content. It may be used to set and access cookies on your computer’s hard drive and to record your activities on the website. Six Apart will use scripts on its websites or third parties’ websites, or in Six Apart services and products for the following purposes:
1) To track the effectiveness of advertising campaigns;
2) To identify sources of traffic to Six Apart’s websites, services, and products;
3) To count the number of clicks on links in web pages, advertisements, emails, or newsletters;
4) To track content distribution;
5) To investigate the dates and times, and geographic locations of use of Six Apart’s websites, services and products, and other activity patterns;
6) To estimate and research Six Apart’s total audience size and traffic; and
7) To conduct research to improve Six Apart’s websites, services and products.

Article 5. Disclosure and Provision of Personal and Other Information to Third Parties

1. When you post a message, your ID with Six Apart or the alias that you use when posting a message will be disclosed to other users. In addition, when you post a message on a blog site of Six Apart, you may be posting a message containing personally identifiable information about yourself. By posting personal information online where anyone can access it, you may receive unsolicited messages from others.

2. Six Apart will not provide your personal data (as defined in the Personal Information Protection Act; hereinafter the same) to any third party without your consent.
However, Six Apart may provide your personal data to third parties in the following cases:
1) If Six Apart provides your name, contact information (email address, address, and telephone number), or other personal data to a Partner who is reliable and working with Six Apart after concluding a confidentiality agreement with such Partner by way of electronic transmission in accordance with Six Apart’s information management regulations and other policies concerning the handling of personal information for the purpose of joint advertising, sales promotion activities, sales, customer service, or the like;
2) If Six Apart provides information to a reliable corporation or individual after concluding a confidentiality agreement in order to outsource the processing of personal information;
3) If Six Apart is required to provide or disclose your personal data by any enforceable judgment, order, or the like issued by a court or other public authority, or is otherwise required to do to fulfill its legal obligations;
4) If Six Apart to take necessary measures to defend against claims for damages or other legal actions by exercising its legal rights or asserting defenses; or
5) If to investigate, or to take preventive or necessary actions in response to the possibility of any illegal act, fraud, danger to the life, body, or property of any person, or a breach of Six Apart’s terms of use, or otherwise under legal requirements.

3. Your personal data will be transferred if Six Apart becomes subject to a merger or other transaction involving the transfer of all or part of its assets. Six Apart will notify you before your personal data is transferred to a third party and becomes subject to that third party’s privacy policy.

4. You may request suspension of the provision of such personal data to third parties by filling out Six Apart’s General Inquiry form (https://movabletype.com/inquiry/general.html).

5. If Six Apart provides personal data or personal-related information to a third party outside Japan, it will comply with its obligations under the relevant laws and guidelines.

Article 6. Setting, Editing and Deleting of Your Account Information

You may refer to and edit your own account information at any time. Six Apart is entitled to dispatch to you specific information relating to Six Apart’s services, such as service announcements, administrative communications, and news from Six Apart (the “Dispatched Information”). The Dispatched Information is deemed as part of your account with Six Apart and you cannot reject the receipt of such information. For some of the services, you may delete your account by visiting the account deletion page. Please note, however, that your identity, billing, and contact information will remain in Six Apart’s records as long as is necessary for its operation.

Article 7. Inquiries Regarding Personal and Other Category of Information

To request notification of the purpose of use of personal information held by Six Apart, or to inquire about disclosure, correction, addition, deletion, suspension of the use, etc. of the personal data held by Six Apart, or about the disclosure of records of provision to third parties or the like, please contact Six Apart using its General Inquiry form (https://movabletype.com/inquiry/general.html). Six Apart will respond to your request or inquiry as quickly as possible.

Article 8. Confidentiality and Security Control

Six Apart will endeavor to keep personal data accurate and up-to-date to the extent necessary to achieve the purpose of its use, and to delete personal data that is no longer needed. In addition, in accordance with the guidelines for the protection of personal information established by the Personal Information Protection Committee, and other policies, Six Apart will take necessary and appropriate security control measures at each stage of acquisition, use, and storage of personal data to prevent leakage, loss, damage and the like of personal data, as follows:
1) Six Apart will establish and comply with policies and regulations regarding the handling of personal data to ensure proper handling of personal information.
2) Six Apart will establish and comply with regulations regarding the handling of personal information, such as handling methods, responsible persons/persons in charge, and their duties, at each stage of acquisition, use, transfer, storage, deletion, and the like.
3) Six Apart will appoint a person in charge of handling personal data, and conduct periodic inspections and audits of the handling of personal data. In addition, Six Apart will establish a system wherein the results of such inspections and audits are reported to the responsible persons, and the responsible persons will evaluate, review and improve the security control measures.
4) Six Apart will clearly state the matters concerning the confidentiality of personal data in its rules of employment and other regulations, and ensure that its employees are thoroughly informed, educated and trained on the security control measures.
5) Six Apart will implement measures to prevent theft or loss of personal data in the areas where such data is handled.
6) Six Apart will equip the information systems that handle personal data with a function to verify the user identity and introduce a mechanism to protect such systems from unauthorized external access or unauthorized software. In addition, Six Apart will set access privileges as necessary, record, analyze, and store access to personal data, and periodically check the existence or not of any record of suspected fraud.
7) If certain personal data is handled outside Japan, Six Apart will implement the necessary security control measures based on its understanding of the systems for the protection of personal information in the country or region where such personal data is handled.

Article 9. Changes in Privacy Policy

Six Apart may amend this Privacy Policy. Six Apart will notify you of any material change in its handling of personal information by sending a notice to the primary email address you have designated in your Six Apart account, or by posting a notice on Six Apart’s websites.

Last amended on Sep. 30th, 2022