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JV-Campus Privacy Policy University of Tsukuba JV-Campus (1-1-1 Tennodai, Tsukuba-shi, Ibaraki) (“JV-Campus”) as manager handles the personal information of User collected and used, etc. by JV-Campus as follows when a User of the JV-Campus Platform uses the Platform Service. Unless otherwise set out, the terminology used in this Privacy Policy has the same meaning as the terminology defined in the JV-Campus Terms of Use (https://www.jv-campus.org/en/terms-of-use/) (the “Terms of Use”). This Privacy Policy takes precedence with respect to the use of the Platform Service in the event of any contradiction or inconsistency with any other privacy policy or rules or terms, etc. of JV-Campus specifying its policy for the protection of personal information. Definition JV-Campus JV-Campus is the operating entity for the JV-Campus Platform. Specifically, the operating entity for JV-Campus is the University of Tsukuba. JV-Campus Platform JV-Campus Platform is the domain administered and operated by JV-Campus to provide the Platform Service. Content Content is the lecture footage, lecture materials, and all other information provided or attempted to be provided to User via the JV-Campus Platform. The Platform Service The Platform Service is provided by JV-Campus to User and the Content Provider. User User is a person who agrees to these Terms of Use, applies to use the Platform Service, and whose application is approved by JV-Campus. Application This Privacy Policy applies when User uses the Platform Service provided by JV-Campus. Please carefully read this Privacy Policy together with the Terms of Use and give your consent before using the Platform Service. JV-Campus deems a User who starts using the Platform Service to have understood this Privacy Policy, which explains the collection, use, provision and retention of personal information of User. Please see 10. Inquiries for questions and inquiries about this Privacy Policy. Collection of Personal Information JV-Campus may collect the following personal information of User in order to achieve the purpose set out in 4. Use of Personal Information, etc. Personal information of User collected by JV-Campus may include information provided directly by User, information relating to the use of the Platform Service by User and information collected from third parties. Log in information Collected information: Name, email address Example: Email address used as log-in ID Information collected on registration Collected information: Name, date of birth, address, User type Example: Information such as name, date of birth, address, and affiliation information (school, department, course/major) provided by User incidental or in relation to the account, and other information relating to User If User is a high-school student or younger: School name, course If User is a university student: University name, department, course, graduate course, major If User is a working adult: affiliated company/organization name, occupation Information relating to Use, etc. of the Platform Service Collected information: Commercial information (usage history, etc.) and Internet and other electronic network behavioral information, such as Example: Affiliation information (school, department, course/major, etc.), gender, age, date of birth, telephone number, address and other User-related information provided by User incidental or in relation to the account Information relating to use of the Platform Service (including actions such as viewing and writing), purchase, viewing and other information relating to the use of the Platform Service by User through the Platform Service, and information relating to transactions of the Platform Service (including payment method, etc. used for payments) Use, purchase of Content, viewing and Content progress for the Platform Service, submission results of tests and reports, and other information relating to the use of the Platform Service by User through the Platform Service, and information relating to transactions of the Platform Service Identity verification documents (meaning copies of a student ID, staff ID, driver’s license, health insurance card, resident card, etc.) and information contained in such documents for identity verification to issue certificates of completion, etc. or as required by law, etc. Information on Information Communication Terminals and Information Collected Using Cookies, etc. When User uses the Platform Service, connects to advertising or Content relating to the Platform Service or enables Cookies, etc. (including web beacons, UID, LTI and other technology, simply, “Cookies, etc.”), JV-Campus automatically collects information relating to the PC, cell phone terminal, tablet or other information communication terminal used by User and information through Cookies, etc. Please see the separately established Cookie Policy (https://www.jv-campus.org/en/cookiepolicy/) for details, etc. on Cookies, etc. Collected information: Behavioral information and location information from the Internet and other electronic networks Example: System information collected from terminals (information such as OS, source IP address, FQDN, user-agent, etc.) Identifiers, etc. collected on system linkage such as LTI linkage Information Collected from Third Parties When User uses the Platform Service, JV-Campus may, to the extent necessary and permitted by applicable laws and regulations, collect credit information and information, etc. necessary to prevent and take measures against fraud, etc. by requesting third parties to provide information on User or from publicly available information. If User has consented, JV-Campus may collect or receive personal information on User from third parties based on such consent. JV-Campus does not intentionally collect or use sensitive information of User such as race, creed, social status, medical history, criminal history, or that User has been a victim of crime, etc. (the “Sensitive Information”), unless such information is indispensable for the provision of the Platform Service or permitted by laws and