This Service Privacy Policy (“Privacy Policy”) sets out how we use and protect the personal data of advertisers and publishers (“business customers” or “you”).

Privacy Policy

This Privacy Policy gives you information about how we collect and use your personal data through your use of the Webridge services (“Services”), including any data you may provide when you register to the Services.
This website is not intended for children and we do not knowingly collect data relating to children.
By using the Services or providing personal data to us, you agree to our collection and use of your personal data in accordance with this Privacy Policy.

Who we are

We are Forit Group. “Forit Group” is made up of different legal entities, specifically, For it Inc. (“Forit”) and its Group Companies (collectively “Forit Group”).
“Group Companies” means the following foreign company in which Forit holds the majority of voting rights (“Subsidiary”) or foreign company in which Subsidiary holds a majority of voting rights (“Sub-subsidiary”):
　Subsidiary FORIT DIGITAL SDN. BHD.(Malaysia).

Controller

This Privacy Policy is issued on behalf of the Forit Group so when we mention "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Forit Group responsible for processing your data. Forit is the controller and responsible for your personal data, and we will let you know which entity will be the processor or joint controller for your data when you apply for using the Services.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 11).

Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and residence information (country and address).
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to and from you and other details of the Services you have applied to us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We use different methods to collect data from and about you including through:

Your interactions with us.

You may give us your personal data by filling in application forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for using the Services;
• create an account on our website;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions.

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

• Identity, Contact Data, and Profile Data is collected from publicly available sources.

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you apply for using the Services.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by logging into the website of the Services and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links within any marketing communication sent to you or by contacting us LINK.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our Terms and Conditions, checking that your contact details are correct, etc.

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Internal Third Parties: Other companies in the Forit Group
• External Third Parties: Service providers who provide IT and system administration services. Professional advisers including lawyers, auditors and insurers who provide consultancy, legal, insurance and accounting services.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where permitted by applicable law, we may transfer the personal data we collect about you to the jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Policy. If you are located in the EU, we have implemented to secure the transfer of your personal data to the jurisdictions.

Forit utilizes the EEA’s or UK’s Standard Contractual Clauses for the purposes of transfers from Forit to its Group Companies and/or service providers located outside of the EEA and/or UK. Regardless of where your information is processed, we apply the same protections described in this Privacy Policy. Our Group Companies process personal data if necessary and appropriate for the business purposes (or legal basis) for which it was collected, and this may include if you have contacted the Group Companies directly for assistance or provide them directly with your information. Your consent to this Privacy Policy and your submission of personal data represents your agreement to those transfers.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten (10) years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [paragraph 9] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details in paragraph 11).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We do not direct our Website to minors and we do not knowingly collect personal data from children under eighteen (18) or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at LINK.

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Personal Data Protection Officer contact details:
Name: HIROKI FUJIMURA
Email: fujimura@for-it.co.jp
Postal Address: 9th floor E-Space Tower, 3-6, Maruyamacho, Shibuya-ku, Tokyo 150-0044 Japan

Company Information:
Company Name: For it Inc.
Postal Address: 9th floor E-Space Tower, 3-6, Maruyamacho, Shibuya-ku, Tokyo 150-0044 Japan
Tel: +81 3-5728-5865
Monday to Friday
10:00-19:00
Regular holidays: Saturday and Sunday/National holidays (under Japanese holiday laws)/Year-End and New Year holidays

If you are unsatisfied with our response to any issues that you raise, you have the right to make a complaint with the data protection authority in your jurisdiction.

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of our website and/or the Services after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.