Privacy Policy

Article 1 (Personal Information)

“Personal Information” refers to information as defined in the Act on the Protection of Personal Information of Japan (Act No. 57 of May 30, 2003). It means any information that can identify a specific living individual, including but not limited to name, date of birth, or other descriptive details, as well as codes that can identify an individual.

Article 2 (Acquisition and Use of Personal Information)

We may collect and use personal information of users of our services (“Users”) for the following purposes. In cases where personal information is used beyond these purposes, we will obtain prior written consent from the relevant User:

• To provide and operate our services;
• To improve and enhance the services, and to develop new ones;
• To inform Users of updates, new features, campaigns, and related services via emails, flyers, and direct mail;
• To notify Users of system maintenance or important service-related announcements;
• To respond to inquiries and verify user identity;
• To provide usage reports;
• To request participation in surveys or events, and to report related results;
• To analyze service usage and apply findings to service improvement and promotional activities;
• To share information with event participants or third parties with User consent;
• To prevent unauthorized or illegal use of our services and respond to violations of terms.

Article 3 (Management and Protection of Personal Information)

We take great care in handling personal information and do not disclose it to third parties without prior consent, except in the following cases:

• When necessary to protect life, body, or property and obtaining consent is difficult;
• When required for public health or child development and consent is difficult to obtain;
• When cooperating with national or local authorities where obtaining consent may hinder official duties;
• When outsourcing handling to trusted third parties to the extent necessary for business operations;
• When business succession occurs through merger or other means;
• When jointly using information with specified parties, with prior notice given to the User;
• When otherwise permitted by law.

We will implement preventive and corrective measures against risks such as unauthorized access, loss, leakage, or alteration of personal information.

Article 4 (Outsourcing of Personal Information Handling)

We may entrust handling of personal data to external contractors. In such cases, we will carefully evaluate their suitability, enter into confidentiality agreements, and provide necessary oversight.

Article 5 (Disclosure of Personal Information)

Upon request by a User, we will disclose their personal information. However, we may decline full or partial disclosure under the following conditions:

• If disclosure may harm the life, body, property, or rights of the User or others;
• If disclosure may interfere with our operations;
• If disclosure may violate laws or regulations.

Article 6 (Correction and Deletion of Personal Information)

• If the information held is found to be incorrect, we will correct or delete it upon User request, following our internal procedures. We will promptly notify the User once such actions are completed.

Article 7 (Discontinuation of Use of Personal Information)

If a User requests that we stop using or delete their personal information for any of the following reasons, we will investigate and respond accordingly:

• If used beyond the intended purpose;
• If obtained unlawfully;
• If used in a way that promotes illegal activity;
• If no longer necessary;
• If there has been a data breach (leakage, loss, or damage), particularly involving sensitive information;
• If a malicious breach occurred or affected 1,000+ individuals.

If the discontinuation is difficult due to cost or technical reasons, we will take alternative measures to protect User rights.

Article 8 (Amendments to Privacy Policy)

We may revise this Privacy Policy as needed unless otherwise restricted by law. Updates will be notified to Users or posted on our website.

Article 9 (Compliance with Laws and Regulations)

We comply with the laws of Japan and all applicable rules related to the handling of personal information.

Article 10 (Inquiries and Complaints)

We will respond promptly and appropriately to any inquiries, complaints, or requests for disclosure, correction, deletion, or suspension of use regarding personal information.

Article 11 (Contact Information)

For any questions regarding this Privacy Policy, please contact:

ITSUWA CORPORATION

TEL: 06-6764-7568

Revised: July 1st