Privacy Policy

About this notice

Kurokomi GK (“we”, “us”, and “our”) will process your personal data in compliance with all applicable laws and any laws that replace them in the future. In this notice, we have provided information based on such laws related to the processing of your personal data. This notice sets out the basis on which any personal data that you provide to us, or that we obtain about you from other sources, will be processed by us. Please ensure that you read and understand this notice.

Some personal data may be subject to other privacy policies issued by us. In such cases, this notice will supersede such other privacy policies in the case where the clauses set forth in such privacy policies contradict the clauses set forth in this notice.

Definitions

In this notice:

(a) your “personal data” refers to “personal information” or “personal data” as defined in the Act on the Protection of Personal Information of Japan or other applicable data protection laws in other countries, and includes data relating to specific individuals (“data subjects”) who can be identified directly from the information itself, or indirectly by combining it with other available data;

(b) “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, regardless of whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction; and

(c) “controller” means a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing of personal data.

How we collect your personal data and what personal data we collect

When you use our service, we may automatically collect, store, and/or use technical data (such as cookies) about the device or software you use to access the service, as well as your interactions with it. This data will be transmitted from your device to our servers.

We may receive personal data about you when you register an account to use our service, and we may also collect and store additional personal data during your use of our service. Such registered or stored personal data will include your name, address, email address, phone number, service usage history, and your communications with us or other users. If you do not provide us with the necessary personal data for account registration, we will not be able to provide our services to you.

Legal bases and purpose of processing your personal data

We will process your personal data on the following legal bases:

(a) Legal Obligation. This refers to cases where we are required to comply with a legal obligation.

(b) Performance of Contract. This refers to cases where the processing of your personal data is necessary for the performance of a contract to which you are party or in order to take certain steps at your request prior to entering into the contract.

(c) Legitimate Interests. This refers to cases where the processing of your personal data is necessary for legitimate interests pursued by us or a third party, such as promoting our business, and where your interests and fundamental rights do not override those interests.

(d) Consent. This refers to cases where you have provided your consent to our processing of your personal data. However, even if we obtain your consent, we may process your personal data based on other legal grounds. The withdrawal of your consent (please see Section 9(g) of this notice below) will not affect the lawfulness of our processing of your personal data based on the consent provided before the withdrawal thereof.

We will process your personal data only to the extent of fulfilling the purposes listed below based on the following legal bases:

(a) Identifying and authenticating you as a service user and storing data entered by you including communication with other users when you use our service (based on performance of contract or legitimate interest);

(b) Communicating with you, including responding to your questions, inquiries, or messages (based on the performance of a contract or legitimate interests);

(d) Sales activities, including sending you direct mail regarding our service (based on your consent or legitimate interests);

(e) Complying with any laws or regulations applicable to us (based on a legal obligation or legitimate interests); and

(f) Cooperating with relevant governmental authorities and agencies, including competent data protection authorities and those that are engaged in administrative or criminal investigations (based on a legal obligation or legitimate interests).

We will not process sensitive data such about you, such as data about your race, ethnic origin, religion, physical or mental health, political opinions, sexual orientation, any actual or alleged criminal offences, or genetic and biometric data.

Third parties who may access your personal data

We may share your personal data with others, who may access it in the cases described below:

(a) Internal Use by Us: We may share your personal data with our employees who are authorized and need to access such data.

(b) Affiliates: We may share your personal data with our affiliates for internal administrative purposes and uses that are consistent with this notice.

(c) Other Users of our Services: We may share your personal data with other users of our service if you choose to use the sharing features available within the service.

(d) Service Providers: We may share your personal data with third-party service providers who perform services (such as providing cloud services or payment services) to help us operate our services.

(e) Legal Process and Safety: We may disclose your personal data to legal or government regulatory authorities as required by any applicable laws. We may also disclose your personal data to third parties as required by any applicable laws in connection with claims, disputes, or litigation, when otherwise required by any applicable laws, if we determine that such disclosure is necessary to protect the health and safety of you or others, or to enforce our legal rights or contractual commitments that you have entered into.

(f) Business Transfers: Your personal data may be disclosed as part of a corporate business transaction, such as a merger, acquisition, company split, business transfer, joint venture, or the financing or sale of company assets, and may be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership.

