privacy
policy

H2L, Inc. (hereinafter referred to as “the Company”) establishes the following Privacy Policy (hereinafter referred to as “this Policy”) regarding the handling of users’ personal information in connection with the services provided on this website (hereinafter referred to as “the Services”).

■ Article 1 (Personal Information)

“Personal Information” refers to “personal information” as defined in the Act on the Protection of Personal Information, and means information regarding a living individual that can identify a specific individual through the name, date of birth, address, telephone number, contact information, or other descriptions contained in such information, as well as data related to physical appearance, fingerprints, and voiceprints, and information such as health insurance card numbers that can identify a specific individual based on the information alone (personal identification information).

■Article 2 (Methods of Collecting Personal Information)

When users register for our services, we may ask for personal information such as their name, date of birth, address, telephone number, email address, bank account number, credit card number, and driver’s license number. Additionally, we may collect transaction records and payment-related information containing users’ personal information—generated between users and our partners—from our partners (including information providers, advertisers, and ad distribution partners; hereinafter referred to as “Partners”).

■Article 3 (Purpose of Collecting and Using Personal Information)

The purposes for which we collect and use personal information are as follows:

　1. To provide and operate our services
　2. To respond to inquiries from users (including identity verification)
　3. To send emails regarding new features, updates, campaigns, etc., for services currently being used by the user, as well as information about other services we provide
　4. To contact users as necessary regarding maintenance, important notices, etc.
　5. To identify users who have violated the Terms of Service or who attempt to use the services for fraudulent or improper purposes, and to refuse such users access
　6. To allow users to view, modify, or delete their registered information, and to view their usage history
　7. To bill users for fees related to paid services
　8. For purposes incidental to the above purposes

■Article 4 (Change of Purpose of Use)

　1. The Company shall change the purpose of use of personal information only when it is reasonably deemed that the new purpose is related to the previous one.
　2. In the event of a change in the purpose of use, the Company shall notify users of the revised purpose via the methods specified by the Company or publish it on this website.

■Article 5 (Changes to Services for Registered Users)

　1. Except in the cases listed below, the Company will not provide personal information to third parties without the user’s prior consent. However, this does not apply in cases permitted by the Act on the Protection of Personal Information or other laws and regulations.
　　1. When it is necessary to protect human life, physical safety, or property, and it is difficult to obtain the individual’s consent
　　2. When it is particularly necessary for the improvement of public health or the promotion of the sound development of children, and it is difficult to obtain the individual’s consent
　　3. When it is necessary to cooperate with a national agency, a local public entity, or a person entrusted by such an entity in the performance of duties prescribed by laws and regulations, and obtaining the individual’s consent may hinder the performance of such duties
　　4. When the Company has notified or publicly announced the following matters in advance and has filed a report with the Personal Information Protection Commission
　　　1. The purpose of use includes provision to third parties
　　　2. The items of data to be provided to third parties
　　　3. The means or methods of provision to third parties
　　　4. The suspension of provision of personal information to third parties upon the individual’s request
　　　5. The method for accepting such requests
　2. Notwithstanding the provisions of the preceding paragraph, in the following cases, the recipient of the information shall not be deemed a third party:
　　1. When the Company outsources all or part of the handling of personal information within the scope necessary to achieve the purpose of use
　　2. When personal information is provided in connection with the succession of a business due to a merger or other reasons
　　3. When personal information is used jointly with a specific party, provided that the individual has been notified in advance, or the information has been made readily available to the individual, regarding the fact of such joint use, the items of personal information to be used jointly, the scope of the parties involved in the joint use, the purposes of use by such parties, and the name or title of the party responsible for managing the personal information

■Article 6 (Disclosure of Personal Information)

　1. When requested by the individual to disclose personal information, the Company shall disclose such information to the individual without delay. However, if disclosure would result in any of the following circumstances, the Company may withhold all or part of the information; in such cases, the Company shall notify the individual of this decision without delay. Please note that a handling fee of 1,000 yen per request will be charged for the disclosure of personal information.
　　1. Where there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party
　　2. Where there is a risk of causing significant hindrance to the proper conduct of the Company’s business
　　3. Where disclosure would otherwise violate laws and regulations
　2. Notwithstanding the provisions of the preceding paragraph, information other than personal information, such as usage history and characteristic information, will not be disclosed in principle.

■Article 7 (Correction and Deletion of Personal Information)

　1. If a user believes that the personal information held by us regarding them is incorrect, they may request that we correct, add to, or delete such personal information (hereinafter referred to as “correction, etc.”) in accordance with the procedures established by us.
　2. If the Company receives a request from a user under the preceding paragraph and determines that it is necessary to comply with such request, the Company shall correct, add to, or delete the relevant personal information without delay.
　3. If the Company performs a correction, etc., pursuant to the provisions of the preceding paragraph, or if it decides not to perform a correction, etc., the Company shall notify the user of this without delay.

■Article 8 (Suspension of Use of Personal Information, etc.)

　1. If the Company receives a request from an individual to suspend or delete the use of their personal information (hereinafter referred to as “suspension of use, etc.”) on the grounds that such information is being handled beyond the scope of the intended purpose or was obtained by improper means, the Company shall conduct the necessary investigation without delay.
　2. Based on the results of the investigation described in the preceding paragraph, if we determine that it is necessary to comply with the request, we shall suspend the use of such personal information without delay.
　3. If we suspend the use of personal information pursuant to the preceding paragraph, or if we decide not to suspend such use, we shall notify the user of this without delay.
　4. Notwithstanding the preceding two paragraphs, if suspending use, etc., would entail substantial costs or if it is otherwise difficult to suspend use, etc., and if alternative measures necessary to protect the user’s rights and interests can be taken, the Company shall implement such alternative measures.

■Article 9 (Changes to the Privacy Policy)

　1. The contents of this Policy may be changed without notice to users, except as otherwise provided by laws and regulations or other provisions of this Policy.
　2. Unless otherwise specified by the Company, the revised Privacy Policy shall take effect upon its posting on this website.

■Article 10 (Contact Information)

For inquiries regarding this Policy, please contact us via the “Contact Us” page.
Company Name: H2L, Inc.
Address: 3-4-21 Roppongi, Minato-ku, Tokyo 106-0032
E-mail: info@h2l.jp