1. About this informative data policy (hereinafter referred to as "Policy")

fluct. Inc. (hereinafter referred to as "fluct") provides a service called "GOLDSPOT" which delivers ads upon requests from media including websites on internet. The Policy puts rules around data regarding internet users (hereinafter referred to as "Users") collected and utilized for ad delivery through GOLDSPOT.
fluct has established the "Privacy Policy" as its basic policy for personal information protection throughout all the services fluct provides. The privacy policy is applied when services are provided along with the Policy. To the extent of any conflict, the Policy prevails over the privacy policy, except for cases where personal information defined by personal information protection law is concerned.

2. User information fluct collects and collection methods

(1) User information fluct collects

In the Policy, "user information" refers to information about individuals that fluct collects based on the Policy, among information generated and accumulated regarding users or terminals in users' terminals including smartphones, personal computers, etc.

fluct collects the following user information with GOLDSPOT. User information does not include any information that identify individual users.

History information (utilization environment and area, published ad data, published ad click information, information about period of time of browsing, clicks, etc., information about OS and browser)

Cookie information (Cookie is a technology to identify browsers. Cookie function can be stopped by changing web browser setting.)

(2) Collection methods

User information is collected automatically when an ad delivered through GOLDSPOT is displayed, and stored in the ad delivery system used by GOLDSPOT.

3. Purpose of utilization

fluct uses user information for the following purposes.

(1) Delivery and provision of ads and contents
(2) To optimize ads fluct displays, and to measure the effect of such ads
(3) Improvement of services, development of new services, and research and development
(4) To create statistical data regarding services

4. Provision to third parties

fluct may provide user information to third parties, provided that they use that information within the purpose of utilization, they comply with laws and regulations and handle appropriately, and do not identify specific individuals.

5. Opt-out

If a user prefers not to receive the delivery of ads with Cookies in ad delivery through GOLDSPOT, the user can stop the delivery with Cookie by following fluct's prescribed procedures to perform opt-out. For information about opt-out, please visit here.

6. Retention period

Cookie information that fluct acquires is retained for up to 2 years from the time that a user last viewed an ad.

7. Handling of personal information

For information regarding the handling of personal information in fluct, please visit here.

8. Inquiry Desk

For comments, questions, complaints, and other inquiries regarding the handling of user information, please contact the following inquiry desk. Please note that fluct cannot receive inquiries from visitors or by phone.

Address: Toranomon Hills Station Tower 36F, 2-6-1 Toranomon, Minato-ku, Tokyo, 105-5536
fluct, Inc. Personal Information Inquiry Desk
Custodian of personal information: Masaki Matsumoto
E-mail：privacy@fluct.jp

9. Procedures for changing Policy

fluct shall review the operation status regarding handling of user information properly, make efforts for continuous improvement, and may change the Policy as necessary. fluct will notify the customers of such change through the prescribed procedure.

Information about GOLDSPOT Service

Our GOLDSPOT is a third-party ad serving service, which means when a user views a website, we, not the publisher, serve an ad to the user’s browser. We take users’ privacy very seriously and thus we provide information we acquire. When we serve ads using GOLDSPOT, we collect following information;

Cookie

We use functionality Cookie to distinguish you from other users. This Cookie allows us to recognize you when you see the same ad. We do not use Cookies for targeting. The Cookie we use expires in 2years. To opt-out of the Cookie we use, please click here.

We appropriately handle above-stated information in accordance with our internal regulations.

Inquiries

If you have questions, comments, or concerns related to this Information, please contact us at privacy@fluct.jp