Definition of Personal Information

APPOS HOLDINGS, personal information is information concerning living individuals as defined by laws concerning the protection of personal information(name, date of birth, other information that allows an individual to be identified). In addition, information that is used in connection with a specific individual, such as E-mail addresses, user IDs, passwords, credit card information and attribute information such as personal interests, family structure and age will also be recognized as such.

Cookies/IP address information

Cookies and IP address information shall not be considered as personal information, as they alone do not allow the individual to be identified. However, in the event that this information is used together with personal information, these shall be defined as personal information as well. In regards to media managed by APPOS HOLDINGS, the purpose and method shall be disclosed in the event that cookies and IP address information are used, regardless of their ability to be used to identify an individual. Furthermore, in cases where the rejection of cookies results in the loss of service, the reason shall be disclosed.

Specifying the purpose of using personal information

In regards to the handling of personal information, APPOS HOLDINGS shall do everything in their power to specify the purpose of use.

Limitations on the use of personal information

APPOS HOLDINGS will not make use of personal information without the express permission of the person concerned, and this use shall not exceed the scope necessary in order to achieve their purpose. In the event that personal information is acquired through consolidation or by other means, APPOS HOLDINGS shall not handle the information in a way that exceeds the agreed Purpose of Use, without the express permission of the person concerned. However, this shall not apply for the following cases.

1. The information is handled outside of its Purpose of Use based on laws and regulations.
2. It is necessary for the enterprise to handle the Person Information outside its Purpose of Use in order to protect the life, body, or property of an individual, and it is difficult to obtain the consent of the person.
3. There is a special need to handle the Personal Information outside its Purpose of Use in order to improve public health and it is difficult to obtain the consent of the person.
4. It is necessary to handle the Personal Information outside its Purpose of Use in order to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining the consent of the person is likely to interfere with the performance of those functions.

Proper Acquisition of Personal Information

APPOS HOLDINGS shall acquire Personal Information through proper means, and must not acquire Personal Information through deception or other wrongful means. Furthermore, they must not acquire information concerning individuals who are minors without the consent of their guardian.

Notice of the Purpose of Use concerning the Acquisition of Personal Information

APPOS HOLDINGS shall disclose the Purpose of Use to the public, prior to acquiring the Personal Information. However, this shall not apply in the following cases.

1. Notifying the person of the Purpose of Use or disclosing this to the public is likely to harm the life, body, property, or other rights or interests of the person or a third party.
2. Notifying the person of the Purpose of Use or disclosing this to the public is likely to harm the rights or legitimate interests of APPOS HOLDINGS.
3. It is necessary to cooperate with a national government organ or a local government in performing the functions prescribed by laws and regulations, and notifying the person of the Purpose of Use or disclosing this to the public is likely to interfere with the performance of those functions.
4. The Purpose of Use is considered to be clear, in light of the circumstance in which the Personal Information was acquired.

Changes to the Purpose of Use of Personal Information

In the event that APPOS HOLDINGS changes its Purpose of Use of Personal Information, the changes must remain related to the Purpose of Use prior to the change and within the scope that is accepted as reasonable. The person concerned must be notified of the changes to the Purpose of Use.

Security measures and Supervision of employees

APPOS HOLDINGS will take the necessary and appropriate measure to ensure the secure management of Personal Information, such as measures to prevent leakage, loss, or damage, and will endeavor to supervise its employees as is appropriate.

Supervision of entrusted persons

If APPOS HOLDINGS entrusts another party with all or part of the handling of Personal Information, it must exercise the necessary and appropriate supervision over the entrusted party, so as to ensure the secure management of the Personal Information with whose handling it entrusts that party.

