Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
• Contact data, such as your first and last name, email address, billing and mailing addresses, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, and age.
• Profile data, such as your username or password used to establish an online account on the Service and any other information that you add to your account profile.
• Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
• User-generated content, such as profile pictures, photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Data providers, such as information services and data licensors that provide demographic and other information.
Account Aggregators, such as data relating to your financial account in financial institutions and the information about your pensions, your employer and real estate owned or rented by you.
Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
Marketing partners, such as joint marketing partners and event co-sponsors.
Third-party services, such as third-party services that you use to log into, or otherwise link to, your service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Location data when you authorize the Service to access your device’s location.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.
Software development kits. An SDK is third-party computer code that we may incorporate into our applications that may be used for a variety of purposes, including to provide us with analytics regarding the use of our applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.
Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal information to:
• provide, operate and improve the Service and our business;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.
Marketing. We, and our service providers, may collect and use your personal information for direct marketing communications. You may opt-out of our marketing communications by emailing us.
Compliance and protection. We may use your personal information to:
• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.
How we share your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, and website analytics).
Account Aggregators. Account Aggregators that, in connection with the provision of the Services, will access, collect, use, process, adapt, store, transfer and delete your information. The Account Aggregators, in connection with the provision of the Services, may access, use, gather, process, transfer and store your information in jurisdictions other than your country of residence and/or the jurisdiction(s) you use the Services in. The Account Aggregators may engage third-party service providers in connection with the Service, including without limitation the operation, maintenance, hosting and security of the Service. The Account Aggregators have the right to make anonymized data based on or derived from your information and combine the anonymized data with that of other users of the Services in a way that does not identify you or any individual person, and to use such anonymized aggregate data for any purpose.
Creditors. Creditors that use the Service, collects your information through an Account Aggregator, and use such information and the results of analysis provided by us.
Linked third-party services. If you log into the Service with another third-party service, we may share your personal information with that third-party service. The third party's use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Company or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Joint Use
We may jointly use your personal information within the scope described below.
Personal information to be shared
• End User Information
• Information on credit analysis or assessment
Names of companies that jointly use your personal information: Dwilar Japan, Inc., a Japanese corporation having its registered office at Osaka Ekimae Daini Building 12-12, 1-2-2 Umeda, Kita-ku, Osaka, Japan.
Purpose of use by parties sharing personal information: Same as the purposes outlined in “How we use your personal information”
Name, address, and representative of the party responsible for managing personal information: Dwilar, Inc., a US corporation having its principle office at 2299 Piedmont Ave., Berkeley, CA, US (CEO Yoshitaka Nakamura)
Your choices
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through another third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party
Your rights
You have the right to ask us: for a copy of your personal data and/or purpose of use; to correct, add, or delete your personal data; to restrict (stop any active) processing of your personal data; and to send you a copy of your personal data you have provided to us in a structured, machine readable format. In addition, you can object to the processing of your personal data under certain conditions (for further information, see the section below entitled “Your right to object to processing”). Please note that these rights are subject to the exceptions under the applicable local laws.
To exercise any of these rights, please contact us.
Your right to object to processing
You have the right to object at any time to the processing of your personal data which is based on our legitimate interests, including “profiling” (i.e. analyzing or predicting your behavior based on your information). When we process your personal data for direct marketing purposes, you have an absolute right to opt out of such processing. To exercise this right, please contact us.
Withdrawing consent
Wherever we rely on your consent in order to process your personal data, you have the right to withdraw that consent at any time. Such withdrawal does not affect the lawfulness of any processing per-formed pursuant to the consent given prior to the withdrawal. To exercise this right, please contact us.
Your right to complain to a supervisory authority
You have the right to lodge a complaint with a supervisory authority, in particular, in the state, province, or country where you have a habitual residence or place of work or where the alleged infringement of the applicable laws took place.
Other Sites and Services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. For information about the safeguards we have in place, please contact us.
International data transfer
We are headquartered in California, the United States and may use service providers that operate in other countries. Your personal data may be transferred from Japan to the United States, Canada, or other locations where privacy laws may not be as protective as those in your state, province, or country, and from the United States to Japan. Under the Act, the countries specified in the European Economic Area (EEA) Agreement and the United Kingdom are not considered "foreign countries" under Article 28, Paragraph 1 of the Act, and therefore are not listed here. The information based on Article 28, Paragraph 2 of the Act regarding the international transfer of your personal data is as follows:
The United States:
• System for the protection of personal information in the relevant foreign country:
Please check the systems at the following URL.
[The United States] https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/#federal
[The State of California]
https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/#california
• Measures taken by third parties located abroad to protect personal information: The third party to whom the information is provided has taken all measures necessary to comply with the eight principles of the OECD Privacy Guidelines.
Canada:
• System for the protection of personal information in the relevant foreign country:
Please check the systems at the following URL.
[Canada] https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_canada/
• Measures taken by third parties located abroad to protect personal information: The third party to whom the information is provided has taken all measures necessary to comply with the eight principles of the OECD Privacy Guidelines.
Account Aggregators will also provide personal information of End Users to Financial Institutions or other third parties to collect End User Information. However, as these Financial Institutions or other third parties vary depending on the End User, it is not possible to identify their names or countries of location at this time.
In addition, in order to select and entrust appropriate businesses as appropriate, although the contractor and the country in which it is located cannot be specified at this time, there may be cases where personal data is entrusted or provided to contractors in foreign countries other than those listed above. In this case, we may begin entrusting to a new contractor without obtaining your consent.
If the third party to whom the information was provided can be identified, you may request that we provide you with information regarding the name of the foreign country, information regarding the personal information protection system of that foreign country, and information regarding the measures taken by the third party to protect personal information.
Data retention
We retain your personal data for a period of three months maximum after your account is deleted, except where legal requirements imposing that we keep your personal data longer or less longer apply.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
How to contact us
For inquiries regarding the handling of personal information, including opinions, questions, and complaints, please contact the following.
Email: XXXX@YYYY
CEO: Yoshitaka Nakamura
