Hands Associates collects personal information when users interact with its products and services. It uses this information to provide and improve its offerings, for marketing purposes, and to notify users of important matters. The company shares limited personal information with partners but does not provide it to third parties without consent. Hands Associates uses physical, electronic, and procedural safeguards to protect personal information in its control.

1. Privacy Policy
Hands Associates , Ltd. (“Hands Associates”) may retain your Personal Information (as defined
in Article 2, Paragraph 1 below, hereinafter the same) that we receive through our website and
services, in order to provide stably or newly develop our products and services. Hands
Associates acknowledges the significance of protecting the Personal Information, handles the
Personal Information in accordance with the Privacy Policy set out below, and ensures
protection thereof.
Article 1. Information Acquisition
Hands Associates acquires your Personal Information, in a lawful and fair manner, when you
use Hands Associates products or services, post as a guest any copyright protected contents
on the Hands Associates blog site or make registrations with Hands Associates in order to enter
into promotions or sweepstakes. Hands Associates may combine your Personal Information
with information which we obtain from our business partners or other companies in a lawful and
fair manner.
Article 2. Scope of Personal Information
1. “Personal Information” means information which Hands Associates acquires pursuant to the
preceding Article and controls and by one or more of which Hands Associates is able to identify
a certain client. Personal Information includes the followings: (i) Your name, contact information
(email address, address, telephone number) and credit card information; (ii) Other information
about you registered on an optional basis, including your date of birth, place of birth, your
mother’s maiden name, sex, postal code, background, user names for instant messaging
services (such as ICQ, AIM, Yahoo and MSN), associate codes for U.S. Amazon.com and its
subsidiaries, occupation, job type and hobbies; (iii) Information relating to transactions between
you and any corporation or individual which is engaged in advertising, promotional or sales
activities or customer services jointly with Hands Associates(“Partner”); (iv) Information which
exists on Hands Associates server or which Hands Associates automatically receives and
records, including your IP address, cookies, web beacons, script and the pages you viewed
sent from your browser
2. Articles posted on Hands Associates blog site are not be deemed as “Personal Information”
or as Personal Information covered by this Privacy Policy.
3. This Privacy Policy does not apply to the practices of companies that Hands Associates does
not own or control or to people that Hands Associates does not employ or manage.
Article 3. Use of Personal Information
1. General Provisions Hands Associates uses your Personal Information for the following
purposes: (i) Provision of products, services and related information; (ii) Billing; (iii) Identification
and authentication of users; (iv) Marketing, sales and advertising activities carried out
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2. individually or jointly with any Partner; (v) Improvement in Hands Associates website and
services; and (vi) Notification of other important matters and research for products and services
development
2. IP Address
Hands Associates receives IP address information from all users which is automatically sent
from each browser to its web pages. Your IP address is stored in Hands Associates user
registration data base upon your registration with Six Apart. IP addresses are used for the
following purposes:
(i) To diagnose service or technology problems reported by our users or engineers that are
associated with the IP addresses controlled by a specific web company or ISP (internet service
provider);
(ii) To place special advertisements based on information concerning any geographical regions
or other information derived from the IP addresses;
(iii) To make reports to the advertisers on the information obtained from the IP addresses;
(iv) To estimate the number of users of Hands Associates from specific geographical regions or
category; and
(v) To determine which users have access privileges to certain content or services
3. Cookies
(1) A “cookie” is a small amount of data, which may include an anonymous unique
authentication code that is sent to your browser from computers on which you view websites
and stored on your computer’s hard drive. You can accept all cookies, reject all cookies or
receive notice when a cookie is set depending on your browser configuration. If you reject all
cookies, you may not be able to use Hands Associates products and services that require you
to log in to your account. However, in many cases Hands Associates products and services do
not require you accept cookies.
(2) Hands Associates uses its own cookies for the following purposes:
(i) To access to your information when you log in;
(ii) To record and keep track of preferences you specify while you are using Hands Associates
services;
(iii) To indicate on Hands Associates web pages the most suitable banner advertisement based
on your interests and actions;
(iv) To estimate and research Hands Associates total audience size and traffic;
(v) To conduct researches to improve Hands Associates contents and services; and
(vi) To require you to re-enter your password after a certain period of time has elapsed to
protect you against others accidentally accessing your account contents
(3) Hands Associates allows any advertising agency to set and access cookies on your
computer. Such agency shall use its own cookies in accordance with its own privacy policy.
Neither the advertiser nor other advertising agency may access Hands Associates cookies.
