Sanwa Investment Privacy Policy

Sanwa Investment provides this Privacy Policy to help you make an informed decision about whether to use or continue using Sanwa Investment Application and Sanwa Investment Services.

When using any of our Services you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Irrespective of which country you reside in or supply information from, you authorize Sanwa Investment to use your information in US and/or any other country where Sanwa Investment operates.

This Privacy Notice is incorporated into and is subject to the Sanwa Investment Terms of Service. Your use of the Sanwa Investment Application and Sanwa Investment Services and any personal information you provide on the Sanwa Investment Services or via Sanwa Investment Application remains subject to the terms of this Privacy Notice and our Terms of Service.

Sanwa Investment is committed to protecting your privacy and to complying with applicable data protection and privacy laws. This Privacy Policy ("Policy") explains how we process personal data. Throughout this Policy the term "personal data" means information relating to an identified or identifiable individual (i.e. a natural person). "Sanwa Investment" refers to Sanwa Investment Corporation, including its affiliates (also referred to as "we", "us", or "our"). This Policy applies for processing of your personal data where Sanwa Investment is the data controller or where we refer to the applicability of this Policy.

1. INFORMATION Sanwa Investment COLLECTS:

Personal Identifiable Information:
You provide certain personally identifiable information (such as your country, your active mobile number, your full name, permission to sync your mobile phone contacts, permission on push notifications (in case of iOS), your valid email, and/or such other information) to Sanwa Investment when choosing to participate in various uses of the Sanwa Investment Services and Application. Personal identifiable information is required to use any of Sanwa Investment's services. Further Sanwa Investment collects this data to optimize and iterate to best serve its users and to help you to find app users you know as well as to notify you the availability of your phone contacts on app.

The Sanwa Investment Application and Services may not function properly if the ability to accept cookies is disabled.

In the activation process your personal identifiable information will be sent to Sanwa Investment and we may associate this information with your active Sanwa Investment Account/communities after securing permission. This combined information may be used to activate Sanwa Investment App services and certain software licenses and to send you personalized messages, for example emails, and other messages. These messages may include information about Sanwa Investment's products and services, such as tips and commercial offers. You may unsubscribe from these messages at any time for example by following the information in the message you receive after taking your device into use, instructions in the device or in the messages. The collected information may also be used to display personalized content as well as to improve Sanwa Investment's products and services. The above information may also apply in case you update the Application of your device.
Device information:
Additionally, beyond mobile phone numbers, we also collect operating system version, product name, mobile screen resolution, device name, device brand and manufacturer, as well as the device's unique identifier (in the iPhone's case, a UDID), network service provider specific identifiers, network settings and other such information.

Location information:
When you use a location-enabled Sanwa Investment service, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points, cell towers or other network based location data. Depending on your positioning settings and your use of location services of other service providers your device may connect to other service providers' servers, which are not controlled or operated by Sanwa Investment. We recommend you to check the privacy policies of such service providers to understand how they process your location data. You can modify the positioning settings of your device from the device settings. Some location based services may allow you to associate your personal data with your location.

Log File Information: 
When you use the Sanwa Investment, Applications or Services, our servers automatically record certain information that you send or receive whenever you chat with any number/ numbers or send / receive any information on chat via Sanwa Investment Application. These server logs may include information such as your chatting details, information send/ receive on chat , IP Address,  the amount of time spent on particular number/s, the date and time of your chat, information that may uniquely identify your phone number and various other details such as chat on P2P, your post, reply to a post, sharing a message/post, invite's to contacts, tell a friend to download the app; abuse a post report and other related information to provide these Services to you.

Unique application numbers:
Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Sanwa Investment when you install or uninstall the service or when that service periodically contacts our servers, such as for automatic updates.

Additional information: 
We collect information relating to your use of our Application and services and your other interactions with us. Such information may include details of the queries or requests you have made, the Application and services provided, delivery details, and other such information, details of agreements between you and Sanwa Investment, records of contacts and communications, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.

Please note that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data. We may also obtain, in accordance with applicable law, some personal data from any publicly available sources.

2. USER DATA

User Data is all the data, including all text, sound, software or image files that you provide, or are provided on your behalf, to us through your use of the Services.

