Clear Inc. (the "Company") sets forth this Privacy Policy (this "Policy") with regard to the treatment of user information, including but not limited to personal information, in the course of the performance of Service provided by the Company (the "Service"), as follows:

1 User Information to be Collected and Method of Collection

For the purposes of this Policy, "User Information" means information identifying users, the user’s history of actions in the Service and other information created or accumulated in relation to users or their devices, that is collected by the Company pursuant to this Policy.

The User Information that the Company may collect in the course of the Service is as follows, depending on the method of collection.

(1) Information provided by the user

The information that may be provided by the user for or through the use of the Service is as follows:
・ name, date of birth, sex and other profile information;
・ e-mail address, telephone number, address and other contact information;
・ inquiries, complaints or other communications;and
・ credit card information, bank account information, e-money information and other information regarding payment method.

(2) Information provided from another service, based on the user's permission for the Service to associate with such a service in relation to the user's use of the Service

If the user permits the Service to associate with other services such as social networking services ("Outside Service") in relation to the user's use of the Service, the Company may collect the following information from the Outside Services in accordance with the conditions agreed by the user at the time of such permission:

・ ID used by the user for the Outside Service; and
・ other information for which the user, in the privacy settings in the Outside Service, permits the disclosure to its associated services.

(3) Information automatically collected by the Company in the course of the user's use of the Service

The Company may collect information regarding access to or use of the Service, which includes the following:

・ referer
・ IP address
・ information regarding server access logs
・ cookies, ADID, IDFA and other identifiers

(4) Information collected by the Company with the consent respectively given by the user in the course of the user's use of the Service

If the user respectively gives the consent in the manner set forth in Section 3.1, the Company may collect the following information from the device used by the user:

・ location information

2 Purpose of Use

Specific purposes of use of the User Information for the provision of the Service are as follows:

(1) provision, maintenance, protection and improvement of the Service, including but not limited to acceptance of registration for the Service, identification, record of user settings and payment of use fees that are related to the Service;
(2) measurement of traffic and actions of the user;
(3) distribution, display and measuring effect of advertisements;
(4) guidance and response to inquiries relating to the Service;
(5) addressing a violation of rules, regulations or policies of the Company relating to the Service (the "Rules");
(6) notice of modification to the Rules or related matters;
(7) business activities concerning the sale of products or services, shipping and payment;
(8) marketing, promotions (through e-mail or other forms of direct mail) and newsletters relating to the Service;
(9) running promotional campaigns related to the Service, including but not limited to notifications of prize draws and delivery of prizes;
(10) holding seminars and events;
(11) point schemes run as part of the Service and provision of services related to such point schemes;
(12) to simplify registration procedures for other services provided by the Company;
(13) improving the Company’s products or services;
(14) to perform activities outsourced by the Company, where User Information is necessary for the performance of such activity; and
(15) to exercise rights or perform duties arising from contractual agreement or law.

When an inquiry is made by phone, the call may be recorded for the purposes of use above or the training of phone operators. In addition, the recorded call may be used in subsequent communications, to provide support, or in the provision of materials to persons making inquiries or visiting the Company.

The Company will only use User Information so far as it is reasonably necessary to fulfil the purpose of use communicated to the user at the time of receiving such information. If it becomes necessary to use the User Information for any other purpose, the Company will inform the user in advance.

3 Method of Notice, Publication and Consent; Method of Requiring Discontinuance of Use

3.1 The user's consent must be obtained before collecting the following User Information:

(1) location information

4 Outside Transmissions; Provision to Third Parties; Information Collection Modules

4.1 This website may save cookies, which are small text files that are used to store pieces of information, in the user’s devices and thereby accumulate and use User Information. Cookies will not be used to view confidential information or change the user’s computer settings.

4.2 The Company uses information collection modules incorporated into the Service to analyze access to and usage of the Service. Thus, the Company provides the User Information to the providers (including but not limited to those outside Japan) of such information collection modules.

5 Provision of Personal Information to Third Parties

The Company shall not provide to any third party (including the same outside Japan) personal information contained in the User Information without the prior consent of the user, except where such provision is required due to any of the following circumstances:

(1) The Company authorizes such third party to handle the personal information in whole or in part to the extent necessary to accomplish the purpose of use;
(2) The personal information is provided through a business transfer by way of merger or other similar transactions;
(3) The personal information is provided to an affiliated party or a provider of an information collection module pursuant to Section 4 hereof;
(4) The Company is required to cooperate with state or local governmental organizations or their agents to perform their duties or obligations pursuant to applicable laws and regulations, and such performance is likely to be precluded if the consent of the user must be obtained; and
(5) In addition to the foregoing, the Company is entitled to provide information pursuant to the Act on the Protection of Personal Information (the "Act") or other applicable laws and regulations.

6 Credit card information used in online transactions

For transactions settled by credit card, the Company will carry out credit card checks using the payment agency GMO Payment Gateway Inc. These checks are performed to settle payments for goods or services and to verify bank account numbers and credit card validity. The Company will not retain or store any information transmitted to GMO Payment Gateway Inc.

