Last update: July 3, 2020

This privacy policy (the "Privacy Policy") governs project initium ("we/our/us") and our video streaming services provided on our website (“our services”). Users of our services (“users”) shall understand and agree with each term of the Privacy Policy.

Section 1. Scope of Information that We Acquire

1. “Personal information” means any information that we acquire from users for operation of our services to manage and use, and that is protected by the Information Protection Law and other laws and regulations.
2. Users need to provide their names, email addresses and credit card information as personal information. All online payments for our services are made through Stripe service by Stripe Japan K.K. ("Stripe") and Stripe acquires users’ credit card information. We does not acquire complete credit card information.
3. We acquire the personal information specified in the preceding paragraph. We also acquire other information such as internet domain names, IP addresses, browser types, used languages, page views and search keywords. We also acquire cookies (meaning information sent from the server to the user's browser to identify the user on the server side and reserved in users’ computers), but use them only for the purposes to accurately determine the number of accesses and to improve our services displaying functions on various browsers.
4. We may ask or request personal information other than prescribed above, in order to identify any of user, when we find any special reason (such as unauthorized access or inappropriate use). In such occasions, we shall make written agreement, either in paper, by email, or other means, between the user and us in advance when we acquire any personal information. We shall not acquire any personal information without the user's consent.

Section 2. How We Collect Personal Information

1. To use our services, users shall be asked to provide their email addresses at the time of registration, and credit card information at the time of payment.
2. Users shall be asked to enter their names to send a message to any of the artists. Users may leave a blank, enter anonymous, or use nicknames. If a user opts a blank, anonymous, or nickname, we shall not acquire the name as personal information.
3. We use cookies to collect, record, and analyse data to use Google Analytics by Google, Inc (“Google”) or to store login information. The information obtained by using cookies does not include any information that can be used to identify a specific individual. The information used for Google Analytics is managed in accordance with Google’s Privacy Policy ( https://policies.google.com/privacy ).
4. Users may always opt not to provide personal information. When a user decides not to provide, however, some of our services are not available.

Section 3. Purpose of Collection and Use of Personal Information

1. The purposes for which we collect and use users’ personal information are as follows:
   1. To provide and operate our services;
   2. To charge users for access to our fee-based services;
   3. To respond to inquiries from users;
   4. To let an artist and us know of a user’s name when we convey his/her message to the artist (If the user’s name is left blank or anonymous, we collect the name as such and convey the message as from the anonymous, and if the user uses a nickname, we collect the name as such and convey the message as from the nickname.);
   5. To identify a user who violates the Terms and Conditions of our services or other agreements, or who attempts to use our service for illegal, improper or unfair purposes, and to suspend our service for him or her and/or cancel his/her membership;
   6. To enable users to view, change, or delete their own registered information and view their usage status;
   7. To compile statistical data on the use of our services to improve them;
   8. To implement marketing activities such as surveys on usage trends of our services;
   9. To plan and examine new services in the future;
   10. To confirm the identity of the user in the event of unauthorized access or inappropriate use, etc; and
   11. For purposes incidental to the purposes prescribed above.

Section 4. Alteration of Purposes of Use

1. We may add, reduce, or alter any purpose of the use of personal information if, and only if, we reasonably believe that the altered purpose of use is related to the purpose of use before the alteration.
2. Any alteration in the purpose of use shall be made in accordance with the procedures for altering this policy as set forth in Section 11.

Section 5. Personal Information Provided to Third Parties

1. Except for the following cases, we shall not provide any of users’ personal information to any third party without the prior consent of the users. However, this does not apply to cases in which the Personal Information Protection Law and other laws and regulations permit, or require, us to provide such information.
   1. When it is necessary to protect a person's life, body, or property and when it is not possible of impractical to obtain the consent of the user;
   2. When it is particularly necessary to improve public health or promote the sound growth of minors, and when it is impractical to obtain the consent of the user;
   3. When it is a duty to disclose personal information to a government or its agency, national or local, or to a person entrusted by them to perform any public services prescribed by law, and when it might interfere with the execution of the governmental services in question to ask the user’s prior consent; or
   4. When the following matters are announced or made public in advance,
      1. That the purpose of use includes the provision of personal information to third parties;
      2. Items of data provided to third parties;
      3. The means or method of providing the information to third parties;
      4. That we shall stop providing personal information to third parties at the request of the person; and
      5. How users may request us to stop providing personal information to third parties.
2. Notwithstanding the preceding subsection, the recipient of such personal information shall not be a third party in the following cases:
   1. When we consign the handling of personal information in whole or in part to the extent necessary for the achievement of any of the purposes of our services; or
   2. When users’ personal information is transferred as a result of the succession of business due to a merger or other reasons.
3. Users shall, by agreeing to this Privacy Policy, give their prior consent that we provide designated personal information to the third parties listed in Schedule 1. If a user requests us to stop providing his/her personal information to the third party, we may, at our discretion, stop or suspend providing information.

