This Privacy Guide provides an easy-to-understand explanation of BASE Group’s approach to personal data, including how the Group acquires, uses, and protects personal data.

1.  BASE Group’s commitment to privacy
BASE Group makes the following commitments to its customers.

・When acquiring or using your personal data, our top priorities are complying with the Personal Information Protection Law and other relevant laws, regulations, guidelines, and taking into consideration the impact on your privacy.

・In order to protect your personal data, we use the best and most up-to-date security measures to prevent any threats to privacy data such as unauthorized use, leakage, or unintentional loss or falsification.

・We regularly assess and improve our internal systems for the safe use and protection of customers’ personal data, led by the person responsible for the handling of personal information, to ensure that they are appropriate in light of social and other circumstances.

・We conduct internal training for executives and employees to familiarize them with the rules to be followed when acquiring or using personal data.

2.  What is personal data?
Personal data refers to information about individual customers, including personal information as defined by the Personal Information Protection Law. It includes information such as a customer’s name and address, IP address, and product purchase and sales history.

3.  Acquisition of personal data
In accordance with its Privacy Policy, BASE Group acquires  customers’ personal data in situations like the following.

（1）When customers are asked to enter the information themselves when using BASE Group products and services (hereinafter referred to as “the Service”).
For example, we acquire your name, address, and other information that you enter when opening a store or purchasing a product.

（2）When the information is transmitted automatically due to using or browsing a BASE Group shop or service.
For example, we obtain your IP address when you log in and your product sales and purchase history.

（3）When personal data is provided to us by a third party
For example, we may acquire information such as your telephone number, email address, browsing history,  or location information from third parties such as DMP businesses and other advertising companies or affiliate service providers.

4.  Use of personal data
BASE Group uses your personal data for purposes such as the following. When using your data, as above, our top priorities are complying with laws, regulations, and guidelines including the Personal Information Protection Law, and taking into consideration the impact on your privacy.

（1）To provide the Service
For example, when you purchase a product from a shop that uses BASE, we will contact you at your email  address to inform you that your product has shipped or that your payment has been completed.

（2）To provide information and respond to inquiries, etc. regarding the Service
For example, when promoting new BASE Group services and functions or to distribute advertisements through an advertisement distribution company.

（3）To respond to acts that violate the terms and policies of the BASE Group related to the Service (hereinafter referred to as “Terms”).
For example, using information such as the customer’s selling history, buying history, or IP address to confirm  a violation of our terms of service.

（4）To notify you of changes to the Terms.
For example, if we make a change to our terms of service, we inform our customers in advance of what the change will entail by sending an email to their email address.

（5）To help improve the Service and develop new services for BASE Group
For example, we use information such as your sales history and purchase history in order to improve the Service so that it better meets your needs.

（6）To create statistical data processed in a format that cannot be individually identified in relation to the Service
For example, we use your personal data to create statistical data on the age groups of people who use the Service.

5.  Sharing of personal data
（1）BASE Group does not provide personal data to third parties without prior consent from customers. However, the following cases do not fall under provision to a third party.

・When all or part of the handling of personal data is entrusted within the scope necessary to achieve the purposes of use set forth in the Privacy Policy

・When personal data is provided in connection with business succession due to a merger or other reasons

・When jointly used in accordance with the provisions of the Personal Information Protection Law

（2）BASE Group may share your personal data with third parties located in foreign countries.
For example, in order to distribute advertisements through an advertisement distribution company, we may share information necessary  for distribution such as customer email addresses with an advertisement distribution company based in the U.S. or Singapore. The companies we share any such data with are limited to those that can be expected to meet the same standards required under Japan’s Personal Information Protection Law in light of the legal system in the country and the company’s system for safe management.

6.  Shared use of personal data within group companies
Your personal data is used jointly by BASE Group companies for the purposes of use announced in the Privacy Policy and elsewhere.

7.  System for protecting personal data
BASE Group will provide necessary and appropriate supervision to its employees so that personal data can be safely managed against risks such as loss, destruction, falsification and leakage of personal information.  In addition, when entrusting all or part of the handling of personal data, BASE Group will provide necessary and appropriate supervision so that the personal data can be managed safely at the outsourcer.

BASE Group may store personal data on the servers managed by a business operator in a third country (U.S.). To ensure that personal data is securely managed by a business operator in the third country, the Company intends to gather information on the regimes of the protection of personal information in the third country and to strictly manage the personal data including limiting access authorities to the servers.

8.  Contact person for inquiries regarding personal data
If you have any questions regarding personal data, please contact us using the information below. Depending on the nature of your inquiry, we may need to verify your identity.

・To contact BASE, Inc. :

BASE, Inc.

BASE, Inc., Person in Charge of Privacy

Telephone: 03-6416-5450

E-mail: hi[at]binc.jp

・To contact PAY, Inc. :

Sumitomo Real Estate Roppongi Grand Tower 37F, 3-2-1 Roppongi, Minato-ku, Tokyo 106-6237

PAY, Inc., Person in Charge of Privacy

Telephone:  03-6441-2025

E-mail: support[at]pay.jp

Reception hours are from 10:00 to 18:00 on weekdays.

9.  In the event of a request for disclosure from a third party
In principle, BASE Group does not comply with requests from a third party to disclose a customer’s privacy data.
However, data may be disclosed in exceptional cases such as the following.

・When we are required to disclose the information by law, such as when responding to a request for disclosure made pursuant to a warrant issued by a judge.

・In situations where disclosure is permitted under the Personal Information Protection Law, such as when disclosure is necessary in order to protect the life, body, or property of the customer or the third party, but it is difficult to obtain the customer’s consent.