PRIVACY POLICY

Recustomer Inc.
Representative Director: Yasuhiro Shibata

Established: April 1st, 2022
Revised: August 1st, 2024

Recustomer Inc. (hereinafter referred to as the “Company”) recognizes that personal information of users (hereinafter referred to as the “Users”) of the services provided on this website (hereinafter referred to as the “Services”) constitutes important private information. The Company is committed to respecting our Users and meeting their trust and expectations by handling personal information appropriately, in accordance with the applicable laws and regulations on personal information protection, and by establishing an organizational structure to ensure its proper management.

Accordingly, the Company has established the following Privacy Policy (hereinafter referred to as the “Policy”) regarding the handling of personal information.

Collection, Use, and Provision of Personal Information
The Company will clearly define the purposes for which personal information is collected and will obtain, use, and provide such information fairly and appropriately, only to the extent necessary to achieve those purposes. Measures will be taken to prevent the use of personal information for purposes other than those specified.

Compliance with Laws and Standards
The Company will comply with laws and regulations concerning personal information, government guidelines, and other social norms, and will strive to appropriately protect personal information.

Proper Management of Personal Information
The Company acknowledges risks such as unauthorized access, loss, destruction, falsification, or leakage of personal information and will implement reasonable security measures. If any issues arise, the Company will take appropriate corrective action.

Responding to Inquiries
The Company will respond appropriately to inquiries from Users regarding the disclosure, correction, suspension of use, and complaints related to personal information handled by the Company.

Continuous Improvement
The Company will maintain and operate management systems and regulations concerning personal information protection, review them periodically, and strive for continuous improvement of the Personal Information Protection Management System.

ARTICLE 1: Personal Information

“Personal information” refers to information about a living individual that can identify a specific person from details such as name, date of birth, or other descriptions, or information containing personal identification codes, as defined in the Act on the Protection of Personal Information (the “Personal Information Protection Act”).

ARTICLE 2: Methods of Collecting Personal Information

The Company may collect personal information such as name, date of birth, address, telephone numbers, email address, bank account number, credit card number, or driver’s license number when a User registers to the Services or through services linked to the Services.

ARTICLE 3: Information of the Personal Information Controller

Company Name: Recustomer Inc.
Representative Director: Yasuhiro Shibata
Address: 8F Ginza-Quint Building, 5-13-1 Ginza, Chuo-ku, Tokyo 104-0061, Japan

ARTICLE 4: Personal Information Protection Manager

Manager: Yasuyuki Obaraki
Email: info@recustomer.co
Phone: +81 3 5829 8330

ARTICLE 5: Purposes of Collecting and Using Personal Information

The purposes for which the Company collects and uses personal information are as follows. If personal information is used for purposes other than those listed below, prior consent will be obtained from the User.

5.1. Retained Personal Data

Type of Personal Information Purpose of Use
Business Partner and User Information - Provision and operation of the Services
- Notifications regarding new features, updates, campaigns and other services or events
- Necessary communications such as maintenance or important announcements
- Identification of Users violating terms of use or attempting improper use
- Analysis of usage to improve the Services or deliver targeted advertising
- Communication for surveys or media coverage related to the Services
Employee Information - For employee management purposes, including labor, HR management, payroll, and welfare administration
Job Applicant Information - For recruitment purposes, including providing recruitment information, assessing eligibility, and related communications
Former Employee Information - For communication and responding to inquiries from former employees
Inquirer Information - To respond to inquiries from Users, including identity verification
Information of Users or Representatives (upon disclosure request) - To respond to disclosure or other requests
Other - For purposes explicitly provided in writing

5.2. Other Personal Information Collected

Type of Personal Information Purpose of Use
Personal information obtained through contracted work - For contract execution, communication, performance of commissioned work, and aftercare
Information obtained from recruitment websites - To assess and notify the outcome of recruitment

ARTICLE 6: Provision of Personal Information to Third Parties

The Company will not provide personal information to third parties without prior consent, except as permitted by the Personal Information Protection Act or other laws, including:
(1) When necessary to protect human life, body, or property, and obtaining consent is difficult;
(2) When particularly necessary for public health or the healthy upbringing of children, and obtaining consent is difficult;
(3) When cooperating with government agencies or local authorities for statutory duties, and obtaining consent may hinder execution;
(4) When delegating handling of personal information to the extent necessary to achieve the intended purpose;
(5) When personal information is provided due to business succession by merger or other reasons; or
(6) When personal information is jointly used with other parties, and Users are informed in advance or it is made easily accessible.

ARTICLE 7: Personal Information Obtained and Provided via Linked Services

When Users use services linked with the Services, the following personal information may be provided to such linked services:

Recipients:
- E-commerce platform operators authorized by the User
- OMS operators authorized by the User
- Other system providers holding order information authorized by the User

Information Provided:
Order information, including purchaser name, billing address, shipping address, telephone number, email, and purchased products

Purpose of Provision:
To facilitate trial purchases, order editing, order cancellation, shipping tracking, exchanges, and refunds between the EC operator and the User

ARTICLE 8: Outsourcing of the Handling of Personal Information

The Company may outsource the handling of all or part of personal information.
In such cases, the Company will take the utmost care to ensure proper handling.

ARTICLE 9: Certified Personal Information Protection Organization

None

ARTICLE 10: Disclosure of Personal Information

1. Upon request by the User regarding retained personal data (including notification of purpose of use, disclosure, correction, addition or deletion, suspension of use, erasure, suspension of third-party provision, and disclosure of records of third-party provision), the Company will respond without delay, after verifying the requester’s identity, within a reasonable timeframe and scope.

Disclosure may be withheld if it risks:
(1) Harm to the life, body, property, or rights of the User or third parties;
(2) Significant interference with proper business execution; and
(3) Violation of laws.

2. Non-personal information such as browsing history or attributes will not, in principle, be disclosed.

3. Requests for disclosure should be directed to the contact below. The Company will provide a “Retained Personal Data Disclosure Request Form” for completion and submission, along with verification documents. A fee of JPY 1,000 per request applies.

ARTICLE 11: Measures for Ensuring the Security of Personal Information

The Company operates a Personal Information Protection Management System based on JIS Q 15001 and internal regulations. Reasonable organizational, human, physical, and technical safeguards are implemented to ensure appropriate handling of personal information. For details, please contact the [Inquiry Desk] below.

ARTICLE 12: Changes to the Privacy Policy

1. This Policy may be revised without prior notice to Users, except as otherwise provided by law or the Policy.
2. Unless otherwise specified, revised Policies take effect upon posting on the website.

ARTICLE 13: Contact Information

For inquiries, complaints, or consultations regarding the handling of personal information, including retained personal data, please contact the following:

Contact Person: Yasuyuki Obaraki (Personal Information Protection Manager)
Address: 8F Ginza-Quint Building, 5-14-1 Ginza, Chuo-ku, Tokyo 104-0061, Japan
Phone: +81 3 5829 8330
Email: info@recustomer.co