7 Voluntary provision of User Information

The provision of User Information shall be at the discretion of the user. However, as such information may be required to perform the Service, the Company cannot be held liable for any loss, damage or other undesirable consequence arising from the provision of false, incomplete or inaccurate information, or from the non-provision of such information (including measures for the deletion of User Information). Such consequences include, but are not limited to, the following: disruption of the Service; incomplete performance or non-performance of the Service, including non-delivery of goods; non-delivery of important notifications; and cases where the user is required to carry out certain procedures in place of the Company. In addition, the Company may be unable to respond to user inquiries due to the non-provision of User Information.

8 Outsourced service providers

The Company may provide User Information to outsourced service providers, so far as such information is necessary to perform the duties entrusted. These duties include shipping, payment and credit procedures related to online sales; the provision of after-sales service; notifications concerning new products and services; and other business activities related to the Service. All outsourced service providers will be required to sign user information protection agreements, and the Company will take all necessary and appropriate measures to ensure compliance with these agreements.

Note 1) The Company outsources to the following service providers: manufacturers that handle direct shipping from breweries; couriers delivering the Company's products; payment agencies; companies printing and shipping address labels for invoices; credit card companies and financial institutions; payment agencies; personal credit information agencies; and asset recovery agencies.

9 Security measures

In the course of handling User Information, the Company will take all proper measures to prevent the external leakage of such information. Furthermore, the Company will implement safety measures at a reasonably appropriate level to protect User Information from risks such as unauthorized access, loss, data corruption and tampering.

Note 2) This website uses a payment system secured with Secure Socket Layer (SSL) technology to protect User Information.

Note 3) User Information that may be used to identify an individual is password protected.

10 Access logs

When a user accesses this website, the Company records basic operational information in the form of an access log. This information is gathered to improve site functionality, determine the cause of any operational problems, gather statistics and conduct analyses on usage. This information will not be used for any purpose other than the aforementioned.

11 Third party advertisements

Third party vendors, including Google, display the Company’s advertisements on numerous sites across the internet. These vendors use cookies to serve advertisements based on the user's prior visits to this website.

Users can turn off Google advertising cookies by visiting the Google Ads opt out page. In addition, users can turn off third party advertising cookies by visiting the Network Advertising Initiative opt out page.

We provide non-personally identifiable information to Criteo, Inc., a service that delivers personalized advertising emails and other advertisements to users who visit our services (websites, apps, email newsletters). For more information about Criteo and how to opt out, please click here.

12 Links to third party websites

This website may contain links to websites run by third parties. The Company is not responsible for any collection of user information by third party websites or services accessible through such links. When leaving this website, we encourage you to read the privacy notice of every other website you visit.

13 Disclosure of Personal Information

Upon request from the user to disclose its personal information under the Act, the Company shall, without delay, disclose to the user such information (or, in the event of non-existence of such personal information, notify the user to that effect) after confirming that the request is genuinely made by the user themselves, to the extent required to do so under the Act and other applicable laws and regulations.

14 Correction and Suspension of Use of Personal Information

14.1 If the Company is required pursuant to the provisions of the Act by the user to (1) correct the content of personal information due to the reason that such information is false, or (2) suspend use of personal information due to the reason that such information is being handled beyond the scope of the purpose of the use previously made public, or has been collected in a fraudulent or otherwise illicit manner, then the Company shall, without delay after confirming that the request is made by the user itself, conduct an appropriate investigation and based upon the results thereof, correct the content or suspend the use of such personal information, and notify the party to that effect. In cases where the Company decides not to make such correction or suspension of the use, the Company shall notify the user to that effect.

14.2 In the event that the Company is required by the user to delete its personal information and has determined that it is necessary to accept such request, the Company shall, after confirming that the request is made by the user itself, delete such personal information and notify the party to that effect.

14.3 Should the Company not be obligated to correct, or suspend use of, information under the Act and other applicable laws and regulations, Sections 8.1 and 8.2 shall not apply.

15 Inquiries

Any suggestions, questions, complaints, or other inquiries on the handling of the User Information must be submitted to:

Clear Inc.
Ryuji Ikoma
2-4-3 Shibuya, Shibuya-ku, Tokyo, Japan

16 Procedure to Amend this Privacy Policy

The Company may amend this Privacy Policy as necessary; provided, however, that in the event of an amendment to this Privacy Policy that legally requires the consent thereto of the users, this Privacy Policy after the amendment shall be applied only to the users that have given the consent in the manner specified by the Company. In the event of any amendment to this Privacy Policy, the Company shall inform the effective time and content of the amended Privacy Policy by posting on the website of the Company or other appropriate way, or notify the user of the same.

This Policy shall be executed in the Japanese language. Japanese shall be the governing language and any translation of this Policy into any other language is for convenience of reference only and shall not bind the parties hereto.

Prescribed on 01/29/2021