We recognize the provision of appropriate protection for your personal information is as our social responsibility. The personal information we collect from you enables identification of individual customers (name, address, telephone number and email address; hereinafter “Personal Information”) and is required by Dentsu Asia Pte Ltd. (hereinafter the “Company”) the owner and operator of the application iButterfly, to provide services to our customers. Allowing us to use your Personal Information appropriately is extremely beneficial in improving our services. In recognition of the importance of our customers’ Personal Information, we have established the following policy for the protection of your Personal Information when it is being handled by the Company. We ensure that this policy is fully understood and upheld by all stakeholders and staff of the Company.
■ Basic Policy for the Protection of Personal Information
1. We comply with laws and ordinances and other guidelines relating to the protection of Personal Information.
2. We establish systems for the protection of Personal Information by establishing the necessary provisions with the administrator and make every effort to educate and train our employees in these systems.
3. We clearly state the purpose of the use of Personal Information and obtain Personal Information through appropriate methods. We also endeavor to maintain information that is accurate and up to date. We do not use Personal Information beyond the scope agreed with the customer and we do not provide Personal Information to third parties.
4. We establish reasonable, safe policies to prevent unauthorized access to or the loss, destruction, alteration or leaking, etc. of Personal Information. Agents to whom our Personal Information business is entrusted are selected on the basis of appropriate standards and are supervised to ensure the maintenance of safety.
5. We have established a customer service desk and procedures to respond sincerely and promptly to all requests and complaints from customers regarding Personal Information.
Inquiries regarding Personal Information:
Telephone: Email: email@example.com
6. We set the shortest necessary period for maintaining customers’ Personal Information and when this period ends we delete and dispose of all Personal Information without fail.
7. If an accident involving the leaking of customers’ Personal Information should occur, we promptly notify the affected parties and disclose the facts as well as our policy for preventing the recurrence of such an accident.
8. We make ongoing improvements to our systems for protecting Personal Information in response to changes in conditions for implementing safety management, system technologies and social trends, etc.
■ Provisions for the Handling of Personal Information
The Company discloses the followings regarding the handling of Personal Information which you as a customer allow us to collect, use and provide and regarding our customer service desk:
1. The collection, use and purpose of the information
We collect the following information of users of this application.
(1) User nickname
Registering user nicknames enables users to participate in ranking. The Company records the registered nicknames and reflects them in rankings. Customers may register their actual names or fictitious names as their nicknames.
(2) UDID information
The Company collects UDID (unique device identifier) information specific to the mobile terminal a customer uses. UDID information is used for the individual recognition of mobile terminals for managing the use of coupons.
(3) Location information
For these services, information on the current location of the user is collected to deliver information (butterflies) appropriate for that location. Therefore, at the time of startup of the application, information on your current location is collected.
(4) Log data
The Company records the following information for the operation and management of the application, for user surveys for improving our services, and for processing various statistics relating to the status of use of the services:
1) Information (butterfly) collection log (UDID information, collected information ID, collection date and time, collection location)
2) Information (butterfly) exchange log (UDID information, exchanged information ID, date and time of exchange, location of exchange)
3) Coupon use log (UDID information, used coupon ID, date and time of use)
(5) Campaign offer information
When the Company runs gift campaigns, we record Personal Information (name, address, telephone number and email address) required for the delivery of gifts.
2. Provision of Personal Information
We do not provide Personal Information to third parties except in the following cases:
(1) When the consent of the customer is obtained
(2) When a request for disclosure is made on the basis of laws or ordinances
(3) When there is a request from a public organization based on a just reason
3. Outsourcing of Personal Information
On occasion we entrust Personal Information in our care to external organizations for forwarding purposes and statistical processing. We select agents on the basis of standards set by the Company. We not only enter into basic agreements with these organizations regarding the handling of Personal Information and its safe management but we also undertake appropriate supervision of these organizations.
4. Inquiries regarding Personal Information
Inquiries regarding Personal Information may be addressed to the information desk at:
5. Period of retention of Personal Information
(1) The period for retaining information of users of the services is in principle six (6) months following termination of the purpose of use. When a retention period in excess of this is established, we endeavour to disclose or give notification of the details thereof.
(2) Personal Information for which the retention period has expired is completely deleted or destroyed.
Effective Date: November 1, 2010
* The Company complies with legislation and guidelines which apply to Personal Information and may review and change the above policy without prior notification.