TRADOM Inc. (hereinafter referred to as “the Company”) (hereinafter referred to as the “Company”) has established the following privacy policy (hereinafter referred to as the “Policy”) regarding the handling of user information, including personal information, for the services provided by the Company (hereinafter referred to as the “Services”). (hereinafter referred to as the “Company”) has established the following privacy policy (hereinafter referred to as the “Policy”) regarding the handling of user information including personal information of users in the services provided by the Company (hereinafter referred to as the “Services”). The following privacy policy (hereinafter referred to as the “Policy”) is set forth below.

1. User Information to be Collected and Method of Collection

For the purposes of this Policy, “User Information” shall mean information pertaining to the identification of users, action history on communication services, and other information generated or accumulated in connection with users or their terminals, which is collected by us in accordance with this Policy.
The user information that we collect in the Service is as follows, depending on the method of collection.

(1) Information provided by the user
The information provided by the user to use the Service or through the use of the Service is as follows.

• Profile information such as name, date of birth, gender, occupation, etc.
• Contact information such as e-mail address, telephone number, address, etc.
• Payment method information such as credit card information, bank account information, and electronic money information
• Still image information including the user’s portrait
• Contents, comments, and other information posted or transmitted by users on the Service
• Information entered or transmitted by users through input forms or other methods determined by the Company

(2) Information provided by other services when the user permits linkage with such other services in the use of the Service.

If you allow us to link your use of the Service with other services, such as social networking services, we will collect the following information from such external services based on what you agreed to when you gave us your permission to do so.

• IDs used by the user on the external service in question
• Other information that the user has authorized to be disclosed to the linked party according to the privacy settings of the external service in question

(3) Information we collect when you use the Service
We may collect information about how you access and use the Service. This may include the following information

• Referrer
• IP address
• Information about server access logs
• Cookies, ADIDs, IDFAs, and other identifiers
• Terminal IDs and other information related to the identification of information and telecommunications terminals
• Information on the browser used, OS, and other information on the telecommunications terminal used
• Location information
• Other information related to the use of this service

2. Purpose of Use

The specific purposes of use of user information related to the provision of this service are as follows.

(1) To provide, maintain, protect, and improve the Service, such as for accepting registration, identification, user authentication, recording user preferences, and calculating payment of usage fees.

(2) To measure user traffic and behavior

(3) To distribute and display advertisements and promotions and to measure their effectiveness

(4) To provide information on this service and to respond to inquiries, etc.

(5) To improve and develop this service and new services (including service development through business alliances with third parties)

(6) To respond to violations of our terms, policies, etc. (hereinafter referred to as “Terms and Conditions, etc.”) regarding this Service.

(7) To notify you of changes to the terms and conditions of this service, etc.

(8) For other matters incidental or related to the preceding items.

3. Third Party Offers

We will not provide personal information among user information to any third party (including parties located outside of Japan) without the prior consent of the user. (including those located outside of Japan) without the prior consent of the user. However, this shall not apply in the following cases.

(1) When we outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use

(2) Cases in which personal information is provided as a result of the succession of business due to merger or other reasons

(3) When personal information is provided to the information collection module provider

(4) When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the consent of the User may impede the execution of such affairs.

(5) Other cases as permitted by the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”) Other cases permitted by laws and regulations

4. Joint Use

We may share all or part of the handling of personal information with our affiliates to the extent necessary to achieve the purpose of use. The term “our affiliates” as used herein refers to our parent company, subsidiaries, and affiliates, as well as other companies to the extent that we are an affiliate of such other companies.

5. Disclosure of Personal Information

When a user requests disclosure of personal information in accordance with the provisions of the Personal Information Protection Law, we will confirm that the request is made by the user himself/herself and disclose the information to the user without delay (if the relevant personal information does not exist, we will notify the user to that effect). (If such personal information does not exist, the Company will notify the user of such fact. However, this does not apply to cases in which we are not obligated to disclose the information under the Personal Information Protection Law or other laws and regulations. Please note that a fee (1,000 yen per case) will be charged for the disclosure of personal information.

6. Correction and Suspension of Use of Personal Information

6-1 When a user requests us to correct the content of his/her personal information in accordance with the provisions of the Personal Information Protection Law because (1) the personal information is untrue, or (2) the personal information has been handled beyond the scope of the purpose of use publicly announced in advance or has been collected through deception or other wrongful means, we will conduct the necessary investigation without delay after confirming that the request is made by the user, and based on the results of the investigation, we will correct the content of the personal information or suspend its use. If a user requests that the use of his/her personal information be discontinued in accordance with the provisions of the Personal Information Protection Law because (1) the information is handled in a manner that exceeds the scope of the purposes of use disclosed in advance or (2) the information was collected through deception or other wrongful means, we will conduct the necessary investigation without delay upon confirmation that the request was made by the user himself/herself, and based on the results, correct or discontinue the use of the information and notify the user thereof. If we decide not to correct or suspend the use of personal information, we will notify the User to that effect.

6-2When a user requests that we delete the user’s personal information, and we deem it necessary to comply with the request, we will delete the personal information after confirming that the request was made by the user himself/herself, and will notify the user to that effect.

6-3The provisions of 6-1 and 6-2 do not apply to cases in which we are not obligated to correct, etc. or suspend the use of personal information under the Personal Information Protection Law or other laws and regulations.

7. Contact for Inquiries

Please direct any comments, questions, complaints, or other inquiries regarding the handling of user information to the contact information below.

Contact (e-mail) : privacy@gfit.co.jp

8. Privacy Policy Modification Procedures

We may change this policy from time to time as necessary. In the event of a change to this policy, we will notify registered users of the revised policy by posting the revised policy on our website or by other appropriate means. In the case of a change that requires the consent of the registered user under the law, the registered user’s continued use of the service after the date of the change shall be deemed to constitute consent to the change without objection.

Established November 17, 2022