We make no claim of ownership in your User Data.  Except as provided in this privacy statement or described in your agreements, we only use User Data to provide and enhance the Services. We don't share your User Data with advertisers, or with anybody else except in the very limited circumstances described in the when Sanwa Investment discloses information section below.

3. ACCESSING, CORRECTING AND DELETING YOUR INFORMATION 

You may access, correct or delete user Data or user Data you have provided to us by using the tools within the Services (for example, editing your profile information on the Service) or by contacting support at support@Sanwa Investment.com. Changes you make to your information on the Service take immediate effect on your Sanwa Investment Network, but data will be retained in secure storage for a limited period afterward as part of our standard data backup process.

4. DATA SECURITY 

We have implemented and will maintain appropriate technical and organizational measures, internal controls, and information security routines intended to protect your information against accidental loss, destruction, or alteration; unauthorized disclosure or access; or unlawful destruction.

We use an advanced encryption technology known as Secure Socket Layer (SSL) to protect the storage and transfer of your data from unauthorized parties. In addition to our online security efforts, we take reasonable steps to protect your personal data offline, as well. All of your information, not just the sensitive information mentioned above, is restricted in our offices. Our main servers are operated from a dedicated Internet hosting facility with state-of-the-art physical security features, including smoke detection and fire suppression systems, motion sensors, and 24/7 secured access and security breach alarms.

5. YOUR CHOICE AND ACCEPTANCE:

You may, of course, decline to submit personally identifiable information through the Sanwa Investment Application or to Sanwa Investment Service, in which case Sanwa Investment may not be able to provide its services to you.

To protect your privacy and security, we take reasonable steps to verify your identity before granting Application access.

Please contact Sanwa Investment via email or available web forms with any questions or comments about this Privacy Notice, your personal information or your consent.

6. DATA LOCATION 

Your Services' data may be transferred to, stored and processed in the Japan or any other country where Sanwa Investment or its affiliates, subsidiaries or service providers maintain facilities. Sanwa Investment abides by the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Economic Area, and Switzerland.

7. HOW Sanwa Investment USES INFORMATION:

Generally:
Sanwa Investment believes that the privacy of its users is paramount and strives to use their data only in ways outlined in this privacy policy. We use Personal Information and Message Data for internal purposes only, such as for informing users of new releases, to operate, maintain, protect, improve and provide you the features and functionality of the Sanwa Investment Application and Services via any communication methods you have provided to the services . When you contact Sanwa Investment, we may keep a record of your communication to help solve any issues you might be facing.

Chat:
Any personal information or content that you voluntarily discloses in chat using the Sanwa Investment services is shown to all the number/s in that conversation and can be collected by those recipient/s of the Chat.   Your name (as it is saved in chat recipient's Address Book) is displayed to the recipient when you chat, send or receive messages through the Sanwa Investment Application and other Users can contact you through your preferred communication method.

Service Providers:
We may engage service providers to perform functions and provide services to us. We may share your private personal information with such service providers subject to confidentiality obligations consistent with this Privacy Policy, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

Transfers:
Sanwa Investment may share data internally with its affiliate companies and may disclose certain information in the event that it is merged, acquired, sold, or some of its assets are acquired.

Improvement:
We use both your personally identifiable information and certain non-personally-identifiable information (such as anonymous User usage data, phone data (phone model, make), IP addresses etc.) to improve the quality and design of the Sanwa Investment Application and Sanwa Investment Service and to create new features, promotions, functionality, and services by storing, tracking, and analyzing User preferences and trends.

User Convenience:
We use proprietary technology to and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time to use the Sanwa Investment Application; (b) provide custom, personalized content and information; (c) monitor individual and aggregate metrics such as total number of conversation, numbers chatted, etc.; and (d) track your chat, information communicated, information shared and such like purposes.

8. WHEN Sanwa Investment DISCLOSES INFORMATION:

Law:
Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your personal information, Usage Data, Message Data, and any other information about you, if we have a good faith belief that it is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce our Terms of Use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Sanwa Investment, its users or the public or to protect the safety of any person as required or permitted by law. However, nothing in this Privacy Policy is intended to limit any legal defences or objections that you may have to a third party's, including a government's, request to disclose your information.  Sanwa Investment also reserves the right to disclose personally identifiable information and/or non-personally-identifiable information that Sanwa Investment believes, in good faith, is appropriate or necessary to enforce our Terms of Service, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our services, and to protect the rights, property, or personal safety of Sanwa Investment, our Users or others.

