Original statement is https://osdn.net/docs-ja/Privacy_Policy (Japanese).

Privacy Policy

This document describes our policies of the following OSDN Sites (individually "Site" and collectively "Sites") on the collection, use, and disclosure of users' personal information, and describes the choices available to users regarding how to update and correct their personal information.

OSDN.net
SRAD.jp
osdn.co.jp

We are committed to good privacy practices regarding personal data, and we aim to give the users of our Sites as much rights as possible to control their own personal information including registration information. Under strict control, we safely accumulate and store personal information that we collect or submitted to us, and take appropriate preventive and corrective actions against improper access to, loss, destruction, falsification, and leaking of personal information.

This Privacy Policy applies to all activities or behaviors of our users during the registering and using of the Sites owned by OSDN. Except as set forth within this Privacy Policy and our Terms of Use Agreement, we do not release personal data about our users and visitors without their permission. By proceeding to use the OSDN Services, you consent that we may process the personal data that we collect from you in accordance with this Privacy Policy.

1. The information we gather

We gather the following types of personal information.

Information given to us by users:
In certain areas of the Sites, we may request a user to provide us with certain personal information. For example, it applies to information such as username, social media services, email address, and self introduction provided in order to complete the profile on the registered account. However, for most of the information, beside username, it is left to the user's discretion to register.

We may request the users to provide us with personal information when they post contents (such as source code, release files, articles, journal, photos, comments, or reviews), create a new account, subscribe to any of our mailing lists, or participate in certain services. That could include personal information such as phone number, name, zip code, age, or profession.

Information we collect about users:
When a user uses the Sites, we may automatically collect technical information about the user’s visit including pages the user visited, the order in which they were visited, page interaction information, the type of device the user is using, IP address, operating system, header information and browser software.

Information we receive from other sources:
We may receive information about our users from various business partners including advertising networks. We may work with third parties to collect information that allows us to associate our users with their accounts they have on social media or other websites.

Aggregated data:
We may aggregate the data we collect from our users (including IP addresses, operating system, and browser software types). In the course of aggregating the data, we anonymize and de-identify it so each piece of data cannot be associated with the user. We may disclose Aggregated Data to advertisers to inform them the number of people who have seen and/or clicked through their advertisements.

2. How we use the information we gather

When faced with business necessity to transfer users' personal data to third parties including advertisers and other business partners, we require them to comply with our Privacy Policy. In accordance with data security and privacy laws, we strive to implement measures designed to ensure the security of your personal data. In the event you encounter any third party associated with us, who you feel is improperly collecting or using information about you, please contact us at the contact information provided at the end of the document.

How we use Aggregated Data:
We use Aggregated Data to build higher quality, more useful sites by performing statistical analysis of collective characteristics and behaviors of our users, and by measuring demographics and interests. We may use statistical information based on this data for commercial purposes, such as to sell, rent, or lease to advertisers and other business partners.

How we use personal data:
We may use personal data a user submits for the following purposes.

• To understand a user’s needs and create content that is relevant to the user
• To conduct market research and planning by sending surveys to users
• To improve services, contents, and products
• To provide customer support to users
• To provide users with information about other services we offer　
• With users' consent, to email users about services, information, products and offers from our business partners
• To personalize a Site for the user
• To provide site features appropriate to a visitor's geographical location
• To notify the user of any changes with a Site which may affect the user
• To allow the user to purchase products or engage in activities the user selects
• To keep track of the consents that a user give us to various uses of the user’s personal data
• To protect the security or integrity of the Sites

When we send certain communications such as a news letter to subscribers, we always include a link to the webpage where they can click to "unsubscribe".

User names, email addresses, and information posted by other users may be publicly available on a Site when a user voluntarily and publicly discloses personal data, such as when a user posts personal data in conjunction with content subject to an open source license, uses features to send a message to another user, or as part of a message posted to a public forum. We are not responsible for any consequences which may occur from the use of personal data that a user chooses to submit to public pages.

