Privacy Policy

Effective Date: December 18, 2023

OEN's Privacy Policy

OEN, Inc. (hereinafter referred to as "OEN", "we", "our" or "us") complies with the Act on the Protection of Personal Information, relevant governmental and ministerial ordinances, and guidelines (hereinafter referred to as "Laws and Regulations") and appropriately manages and uses personal information as described below. This Privacy Policy is subject to the privacy policy, terms of use, guidelines, etc. (hereinafter referred to as "Service Regulations") of each service. In the event of any conflict between this Privacy Policy and the contents of the Service Regulations, the contents of the Service Regulations shall take precedence.

1. Obtainment of Personal Information

OEN will obtain personal information to the scope necessary for the achievement of the purpose of utilization notified or announced in advance through appropriate and lawful means.

2. Cookies, Advertising Identifiers, and IP Address Information

We do not consider cookies, advertising identifiers (including but not limited to Identifiers for Advertisers/IDFA and Google Advertising Identifiers/AAID) and IP address information (hereinafter collectively referred to as "Cookies, etc.") to be personal information as Cookies, etc. cannot be used independently to identify a specific individual. However, we will deem Cookies, etc. to be personal information if they are incorporated and used together with personal information.
We disclose the purpose or method of utilization of any Cookies, etc. it utilizes within the media it operates, even if any specific individual cannot be identified. It is possible to set a browser or operating system to refuse cookies and advertising identifiers, and if a service cannot be used when a browser or operating system is set to block cookies and advertising identifiers, we will make a public announcement to that effect. Cookies and IDFA/ADID can be blocked via the following page.
https://www.o-e-n.co.jp/privacy-policy

3. Specification of Purpose of Utilization of Personal Information

We will specify, to the extent possible, the purpose of utilization of personal information we handle, and notify you (hereinafter referred to as "you", or the "Individual"); the subject of the personal information, in a concrete and easy-to-understand manner, or publicize such purpose.

4. Restrictions on Utilization of Personal Information

We will not handle personal information beyond the scope necessary to achieve the purpose of utilization without obtaining your prior consent. In the event we acquire personal information as a result of a merger or for any other reason, we will not handle such information beyond the scope necessary for achieving the purpose of utilization before the succession of business. However, these restrictions do not apply in any of the following cases:

1. when required by law;
2. when it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain consent of the Individual in question;
3. cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the Individual concerned; or
4. cases in which the handling of personal information is necessary for cooperation with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the Individual's consent is likely to impede the execution of such affairs.

5. Proper Acquisition of Personal Information

We acquire personal information in an appropriate manner and do not acquire personal information through deception or any other wrongful means. We are also mindful to avoid collecting information of a personal nature from any child under the age of fifteen (15) without the consent of their legal representatives (such as a person who has parental authority).

6. Notice of Purpose of Utilization at the Time of Acquisition of Personal Information

When we acquire personal information, we will disclose in advance the purpose of utilization; however, this does not apply in any of the following cases:

1. cases in which notifying the Individual of the purpose of utilization or publicly announcing it is likely to harm the life, body, or property or any other right or interest of the Individual or a third party;
2. cases in which notifying the Individual of the purpose of utilization or publicly announcing it is likely to harm any right or legitimate interest of OEN;
3. cases in which it is necessary to cooperate with a national agency or local public body in the performance of its duties as prescribed by law, and in which notifying the Individual of the purpose of utilization or publicly announcing it is likely to impede the execution of such duties; or
4. cases in which it is deemed that the purpose of utilization is clear in consideration of the circumstances of the acquisition.

7. Changes to Purpose of Utilization of Personal Information

If we change the purpose of utilization of personal information, we will not do so beyond the scope that is reasonably considered to be relevant to the purpose of utilization before the change and will notify you or publicly announce the changed purpose of utilization.

8. Secure Management of Personal Information and Supervision of Employees

We shall establish rules for the protection of personal information and provide necessary and appropriate supervision to our employees in order to prevent leakage, loss, or damage of personal information and otherwise ensure the safe management of personal information.

9. Supervision of Subcontractors

When we outsource all or part of the handling of personal information, we will conclude a contract with the subcontractor that includes confidentiality or will require the subcontractor to agree to the terms and conditions stipulated by us and will provide necessary and appropriate supervision to ensure that the subcontractor manages personal information securely.

