Privacy Policy

This English translation is provided for reference only. In the event of any discrepancy, the Japanese version shall prevail.

Lumilinks inc. (hereinafter referred to as the "Company") recognizes the importance of protecting personal information in the services provided on this website. The Company complies with the Act on the Protection of Personal Information and hereby establishes the following privacy policy (hereinafter referred to as the "Policy").

Article 1 (Definition of Personal Information)

"Personal information" refers to "personal information" as defined in the Act on the Protection of Personal Information, meaning information about a living individual that can identify a specific individual by the name, date of birth, address, telephone number, contact details, or other descriptions contained in such information, as well as information that can identify a specific individual on its own, such as data relating to facial appearance, fingerprints, or voiceprints, and insurer numbers on health insurance cards (personal identification information).

Article 2 (Business Operator Information)

Company name: Lumilinks inc.

Address: 2F-C, Shibuya Dogenzaka Tokyu Building, 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan

Representative: Kogiso

Article 3 (Methods of Acquiring Personal Information)

The Company may ask customers for personal information such as their name, date of birth, address, telephone number, email address, and social networking service accounts when they register to use our services.

The Company may also collect transaction records and payment information containing customers' personal information from transactions between customers and our business partners (including information providers, advertisers, and advertising distributors; hereinafter referred to as "Business Partners").

Article 4 (Purposes of Use of Personal Information)

The Company uses personal information for the following purposes:

  1. To provide and operate the Company's services
  2. To respond to inquiries from customers (including verifying their identity)
  3. To send emails about new features, updates, campaigns, and other information regarding the services customers are using, as well as information about other services provided by the Company
  4. To contact customers as necessary, such as for maintenance and important notices
  5. To identify users who violate the terms of service or attempt to use the services for fraudulent or improper purposes, and to refuse their use of the services
  6. To allow customers to view, modify, or delete their registered information and to view their usage status
  7. To bill customers for usage fees in paid services
  8. Purposes incidental to the purposes of use described above

Article 5 (Changes to the Purposes of Use)

The Company shall change the purposes of use of personal information only when the new purposes are reasonably deemed to be related to the purposes before the change.

If the purposes of use are changed, the Company shall notify customers of the new purposes or publish them on this website in the manner prescribed by the Company.

Article 6 (Security Measures for Personal Data)

In order to protect personal information, the Company takes measures in accordance with its information security regulations, including the management of such personal information, the designation of methods for taking personal information off-site, and the prevention of unauthorized access by third parties, in order to prevent the leakage, loss, falsification, or destruction of personal information.

Article 7 (Provision of Personal Data to Third Parties)

1. The Company shall not provide personal information to third parties without obtaining the prior consent of the customer, except in the following cases. However, this shall not apply to cases permitted under the Act on the Protection of Personal Information or other laws and regulations.

  1. When it is necessary to protect the life, body, or property of a person and it is difficult to obtain the consent of the individual
  2. When it is particularly necessary to improve public health or promote the sound upbringing of children and it is difficult to obtain the consent of the individual
  3. When it is necessary to cooperate with a national government agency, a local government, or a party entrusted by either in executing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of such affairs
  4. When the Company has notified or publicly announced the following matters in advance and has filed a notification with the Personal Information Protection Commission
    • That the purposes of use include provision to third parties
    • The items of data to be provided to third parties
    • The means or methods of provision to third parties
    • That the provision of personal information to third parties will be stopped at the request of the individual
    • The method for accepting requests from the individual

2. Notwithstanding the preceding paragraph, the recipient of the information shall not be deemed a third party in the following cases.

  1. When the Company entrusts all or part of the handling of personal information to the extent necessary to achieve the purposes of use
  2. When personal information is provided in connection with the succession of business due to a merger or other reasons
  3. When personal information is used jointly with a specific party, and the individual has been notified in advance of, or placed in a position to easily learn, that fact, the items of personal information to be used jointly, the scope of the parties using it jointly, the purposes of use of those parties, and the name of the person or entity responsible for the management of such personal information

Article 8 (Procedures Concerning Personal Data)

Customers may request the disclosure of their personal information or records of provision to third parties, except in the following cases:

  1. When disclosure is likely to harm the life, body, property, or other rights or interests of the individual or a third party
  2. When disclosure is likely to seriously impede the proper execution of the Company's business
  3. When disclosure would violate laws and regulations
  4. When it cannot be confirmed that the request for disclosure was made by the individual concerned

Article 9 (Suspension of Use of Personal Information)

If a customer requests the suspension of use or deletion of their personal information (hereinafter referred to as "Suspension of Use, etc.") on the grounds that it is being handled beyond the scope of the purposes of use or that it was obtained by improper means, the Company shall conduct the necessary investigation without delay.

If, based on the results of the investigation, the Company determines that it is necessary to comply with the request, the Company shall carry out the Suspension of Use, etc. of the personal information without delay.

When the Company has carried out the Suspension of Use, etc., or has decided not to do so, the Company shall notify the customer without delay.

Where the Suspension of Use, etc. would require a large expense or is otherwise difficult to carry out, and alternative measures necessary to protect the rights and interests of the customer can be taken, the Company shall take such alternative measures.

Article 10 (Contact for Inquiries and Complaints Regarding the Handling of Personal Information)

For questions, concerns, complaints, or other inquiries regarding the Company's handling of personal information, please contact us at the following:

Address: 2F-C, Shibuya Dogenzaka Tokyu Building, 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan

Company name: Lumilinks inc.

Email: [email protected]

Enacted March 17, 2025