Section 6. Proper Management of Personal Information

1. We shall take reasonable steps and measures that are necessary and appropriate to safely manage personal data to prevent leakage, loss, or damage of personal information we acquire.

Section 7. Disclosure of Personal Information to the User

1. We shall disclose to a user his or her personal information without delay at his or her request, unless such disclosure might be any of the following cases. We shall notify the user without delay of non-disclosure in whole or in part if we so decide.
   1. Where the disclosure might cause any harm to the life, body, property, or other rights or interests of the user or a third party;
   2. Where the disclosure might significantly obstruct the proper operation of our business; or
   3. Where the disclosure would be a violation of the law.
2. Notwithstanding the preceding subsection, we shall not disclose any information in anonymized form, such as historical information, non-personal characteristic information, and other information that cannot identify any individual.

Section 8. Correction and Deletion of Personal Information

1. Users may, through the way we set forth, correct, add, or delete personal information (hereinafter "correction" includes “correction, addition, and/or deletion” unless otherwise stated), or request us to correct personal information, when the user's personal information held by us is or becomes incorrect.
2. We shall, at the user’s request in accordance with the preceding subsection and when we find the request is legitimate, correct his or her personal information without delay.
3. We shall notify the user without delay that we have corrected his or her personal information according to the preceding subsection, or that we have decided not to correct when we decide so.

Section 9. Suspension of Use of Personal Information, etc.

1. The user may request us to suspend the use of or delete his or her personal information (hereinafter “suspension” includes suspension of the use of personal information and deletion of the same unless otherwise stated) on the grounds that his or her personal information has been used in a manner out of the scope of any of the purposes, or that it has been acquired by illegal or improper means. We shall conduct any reasonable investigation on it without delay.
2. We shall suspend any use of the user’s personal information without delay if after investigation we find that the request has a legitimate cause and is right.
3. We shall notify the user without delay that we have suspend the use of his or her personal information in accordance with the preceding subsection, or that we have decided not to.
4. Notwithstanding the preceding subsections, we may take any alternative measure when it is available and sufficient to protect the user’s rights and interests and when the suspension incurs a large amount of costs or is otherwise impractical.
5. In case that we no longer need the use of personal information of a user, such as when he or she withdraws from our services, we shall delete his or her personal information.

Section 10. Publication and Deletion Procedures for Contents

1. Contents published in our services can accidentally have information that can identify any individual, such as his or her appearance and voice. The individual may request for deletion of such information through the contact form stated in Section 12. At the request, we shall conduct the reasonable investigation on it without delay.
2. We shall delete the information without delay if we find that the request has a legitimate cause and is right based on the investigation.
3. We shall notify the individual without delay that we have deleted the information, or that we decided not to.
4. Notwithstanding the preceding subsections, we may take any alternative measure when it is available and sufficient to protect the individual’s rights and interests and when the deletion incurs a large amount of costs or is otherwise impractical.

Section 11. Alterations to Privacy Policy

1. We reserve the right to alter this Privacy Policy at any time without notice to the users when necessary. Any alterations shall be notified on this page, with the update on the "last update" date at the top of this page.
2. Any alterations to this policy shall be effective when it is published on this page.
3. Users shall agree to the altered Privacy Policy by continuing to use our services after the alteration.

Section 12. Contacts and Inquiries

1. Anyone may contact us through the contact form at ( https://www.initium-auditorium.com/contact ).

Schedule 1.

Third Parties with whom we provide users’ personal information	Items of data	Means or method of providing the information
Google Analytics	Browsing information	API provided by Google LLC
Mux	Information on Video Viewing	API provided by Mux, Inc.

The End of This Document.