Startrail Network Privacy Policy

This Privacy Policy sets forth the handling and processing of information containing the Personal Information of Startrail Participants (including persons seeking to become Startrail Participants; such information is hereinafter defined as “Participant Information”) on the Startrail Network (“Service”). When using the Service, you must read in entirety and consent to this Privacy Policy. Except where otherwise specified herein, the terms used in this Privacy Policy will have the meanings given to them in the Startrail Network Terms of Service.

1. Definitions

The following terms used herein will have the meanings set forth below.

1.1. “Personal Information”

Personal information as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information (“Personal Information Protection Act”).

1.2. “Participant Information”

Startrail Participant Personal Information and usage history on the Service, and other information that is generated or accumulated in connection with Startrail Participants or on Startrail Participant devices and is collected by Startrail in accordance with this Privacy Policy. Details are set forth in Article 2. 

2. Acquired Participant Information, Purposes of Use, etc.

Startrail will, on the Service, acquire the Participant Information set forth in the following items, in the situations identified therein, for the purposes of use set forth in such items.

3. Provision to Third Parties

3.1.    Startrail will not provide third parties with any Participant Information that falls under Personal Information, except in the cases set forth in Paragraph 2 and in the following items.

3.1.1.    Where the relevant Startrail Participant’s consent for provision to third parties has been obtained in advance;

3.1.2.    Pursuant to applicable laws and regulations;

3.1.3.    Where provision is necessary to protect the life, person or property of any individual and it is difficult to obtain the consent of the relevant Startrail Participant;

3.1.4.    Where provision is particularly necessary for the improvement of public health and hygiene or the promotion of sound childrearing, and it is difficult to obtain the consent of the relevant Startrail Participant; or

3.1.5.    Where provision is necessary to cooperate with the performance of administrative business by a national administrative organ or local public entity or a person entrusted thereby, and where obtaining the consent of the relevant Startrail Participant may impede such performance.

3.2.    Startrail uses Google Analytics, an external service, to measure the frequency of use etc. of the Service for the purposes that include, without limitation, improving the Service. Google Analytics uses Cookies to collect anonymous traffic data. These actions do not result in the identification of individual users. For the information collected by Google Analytics and the handling thereof, see the Google Privacy Policy and the webpage “How Google Uses Information from Sites or Apps that Use Our Services” (google.com/intl/ja/policies/privacy/partners/).

3.3.    Startrail Participants are entitled to record Startrail Registry Records on the Ethereum blockchain in conjunction with the use of the Startrail Network. This Startrail Registry Record will be publicly accessible in the Ethereum blockchain. Startrail Participants acknowledge, in advance, that in cases where Startrail Registry Records contain Personal Information of such Startrail Participants, this Personal Information will be publicly available. In addition, where such Startrail Registry Records contain Personal Information of third parties, the relevant Startrail Participant agrees to obtain the consent of such third parties to publicly disclose such information on the Ethereum blockchain. For clarity, the Startrail Registry Record is recorded directly on the Ethereum blockchain by Startrail Participants, and Startrail will not directly obtain such information from Startrail Participants.

4. Disclosure of Personal Information

4.1.    When a Startrail Participant has requested disclosure of Personal Information under the provisions of the Personal Information Protection Act, Startrail will confirm that such Startrail Participant is in fact the person who made the request, and will thereupon make disclosure to the Startrail Participant without delay or, if no such Personal Information exists, notify the Startrail Participant to that effect; provided, however, that the foregoing will not apply in cases where Startrail is not obligated to make disclosure under the Personal Information Protection Act or other laws and regulations.

4.2.    For disclosure of Personal Information as set forth in the preceding paragraph, Startrail will be entitled to charge a fee of 1,000 yen per instance of disclosure from Startrail Participants.

5. Revision, Suspension of Use, etc. of Personal Information

5.1.    When a Startrail Participant has made a request under either of the following conditions, Startrail will confirm that such Startrail Participant was in fact the person who made the request, and will thereupon conduct any necessary investigations without delay, revise the content or suspend the use of the relevant Personal Information in accordance with the results, and notify the Startrail Participant of actions taken. If it is decided that revision or suspension of use will not be carried out, Startrail Participants will be also notified to that effect.

5.1.1.    Request for revision of Personal Information under provisions of Personal Information Protection Act, because such Personal Information is inaccurate; or

5.1.2.    Request for suspension of use of Personal Information under provisions of Personal Information Protection Act, because such information is being handled beyond the scope of the officially announced purposes of use, or for reason that such information was collected under false pretenses or by other improper means.

5.2.    When a Startrail Participant has made a request for deletion of such Startrail Participant’s Personal Information and Startrail has deemed it necessary to comply with such request, Startrail will confirm that such Startrail Participant was in fact the person who made the request, and will thereupon delete such Personal Information and notify the Startrail Participant to that effect.  

5.3.    The provisions of Paragraph 1 and Paragraph 2 will not apply in cases where Startrail is not obligated to carry out revisions etc. or suspensions of use etc. under the Personal Information Protection Act or other laws or regulations.

6. Contact

Please direct opinions, questions, feedback, and all other inquiries related to the handling of Participant Information to:

contact@startrail.io

7. Amendments to this Privacy Policy

7.1.    Startrail is entitled to amend this Privacy Policy when it deems such amendments are necessary.

7.2.    When this Privacy Policy is amended, Startrail will publicly announce on the Service or by other Startrail-prescribed method, or will notify Startrail Participants of, the fact that this Privacy Policy has been amended, the particulars of the amended Privacy Policy, and the effective date of such amendments; provided, however, that for any amendments of this Privacy Policy for which the consent of Startrail Participants is required under laws and regulations, Startrail will obtain the consent of such Startrail Participants using a Startrail-prescribed method.

Startbahn, Inc.

As of June 1, 2020