User of Service:
Other users of Sanwa Investment Services and Sanwa Investment Application may see your status i.e. contact on app or/and chat with you in a way that is consistent with the use of the Services. In other words: If another Sanwa Investment Services User has your phone number stored in their Address Book, they will be able to see your status information either on app  and Chat and/or exchange information with you.

Your Consent:
We may share or disclose your information at your direction. Please be aware that, whenever you share information on a team group Id available profile page, this information may be accessed by the team. In addition, when you share information in instant message, or any other communications with third parties, that information may be passed along or made public by others. That means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications. CONSIDER CAREFULLY BEFORE DISCLOSING ANY PERSONAL DATA OR OTHER INFORMATION THAT MIGHT BE ACCESSIBLE TO OTHER USERS.

Fraud Prevention:
Sanwa Investment may share Contact Data with third parties for purposes of fraud prevention or to process payment transactions, as further described in this statement.

Notwithstanding the above policies, we reserve the right to disclose your personal information to appropriate third parties if we are required to do so by law or we believe that such action is necessary:

- To  protect the company's rights and property;

- To investigate reports of users sending material using a false e-mail address or users sending harassing, threatening, or abusive messages;

- To protect Sanwa Investment against misuse or unauthorized use of our Website and/or the Sanwa Investment service; or

- During emergencies, such as when we believe someone's physical safety is at risk.

- To any third party with your prior consent to.

Please note that the Services may include links to or allow you to install third-party or other Sanwa Investment products and services whose privacy practices may differ from the Services.  Your use of such products or services, and any information you provide to a third party, is governed by their privacy statements. We encourage you to review these other privacy statements.

9. Commitment to Children's Privacy:

Protecting the privacy of young children is especially important. For that reason, Sanwa Investment does not knowingly collect or maintain personally identifiable information or non-personally-identifiable information on the Sanwa Investment Application from persons under 13 years of age without the consent of their parents or guardians and no part of our Application and/or services is directed to or intended to be used by persons under 13 years of age. If you are under 13 years of age, then please do not use Sanwa Investment Application and/or Service at any time or in any manner. If Sanwa Investment learns that personally identifiable information of persons under 13 years of age has been collected on the Sanwa Investment database, then Sanwa Investment may deactivate the account and/or make the service inaccessible.

10. International Users:

If you are a User accessing the Sanwa Investment Application and Services from the Japan, European Union, U.S., or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from US laws, please be advised that through your continued use of the Sanwa Investment Application and Services, which are governed by US law, this Privacy Notice, and our Terms of Service, you are transferring your personal information to US and you consent to that transfer.

11. In the Event of Merger, Sale, or Bankruptcy:

In the event that Sanwa Investment is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our Users as part of such merger, acquisition, sale, or other change of control. In the (hopefully) unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

12. Controller of Privacy Policy:

Sanwa Investment Corporation is the controller of your personal data. In addition, the Sanwa Investment affiliate providing the Application or service may be a controller of your personal data. You may find the identity of the controller and its contact details by reviewing the terms and conditions of such a Application or service or by using contact information provided in the applicable Sanwa Investment websites.

13. How to Contact Us

Sanwa Investment welcomes your comments.  If you have questions about Sanwa Investment's privacy and security commitments, or if you have other technical or other customer support questions, please contact us at info@sanwa-investment.co.jp

14. SUPPORT DATA

Support Data is the information we collect when you submit a support request or run an automated trouble-shooter, including information about hardware, software, and other details related to the support incident, such as: contact or authentication information, chat session personalization, information about the condition of the computer and the application when the fault occurred and during diagnostics, system and registry data about software installations and hardware configurations, and error-tracking files. Support may be provided through phone, e-mail, or online chat.

15. Changes and updates to this Privacy Notice

Sanwa Investment may from time to time change this Policy or change, modify or withdraw access to this Application at any time with or without notice and this will be reflected by the last modified date below. Your continued use of the Sanwa Investment Application and Services constitutes your agreement to this Privacy Notice and any future revisions. . If there are material changes to this statement or in how Sanwa Investment will use your information, we will notify you by either posting a notice of such changes before they take effect or by direct notification. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy and to stay aware of any such changes.