Privacy Policy – Kumatora

About This Policy

Kumatora (hereinafter referred to as “the Company”) has established the following privacy policy regarding the handling of users’ personal information in the services provided on this website (hereinafter referred to as “the Service”).

1. Definition of Personal Information

“Personal Information” refers to “personal information” as defined in the Act on the Protection of Personal Information. It refers to information relating to a living individual that falls under the following categories:

Identification Information

• Name
• Date of Birth
• Address
• Telephone Number
• Email Address

Individual Identification Information

• Facial recognition data
• Fingerprints or voice prints
• Health insurance card insurer number
• Other information that can identify a specific individual

2. Methods of Collecting Personal Information

The Company collects personal information in the following ways:

Direct Collection

When registering for use, we may ask users to provide the following information:

• Name, Date of Birth, Address
• Telephone Number, Email Address
• Bank Account Number
• Credit Card Number
• Driver’s License Number

Indirect Collection

We may collect transaction records and payment information between the user and our partners (including information providers, advertisers, ad distributors, etc., hereinafter referred to as “Partners”) from such Partners.

3. Purpose of Use of Personal Information

The Company uses the collected personal information for the following purposes:

• Provision and operation of the Service
• Responding to inquiries (including identity verification)
• Sending emails regarding new features, updates, campaigns, and other services provided by the Company
• Contacting users for maintenance or important notices as necessary
• Identifying users who violate the terms of service or attempt to use the service for fraudulent or unjust purposes, and refusing their use
• Allowing users to view, change, or delete their own registration information and view their usage status
• Billing users for paid services
• Purposes incidental to the above purposes

4. Changes to Purpose of Use

Conditions for Change

The Company shall change the purpose of use of personal information only when it is reasonably recognized that the changed purpose is relevant to the purpose before the change.

In the event of a change in the purpose of use, the Company shall notify the user of the changed purpose by the method prescribed by the Company or publish it on this website.

5. Provision to Third Parties

In principle, the Company will not provide personal information to third parties without the user’s consent. However, the following cases are exceptions:

Exceptions where provision is allowed

• When it is necessary for the protection of human life, body, or property, and it is difficult to obtain the consent of the person concerned.
• When it is particularly necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the person concerned.
• When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by them in executing the affairs prescribed by laws and regulations, and obtaining the consent of the person concerned is likely to impede the execution of such affairs.
• When permitted by the Act on the Protection of Personal Information or other laws and regulations.

Cases not considered Third Parties

• When the Company entrusts all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
• When personal information is provided in connection with business succession due to a merger or other reasons.
• When personal information is used jointly with a specific person, provided that the person concerned has been notified in advance or the information has been made readily available to the person concerned regarding such fact, the items of personal information to be jointly used, the scope of joint users, the purpose of use by the users, and the name or appellation of the person responsible for the management of the personal information.

6. Disclosure of Personal Information

When requested by the person concerned to disclose personal information, the Company shall disclose it to the person without delay.

Disclosure Fee

A fee of 1,000 yen per case will be charged for disclosure.

Cases where disclosure cannot be made

However, if disclosure falls under any of the following, we may not disclose all or part of the information. If a decision is made not to disclose, we will notify the person without delay.

• When there is a risk of harming the life, body, property, or other rights and interests of the person concerned or a third party.
• When there is a risk of significantly hindering the proper implementation of the Company’s business.
• When it would violate other laws and regulations.

7. Correction and Deletion of Personal Information

If the user’s personal information held by the Company is incorrect, the user may request the Company to correct, add, or delete the personal information (hereinafter referred to as “Correction, etc.”) according to the procedures strictly defined by the Company.

Process Flow

1. The Company receives a request from the user.
2. The Company determines the necessity of the request based on the purpose of use.
3. If deemed necessary, the Company performs the Correction, etc. without delay.
4. The Company notifies the user of the result (either that the correction has been made or that a decision has been made not to make the correction).

8. Suspension of Use of Personal Information

The Company conducts necessary investigations without delay if requested by the person concerned to suspend or delete the use of personal information (hereinafter referred to as “Suspension of Use, etc.”) for the following reasons:

• Because the information is handled beyond the scope of the purpose of use.
• Because the information was obtained by fraudulent means.

Alternative Measures

However, if the Suspension of Use, etc. requires a large amount of cost or is otherwise difficult to implement, and if alternative measures can be taken to protect the rights and interests of the user, such alternative measures shall be taken.

9. Changes to This Policy

Policy Updates

The contents of this policy may be changed without notifying the user, except for laws and regulations and other matters otherwise specified in this policy.

Unless otherwise specified by the Company, the changed privacy policy shall take effect from the time it is posted on this website.

10. Inquiries

Contact Us

For inquiries regarding this policy, please contact the Company.

If you have any questions or concerns regarding the handling of your personal information, please feel free to contact us.