1. Information We Collect
We collect information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Customer or Customer’s device (“Personal Data”). In particular, we will collect the following categories of Personal Data:
A real name, postal address, online identifier, internet protocol address, email address, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, address, telephone number, and any other financial information.
A name, address, telephone number, and any other financial information.
Records of services purchased, or other purchasing histories.
We obtain your Personal Data directly from you in our relationship with you, including, but not limited to, when you (i) make your personal account, (ii) apply to use the Service, (iii) access or use the Service, and (iv) communicate with us for inquiry about the Service.
2. Use of Personal Data
We may use the Personal Data for one or more of the following business purposes indicated below:
・to provide the Services and enable Customers’ efficient use of the Services;
・to process details regarding Customers’ use of the Services;
・to process and administer Customers’ personal account and registrations of the Service;
・to provide various services correspondence to the Customers (including to notify the Customers of changes to the Services);
・to process details of Personal Data that the Customers voluntarily provide on the Services;
・to perform, monitor and enforce contracts concluded between the Customers and the Company;
・to conduct research, analysis, develop our products;
・to provide notification of information related to the Service and our other products; and
・to serve advertisements to the Customers on our applications based on the use of the Services and/or on third-party sites and applications.
3. Legal Ground for Data Processing
We primarily process your Personal Data based on your consent to this Policy. If you wish to withdraw your consent, you may proceed at any time by informing us of the withdrawal of consent to us through our contact channel that is specified in this Policy. However, the withdrawal of consent will not affect the collection, use, or disclosure of Personal Data you have already given consent to the Company.
Other than where justified by your consent, we will usually process Personal Data where necessary (i) for the performance of contracts executed with you; (ii) for ensuring compliance with our legal obligations; or (iii) for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests.
We will not collect additional categories of Personal Data or use the Personal Data we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.
4. Sharing or Disclosure of Personal Data
We may share or disclose your Personal Data to a third party for business purposes or commercial purposes, including but not limited to, with third party agents, suppliers, or contractors. When we disclose Personal Data to service providers for business purposes or commercial purposes, we enter a contract that describes such purposes and requires the service providers to both keep that Personal Data confidential and not use it for any purpose except for performing the contract.
In the preceding twelve (12) months, we have shared or disclosed the Personal Data to the service providers including a crowd vendor and e-commerce platformer for business purposes or commercial purposes.
5. Data Storage and Retention Period
Your Personal Data will be stored securely in our data server or in the third-party’s data server. We will strictly control access to this information and will review such access control from time to time. We will not keep your Personal Data for longer than required for the purpose of which it has been processed, in accordance with the applicable laws or legislations in respect with protection of your Personal Data (the “Applicable Law”) or in any case to allow the Company to protect the legitimate rights and interests of its own or of third parties. To determine the appropriate retention period for the Personal Data, we shall consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the purposes for which we process the Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
6. Sales of Personal Data
We will not sell your Personal Data to a third party, and we have not sold any Personal Data in the preceding twelve (12) months.
7. Your Rights and Choices under the Applicable Law
Pursuant to Applicable Law, you may have several rights on our processing of your Personal Data, which may include, to request access to, correction, or deletion of your Personal Data, restrict processing of your Personal Data, to ask for data portability, and to withdraw your consent to this Policy. You are also entitled to object to the processing of your Personal Data in certain instances.
When we receive a request based on your rights above, we will conduct all necessary investigations without delay and consider whether your request meets the criteria and condition to exercise such rights under the Applicable Law. For exercising your rights specified in this section, you can reach out to us by contacting to the person/department that is provided in the Section 8 (Contact Us).
You also have the right to lodge a complaint with the data protection supervisory authorities if you have any complaint regarding our processing of your Personal Data.
8. Contact Us
If you have any questions or comments about this Policy, the ways in which we collect and use your information described above, or wish to exercise your rights provided in the Section 7 (Your Rights and Choices under the Applicable Law), please do not hesitate to contact us at:
1. Your Rights and Choices under CCPA
CCPA provides consumers who are residents of California with specific rights regarding Personal Data. If you are a California resident, this Section 1 describes your CCPA rights and explains how to exercise those rights.
(1) Access Right to Specific Information
You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your Personal Data over the past twelve (12) months from the time of your request. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following information:
・The categories of Personal Data we collected about you;
・The categories of sources for the Personal Data we collected about you;
・Our business or commercial purpose for collecting or selling that Personal Data;
・The categories of third parties with whom we share or sell that Personal Data;
・The categories of Personal Data sold by each third party who sold Personal Data;
・The categories of Personal Data disclosed for business purposes or commercial purposes; and
・The specific pieces of Personal Data we collected about you.
Please note that we will not sell your Personal Data to a third party, and we have not sold any Personal Data in the preceding twelve (12) months.
(2) Deletion Request Rights
You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
・Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
・Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
・Debug products to identify and repair errors that impair existing intended functionality;
・Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise other rights provided for by law;
・Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
・Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
・Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
・Comply with legal obligations; or
・Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
(3) Opt-Out Rights
We will not sell your Personal Data to a third party, and we have not sold and will not sell any Personal Data collected from consumers.
We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not:
・Deny you the Service;
・Charge you different prices or rates for the Service, including through granting discounts or other benefits, or imposing penalties;
・Provide you a different level or quality of the Service; or
・Suggest that you may receive a different price or rate for the Service or a different level or quality of the Service.
(5) Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 4 (Contact Us).
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:
・Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative (e.g. a copy of your passport, residence certificate, etc.); and
・Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.
We reserve the right, at our discretion, to change, modify, add, or remove portions from this Policy at any time. However, if at any time in the future we plan to use Personal Data information in a way that materially differs from this Policy, we will post such changes here or otherwise notify you in a manner that complies with law. We encourage you to periodically review our website for the latest information on our privacy practices.
3. Contact Us
If you have any questions or comments about this Policy, the ways in which we collect and use your information described above, or wish to exercise your rights provided in the Section 1 (Your Rights and Choices under CCPA), please do not hesitate to contact us at: