Rafu Shimpo’s Privacy Policy

EFFECTIVE DATE: August 31, 2007

IINTRODUCTION. The Rafu Shimpo (“us,” “we,” or “Company”) is committed to
respecting the privacy rights of its customers, visitors, and other users
of the Company’s websites (“the Sites”). We created this Privacy Policy
(“Privacy Policy”) to give you confidence as you visit and use the Sites,
and to demonstrate our commitment to fair information practices and the
protection of privacy. This Privacy Policy applies only to The Rafu
Shimpo’s websites listed below:

www.rafu.com
www.rafushimpo.com
www.rafunews.com

This Privacy Policy does not apply to any other websites that you may be able to access from the Sites, each of which may have data collection, storage, and use practices and policies that differ from this Privacy Policy.

INFORMATION COLLECTION PRACTICES

TYPES OF INFORMATION COLLECTED BY THE COMPANY

(i) TRAFFIC DATA. We automatically track and collect the following categories of information when you visit our Sites: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Sites; and (4) types of web browsers used to access the Sites (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Sites. We also use “cookies” to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, and to store your password so you do not have to re-enter it each time you visit the Sites.

(ii) PERSONAL INFORMATION. In order for you to access certain premium services and to purchase products that we offer via the Sites, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information: (1) Contact Data (such as your name, mailing address, and e-mail address); (2) Financial Data (such as your account or credit card number); and (3) Demographic Data (such as your zip code, age, and income). If you communicate with us by e-mail, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, any information provided in such communication may be collected as Personal Information.

USES OF INFORMATION COLLECTED

(i) COMPANY USE OF INFORMATION. We use your Contact Data to send you information about our company or our products or services, or promotional material from some of our partners, or to contact you when necessary. We use your Financial Data to verify your qualifications for certain products or services and to bill you for products and services. We use your Demographic Data to customize and tailor your experience on the Sites, displaying content that we think you might be interested in and according to your preferences.

(ii) SHARING OF PERSONAL INFORMATION. We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share your Demographic Data with advertisers and other third parties only on an aggregate (i.e., non-personally-identifiable) basis. We share your Contact Data with other companies who may want to send you information about their products or services, unless you have specifically requested that we not share Contact Data with such companies. We share your Contact Data and Financial Data with our business partners who assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Sites. Those business partners have all agreed to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to Company.
If you do not want us to share your Contact Data with any third parties, please email us at privacy@rafu.com or select the “opt out” box on our online forms, but please understand that such a request will likely limit your ability to take advantage of all of the features and services we offer on the Sites. Similarly, if you do not want to receive any email advertising from The Rafu Shimpo, please email us at privacy@rafu.com. In addition, we maintain a procedure for you to review and request changes to your Personal Information; this procedure is described below.

(iii) USER CHOICE REGARDING COLLECTION, USE, AND DISTRIBUTION OF PERSONAL INFORMATION. You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Sites; however you will not be able to access and use those portions of the Sites that require your Personal Information. If you do not wish to receive information and promotional material from us or from some of our partners, you may select the appropriate “opt-out” option each time we ask you for Personal Information.

CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION. Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Service. Your Personal Information is stored on secure servers that are not accessible by third parties. We provide you with the capability to transmit your Personal Information via secured and encrypted channels if you use a similarly equipped web browser.

USER ABILITY TO ACCESS, UPDATE, AND CORRECT PERSONAL INFORMATION. We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may visit your personal profile at www.rafushimpo.com [web address used by websites’ operator for user access to Personal Information]. Through your personal profile you may: (a) review and update your Personal Information that we have already collected; (b) choose whether or not you wish us to send you information about our company, or promotional material from some of our partners; and/or (c) choose whether or not you wish for us to share your Personal Information with third parties.

LOST OR STOLEN INFORMATION. You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.

PUBLIC INFORMATION. The Sites contains links to other Websites. We are not responsible for the privacy practices or the content of such Websites. We also make chat rooms, forums, message boards, and news groups available to you. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information.

CHILDREN’S PRIVACY

The Children’s Online Privacy Protection Act (“COPPA”) requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age. The Rafu Shimpo is particularly concerned with providing a safe online environment for children. To that end, we require the consent of parents and guardians in order for children under 13 years of age to use certain features of The Rafu Shimpo’s Web sites.

Parental consent can be provided in two ways: (1) Fax a copy of a completed Parental Consent Form including your signature, to the facsimile number provided on the Parental Consent Form. This form will be available in applicable areas of our site. (2) Mail a completed Parental Consent Form to the address indicated.

The Rafu Shimpo does not ask children under age 13 for more personal information, as a condition of participation, than is reasonably necessary to participate in a given activity or promotion. Minors between the ages of 13 and 17 must get the permission of their parent(s) or legal guardians(s) before making purchases, including subscriptions, on this site.

The Rafu Shimpo will not knowingly disclose personal information about users under the age of 13 without prior parental or legal guardian consent, except as required by law. If for any reason you wish to access, update or remove information about your child that has been previously provided to The Rafu Shimpo you may e-mail us at privacy@rafu.com. The Rafu Shimpo strongly recommends parental supervision when a child uses the Internet, particularly when a child enters a forum or uses e-mail. We also encourage parents to instruct their children not to give out personal information in these areas.

UPDATES AND CHANGES TO PRIVACY POLICY. We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Sites and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Sites. If you have concerns about this Privacy Policy or our privacy practices in general, contact us at
privacy@rafu.com.