Privacy Policy

GENERAL Inc. (GNL) takes privacy issues seriously and has prepared this Privacy Policy to inform You how GNL collects, uses, and discloses information, including Personal Information as defined below, in connection with Your use of the "Services," which consist of (i) GNL's website (the "Website"), and (ii) all services and content provided by GNL relating to this Website.

Your use of this Website constitutes Your acceptance of the terms and conditions of this Privacy Policy. If You do not agree to the terms and conditions of this Privacy Policy, do not use this Website. By providing Your Personal Information (as defined below) to GNL, You acknowledge that such Personal Information may be used and disclosed in accordance with this Privacy Policy.

1. Personal Information

"Personal Information" is information that identifies You as an individual or relates to an identifiable person. GNL collects the following Personal Information about You in connection with Your registration for and use of the Services:

• First and last names
• Address
• E-mail address
• Phone number
• Fax number

2. Other Information

"Other Information" is any information that does not reveal Your identity nor directly relate to any individual. In addition to Personal Information, GNL also collects (both actively and passively) Other Information listed below in connection with Your use of the Services. GNL may use Other Information for any purposes, provided that, if GNL is required to treat Other Information as Personal Information under applicable laws, GNL may use it for the same purposes for which GNL uses and discloses Personal Information as described in this Privacy Policy. Other Information that we may collect about Your use of the Services includes:

• Usage Data: GNL may collect data and statistics about Your usage, such as when, how, and how long You use the Services.
• Device Data: GNL may collect the IP address assigned to the device that You use or access the Services.

3. Aggregated Personal Information

Aggregated Personal Information is Personal Information and Other Information that is compiled in an aggregated fashion and does not identify You as an individual or any other user of the Services. For example, GNL may aggregate Personal Information and Other Information to estimate the percentage of users visiting from a specific country or region. GNL may use and disclose such Aggregated Personal Information for legitimate purposes. For example, GNL may share such Aggregated Personal Information with its affiliated companies, agents, and business partners for their marketing and other business purposes, and disclose user statistics in the form of Aggregated Personal Information in order to describe GNL’s Services to current and prospective business partners as well as other third parties for legitimate purposes.

4. How We Use Your Personal Information

Without limitation to the provisions of Section 3, GNL may use Your Personal and Other Information without notice to You for the following purposes:

• To provide You with the Services, including responding to Your inquiries and fulfilling Your requests
• To conduct normal company business, such as performing data analysis and analytics, developing new products and services, and providing, maintaining, developing, and enhancing the Services

5. Sharing Your Personal Information with Third Parties

GNL is not in the business of selling Your Personal Information to third parties. However, under some circumstances, GNL may share Your Personal Information with third parties without notice to You, including for the purposes set forth in Section 4 and under the circumstances set forth below and for other legitimate purposes:

• GNL’s subsidiaries and affiliated companies

GNL may share Your Personal Information with its subsidiaries and affiliated companies. GNL is solely responsible for the management of such shared Personal Information.

• Regulatory authorities and law enforcement agencies

When GNL believes it necessary or appropriate: (a) under applicable laws, including laws outside Your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and government authorities, including public and government authorities outside Your country of residence; (d) to enforce GNL’s terms and conditions; (e) to protect GNL’s business operations or those of any of GNL’s affiliated companies; (f) to protect GNL’s rights, privacy, safety, or property, or those of GNL’s affiliated companies, You or others; and (g) to allow GNL to pursue available remedies or contain damage that GNL may sustain.

• Other third parties

Third parties arising in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition, directly or indirectly, of all or any portion of GNL’s businesses, assets, or stock (including as a result of a bankruptcy or similar proceedings)

6. Security

GNL uses reasonable organizational, technical, and administrative means to protect Personal Information within its organization. However, no data transmission or storage system can be 100% secure. If You have reason to believe that Your interaction with GNL is no longer secure (for example, if You feel that the security of Your account has been compromised), notify GNL immediately in accordance with the "Contact GNL" section below.

