1. About this Policy

This policy applies to the Processing of your Personal Data by Avex Management Inc. (“we”, “us,” and “our”) in the services provided on this Application. In the event of any inconsistency between the provisions of this Policy and the provisions of our Privacy Policy (https://avex.com/jp/en/public/privacy/), the provisions of this Policy shall prevail to the extent of the inconsistency.

2. Definitions

In this Policy:

1. “Personal Data” means any information relating to an identified or identifiable natural person;
2. “Affiliates” means the companies listed in the "Group companies" section of our website (https://avex.com/jp/en/corp/officer/）; and
3. “Process/Processing” means any activity or operation that is carried out in respect of the Personal Data, such as collecting, storing, using, transferring, or deleting it.

3. How we collect your Personal Data and what Personal Data we collect

We may collect information that you provide to us, whether by means of a form on our website, by email, in a letter, or otherwise, such as your name, address, nickname, email address, telephone number, date of birth, gender, nationality, details of your inquiry, your self-description, profile photo, and credit card details.

We may receive your name, address, telephone number, email address, and other information from the sales platform(Merchbar).

We also may automatically collect your cookies when you visit our website.

4. Purpose of Processing Personal Data

We use the Personal Data that we hold about you for the following purposes. We will use your Personal Data only to the extent that it is necessary to do so to fulfill the purposes described below.

1. to send you our email newsletter;
2. to analyse your interests;
4. to respond to your inquiries;
5. to provide you with our fan club services;
6. to deliver products you have purchased;
7. to provide customer support for products you have purchased;
8. to comply with any laws and regulations applicable to us;
9. to cooperate with relevant governmental authorities and agencies, including competent data protection authorities and those that are engaged in administrative or criminal investigations; and
10. to establish, exercise or defend legal claims.

5. Disclosure of Personal Data to recipients and joint use of Personal Data

We may share your Personal Data with the following categories of recipients:

1. Affiliates: We may share your Personal Data with our Affiliates;

（Joint use of Personal Data）

Under Japanese law, we may share your Personal Data, as referenced in Section 3 above (excluding Personal Data that we receive from sales platforms), with our Affiliates in the framework of joint use under the Personal Data Protection Act, for the purposes referred to in Section 4 (a) to (d) above. In this case, we will be the party responsible for the management of your Personal Data. Please refer to Section 2 above for the scope of "Affiliates" and to Section 9 below for our address and the name of our representative.

2. Our employees: We may disclose your Personal Data to our employees who have the authority and need to access it; and
3. Service providers: We may disclose your Personal Data to service providers, such as music producing companies, record companies, delivery companies, and IT service providers.

6. Storage period for Personal Data

We will retain your Personal Data that we collect for the period necessary to Process such Personal Data. For example, Personal Data Processed for the purpose of sending you the email newsletter will be retained until one month after you have cancelled your membership to the newsletter. However, this does not apply if we are required by law to retain your Personal Data for a longer period of time, in which case, we will retain it for the period required by law.

7. Your rights

You have a number of legal rights in relation to the Personal Data that we hold about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but typically will include the following:

1. Right to obtain information regarding the Processing of the relevant Personal Data and to access the relevant Personal Data that we hold;
2. Right to request rectification of the relevant Personal Data if it is inaccurate or incomplete;
3. Right to request erasure of the relevant Personal Data in certain circumstances;
4. Right to request that we restrict our Processing of the relevant Personal Data in certain circumstances;
5. Right to object to our Processing of the relevant Personal Data;
6. Right to receive the relevant Personal Data in a structured, commonly used, and machine- readable format and/or to request that we directly transmit such Personal Data to a recipient where this is technically feasible; and
7. Right to withdraw your consent to our Processing of the relevant Personal Data at any time.

You may exercise any of your rights by contacting us, using the information about us indicated in Section 9 below. You also may lodge a complaint with the data protection authority if you believe that any of your rights have been infringed by us.

8. Security control measures

We take all necessary and appropriate security control measures, including measures to prevent the leakage, loss, or damage of Personal Data to be Processed, such as establishing rules for the Processing of Personal Data, regular self-inspection of the Processing of Personal Data, regular training of employees in the Processing of Personal Data, prevention of theft or loss of equipment Processing Personal Data, and implementation of access controls. We also exercise appropriate supervision over our contractors and employees who Process Personal Data.

You may obtain further details about the security control measures we have in place in relation to the Processing of your Personal Data by contacting us using the information about us indicated in Section 9 below.

9. Contact details

If you have any questions about this Policy, your rights, or any other matter relating to the protection of your Personal Data, please contact us at the following address:

1. Address of head office: Avex Building, 3-1-30 Minami-Aoyama, Minato-ku, Tokyo 107- 8577 (General Reception on 2nd Floor)
2. Name of representative: Shingo Toguchi
3. Contact form: https://dev-xg.pasch.fan/contact

as of March 18, 2022

Avex Management Inc.