Restriction on Provision to a Third Party

APPOS HOLDINGS will not provide a third party with Personal Information without in advance obtaining the person’s consent to do so, except in the following cases:

1. The Personal Information is provided to the third party based on laws and regulations.
2. It is necessary to provide the third party with the Personal Information in order to protect the life, body, or property of an individual, and it is difficult to obtain the consent of the person.
3. There is a special need to provide the third party with the Personal Information in order to improve public health or promote healthy child development, and it is difficult to obtain the consent of the person.
4. It is necessary to provide the third party with the Personal Information in order to cooperate with a national government organ, local government, or person entrusted thereby with performing functions prescribed by laws and regulations, and obtaining the consent of the person is likely to interfere with the performance of those functions.
5. In the event that the following matters were published or given notice.
   1. If provision to a third party was included in the Purpose of Use.
   2. Data Items to be provided to a third party.
   3. Means or the manner in which it will be provided to a third party.
   4. It will stop providing Personal Information to a third party at the request of the person. However, the following cases shall not be deemed as third parties as defined above.
      1. If APPOS HOLDINGS entrusts with all or part of the handling of Personal Information within the scope necessary for achieving the Purpose of Use.
      2. If the Personal Information is provided due to a merger or other such circumstances.
      3. If specific business operators have joint use of the Personal Information and the enterprise notifies the person of this in advance as well as notifying the person of the items of the Personal Information of which the specific business operator have joint use, the extent of the joint users, the users’ Purpose of Use, and the name of the business operators responsible for managing the Personal Information, or the enterprise makes the foregoing information readily accessible to the person in advance.

Disclosure, etc. about Personal Information

APPOS HOLDINGS must make the following information about the Personal Information accessible to persons, which includes providing answers without delay as requested by the person.

1. Purpose of Use of Personal Information (However, this excludes cases where it has been established that laws protecting Personal Information do not apply. In the event that it has been decided to not provide an answer, they must notify the person concerned of the reason without delay.)
2. Inquiries regarding Personal Information

Disclosure of Personal Information

APPOS HOLDINGS is requested by a person to disclose the Personal Information, they must disclose the Personal Information without delay, provided, however, that in a case falling under one of the following items, they may choose not to disclose all or part of the Personal Information:

1. If disclosure is likely to harm the life, body, property, or other rights or interests of the person or a third party.
2. If disclosure is likely to seriously interfere with the proper implementation of the business of APPOS HOLDINGS.
3. If disclosure would violate any other law or regulation.

Furthermore, in regards to access logs and information other than Personal Information, they shall not be disclosed by principle.

Corrections, etc. of Personal Information

If APPOS HOLDINGS is requested by a person to correct, add, or delete Personal Information on the grounds that the information is not factual(such a correction, addition, or deletion is referred to as a “Correction, etc.” hereinafter), unless another law or regulation specifies special procedures for such a Correction, etc. the enterprise must undertake the necessary investigations without delay within the scope that this is necessary for achieving the Purpose of Use, and, on the basis of the results, Correct the Personal Information and notify the person concerned.

Discontinuation of Personal Information, etc.

If APPOS HOLDINGS is requested by a person to discontinue using or delete Personal Information on the grounds the Personal Information is being handled outside of the scope disclosed in the Purpose of Use, or the Personal Information was acquired through false or other unlawful means(such an action is referred to hereinafter in this Article as “Discontinuance,etc.”), and there are found to be grounds for the request, the enterprise must discontinuance of the Personal Information without delay and notify the person concerned. However, this does not apply if the discontinuance, etc. of the Personal Information would require a costly expenditure or prove otherwise difficult, and the enterprise takes the necessary alternative measure to protect the rights and interests of the person.

Explanations of Reasons

If APPOS HOLDINGS, despite requests from the principal,

1. If does not notify the person concerned on the Purpose of Use.
2. If all or part of the Personal Information is not disclosed.
3. If the discontinuation of the Personal Information does not come into effect.
4. If the provision of Personal Information to a third party is not discontinued.

If any of the above are decided, they must notify the person concerned and explain the reason.

Contact

Please send any inquiries in regards to APPOS HOLDINGS Privacy Policy to following:

Address : Azuero Business Center, Avenida Perez Chitre, Panama City, Republica de Panama

APPOS HOLDINGS Privacy Policy Management