TRADOM Inc. (hereinafter, the “Company”) establishes this Privacy Policy (hereinafter, this “Policy”) as set forth below regarding the handling of user information, including personal information, of users in connection with the services provided by the Company (hereinafter, the “Services”).
1. User Information Collected and Methods of Collection
In this Policy, “User Information” means information relating to the identification of a user, behavioral history on the communication services, and other information generated or accumulated in relation to a user or a user’s device, which the Company collects pursuant to this Policy.
The User Information collected by the Company in the Services is as follows, depending on the method of collection.
(1) Information provided by users
The information provided by users in order to use the Services, or through the use of the Services, is as follows:
- Profile information such as name, date of birth, gender, and occupation
- Contact information such as email address, telephone number, and address
- Payment-method information such as credit card information, bank account information, and electronic money information
- Still-image information including a user’s likeness
- Content, comments, and other information that a user posts or transmits on the Services
- Information that a user enters or transmits through input forms or other methods designated by the Company
(2) Information provided by another service where a user permits linkage with such other service in connection with the use of the Services
Where a user, in using the Services, permits linkage with another service such as a social networking service, the Company collects the following information from such external service based on the content consented to at the time of such permission:
- The ID that the user uses on such external service
- Other information that the user has permitted to be disclosed to the linked party under the privacy settings of such external service
(3) Information collected by the Company when a user uses the Services
The Company may collect information regarding the access status and methods of use of the Services. This includes the following:
- Referrer
- IP address
- Information relating to server access logs
- Cookies, ADID, IDFA, and other identifiers
- Information relating to device identification, such as device ID
- Information relating to the browser, OS, and other device used
- Location information
- Other information relating to the usage status of the Services
(4) Information acquired in payment, payment collection services, collection of sales proceeds, and other related services
In providing payment, payment collection services, collection of sales proceeds, and other related services among the Services, the Company may acquire, from business partners, member merchants, and other transaction-related parties, the user’s name, email address, country/region, transaction details, payment amount, payment due date, and other information necessary for settlement or transaction management.
In addition, in connection with transactions using digital assets or other similar assets with property value, the Company may acquire wallet addresses, the types of digital assets used, the blockchain used, transaction hashes, transfer amounts, transfer dates and times, consent logs, and other transaction-related information.
2. Purposes of Use
The specific purposes of use of User Information related to the provision of the Services are as follows:
(1) To provide, maintain, protect, and improve the Services, including acceptance of registration for the Services, identity verification, user authentication, recording of user settings, and calculation of usage-fee settlement;
(2) For settlement processing, collection of sales proceeds, notification of completion or non-completion of payment, identity verification, transaction screening, credit screening, AML/CFT, economic-sanctions compliance, wallet screening, transaction monitoring, prevention of fraudulent use, dispute handling, legal compliance, and response to public authorities, in relation to payment, payment collection services, collection of sales proceeds, and other related services;
(3) To measure user traffic and behavior;
(4) To distribute, display, and measure the effectiveness of advertisements and promotions;
(5) To respond to inquiries and provide information regarding the Services;
(6) To improve and develop the Services and new services (including service development through business alliances with third parties);
(7) To respond to acts that violate the Company’s terms, policies, etc. relating to the Services (hereinafter, the “Terms, etc.”);
(8) To give notice of changes to the Terms, etc. relating to the Services; and
(9) For matters incidental or related to each of the preceding items.
3. Provision to Third Parties
Among User Information, the Company will not provide personal information to third parties (including parties located outside Japan) without obtaining the user’s prior consent. Provided, however, that this shall not apply in the following cases:
(1) Where the Company entrusts all or part of the handling of personal information to the extent necessary to achieve the purposes of use;
(2) Where personal information is provided in connection with a business succession due to a merger or other reason;
(3) Where personal information is provided to a provider of an information-collection module;
(4) Where it is necessary to cooperate with a national agency, a local government, or a party entrusted thereby in carrying out affairs prescribed by laws and regulations, and obtaining the user’s consent is likely to impede the performance of such affairs; and
(5) Other cases permitted under the Act on the Protection of Personal Information (hereinafter, the “APPI”) or other laws and regulations.
4. Joint Use
The Company may jointly use personal data to the extent necessary to achieve the purposes of use, as set forth below.
(1) Items of personal data to be jointly used
Among the User Information set forth in “1. User Information Collected and Methods of Collection” of this Policy, information within the scope necessary to achieve the purposes of the joint use.
(2) Scope of joint users
The Company’s affiliated companies. For the purpose hereof, the Company’s affiliated companies mean the Company’s parent company, subsidiaries, and affiliates, as well as any company or other entity of which the Company is an affiliate.
(3) Purpose of use by the joint users
The purposes set forth in “2. Purposes of Use” of this Policy.
(4) Party responsible for the management of jointly used personal data
TRADOM Inc.
Address: FINOLAB, 4F Otemachi Building, 1-6-1 Otemachi, Chiyoda-ku, Tokyo 100-0004, Japan
Representative: Shinichiro Urashima, Representative Director and President
5. Disclosure of Personal Information
When a user requests disclosure of personal information based on the provisions of the APPI, the Company will, after confirming that the request is made by the user themselves, disclose such information to the user without delay (or, if such personal information does not exist, notify the user to that effect). Provided, however, that this shall not apply where the Company is not obligated to make disclosure under the APPI or other laws and regulations. Please note that a fee (1,000 yen per request) will be charged for the disclosure of personal information.
6. Correction and Suspension of Use, etc. of Personal Information
6-1 Where a user requests, based on the provisions of the APPI, (1) correction of the content of personal information on the ground that the personal information is not true, or (2) suspension of use of personal information on the ground that it is being handled beyond the scope of the purposes of use announced in advance or that it was collected by deception or other wrongful means, the Company will, after confirming that the request is made by the user themselves, conduct the necessary investigation without delay and, based on the results, correct or suspend the use of the personal information and notify the user to that effect. Where the Company decides not to make such correction or suspension of use, it will notify the user to that effect.
6-2 Where a user requests deletion of the user’s personal information and the Company determines that it is necessary to comply with such request, the Company will, after confirming that the request is made by the user themselves, delete the personal information and notify the user to that effect.
6-3 Where the Company is not obligated to make correction, etc. or suspension of use, etc. under the APPI or other laws and regulations, the provisions of 6-1 and 6-2 shall not apply.
7. Contact for Inquiries
For opinions, questions, complaints, and other inquiries regarding the handling of User Information, please contact us at the following:
Contact (email): privacy@tradom.jp
8. Procedure for Changes to this Privacy Policy
The Company will change this Policy as necessary. When changing this Policy, the Company will announce the effective date and the content of the revised Policy by posting on the Company’s website or by other appropriate means, or will notify registered users. Where the change is of a nature that requires the consent of registered users under laws and regulations, the continued use of the Services by a registered user on or after the effective date of the change shall be deemed to constitute consent to the content of such change without objection.
Established: November 17, 2022
Last revised: July 1st, 2026