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Privacy Policy

Knee High Media Japan LLC is concerned about privacy issues, and about the handling of your Personal Information (as defined below) in compliance with applicable laws, regulations and guidelines (including the Act on the Protection of Personal Information of Japan). We want you to be familiar with how we collect, use and disclose information. This privacy policy (the “Privacy Policy”) describes our practices in connection with information collected through (a) our Papersky Magazine application for the iPad (the “App”) and (b) our website located at http://www.khmj.com/ (the “Site,” and collectively with the App, the “Services”). By using the App or the Site, you agree to the terms and conditions of this Privacy Policy.

This Privacy Policy applies only to our online information-gathering and dissemination practices through the App and the Site, and does not apply to any of our other practices, including those conducted offline. Further, if you submit any information to any third party, such third party’s collection, use and disclosure of such information may be governed by its privacy policy and is not governed by this Privacy Policy (and in any event, we are not responsible for the information collection, use and disclosure practices of third parties)

1. Definitions.

For purposes of this Privacy Policy, “Personal Information” means information that identifies you as an individual, such as name, postal address, telephone number, email address or credit/debit card number, and “Non-Personal Information” means information that does not reveal your specific identity or does not directly relate to an individual, such as browser information, device information, information regarding App usage, server log files, IP addresses, referring URLs, demographic information and aggregated information.

2. The App.

Personal Information.
i. Use and Disclosure of Personal Information Collected Through the App. We may collect email address Information when you create an App account.

ii. Use of Personal Information Collected Through the App. We may use the Personal Information we collect through the App:

* To respond to your inquiries and fulfill your requests, such as to re-set passwords.
* To provide you with maintenance and support for the App.
* To send you important information regarding the App, changes to our terms, conditions, and policies and/or other administrative information.
* For our business purposes, such as data analysis, enhancing the App and identifying usage trends.
* As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including those outside your country of residence; (d) to enforce our terms, conditions and policies; (e) to protect our operations, rights, privacy, safety and/or property, and/or those of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

b. Non-Personal Information.

i. Collection of Non-Personal Information Through the App. We and our service providers may collect Non-Personal Information through the App in a variety of ways, including:

* Device information — certain Non-Personal Information is collected automatically through the devices on which you install or use the App, such as your operating version, device model and language, and the version of the App you are using.
* App usage information — we and our service providers receive Non-Personal Information from you when you select companies or securities to track using the App or submit other requests through the App.

ii. Use and Disclosure of Non-Personal Information Collected Through the App. We may use and disclose the Non-Personal Information we and our service providers collect through the App for any purpose, except where we are required to do otherwise under applicable law. For example, we may use and disclose such information for the following purposes:

* To provide you with App functionality (for example, to provide you with information about companies and securities about which you have requested such information).
* To ensure that the App functions properly and to understand usage of the App.
* To personalize your experience with the App.
* For our business purposes, such as data analysis, developing new products, enhancing the App, improving our products and services and identifying usage trends.

3. The Site.

a. Personal Information.

i. Collection of Personal Information Through the Site. Personal Information is only collected through the Site when you voluntarily provide it to us. For example, you may send us an electronic mail message through a “mailto:” link on the Site in order to request information about or support for our products and services.

ii. Use of Personal Information Collected Through the Site. We may use the Personal Information we and our service providers collect through the Site:

* To respond to your inquiries and fulfill your requests, such as to send newsletters to you.
* To provide you with maintenance and support for our products and services.
* To send you important information regarding the Site, changes to our terms, conditions, and policies and/or other administrative information.
* To send you marketing communications that we believe may be of interest to you (for example, research reports and general announcements on new features, updates, products and services).
* For our business purposes, such as data analysis, enhancing the Site, improving our products and services and identifying usage trends.
* As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including those outside your country of residence; (d) to enforce our terms, conditions and policies; (e) to protect our operations, rights, privacy, safety and/or property, and/or those of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

iii. Disclosure of Personal Information Collected Through the Site. We may disclose the Personal Information we and our service providers collect through the Site:

* To our third-party service providers who provide services such as website hosting, data analysis, IT services and customer service to enable them to provide services. We may use cloud service providers (such as Amazon Web Services LLC) in connection with the hosting of data and the storage of Personal Information.
* To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
* As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including those outside your country of residence; (d) to enforce our terms, conditions and policies; (e) to protect our operations, rights, privacy, safety and/or property, and/or those of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

b. Non-Personal Information.

i. Collection of Non-Personal Information Through the Site. We and our service providers may collect Non-Personal Information through the Site in a variety of ways, including:

* Device and browser information — certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (e.g., Windows or Macintosh), screen resolution, operating system version and Internet browser type and version.
* Server log files — IP addresses are identified and logged automatically in server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited.
* Aggregating information — we may aggregate Personal Information so that the end-product does not personally identify you or any other Site user.

ii. Use and Disclosure of Non-Personal Information Collected Through the Site. We may use and disclose the Non-Personal Information we and our service providers collect through the Site for any purpose, except where we are required to do otherwise under applicable law.

4. THIRD-PARTY SITES. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any application, site or resource to which the App, any data available through the App, or the Site links. The inclusion of a link in the App, any data available through the App, or the Site does not imply our endorsement of the linked application, site or resource.

5. SECURITY. We seek to use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or any wireless service, and no data storage system, can be guaranteed to be 100% secure. You acknowledge and agree that any information you transmit through the Services is so transmitted at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any App LOGIN code or any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

6. YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION. If you have provided us with Personal Information and you no longer wish to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving such marketing-related emails by emailing us at [email protected] with your name and email address, and specify that you are opting-out of receiving marketing-related emails from us. We will try to comply with your request(s) as soon as reasonably practicable. We are not responsible for changing, removing or suppressing information from the databases of third parties. Also, if you do opt-out of receiving marketing-related messages from us, we may still send administrative messages to you; you cannot opt-out from receiving administrative messages.

7. RETENTION PERIOD. We will retain information that we collect through the Services for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law.

8. USE OF THE SERVICES BY MINORS. The Services are not directed to individuals under the age of fourteen (14), and we request that these individuals do not provide information through the Services.

9. CROSS-BORDER TRANSFER. Information that we collect through the Services may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country.

10. UPDATES TO THIS PRIVACY POLICY. We may change this Privacy Policy. Please check the “Last Updated” legend at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. Your use of any Service following these changes means that you accept the revised Privacy Policy.

11. CONTACTING US. If you have any questions about this Privacy Policy, have any complaints about our handling of your Personal Information under this Privacy Policy, or wish to exercise your choices regarding your Personal Information under applicable law (including requesting the disclosure, correction, addition, or deletion of, or discontinuance of utilization of, your Personal Information), please contact us by email at [email protected] Email communications are not necessarily secure, so please do not include credit card information or sensitive information (e.g., credit card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) in any email to us.

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