Last Updated: April 16, 2022

1. Introduction

ITOTSUKA (hereinafter referred to as “we”) establishes this Privacy Policy (hereinafter referred to as “this Policy”) regarding the handling of personal information of users (hereinafter referred to as “Users”) in connection with our products and services (hereinafter referred to as “Services”).

2. Definition of Personal Information

"Personal Information" refers to information as defined in the Act on the Protection of Personal Information and means information about a living individual that can identify the specific individual, such as name, date of birth, email address, and other descriptions, as well as facial image, fingerprint, voiceprint data, and health insurance number and other information that can identify an individual on its own (“Personally Identifiable Information”).

3. Methods of Collecting Personal Information

We may ask Users for personal information such as name, date of birth, and email address during registration. We may also collect transaction records including personal information between Users and our partners (including data providers, advertisers, and ad distributors, hereinafter referred to as “Partners”).

4. Purpose of Use of Personal Information

We collect and use personal information for the following purposes:

1. To provide and operate our Services
2. To respond to User inquiries (including identity verification)
3. To send emails regarding new features, updates, campaigns, and other services we provide
4. To contact Users when necessary for maintenance and important notices
5. To identify and block Users who violate terms or attempt to use the Services for fraudulent purposes
6. To allow Users to view, edit, or delete their registration and check their usage
7. To bill Users for paid Services
8. For other purposes incidental to the above

5. Changes to Purpose of Use

1. We may change the purpose of use of personal information only if reasonably deemed related to the original purpose.
2. If the purpose is changed, we will publicly announce it on our website.

6. Provision of Personal Information to Third Parties

1. We will not provide personal information to third parties without prior consent from the User, except when allowed by law, such as:
   • When necessary to protect life, body, or property, and it is difficult to obtain the User’s consent
   • When necessary for public health or the sound development of children, and it is difficult to obtain the User’s consent
   • When cooperating with national or local government agencies, and obtaining consent may interfere with their duties
   • When the following information is publicly announced in advance and reported to the Personal Information Protection Commission:
     • That the purpose includes third-party provision
     • The items of data to be provided
     • The method of provision
     • That provision will be stopped upon User request
     • The method for accepting User requests
2. The following cases are not considered third-party provision:
   • When outsourcing handling of personal information to the extent necessary
   • When personal information is transferred due to business succession such as merger
   • When shared use with a specific party is notified in advance, including the items shared, scope of users, purpose of use, and the responsible party’s name

7. Disclosure of Personal Information

1. Upon User request, we will disclose their personal information without delay. However, we may refuse disclosure in the following cases, and will notify the User:
   • If it may harm the life, body, property, or rights of the User or a third party
   • If it may seriously interfere with our operations
   • If it violates laws
2. We will not disclose non-personal information such as history or characteristics, in principle.

8. Correction and Deletion of Personal Information

1. Users may request correction, addition, or deletion (“Correction”) of their personal information if it is incorrect.
2. If we deem the request valid, we will promptly perform the Correction.
3. We will notify the User if Correction is made or denied.

9. Suspension of Use, etc. of Personal Information

1. If a User requests suspension or deletion (“Suspension”) of their personal information due to unauthorized use or collection, we will promptly investigate.
2. If we deem the request valid, we will promptly perform the Suspension.
3. We will notify the User of the outcome.
4. If Suspension is difficult due to cost or technical reasons, we may take alternative actions to protect User rights.

10. Changes to Privacy Policy

1. We may change this Policy without prior notice to Users, unless otherwise required by law.
2. Unless otherwise specified, the revised Policy will take effect when posted on our website.

11. Contact

For inquiries about this Policy, please contact:
Email: y.itotsuka@gmail.com