10. Restrictions on Provision to Third Parties

We will not provide personal information to third parties without obtaining your prior consent, except in the following cases:

1. when required by law;
2. when it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the Individual in question;
3. when it is especially necessary to improve public health or to promote the sound growth of children, and it is difficult to obtain the consent of the Individual in question;
4. cases in which the provision of personal information is necessary for cooperating with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the Individual's consent is likely to impede the execution of the relevant affairs.

11. Personal Information Disclosure

When we receive a request from you for disclosure of your personal information, we will disclose such information to you without delay. However, we may decide not to disclose all or part of the information in any of the following cases, and in that case we will notify you immediately to that effect:

1. if there is a risk of harm to the life, body, property, or other rights or interests of the Individual concerned or a third party;
2. if there is a risk of significant hindrance to the proper conduct of OEN's business; or
3. if it would violate other laws or regulations.

12. Correction of Personal Information

When we receive a request from you to correct, add, or delete (hereinafter referred to as "correct") your personal information on the grounds that it is untrue, we will make the necessary investigation without delay to the extent necessary to achieve the purpose of utilization, except in cases where special procedures are prescribed by other laws.

13. Discontinuance of Utilization of Personal Information

If you request us to cease use of or delete your personal information (hereinafter referred to as "cease use") on the grounds that your personal information is being handled in a manner that exceeds the scope of the purpose of utilization previously announced, or that the information was obtained through deception or any other wrongful means, we will conduct any necessary investigation without delay and, and on the basis of the results, cease use of the information and notify you to that effect. However, in cases where it is difficult to cease use of personal information due to the large amount of costs involved or other reasons, and alternative measures can be taken to protect your rights and interests, alternative measures will be taken.

14. Explanation of Reasons

If we decide not to do any of the following despite receiving a request from you, we will endeavor to explain the reason for that decision to you when notifying you of that decision:

1. notify the purpose of utilization of your personal information;
2. disclose all or part of your personal information;
3. discontinue the cease use of your personal information; or
4. discontinue provision of your personal information to any third party.

15. Inquiries

If you have any questions or concerns regarding the contents of this Privacy Policy, please use the following contact details:

OEN, Inc.
40-1 Udagawacho Shibuya-ku, Tokyo
Legal & Compliance Office Privacy Policy Manager
For inquiries regarding the Privacy Policy, please contact below:
oen@cyberagent.co.jp
Takunori Fujii
Personal Information Protection Manager

Established: September 24, 2004
Revised: April 1, 2022

Guidelines for Handling Personal Information

(For ABEMA Live Users)
Users who use various services provided through the video streaming service "ABEMA Live" (hereinafter referred to as "the Service") provided by OEN, Inc. (hereinafter referred to as "OEN", "we", "our" or "us") are requested to read and agree to the following terms. In accordance with OEN's Privacy Policy, OEN shall strictly manage the personal information of customers who use the Service (hereinafter referred to as "you" or "user"), and shall stipulate the following guidelines on handling of personal information (hereinafter referred to as "Guidelines") for specific details regarding the personal information obtained and how it is processed and used.

1. Scope of these Guidelines

These Guidelines applies to users who use the Service.

2. Information Collected

1. We collect the following types of personal information from users.
2. Personal information means information as defined in the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act") and related government ordinances, and guidelines (hereinafter referred to as "Laws and Regulations").
3. The following are specific examples of how we collect personal information.
   1. When obtaining information required for membership registration in order for a user to start using the Service or to use a specific service within the Service
   2. When obtaining user access information, cookies, advertising ID numbers, etc. through browsers or applications (SDKs, web beacons, etc.) when users use the Service.
   3. When obtaining email addresses, etc. (this may include names and contact information) that users submit via inquiry forms for inquiries about the Service.
   4. When a user applies to participate in or makes inquiries about events or other activity related to the Service or sends a document or other information to us.
4. In order for us to provide the Service to users, it is essential that such information be provided by users. If you do not want us to collect your personal information, please do not to provide it to us.

3. Cookies and Web Beacons

We use cookies in the Service, a small text file that may be used to collect information about your activity on the Service and to make the use of the Service as comfortable as possible for you, not only for your current use of the respective Service but also for latter uses. For example, when someone visits a web page within the Service, a cookie is placed on the user's device (if the user accepts cookies) or is read if the user has accessed the Service previously. These cookies enable us to collect information such as user ID, app version, operation system, device name, and error code, etc. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. If you do so, you may not be able to take advantage of the personalized features enjoyed by other users of our Service.
We also use Web Beacons (also known as "clear GIFs", "web bugs" or "pixel tags") tiny graphics with a unique identifier, similar in function to cookies, which are used to count the number of users who have visited certain web pages of the Service and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, web beacons can inform the sender whether and when the email has been opened. In contrast to cookies, which are stored on a user's computer's hard drive, web beacons are embedded invisibly on web pages.

