Privacy Policy

Terms used in this privacy policy

• “SMARTRA”: the SMARTRA system or this system

• “you”: the user of the SMARTRA system

• “we”: T&TIS, INC., The Aqua Enterprise Company or their affiliates

Introduction

There are many ways to use the service, SMARTRA,- for predicting your arrival time, for getting economical goods or a service, for meeting your friend just in time, for getting a timely and special service, for getting a reward and so forth.

As you more provide your information such as your travel information, SMARTRA Report, SMARTRA increasingly accumulates more data to precisely predict a travel time, to provide you with an appropriate, interesting, economical and timely advertisement, to give you a timely, special service and to let you meet your friend just in time. As you more use SMARTRA for your prediction, rendezvous, shopping, travel, guidance or reward, SMARTRA becomes more sophisticated by getting the supports from advertisers. It in turn gives you much more benefits, such as providing you with much more accurate prediction, giving you a much more valuable advertisement, letting you buy much more valuable goods or a service, or letting you exchange your points with a much more valuable reward. It also enables us to improve the SMARTRA system and provide you with a much more user-friendly interface. Hence, it is important for you to provide SMARTRA with your information in order to get better service from the system.

When you use SMARTRA, we would like you to know how we are using the information and how you can protect your privacy. Your privacy is also essential for the system because the system contributes to travelers, including you when you travel, and other stakeholders by using a part of your personal information: e.g. your SMARTRA Report is used for a statistical calculation and a statistic is delivered to them. Regardless of your experience, please take time to learn about our system.

Child

All users who can understand SMARTRA are allowed to use the SMARTRA system. However, we require the children under age 20 to get the permission from their parent or guardian. If they use the system, it is considered that the parent or guardian agrees that he/she has understood this privacy policy and system, that he/she has admitted them to use the system, and that their information is subjected to this privacy policy as adult’s information is subjected.

Information the system gets

The system collects information, e.g. your personal information such as your postal code, gender and age, information on what transportation you used such as the flight number, departure place or departure time, and information on which advertisement you checked most, to provide users with better services.

There are mainly two styles to get your information: one is receiving the information you input on the website of SMARTRA and the other is getting your communication information while you use the system.

  • Information you input: unless you only browse the website of SMARTRA, the system requires you to register for a SMARTRA account. When you register, the system asks for your personal information, such as your name, gender, age, email address, telephone number. It may also ask you to input your credit card number, Social Security number or the like in case the system needs to process your request. The system also recommends that you input your SMARTRA Report for making a contribution to other travelers or stakeholders and for getting the reward.
  • Device Communication Information: the system may collect the information on the service you use and on how you use it, like when you visit a website of our advertiser. This information mainly includes, but is not limited to, software or hardware attributes or IDs, log information, location information, local storage information in user’s terminal, the page you request, cookies and anonymous identifiers.

The typical information we collect includes, but is not limited to, the followings.

  • • User Information: User Registration, User Setting, SMARTRA Report or SMARTRA Setting.
  • • Signage Manager’s Information: Signage Registration or Signage Setting.
  • • Advertiser’s Information: Advertiser Registration or Advertisement Setting.
  • • Benefit and Reward Information: point, prize and lottery information.
  • • Device Communication Information: the information which stems from the communication between the system and your device.

How we use the information we collect

We, T&TIS, INC., The Aqua Enterprise Company and our affiliates, use personal information to provide, maintain, protect and improve the service, to develop a new service or system, and to support you. We use the information to offer you customized content as well: e.g., giving you more relevant prediction information or advertisement.

We use a part of your information for the analysis and prediction of the travelers and other stakeholders. The result of the analysis or prediction is sent to them and supports their travels or business activities.

We aim to help them to have a better travel, rendezvous, shopping, reward or business. Your information is get together, collectively makes a big power and supports them a lot. By building this support system, we help to make a better world and contribute to the society.

When you contact the system, we may record your communication to provide you with more customized service. We may email you by using your email address to inform you about our services: e.g. letting you know about changes or improvements or asking you to explain about your unclear SMARTRA Report.

We exploit the information collected from cookies and other technologies in order to improve our service which results in improving your user experience. For instance, we are able to continuously show you the website written in the language you chose by keeping your language choice. You will be thereafter able to see the advertisement written in the language you prefer without any language selection as well. The system may also use targeted advertisements based on personal information. Advertisers, including companies serving advertisement, may infer that a user who accesses, checks, or clicks a targeted advertisement fulfills a targeting criterion, e.g., retirees over 60 living in a particular area.