Transfer of your personal data outside your country

Your personal data may be transferred to, and stored by, third parties outside your country (in most instances, such third parties are located in Japan or Singapore) when you use our service. When we transfer your personal data to a third party outside your country, we will ensure that:

(a) the recipient country has been certified by the government of your country to ensure an adequate level of protection for the rights and freedoms that you hold in respect of your personal data;

(b) the recipient has entered into a contract governing the transfer of personal data, as required under applicable data protection laws; or

If the GDPR or UK GDPR applies to our processing of your personal data, we will transfer your data to recipients located in Japan based on (a) above (i.e., the adequacy decision pursuant to Article 45 of the GDPR) and recipients located in Singapore based on (b) above (i.e., the SCC pursuant to Article 46 of the GDPR).

Please note that Japan and Singapore have comprehensive data protection laws which protect the personal data of foreign nationals. These laws impose various obligations on businesses to protect personal data, including: (1) the obligation to collect personal data lawfully and based on a clear purpose; (2) the obligation to notify data subjects of the purpose of data use and provide contact information, and to use the personal data only for the stated purpose; (3) the obligation to securely manage personal data; and (4) the obligation to respond to inquiries about how personal data is processed and to correct any inaccuracies regarding personal data. Additionally, the competent authorities in Japan and Singapore can impose sanctions on businesses that violate these obligations. However, the level of protection given by these laws may be lower than that provided by the data protection laws in your country, as legal provisions vary across jurisdictions. If you consent to international data transfers under (c) above, you accept the risks arising from these differences in data protection standards.

You can obtain further details about the protection of your personal data—including, if applicable, copies of international data transfer agreements we have entered into—when your data is transferred outside your country, by contacting us using the contact information provided in Section 11.

Retention Period

We will retain your personal data from the time you register or store it in our service until two weeks after you delete your account.

How we protect your personal data

We are committed to safeguarding and protecting your personal data and will implement and maintain sufficient technical and organizational measures to ensure an appropriate level of security to protect your personal data from accidental or unauthorized destruction, loss, alteration, disclosure, or access. You can obtain more details about our technical and organization measures by contacting us using the information about us indicated in Section 11.

Your rights

You have a variety of legal rights in relation to the personal data that we hold about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but typically will include:

(a) the right to obtain information regarding the processing of your personal data and to access the personal data that we hold about you;

(b) the right to request rectification of your personal data if it is inaccurate or incomplete;

(c) the right to request erasure of your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:

(i) it is no longer necessary for us to retain your personal data for the purposes for which we collected it;

(ii) we are only entitled to process your personal data with your consent, and you withdraw such consent; or

(iii) you object to our processing of your personal data for legitimate interests, and such legitimate interests do not override your own interests, rights, or freedoms;

(d) the right to request that we restrict our processing of your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:

(i) you dispute the accuracy of your personal data (but only for the period of time necessary for us to verify its accuracy);

(ii) we no longer need to use your personal data except for the establishment, exercise, or defence of legal claims; or

(iii) you object to our processing of your personal data for legitimate interests (but only for the period of time necessary for us to assess whether such legitimate interests override your own interests, rights, or freedoms);

(e) the right to object to our processing of your personal data;

(f) the right to receive any personal data which we process about you on the basis of your consent (as opposed to any other legal grounds) and where such processing is carried out by automated means in a structured, commonly used, and machine-readable format and/or to request that we transmit that data to a recipient where doing so is technically feasible. Please note that this right only applies to personal data which you have provided to us; and

(g) the right to withdraw your consent to our processing of your personal data at any time. However, please note that we may still be entitled to process your personal data if we can rely on other legal grounds for doing so.

You can exercise your rights by contacting us using the information about us indicated below in Section 11. You can also file a complaint with the competent data protection authority if you believe that any of your rights have been infringed by us.

Changes to this privacy notice

We may amend this notice from time to time and will post an updated notice as necessary. We recommend that you review this notice periodically. If we make any material changes to this notice, you will be provided with appropriate notice, such as notice of such change being posted on our application or website.

Contacts

Any questions, comments, or requests regarding this notice are welcome. Please contact us using the information below.

Controller (us):

Name: Kurokomi GK

Representative Director: Hiromi Horibe

Main Office Address: 62 Kitayashiki Kochinocho Konan-shi Aichi, Japan

E-mail Address: h-horibe@kurkomi.com