3. How we share information we gather

We may share your personal data in the following ways:

• Only when in accordance with the following two provisions, we may share your personal data with third party service providers that help us with our business activities such as email marketing, telemarketing, or customer service, as well as business-to-business lead buyers, data aggregation companies, and advertising networks.
  • (i) Use user’s personal data only as necessary to provide these services.
  • (ii)Include provisions to establish safeguard within our contracts, terms of use, and memoranda to protect the confidentiality.
• We may share user’s personal data with open source projects that use OSDN.net. This is for the purpose of conducting smooth open-source-project operation, and open source projects are required to comply with our Terms of Use and Privacy Policy. The followings are the two types of information that will be shared.
  • (i) Mailing lists: Regarding mailing lists managed by an open source project, the administrative rights to the list of personal email address information are granted to the manager of the open source project.
  • (ii) Access analysis: We may use third party service providers to conduct access analysis on webpages managed by open source projects.
• We may share with third parties Aggregated Data compiled from information collected from users of the Sites. Aggregated Data is used as statistics, and no single person can be identified by such compiled information.
• We may share certain data from the Sites with researchers and research organizations for the purpose of supporting academic and scholarly research on open source software.
• We may disclose information submitted by users as we reasonably feel is necessary to protect our systems, servers, networks or business, and/or to resolve security or technical issues.
• We may also disclose your personal data when we believe that disclosure is necessary to protect our rights and safety of users, investigate fraud, respond to a government request, or comply with legal process. We also reserve the right to suspend or terminate the user’s use of the Sites in connection with any suspected illegal or infringing activity or if the user is in violation of our Terms of Use Agreement.
• If OSDN or any of the Sites is involved in a merger, acquisition, or sale, we will notify our users of any changes made regarding personal data.

4. Cookies, web beacons and similar tracking Technologies

On OSDN Sites, there are pages that use technology called "web beacons". It is a technology also known as clear GIF, in which small graphic files are used to track the accesses to certain pages. With this technology, it is possible to track a specific individual, but on our Sites, we do not use it for such purpose to obtain personal data, except that we may use it as a part of the mechanism to make sure that the downloading of contents occurs at a server that is geographically close to the user.

Certain browsers have a "Do Not Track" feature that allows you to tell websites or applications that you do not want to have your online activities tracked. Please note that at this time our Sites generally do not respond to browser "Do Not Track" signals.

We also use cookies on our Sites to provide our users with information that meets their needs. Cookie is a data file that is sent to the browser from a site that a user visited, which could be stored in the user's environment by the browser. It is user's responsibility to turn off cookies or delete existing cookies from the user’s environment. Please note that by opting out of cookies, you may encounter a situation where a part of or the entire OSDN Site may not function properly.

Interest-Based Advertising:
We may also participate in advertising networks that use interest-based advertising methods relying on cookies, web beacons and other tracking technologies. This means that a user may see advertising on our Sites tailored to the user’s browsing behavior, or the user may see our advertising on other websites based on their behavior on our Sites.

Some internet browsers, websites, and mobile devices offer opt-outs for interest-based advertising. For additional information, please refer to the website that you are visiting, your browser and/or your device settings, and our "Policy and Procedures Regarding Advertisement Agents". From the document, you can opt-out of receiving interest-based ads individually from external service providers.

You can also opt-out of interest-based ads from the the links below.

NAI website http://www.networkadvertising.org/choices/
DAA website http://www.aboutads.info/choices/
DDAI (For Japanese users) http://www.ddai.info/optout
Your Online Choice (For EEA users) http://www.youronlinechoices.com/

Access Analysis:
On our Sites, in order to conduct a research on the users’ trends or to deliver the most relevant advertising, we acquire statistical information regarding Site usage by using third party access analysis service. Like the aforementioned interest-based advertising, this access analysis service uses technologies such as cookies. With this access analysis tool, data obtained by advertising network may be statistically processed in conjunction with the user attribute data obtained by advertising networks, and this information does not identify any specific individual and will be treated in a form of anonymous data. It will not be used for any other purposes.