We use all the information the system has for making the best analysis and prediction which are used for reporting for internal or external clients. The result of the analysis or prediction is anonymous, so your data is not identified. We also use all the information for our research to improve or develop our system. The person who engages the research complies with this privacy policy and the rules stipulated by us, such as a non-disclosure agreement between the person and us.

When we understand that you are repeatedly sending us inappropriate information or that you have a malicious intention to decrease the functions, quality, contribution or brand image of our service, we delete your information, such as your ID, the information you provided and your points you have had, without your consent and may prohibit you from accessing to the service again. In the case we need to take a further action, we might regrettably have to take the following (a) and (b).

(a) We might ask a police or legal authority to investigate your conduct on suspicion of fraudulent obstruction of business. In this case, we will submit your information to the police or legal authority and
(b) We might publicly disclose a part of your information to prevent any similar case. We might disclose your name, age, gender, nationality and what you have done but will not disclose identifiable data, such as your full address or telephone number.

We must do such actions to keep the system reliable and useful for other good users.

The system may record and process your personal information in plural countries around the globe. We will request your consent in advance when we have a purpose other than those that are described in this privacy policy and use your personal information.

Information you share

The information you provide, except for the identifiable personal data such as your full ID, TEL, FAX or address is used for the analysis or prediction so is shared with other users. However, the users can only get the result of the analysis or prediction, anonymous data. It is noted that a part of information which is not personal information but is provided by you, such as transportation or check point information you input, is disclosed by the SMARTRA system and is used also by other users.

When you got a reward, such as wining a prize at a lottery or getting goods or a service, by using the points you have earned, we may disclose a part of your personal information, such as your mane, age, and gender, in order to let other users know who won the prize or got the goods or service. But we don’t disclose identifiable personal data such as your full address, ID, password, and phone number.

When you input pieces of your information to meet your friend, relatives, or other stakeholders such as a sales representative just in time, the information, such as your name or nick name, travel situation, and expected arrival time, will be subjected to the public. A signage, Rendezvous Display, at the rendezvous point you select shows the information to the public so that the public, including your meeting partner(s), can learn your travel situation and expected arrival time. We recommend that you input your nick name, instead of your real name, when you provide your information for that rendezvous service.

When you opt to notify of the said information the sales representative who works for the vendor of advertised goods or a service, your data such as your name or nick name, email address, travel situation, and predicted travel time will be given to the representative.

Access to and Revision of your personal data

You can access and change your personal information while you use SMARTRA. The website of the SMARTRA has a button to open a page on which you can change, delete or add your personal information. We reject requests to change to dishonest data, unreal data or risky data such as virus data. We work hard to keep the system in a good condition by protecting information from accidental or intentional deterioration. Because of that, when you change your information at our system, we may not modify the copy of the information in our backup servers at the same time.

Information we share

We do not share personal information with any outsider. But we may exceptionally share it:

  • • at the time when we get your consent or
  • • at the time when we consider that access, use, record or disclosure of your data is seemed to be required to meet any law, regulation, rule and governmental request, to cooperate with an inspector for investigation of any violation, crime or incident, to prevent or detect any fraud or security attack, and to defend the SMARTRA system, users, other stakeholders and the public from any threat or attack.

We may also require our affiliates, trusted corporations or reliable individuals to comply with our instructions, NDA, guideline, rules and this privacy policy and send your personal information to them.

We may share unidentifiable, collective information, such as a statistic or result of the analysis or prediction, publicly and with our partners, such as signage managers, facility managers, advertisers or linked sites. For instance, we may share the information publicly to show the trends of the general use of SMARTRA. If one of us is involved in an M&A or asset sale, we will keep the confidentiality of your personal information and notify you before your personal information is transferred to the third party.

Information Security
We defend your information and the data of the SMARTRA system by preventing unauthorized access to, change of, output of, or delete of the information we have.

We, in addition, provide strict access to personal information for our employees, affiliates, contractors and agents who have to know it in order to process it for us, and who are subject to our none-disclosure agreement and the like and may be penalized if they fail to obey these rules.

Application

This privacy policy shall apply to the SMARTRA service. However, it excludes the service which works as a part of the SMARTRA service and has a different privacy policy. It does not apply to services offered by other entities, including goods, services or sites which may be shown to you as a portion of the SMARTRA service or which may be linked from the SMARTRA service. It does not apply to the information practices of other entities that advertise the SMARTRA service and that may exploit cookies and other technologies to provide related advertisements.

Change

We will review and change this privacy policy as we need. We will notify you about significant changes by sending a mail to your email address or by posting a notice on our web site.

Enforcement: April 15th, 2014

The Aqua Enterprise Company The Aqua Enterprise Company
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