4. Cookies and Tracking Tools of Third-Party Providers

Google Analytics
We use Google Analytics, a web analytics service provided by Google LLC ("Google"), that collects anonymous statistical and analytical information about how users use the Service. For example, Google gathers and aggregates data about page views and clicks on the Service. These analytics are not used to track your journey to other websites or to identify you. The information generated by the Google Analytics cookies regarding your use of the Service (including your IP address) will be transmitted to and stored by Google on servers in the United States and Japan. For information on how to opt out of Google Analytics cookies, please visit: http://tools.google.com/dlpage/gaoptout or adjust your web browser settings to block these cookies along with other cookies.
For more information about Google's privacy policy, please visit: https://policies.google.com/privacy?hl=en

5. Use of Personal Information

1. We use personal information for the purposes specified below:
   1. Distribution of content and related services (including match and event announcements and advertisements);
   2. Development of services, analysis of statistics, analysis, surveys and other marketing activities to improve services;
   3. Responding to inquiries, consultations, and complaints, and resolving disputes;
   4. To provide special offers, updates and other new services from the Service or other third parties, or if you have requested this information or promotional materials;
   5. To provide services requested by you;
   6. To achieve marketing or promotional purposes;
   7. To confirm, investigate, and analyze whether the Service meets your needs;
   8. To help us create and publish content that is most relevant to you;
   9. To notify you of any changes to the Privacy Policy, these Guidelines or Terms of Use, as necessary;
   10. To grant you access to limited-entry areas of the Service;
   11. To send newsletters and other information that you request;
   12. To contact you in response to your inquiries; and
   13. In other manners as disclosed within these Guidelines or at the time of collection.
2. We will process your personal information in accordance with your consent when you indicated that you accept these Guidelines. You may revoke your consent to this processing at any time. However, this withdrawal does not affect the legality of the process taken before you revoked your consent.
3. We retain your personal information as long as your account is active or as long as it is necessary to provide the Service.

6. Disclosure to Third Parties

1. We may only share or disclose your personal information with third parties in the following cases, and the third parties may use the personal information only for the period necessary to accomplish those purposes:
   1. To fulfill the provision of services to you. For example, if you choose to engage with services on the Service, we may share your personal information in order to provide services to you. Also, if you are participating in a sweepstake or contest, we may use your personal information in order to fulfill the terms of that promotion. This means that we may share information for prize fulfillment purposes including, for example, sharing your postal address with a postal service or mail carriers. We may also share your information with co-sponsors of that promotion.
   2. To outsource processing to affiliates, strategic partners, agents, third-party marketers, or other parties in order to provide services that are likely to be of interest to you. If you wish us not to use your personal information for marketing purposes, you may make a request in accordance with Section 8 of these Guidelines.
   3. To transfer personal and other information to Amazon Web Services, Inc. and other cloud service providers to store and manage users' personal data on our servers.
   4. To process and fulfill orders, provide customer service, maintain and analyze data, send customer communications, and collect entries, and other promotions. Delegated third parties, including unaffiliated third-party service providers, agents or independent contractors, who help us maintain our Service and provide other administrative services to us will be handling this. When delegating third parties to handle some or all personal information, we enter into confidentiality agreements and other agreements for the protection of personal information with the delegated parties and requests consent to the terms and agreements thereof so as to safely manage personal information. Third party service providers that help us administer our Service will have access to users' personal information. If you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any personal information to us.
   5. To comply with the laws and regulations, we may share personal information when necessary or in the good faith that such action is necessary under the requirements of the law, a legally-binding court order or governmental order from an investigation agency or competent regulatory authority that is issued through due process, to protect and defend and defend our rights or property, including the rights and property of OEN or to act in urgent circumstances when it is necessary to protect the life, body, or property of a person, and the consent of the identified individual is difficult to obtain.
   6. To third parties as part of any corporate reorganization process, including but not limited to mergers, acquisitions and sales of all or substantially all of our assets.
2. We will not share or disclose your personal information to any third party except as provided in these Guidelines or with your consent.