regulations. JV-Campus will immediately delete any sensitive information that JV-Campus has unintentionally obtained, or User has provided of User’s own accord. Collected information: Collection source Identifier: Ad network, internet service provider, data analytics provider, platform, social network, data company Protected characteristics (name, date of birth, gender, etc.): Governmental organization, platform, social network, data company Commercial information (usage history, etc.): Internet service provider, data analytics provider, platform, social network, data company Behavioral information and location information from the Internet and other electronic networks: Internet service provider, data analytics provider, platform, social network, data company Location information: Internet service provider, data analytics provider, platform, data company Usage of Personal Information, etc. Personal Information Usage Purpose JV-Campus uses personal information for the following purposes. To provide login-functions, etc. JV-Campus provides the function for User to log in to an account, and uses personal information to manage, etc. User information. To analyze the status of User’s attendance, etc., to manage course progress and evaluate educational progress, etc. JV-Campus uses personal information to analyze the course progress, frequency of attendance, and duration of attendance of User to manage course progress and evaluate educational progress, etc. of courses taken by User. This information may be provided to the university User is affiliated with. To report results JV-Campus uses personal information report results of platform usage and behavioral analytics. Any personal information that could identify an individual will not be included in such a report. To propose Content and perform advertising, promotion and marketing to User JV-Campus uses personal information to propose Content and perform advertising, promotion and marketing to User based on analyses of the User’s course enrollment status. To communicate, etc. with User JV-Campus uses personal information to give notices and communications, etc. to User. Legal Basis for Use of Personal Information JV-Campus is legally permitted to handle personal information in the following cases. With the consent of User (User may withdraw consent at any time) It is necessary for JV-Campus to perform its contractual obligations for the Platform Service It is necessary for JV-Campus to comply with its legal obligations, such as obtaining User’s identity verification documents to satisfy money-laundering prevention obligations It is necessary to secure the legitimate interests of JV-Campus, such as understanding the usage of the Platform Service by User to improve services, or conduct marketing aimed at User It is necessary to protect the material interests of User or another natural person Retention of Personal Information JV-Campus sets a retention period for User’s personal information within the scope necessary for its usage purpose, and at the end of the retention period, or once the usage purpose has been achieved, deletes, destroys or irreversibly anonymizes the personal information by an appropriate method without delay. Provision or Sharing of Personal Information with Third Parties, etc. Provision or sharing of personal information with third parties JV-Campus provides and shares personal information of User with third parties as set out below. However, JV-Campus will not provide (including for a fee or free of charge; the same applies hereinafter) or share the personal information of Users who are under 13 years of age with a third party. JV-Campus will not provide or share the personal information of any User who is at least 13 years of age and under 16 years of age with a third party, unless User consents through the opt-in procedures prescribed by JV-Campus. Recipient: Business operators and other corporations or organizations providing Content using an Individual Institution Box(*) (“Individual Institution Box Exhibitor”) (*) An Individual Institution Box is an area installed in the JV-Campus Platform in which Individual Institution Box Exhibitor can allow User to use Content. Provided personal information: Information to identify User: account ID (email address), name, date of birth, affiliated university, etc. (if necessary to issue certificates of completion) Information relating to Content usage: viewing and progress of Content provided by Individual Institution Box Exhibitor to User, submission results such as test and reports, confirmation of grade management such as grades and course completion, and other information necessary for grade management Recipient: Business operators and other corporations and organizations that are contracted by the JV-Campus to provide Content to a Strategic Package Box (*) (*) This is an online lecture package comprising Content, live streams and other related services provided by JV-Campus Provided personal information: Information to identify User: account ID (email address), name, date of birth, affiliated university, etc. (if necessary to issue certificates of completion) Information relating to Content usage: Service usage, purchase of Content, viewing and progress, submission results for tests, reports, etc., confirmation of grade management such as grades and course completion, and other information necessary for grade management. Recipient: Business operators and other corporations and organizations using a Strategic Package Box (“Strategic Package Box Purchaser”) Provided personal information: Account ID (email address) If the Strategic Package Box Purchaser is a university or other educational institution: information necessary to identify User within the school such as user name and educational institution, course and year at affiliated university, etc. If the Strategic Package Box Purchaser is a corporation: information necessary to confirm that User has usage authority, such as User’s name Information relating to Content usage: Platform Service usage, purchase of Content, viewing and progress, submission results of