Privacy Policy

Article 1 (Definition of Personal Information)

“Personal Information” means personal information as defined by Japan’s Act on the Protection of Personal Information (“APPI”).

Information relating to an individual that is not Personal Information, such as certain cookies, device identifiers, or browsing history, may constitute “personal-related information” under the APPI. Depending on how such information is handled, it may also constitute Personal Information when it can readily be matched with other information to identify a specific individual.

Article 2 (Method of Collection)

The Operator may collect information that Users enter or send through the Service, such as an email address, date of birth, profile information, content such as posts, comments, and images, and inquiry details, as well as usage information and logs necessary to provide the Service.

If Paid Services are offered, the Operator may receive information necessary to verify purchases, refunds, and subscription status from Apple or other payment providers. Payment-card information may be handled directly by the payment provider and may not be received by the Operator. The actual categories collected depend on the Service features and external services in use.

Article 3 (Purpose of Use)

1. The Operator collects and uses Personal Information for the following purposes:
   • To provide and operate the Service.
   • To confirm eligibility to use the Service, such as age requirements.
   • To respond to User inquiries (including identity verification).
   • To send notices regarding new features, updates, campaigns, or announcements.
   • To contact Users regarding maintenance or important updates.
   • To prevent and restrict fraudulent or prohibited use.
   • To allow Users to view, modify, or delete their registration information, and to check their usage status.
   • To process billing and payments for paid services.
   • For other purposes related to the above.
2. For the avoidance of doubt, the Operator will not provide Users’ Personal Information to third parties for the purpose of AI training or model development.

Article 4 (Change of Purpose of Use)

The Operator may change the purpose of use only if the new purpose is reasonably deemed to be related to the original purpose. The revised purpose will be notified or published by a method prescribed by the Operator.

Article 5 (Provision of Personal Information to Third Parties)

1. The Operator will not provide Personal Information to any third party without prior consent of the User, except in the following cases:
   • When necessary to protect human life, body, or property and it is difficult to obtain consent.
   • When particularly necessary for public health or the sound upbringing of children and it is difficult to obtain consent.
   • When required to cooperate with a national or local authority, or a party entrusted by one, in executing duties prescribed by law, and obtaining consent may hinder the execution of such duties.
   • When the following have been announced or notified in advance and reported to the Personal Information Protection Commission:
     • That third-party provision is included in the purpose of use.
     • The items of data to be provided.
     • The method or means of provision.
     • That the User may request cessation of such provision.
     • How Users can request cessation of provision.
   • Where the Operator provides personal-related information to a third party and it is expected that the third party will acquire it as personal data, the Operator will follow the APPI and other applicable law, including any required confirmation that the individual’s consent has been obtained.
2. Notwithstanding the above, the following cases are not considered “third-party provision”:
   • When outsourcing operations to the extent necessary to achieve the purpose of use.
   • When Personal Information is transferred due to business succession such as a merger.
   • When shared use occurs with specific parties, provided that the items, scope, purpose, and responsible party are notified in advance or made easily accessible.
3. Under no circumstances will the Operator sell Users’ Personal Information to any third party.

Article 6 (Disclosure of Personal Information)

1. Upon request, the Operator will disclose the relevant Personal Information without delay. However, the Operator may withhold all or part of it in the following cases and will notify the reason:
   • If disclosure may harm the life, body, property, or other rights or interests of the User or a third party.
   • If disclosure may significantly hinder the proper execution of the Operator’s business.
   • If it violates laws or regulations.
2. A handling fee may be charged in accordance with applicable laws, including any maximum amounts or exemptions permitted by such laws.
3. As a rule, non-personal information such as logs or characteristics data will not be disclosed.

Article 7 (Correction and Deletion of Personal Information)

1. If their Personal Information is inaccurate, Users may request correction, addition, or deletion (“Correction, etc.”) through the procedure prescribed by the Operator.
2. The Operator will make the Correction, etc. without delay if it determines that the request should be accepted.
3. The Operator will notify the User without delay when the Correction, etc. has been made or denied.

Article 8 (Suspension of Use, etc.)

1. Users may request suspension of use or deletion (“Suspension, etc.”) of Personal Information if it has been handled beyond the stated purpose or acquired by improper means.
2. The Operator will investigate and, if necessary, carry out the Suspension, etc. without delay.
3. The Operator will notify the User without delay when the Suspension, etc. has been carried out or denied.
4. If the Suspension, etc. requires excessive cost or is otherwise difficult, the Operator will take necessary alternative measures to protect Users’ rights and interests.

Article 9 (Handling After Account Deletion)

1. Users may delete their account at any time using the account deletion feature in the Service. Deleting the app from a device does not delete the account or Personal Information.
2. When an account is deleted, the Operator immediately deletes that User’s profile, posts, comments, images, and other Personal Information.
3. Notwithstanding the above, information that must be retained under applicable law may be kept only for the required period.

Article 10 (Security Measures)

1. The Operator takes necessary and appropriate measures, such as access control and encryption in transit, to prevent leakage, loss, or damage of Personal Information and otherwise keep it secure.
2. When the Operator handles Personal Information using cloud services or similar services provided by businesses in foreign countries, it takes security measures based on an understanding of the personal-information protection systems of those countries.
3. Details of these measures will be provided without delay upon request.

Article 11 (Report and Notification in Case of Data Breach)

1. If a data breach or similar incident is subject to mandatory reporting under the APPI, including cases involving sensitive data, a risk of financial harm, suspected wrongful conduct, or more than 1,000 affected individuals, the Operator will report to the Personal Information Protection Commission and notify affected individuals as required by law.
2. Where reporting is required, the Operator will make a prompt initial report and generally submit a final report within 30 days after discovery, or within 60 days where wrongful conduct is suspected, and will notify affected individuals as required by law.
3. Whether reporting or notification is required, and the manner of doing so, will be determined under the APPI, its regulations, and applicable guidance of the Personal Information Protection Commission.

Article 12 (Amendment of the Privacy Policy)

1. The Operator may amend this Policy as necessary. Where applicable law requires User consent for an amendment, the Operator will obtain it.
2. The amended Policy takes effect when it is published within the Service, or on the effective date if one is specified.
3. For material changes, the Operator will notify Users in an easy-to-understand way, such as through in-app announcements.

Article 13 (Supplement for U.S. Residents)

1. If the California Consumer Privacy Act, as amended (CCPA/CPRA), applies to the Operator, covered California residents may have rights under applicable law to access or obtain disclosure of Personal Information, request deletion or correction, opt out of sale or sharing, and, where applicable, limit certain uses or disclosures of sensitive Personal Information.
2. If the Operator engages in a practice treated as a “sale” or “sharing” of Personal Information and applicable law requires an opt-out method, the Operator will provide the required method.
3. Where required by applicable law, the Operator will honor legally recognized opt-out preference signals such as Global Privacy Control. Other U.S. state privacy laws will be addressed to the extent they apply to the Operator.

Article 14 (Priority of Regional Supplements)

If this Policy conflicts with any applicable regional supplement, the supplement shall prevail for Users residing in that region.

Article 15 (Contact Information)

For inquiries regarding this Policy, please contact us as follows. Business information that must be displayed or disclosed by law, which may include an address or telephone number, will be provided without delay upon request in accordance with applicable law.

Contact: Rein Support
Email: info@reinics.com