Privacy policy

As part of its efforts to safeguard the personal information of the users ("Users") of its online school MANABI JOURNEY (the "Service"), WENet Inc. ("WENet") has established this Privacy Policy, which governs its management of personal information.

01. Definition of Personal Information

For the purposes of this Privacy Policy, personal information is defined as any information that might be used to identify specific individuals, including names, email addresses, home addresses, telephone numbers, and other applicable descriptive information. Personal information also includes all information that might be used to easily identify a specific individual by way of comparison with other information.

02. Consensual Management of Information and the Right to Withdraw Consent

By registering as a member, the User agrees to the terms of this Privacy Policy and consents to the management of their personal information as described. On the basis of the User's consent, WENet will manage the User's personal information. However, the User may withdraw their consent at any time. If the User is a minor, etc., it will be presumed that the consent of an applicable individual as listed in Article 5, Section 1 of the Terms of Use has been obtained.

03. The Purposes for Which WENet Uses Personal Information

The personal information obtained in the course of the provision of the Service will be used for the following specific purposes.

  • For service at the time of registration for the Service; confirmation of identity; payment procedures at the time of course registration; and the provision, upkeep, management, protection, and improvement of the Service
  • For the provision of information relating to the Service; in order to respond to inquiries, etc.; and in order to provide notice of revisions or other changes to the Terms of Use, etc.
  • For the distribution or display of advertisements by WENet or third parties, and for the purpose of providing various types of information
  • For the purpose of marketing involving the ascertainment and statistical analysis, etc., of Users' usage situations and tendencies
  • For the ascertainment of the state of WENet's advertising distribution, the measurement of advertisement effectiveness, and the display of behaviorally targeted advertisements (certain portions of the website only)
  • For other purposes incident to the purposes listed above

04. Appropriate Collection of Personal Information

The purposes for which WENet will use personal information will be specified in advance. WENet will collect only that information which is necessary in order to accomplish said purposes, and only by lawful, appropriate means.

05. Requirement to Provide Personal Information

The personal information that the User will be asked to provide is necessary in order to facilitate the User's use of the Service. If the User chooses not to provide said information, the User may be unable to use the Service.

06. Provision of Personal Information to Third Parties

WENet will not provide personal information to any third party without the advance consent of the User in question, except for in the cases listed below, and in cases in which the provision of said information is permitted under Japan's Personal Information Protection Law or any other applicable law.

  • Cases in which it is necessary in order to protect the life, health, or property of an individual, and in which it would be excessively difficult to obtain the consent of the User
  • Cases in which it is particularly necessary in order to facilitate the improvement of public health or the healthy upbringing of children, and in which it would be excessively difficult to obtain the consent of the User
  • Cases in which WENet is required to assist with the execution of legally-defined duties by a government agency, local public organization, or any entity commissioned by a government agency or local public organization, and in which the act of obtaining the User's consent would carry the risk of hindering the execution of said duties
  • Cases in which disclosure is required by law

Notwithstanding the stipulations listed above, in the following cases, restrictions on the provision of personal information will not apply to third parties.

  • Cases in which WENet is entrusting personal information, in whole or in part, to a third party as required in order to accomplish the purposes of the use described above
  • Cases in which personal information is provided due to the transfer of WENet's operations resulting from a merger or other cause
  • Cases involving the shared use of information as defined by Japan's Personal Information Protection Law

WENet may provide personal information to a third party in accordance with Article 16, Section 4 of the Terms of Use. In all such cases, WENet will enter into a contract with the third party concerning the proper protection of all personal information, and will ensure the third party's compliance with the EU General Data Protection Regulation (GDPR) and all other applicable laws.

07. Release of Personal Information

In the event that the User requests the release of their own personal information under the provisions of Japan's Personal Information Protection Law, WENet will disclose the information to the User without delay upon confirming that the request is being made by the User in question. In all such cases, a handling charge of ¥1,080 (tax included) per request will be required.
*In the event that no applicable personal information exists, WENet will notify the User to that effect.
*The preceding does not apply in cases in which WENet does not bear responsibility for the release of personal information under the Personal Information Protection Law or any related law.

08. Correction of Personal Information

  • WENet may request the cooperation of the User in order to ensure that the User's personal information is accurate and up-to-date.
  • Via the Service's website, the User may undertake a procedure to verify, correct, supplement, or delete their personal information; to exercise their right to data portability; to suspend the use of their personal information; or to suspend the provision of their personal information to WENet's partners. The procedures for verification, correction, and supplementation of personal information can be undertaken through the website's My Account section. To undertake the procedure to delete personal information, exercise your right to data portability, suspend the use of your personal information, or suspend the provision of your personal information to WENet's partners, please submit a request from the Inquiry section of the Service's website. (If you wish to submit a request regarding any personal information in WENet's possession for which you are unable to undertake any of the aforementioned procedures through the method described above, please submit a request from the Inquiry section of the Service's website.)
  • The User has the right to lodge a complaint with the data protection authority in the country of jurisdiction regarding the handling of personal information relating to the User.

09. Measures for the Protection of Personal Information

WENet has implemented the appropriate measures in order to ensure the safety of the personal information that it handles. WENet will endeavor to prevent, and, if necessary, rectify any unauthorized access to personal information, or loss, destruction, falsification, or unauthorized disclosure of personal information. Furthermore, in the event that WENet elects to entrust to a third party the management of personal information, in full or in part, in order to accomplish the purposes of use as described above, WENet will enter into a contract with said third party that encompasses matters including the nondisclosure of the personal information, and will oversee the third party as necessary and appropriate, for the purpose of ensuring the safe management of the personal information by the third party.

10. Use of Cookies and Similar Technologies

For the purposes of ascertaining details pertaining to the use of WENet's services and improving said services, some aspects of the Service require that the User has permitted the use of technologies such as cookies. At no time will the use of these technologies result in the acquisition of personal information that the User has not entered. In the event that the User has disabled cookies, the User may be unable to use the Service.

11. Privacy Policy Revision Procedure

WENet will review its operational situation relating to the management of personal information, and make continuous efforts toward its improvement. Consequently, portions of this Privacy Policy may be revised. In the event of a major revision, information regarding the revision will be provided on this website. The revised Privacy Policy will take effect upon being published on this website, except in special cases as determined by WENet.

12. Retention Period

WENet will retain the User's personal information for as long as retaining said information is necessary in order to provide the User with the Service. In the event that it is no longer necessary to retain personal information, WENet will promptly delete said information.

13. Transfer of Personal Information to Countries Outside the EU

In order to accomplish the purposes of use described above, WENet may transfer the User's personal information to countries outside the EU (including Japan), and handle the information in said countries. In countries outside the EU, data subject rights such as those stipulated by the GDPR may not be recognized. However, WENet guarantees that sufficient measures concerning the protection of the User's personal information will be taken, including the conclusion of standardized contracts based on the GDPR.

14. Point of Contact for Inquiries

If you wish to submit any comments, questions, or other inquiries regarding WENet's management of personal information, please contact us at the following.

Personal Information Inquiry Desk
Benten 501 Building, 3-2-20 Benten, Chuo-ku, Niigata-shi, Niigata 950-0901, Japan
(The Inquiry section)

(Supplementary Provisions)
Enacted January 10th, 2018
Revised July 25th, 2018