ORGO Inc. (hereinafter referred to as “the Company”) sets forth the following privacy policy (hereinafter referred to as “this Policy”) regarding the handling of user information, including personal information, in connection with the web services and applications operated by the Company (hereinafter referred to as “the Service”).
1. Collected User Information and Collection Methods
In this Policy, “user information” refers to information collected by the Company under this Policy that includes identifiers of users, behavioral history on communication services, and other data generated or stored in relation to the user or the user’s device (such as smartphones or PCs).
Types of user information collected by the Company through the Service are as follows:
(1) Information provided by users:
Users may provide the following information when using the Service:
- Name
- Phone number
- Email address
- Date of birth
- Physical information
- Any other information entered by the user into forms designated by the Company
(2) Information provided through linked services:
If a user allows linkage with external services such as social networking services (SNS), the Company may collect the following information as permitted by the user’s consent at the time of linkage:
- IDs used in the external services
- Information the user has permitted to be disclosed through the external service’s privacy settings
(3) Information automatically collected during use of the Service:
The Company may collect information related to the access status and usage of the Service, including:
- Device information
- Log data
- Cookies and anonymous identifiers
- Location information
(4) User demographic data collected via Google Analytics:
The Service may collect demographic data through Google Analytics, such as:
- Age
- Gender
- Interests
These data are anonymized and cannot identify individuals. For more details, refer to the Google Analytics Terms of Service.
2. Purposes of Use
(1)User information will be used for the provision of the Service as described in Section 2 and may also be used for other purposes described in Section 3.
(2)Specific purposes of use related to providing the Service:
- To register users for the Service, verify identity, calculate fees, and provide, maintain, protect, and improve the Service
- To send information about the Service, new features, updates, campaigns, and other services offered by the Company (including via email)
- To respond to inquiries regarding the Service
- To respond to actions that violate the Service’s terms, policies, etc. (collectively “Terms”)
- To notify users of changes to the Service or the Terms
- To identify and respond to users who violate the Terms or attempt to use the Service for unlawful or unfair purposes
- To provide information to third parties as specified in this Policy
- For purposes incidental to the above
(3)Other purposes of use beyond Section 2:
| (1) To create statistical data in a format that cannot identify individuals, for purposes related to our services | Device info, log info, cookies, anonymous ID, location info, physical info |
| (2) To distribute or display ads from the Company or third parties | Device info, log info, cookies, anonymous ID, location info |
| (3) To integrate and analyze obtained information and use the results for marketing, including recommendations and advertisements | Name, email address, date of birth, other form entries designated by the Company |
3. Methods of Notification, Disclosure, or Consent; How to Request Suspension of Use
- Prior consent from users will be obtained for the collection of the following information:
- Device information
- Location information
- Users may request the suspension of the use of some or all user information through settings provided within the Service. In such cases, the Company will promptly comply in accordance with its internal procedures. However, certain information is essential for the provision of the Service, and may only be stopped upon complete withdrawal from the Service.
4. Provision to Third Parties
The Company does not provide personal information to third parties without the user’s prior consent, except where permitted by law. However, the following cases are excluded:
- When the Company outsources handling of personal information within the scope necessary to achieve the intended purpose
- When the Company outsources all or part of the Service operation or transfers the Service
- When personal information is provided as part of a business succession due to a merger or other reason
- When providing personal information to module providers in accordance with Section 4 provisions
Information Collection Modules:
- Module Name: Google Analytics
Provider: Google LLC
Data Collected: Device info (OS version, etc.), device identifier, IP address, cookies - Module Name: Remarketing Tag / Conversion Tracking Tag
Provider: Google LLC
Data Collected: Same as above - Module Name: Site Retargeting Tag / Conversion Measurement Tag
Provider: LY Corporation (LINE Yahoo)
Data Collected: Same as above - Module Name: Facebook Pixel
Provider: Meta Platforms, Inc.
Data Collected: Same as above - When cooperation is required with government agencies or local public bodies in accordance with laws
- When permitted by other laws and regulations
5. Disclosure of Personal Information
The Company will not disclose personal information to third parties except in the following cases:
- With the user’s consent
- When necessary for operational purposes such as displaying access logs (excluding user registration information)
- When the Company provides minimal personal information to its partners or advertisers for specific operations, with user consent
- When disclosure is required by law (e.g., subpoena, Provider Liability Limitation Act)
- When there is reasonable suspicion of Terms violation and disclosure is deemed necessary to protect the Company’s rights or services
- When urgent necessity exists to protect the life, body, or property of the user or third party, and it is difficult to obtain consent
6. Correction and Suspension of Use of Personal Information
- Upon user request, the Company will investigate and, if appropriate:
- Correct inaccurate personal information
- Suspend use or delete personal information obtained beyond disclosed purposes, fraudulently, or if usage is no longer necessary
- Respond to mandatory reports to the Personal Information Protection Commission or threats to user rights
If corrections or suspensions are not feasible due to high costs or difficulty, alternative measures will be considered to protect user rights.
- If the Company is not legally obligated to make corrections or suspend use, the above provisions do not apply.
7. Changes to This Policy
The Company will review and revise this Policy as necessary to improve operations and data protection. Changes will be notified via a method prescribed by the Company. For changes requiring user consent under the law, consent will be obtained in advance.
8. Security Measures
The Company implements organizational, physical, human, and technical measures for managing personal data securely. These include restricting access, defining responsibility for handling personal data, including confidentiality obligations in employment rules, monitoring room access, and implementing systems to prevent unauthorized access.
9. Contact Information
For inquiries regarding this Policy, please contact:
E-mail: info@epose.com
10. Handling of Non-User Personal Information
Personal information held by the Company that does not relate to users will be handled in accordance with this Policy. The Company will respond promptly upon request from the individuals in question.
11. Governing Law
This Policy shall be governed and interpreted in accordance with the laws of Japan.
ORGO Inc.
2-7, Odori Nishi 18-chome, Chuo-ku, Sapporo, Hokkaido
CEO: Noriyoshi Komoda
Established: July 16, 2024
Revised: December 9, 2024
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