tests, reports, etc., confirmation of grade management such as grades and course completion, and other information necessary for grade management. Recipient: Universities or other educational institutions that link accounts through LTI linkage (immerse U (Kansai University), etc.) Provided personal information: Information to identify enrollee: account ID (email address), some information associated with the account saved at JV-Campus, enrolled course name Provision and Sharing, etc. based on Laws and Regulations, etc. In addition to (1), JV-Campus may provide User personal information to third parties as follows. Under laws and regulations Receives a request for disclosure from a law enforcement agency or administrative agency with due authority, or an agency or body, etc. equivalent to these Is necessary to protect the life, body or property or credibility of a person, etc., or has justifiable grounds for the provision of personal information Other In the event JV-Campus sells or transfers some or all its business, User personal information may be transferred to the buyer or acquirer of the business as part of the transaction. In such event, the usage purpose of User personal information may not be changed without the consent of User. User Rights Certain rights may be recognized for the User’s own personal information, including the following rights based on laws and regulations. Right to access personal information: right to request access to information about User personal information, such as personal information categories, handling purposes, and other information set out in applicable laws and regulations Right to amend personal information: right to amend inaccurate personal information Right to erase personal information: right to request the erasure of personal information of User collected by JV-Campus Right to restrict the use of personal information Right to file an objection to the use of personal information: right to file an objection for an aspect of handling of User personal information, such as profiling or other handling based on applicable laws and regulations depending on the circumstances Data portability: right to receive and send to third party’s personal data in a usable electronic format Understand the handling of personal information: the right to check the collection source, the purpose of collecting and providing it to a third party, the contents of the retained information and the details of third parties to whom the information is provided Freedom to exercise rights: User is able to freely exercise its rights, and JV-Campus will not refuse to provide products or services on the basis purely of User exercising its rights on the basis of discriminatory treatment. Please contact us in accordance with 10. Inquiries for inquiries as to whether the following rights apply, or if you wish to exercise such rights. User may also exercise such rights through an authorized agent in accordance with applicable laws and regulations. Written permission must be given to such authorized agent. If requested by User, JV-Campus may perform identity verification based on already collected personal information of User, as well as request the submission of other information for the purpose of identity verification. JV-Campus may also request the submission of additional information for the purpose of appropriately handling requests from User. Please contact JV-Campus if there is any change in User information or User information held by JV-Campus is inaccurate, in order to update or amend User information. Rights of User based on applicable laws and regulations are not absolute, and JV-Campus may not be able to grant a request from User if there are grounds under applicable laws and regulations. The provision of personal information by User to JV-Campus is made in principle at the volition of User. Failure to provide personal information (including cases where personal information is deleted or its usage is restricted at User’s request) may result in disadvantages, such as some or all functions provided by the Platform Service not working, etc. depending on the type of personal information. Overseas Transfer JV-Campus may transfer User personal information to countries that do not have equivalent personal information protection laws to the country User resides in. As required by applicable laws and regulations, JV-Campus transfers information after taking appropriate protection measures (contractual guarantees, etc.) to ensure User personal information is sufficiently protected. Please contact JV-Campus in accordance with 10. Inquiries to check the details of such protection measures. Security Measures JV-Campus complies with applicable laws and regulations and handles personal information under a high level of security in order to prevent unauthorized access and leaks of User personal information, maintain the accuracy of personal information and appropriately destroy personal information if required. JV-Campus encrypts communications when it collects or transfers personal information, restricts access to stored personal information, and only permits persons necessary to perform services to handle it. JV-Campus conducts periodic reviews of the above practices to ensure that its safeguards are properly implemented and remain appropriate. Amendment to this Privacy Policy JV-Campus may from time to time amend this Privacy Policy as necessary to respond to changes in laws and regulations and out of business necessity, and display such amendments, etc. on JV-Campus Privacy Policy [posted at https://www.jv-campus.org/en/privacy-policy/]. We ask User to thoroughly check the contents of the latest Privacy Policy after such amendment, etc. as displayed on our website. Inquiries Please contact JV-Campus by the following methods if you have any comments on this Privacy Policy or about the exercise of rights of User under applicable laws and regulations. Inquiries: Bureau of Global Initiatives, Tsukuba University JV-Campus 1-1-1 Tennodai, Tsukuba-shi, Ibaraki 305-8577 URL: TO BE ADVISED Established March 10, 2022 Revised April 22, 2022 August 28, 2022