Third party website links & subdomains:
On OSDN Sites, links to third party websites are provided solely as a convenience to the user. When a user uses these links, the user leaves the Sites. Please note that our Privacy Policy do not apply to these third party websites. We do not review and control these third party sites, and are not responsible for any of the third party sites, their content, or their privacy practices. We do not endorse or make any representations about the third party websites and products.

With respect to OSDN.net, we deliver the following services via subdomains (except language subdomains or country subdomains).　

• Web hosting environment for information sharing between developers and end users.
• Downloads of software through third-party mirror providers.

Any personal data a user provides through the use of any third party web contents, software, and services is subject to that third party’s policies governing privacy and security.

5. Security

On our Sites, we encrypt most of the transmission of information, including when users enter personal information on our web forms. We follow generally accepted standards to protect the personally identifiable information submitted to us.

However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee that information will not be accessed, disclosed, altered, or destroyed. It is users' responsibility to protect the security of their login information, and we advise that users do not make any confidential information publicly available through our Sites.

6. Polls & Sweepstakes　

Occasionally, we may conduct sweepstakes, contests, and polls on our Sites in order to better deliver advertisements and contents and to better understand the users' needs.

Participation in these sweepstakes or contests is completely voluntary, and a user who decides to participate may be requested to submit information which typically includes contact information. Any personal data that users submit in connection with these activities will be treated in accordance with this Privacy Policy. However, for certain sweepstakes, we may individually provide additional terms. We may use a third party service providers to conduct these polls or contests. These third party service providers will be prohibited from using our users’ personal data for any other purposes.

7. Social Media

OSDN Sites include widgets provided by generally well-known social media, such as the Facebook "Like" button. Using sign-in services of these social media networks, you may be able to login to OSDN Sites or post contents on social media sites either manually or automatically. Please note that your interactions with these features are subject to privacy policy of the company providing it, and not by this Privacy Policy.

8. Users' Rights

This section describes the rights granted to users regarding their access to personal data they submit, and the choices available to them for updating, correcting, and deleting their personal data.

Access to data:
Upon request, OSDN will provide a user with information about whether we hold, or process on behalf of a third party, any of the user’s personal information. To request this information, contact us at the contact information provided at the end of the document. If the a user's personal data changes, the user may correct, update, or delete the personal data by making the change on the user information page or by contacting us at the contact information provided at the end of the document.

Data Retention:
We retain user’s personal data for as long as the user's account is active or as needed to provide the user OSDN Site Services, or as otherwise required by applicable law or related legal purposes.　 If a user wishes to cancel his/her account or request that we no longer use his/her identifiable personal data, the user can contact us at the contact information provided at the end of the document.

Journals, blogs, forums, mailing lists:
The Sites may offer publicly accessible blogs, journals, community forums, and mailing lists. Users should be aware that any information they provide in these areas may be read, collected, and used by others who access them. To request removal of one’s personal data from these areas, users can contact us at the contact information provided at the end of the document. However, in some cases, we may not be able to completely remove the user’s personal data. This might be the case where the user have added comments to a project discussion or made a contribution to a mailing list, where removing his/her personal data could disrupt the function of the underlying system.　 In these cases, we may comply with the request by anonymizing the data so that it can not be associated with a specific user.

Emails for marketing purposes:
At any time, users can opt-out of receiving email notifications for promotional or marketing purposes. Please note that opting out of these emails will not end our transmission of important information as long as the user’s account exists.

9. Minors

Minors under 18 years of age require the consent from their parent or other legal guardian. Their proceeding to use the OSDN Services shall be deemed that they are given the parental consent. We do not knowingly collect personally identifiable information from minors. If you have reason to believe that a minor has provided Personal Information to our Sites, please contact us. Upon confirming that we possess the minor’s personally identifiable information, we may delete that information from our databases.