7. Security

1. No data transmission over the Internet can be guaranteed to be 100% secure.
   Therefore, we cannot ensure or warrant the security of any information you transmit to us, and you understand that any information that you transfer to us is done at your own risk.
2. We have established rules for the protection of personal information, and have incorporated appropriate administrative, technical, organizational, and physical security measures that are required under applicable laws and regulations.
3. We use firewalls to protect your information from unauthorized access, disclosure, alteration or destruction. However please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
4. If we learn of security systems breach, we may attempt to notify you electronically so that you can take appropriate protective measures can be taken. By using the Service or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues related to your use of the Service.
5. We may post a notice on our Service if a security breach occurs. We may also send an email to you at the email address you have provided in these circumstances.

8. Access, Portability & Correction of Personal Information

You have the right, in accordance with Article 18 of these Guidelines, to access the information held by us and to request the correction or transfer of the information, or to object to the processing of any data relating to you. We will make necessary investigation without delay for any transfer, correction, addition, deletion or objection to the processing of personal information (hereinafter referred to as "correction") and provide you or a nominated third party with your personal information as soon as possible or perform correction as soon as possible.

9. Choice & Opt-Outs

You may opt out at any time by turning off communications or data regarding the Service, including (i) notices of concerning usage violations, (ii) updates, and (iii) notifications regarding use of the Service, and information or data regarding transactions, products, and/or services that you may have purchased or selected, at the device level by means of a setting.

10. Discontinuation & Deletion of Personal Information

You have the right in accordance with Article 18 of these Guidelines to request that we stop processing your personal data and to delete the information that we hold about you. If you request the deletion or erasure of personal information (hereinafter referred to as "cease use") on the grounds that it was processed for purposes other than those for which it was obtained or was obtained by deception or other unlawful means, we will, upon verifying the identity of the user who made the request, we will conduct the necessary investigation without delay, and based on the results of such investigation, we will, to the extent possible for you, cease use the personal information without charge, and notify you to that effect. However, we may retain a copy of your personal information if required or permitted by law.

11. International Transfer of Information

If you choose to provide us with personal information from outside Japan, it will be stored in Japan. We may transfer (by any means including sending or allowing access) that information across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are using the Service from the European Union (EU) or any other region where data acquisition and use laws apply, your personal information will be transferred to Japan, however, please note that Japan does not have the same data protection laws as the EU and you will not have many of the rights afforded to data subjects in the EU. By providing your personal information, you consent to:

1. the use of your personal information for the purposes specified in these Guidelines;
2. the transfer of your personal information to Japan as indicated above; and
3. that the laws of Japan shall apply.

12. Push Notification

We may send push notifications through the web or applications to send you updates and other service-related notifications that may be of importance to you. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings.

13. Third Party Services

This statement applies solely to the information collected on the Service. The Service may contain links to other webservices. We are not responsible for the privacy practices or the content of these other webservices.

14. Assignment

In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal and non-personal information collected via the Service to the other party.

15. Changes to these Guidelines

1. We reserve the right to change these Guidelines from time to time. When we do, we will also revise the "Last Updated" date at the top of these Guidelines.
2. For some changes to these Guidelines, we may attempt to obtain your consent before implementing the change by placing a notice on the Service. Continued use of the Service following such notice will be viewed as consent to such changes unless otherwise specified.

16. Online Tracking

We do not support "Do Not Track" (DNT) browser settings and do not currently participate in any framework that would allow the us to respond to user signals or other mechanisms for obtaining users' personal or non-personal information.

17. Our Policy Regarding Children

We do not knowingly collect or solicit personal information from anyone under the age of sixteen (16) or knowingly allow such persons to use the Service. If you are under sixteen (16), please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of sixteen (16) may provide any personal information. In the event that we learn that we have collected personal information from a child under age sixteen (16), we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of sixteen (16), please contact us using the contact details set out in "19. Contacting Us" of the Guidelines.

18. Right to Complain

If you object to the way in which we process your personal information, you have the right to lodge a complaint with your local data protection authority having jurisdiction over your region.

19. Contacting Us

If you have any questions regarding these Guidelines, and the Privacy Policy on the handling of personal information, or any information, correction, suspension or deletion of data, please contact us at the following e-mail address:

English: cs-support-en-ml@abema-global.com
Thai: cs-support-th-ml@abema-global.com
Korean: cs-support-kr-ml@abema-global.com
Tagalog: cs-support-tg-ml@abema-global.com