4. Web Beacon
A “web beacon” is an electronic file that signals when a web page, an advertisement, a video or
other types of content, an email or a newsletter has been viewed. Hands Associates uses web
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3. beacons on its or third party’s website, or in its services and products, for the following
purposes:
(i) To count visitors to websites;
(ii) To recognize and access cookies;
(iii) To record page view information;
(vi) To record the internet protocol address of the computer that downloads a web beacon;
(v) To record the type of browser used to view a page where a web beacon is placed;
(vi) To track the delivery, viewing and responses to emails and newsletters;
(vii) To estimate and research our total audience size and traffic;
(viii) To conduct research to improve Hands Associates websites, services and products
5. Script
A “script” is a short section of computer code included in a web page or other content that can
be used to set and access a cookie on your computer’s hard drive and to record your activity
on a website. Hands Associates uses scripts on its or any third party’s websites or in its
services and products, for the following purposes:
(i) To track the performance of advertising campaigns;
(ii) To identify sources of traffic to Hands Associates websites, services and products;
(iii) To count the number of “clicks” on a link in a web page, advertisement, email or newsletter;
(iv) To follow the distribution of content;
(v) To measure patterns of activity on Hands Associates websites, services and products such
as usage by date, time and geographic location;
(vi) To estimate and research our total audience size and traffic; and
(vii) To conduct research to improve Hands Associates websites, services and products
Article 4. Information Disclosure and Provision
1. When you post a message, your ID with Hands Associates or alias that you are posting under
may be disclosed to other users. In addition, when you post a message on Hands Associates
blog sites, you may possibly post a message which may include personally identifiable
information about you. If you post Personal Information online that is accessible to the public,
you may receive unsolicited messages from other parties in return.
2. Hands Associates does not provide your Personal Information to any third party without your
consent. However, we may provide it to a third party when:
(i) Hands Associates provides the Personal Information, including your name, contact
information (email address, address, telephone number), etc. by way of electronic transmission
in accordance with Hands Associates Information Control Regulation and other policies
concerning the handling of the Personal Information, to our reliable Partners that conduct
businesses together with Hands Associatesin order to carry out advertising, promotional or
sales activities or customer services, by executing confidentiality agreements with such
Partners;
(ii) Hands Associates provides the Personal Information, for entrusting the administration
thereof, to any reliable corporation or individual by executing a confidentiality agreement;
(iii) Hands Associates is required to provide or disclose such Personal Information by any order
or judgment issued by a court or other public authority, or otherwise necessary for performance
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4. of obligations under laws and regulations;
(iv) Hands Associates takes actions necessary for protecting itself from damage claims and
other legal actions, by exercising its legal rights or putting up defenses;
(v) Hands Associates conducts research, adopts preventive measures and takes necessary
actions if there exists a possibility of illegal acts, suspected fraud or bodily injury or death,
breach of Hands Associates service conditions or if it is legally required
3. If Hands Associates becomes subject to acquisition or other transaction which accompanies
transfer of a part or all of Hands Associates assets, your Personal Information will be
transferred. In such case, Hands Associates will inform you to that effect before your Personal
Information is transferred to and becomes subject to the privacy policy of any third party.
4. You may request suspension of provision of such Personal Information to any third party
Article 5. Setting, Edit and Deletion of Your Account Information
You may refer to and edit your own account information at any time. Hands Associates is
entitled to dispatch to you specific information relating to Hands Associates services, such as
announcements concerning the services, communication required for the administrative
purpose and news from Hands Associates(“Dispatched Information”). The Dispatched
Information is deemed as part of the account with Hands Associates and the receipt thereof
may not be rejected. For a part of services, you may delete your account by visiting the
applicable account deletion page; however, please note that your identification, billing and
contact information remains in our records for a period necessary for our business reasons.
Article 6. Disclosure, Correction, Suspension of Use and Deletion of Personal
Information
As for disclosure, correction, suspension of use, deletion and other procedures concerning the
Personal Information owned by Six Apart, please contact us by following a certain method
prescribed by Six Apart. We will respond to the request as soon as practicable upon your
notification.
Article 7. Confidentiality and Safety Control
1. Only limited employees who are deemed to be in need of access to your Personal
Information in order to provide you with the products and services may have access to your
Personal Information. We control your Personal Information appropriately by appointing a
control manager.
2. Hands Associates uses physical, electronic, and procedural safeguards to protect your
Personal Information. Your account information is password-protected. In certain procedures,
Hands Associates uses industry-standard SSL-encryption to enhance security for data
transmissions.
3. Hands Associates complies with laws, ordinances and rules relating to the Personal
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5. Information and ensures the protection and appropriate handling of the Personal Information.
4. Hands Associate s destroys Personal Information by (i) shredding or tearing up, if such
Personal Information is recorded in written form or in a CD-ROM or other physical recording
media, or (ii) deleting, if such Personal Information is in an electronic form.
Article 8. Modification to Privacy Policy
Hands Associates is entitled to modify this Privacy Policy. If Hands Associate smodifies the
Personal Information handling procedures in a material respect, we will notify you to that effect
by sending notice to the primary email address designated in your account with Hands
Associates or by posting such notice on Hands Associates site.
Last updated on 7October, 2012
Copyright © 2011 Hands Associates Ltd. All rights reserved.
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