10. Special types of personal data:

We do not intentionally collect any personal data that is considered "special" or "sensitive" under the GDPR (General Data Protection Regulation), including racial or ethnic origin, political opinions, religious, biometric, or health data, or data concerning anything to do with a person's sexuality.

11. Applicable law

Our Privacy Policy has been prepared to comply with applicable Japanese law. Users located in the European Economic Area may have additional rights arising under GDPR.

12. Data transfers to third countries

We provide our Sites and related services from Japan and USA. We may outsource the handling of your personal information to a third party service provider located outside of the user’s residential country, and we may share the information. Since it is not possible for users to use our Sites and services without these data transfers, we require their consent to the transfer of their personal data to Japan or countries where the third party service providers are located.

In these cases, the user’s personal information will be subject to personal information protection law that may be different from the law of the user's residential country, and in those areas the user may have less legal rights in relation to the user’s personal information. We treat users' personal data in accordance with the terms of our Privacy Policy expressed in this document.

13. OSDN Supplemental Privacy Policy for California Residents

The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how we handle personal information of California residents and gives California residents certain rights with respect to their personal information.

OSDN is both a “business” and a “service provider” under the CCPA. The following supplemental privacy policy applies to information we collect in our role as a business—this is when we interact directly with you.

When we act as a service provider (for example, by providing our services to another company that you interact with), we follow the instructions of the business that engaged us with respect to how we process your personal information. If you would like more information about how your personal information is processed by other companies, including companies that engage us as a service provider, please contact those companies directly.

This supplemental privacy policy is effective as of January 1, 2020, shall apply only to residents of California, and may be subject to change. The general privacy policy shall continue to apply to the extent that it applies to you as a resident of California. If you are a resident of California, we are required to disclose certain uses and disclosures in a certain format, as well as to inform you of certain rights you may have.

Information We May Collect:
We may collect the following categories of information:

• Identifiers
• Demographic Information
• Internet or other electronic network activity information
• Electronic or similar information

For each category of information, we collect the information from a variety of sources, including directly from you, from your devices, from your social media profiles, and/or from third party providers. We collect the information to provide you with services, protect our customers and ourselves (including the services), and to improve the services. We do not share personal information with Third Parties as the term is defined under the CCPA.

Additional Disclosures:
We do not sell personal information of any individual, including personal information of minors under 16 years of age.

We have disclosed the following categories of personal information for a business purpose in the 12 months prior to this Policy’s last update.

• Identifiers
• Demographic Information
• Internet or other electronic network activity information
• Electronic or similar information
• Inferences drawn from any of the above information.

We have not disclosed any personal information for valuable consideration in the 12 months prior to this Policy’s last update.

Your Rights:
You may have certain rights with respect to your personal information, including:

• The right to access, including the right to know the categories and specific pieces of personal information we collect;
• The right to deletion of your personal information, subject to certain limitations under applicable law;
• The right to request disclosure of information collected;
• The right to disclosure of information disclosed for valuable consideration; and
• The right not to be discriminated against for exercising certain rights under California law.

To exercise these rights, please submit a request by emailing privacy@appirits.com. Please be as specific as possible in relation to the personal information you wish to access. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We will respond to your request within 45 days of receipt, or notify you if we require additional time.

If you would prefer, you may designate an authorized agent to make a request on your behalf.

14. Changes that Could Be Added to this Privacy Policy

We may update a part of or the entire Privacy Policy expressed in this document in the future. If we make any material changes we will notify our users by means of a prominent notice on our Sites.

Note that, by using the OSDN Services, users signify their agreement to this Privacy Policy. If you do not agree to this Policy, please terminate the use of the OSDN Services. Therefore, users are advised to review this Privacy Policy periodically.

15. Contact information

Questions, complaints, request, and other inquiries regarding this Privacy Policy contact us at the address below.

Personal information inquiry and consultation desk
TEL: +81-3-6690-9870 Mon - Fri, 10:00 - 17:00 JST
E-Mail: privacy@appirits.com

last update: 2020/11/27