7. Choices and Access

As outlined in this Privacy Policy, You can choose at any time to not provide Your Personal Information to GNL through the Services. However, doing so may prevent You from obtaining some information through the Services.

• Receiving electronic communications from GNL

If You no longer wish to receive marketing-related e-mails from us, You may opt out by following the instructions provided in such e-mails.

• GNL’s sharing of Your Personal Information with its affiliated companies for their direct marketing purposes

If You do not want GNL to share Your Personal Information with its affiliated companies for their direct marketing purposes, You may opt out by following the instructions provided in the applicable e-mails.

If You opt out of receiving any of the foregoing communications through the means outlined above, GNL will try to accommodate Your request as soon as reasonably practicable. Note that GNL may continue to send You some types of message, such as administrative or Services-related messages.

8. Review or Update Your Personal Information

If You wish to access, modify, or update the Personal Information You have provided to GNL, You may do so by following the instructions provided in the "Contact GNL" section below.

If You have any questions regarding GNL’s handling of the personal information You have provided to GNL, contact GNL using the inquiry form provided from the link below.

State Your request clearly in the form. For Your protection, GNL processes a request regarding only the Personal Information associated with an e-mail address from which You send a completed form to GNL, and GNL may need to verify Your identity before processing Your request. GNL will try to respond to Your request as soon as reasonably practicable.

Note that GNL may need to retain some information for record-keeping purposes, and that some residual information will remain in GNL’s databases and other records, which will not be removed.

• Inquiry Form (Global Site)

9. Retention of Your Personal Information

GNL will retain your Personal Information for the period necessary to serve the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

10. Use of Services by Minors

The Services are not intended for children under the age of 13, and GNL requests that they not provide Personal Information through the Services. If You are under 13, do not provide GNL with any Personal Information about you. If You have reason to believe that a child under the age of 13 has provided Personal Information to GNL through the Services, contact us and GNL will delete that information from its databases.

11. Transfer of Personal Information

The Services are managed and operated by GNL in Japan. Your Personal Information is collected, stored, and processed in Japan. Your use of the Services constitutes Your consent for us to transfer Your Personal information to countries outside of Your country of residence that may have data protection laws and regulations that are different from those of Your country of residence. Under some circumstances, courts, law enforcement agencies, or regulatory authorities in countries outside of Your country of residence may access Your Personal Information.

12. Sensitive Information

DO NOT send, disclose, or otherwise make available to GNL any sensitive Personal Information about You, such as Your social security number and information regarding Your racial or ethnic background; political opinion, religion, or other beliefs; health, biometric or genetic characteristics; and criminal records, through the Services or any other means.

13. Cookies

A cookie is a piece of data that a website can send to your browser and is stored in your computer. It does not store any Personal Information and is used to improve the functionality of a website and anonymously track user visits to the website, enabling the site operator to improve the overall user experience on the website. We do not use information collected from cookies based on your location, IP address, Internet service provider, company, or other identifiable data. We may, for example, track the total number of visitors to a specific page on this Website, record where they come from, and what keywords they enter into a search engine to find this Website.

For further information about cookies, how we use them, and how they can be disabled, see our Cookie Policy.

Cookie Policy

14. Changes to Privacy Policy

GNL reserves the right to change, modify, or update this Privacy Policy at any time. The "LAST UPDATED" legend at the bottom of this page indicates when this Privacy Policy was last updated. Your continued use of or access to the Services following the posting of any changes constitutes Your acceptance of such changes.

15. Contact GNL

If you have any questions regarding GNL’s handling of the Personal Information You have provided to GNL, contact GNL using the inquiry form provided from the link below.

When you contact us by e-mail, do not include any sensitive information in Your e-mail, as e-mail communication is not always secure.

• Inquiry Form (Global Site)

LAST UPDATED: May 2018