Haya pass Co., Ltd. (hereinafter referred to as "the Company") establishes the following Privacy Policy (hereinafter referred to as "this Policy") regarding the handling of users' personal information in connection with the services provided on this website (hereinafter referred to as "the Service").

Article 1 (Personal Information)

"Personal Information" refers to personal information as defined by the Act on the Protection of Personal Information. It means information about a living individual that can identify a specific individual through the name, date of birth, address, telephone number, contact information, or other descriptions contained in such information, as well as data related to physical appearance, fingerprints, voiceprints, and information such as health insurance card numbers that can identify a specific individual on its own (Personal Identification Information).

Article 2 (Methods of Collecting Personal Information)

When users register for use, we may ask for personal information such as name, date of birth, address, telephone number, email address, bank account number, credit card number, and driver's license number. We may also collect transaction records and payment-related information containing users' personal information, which were made between users and our partners (including information providers, advertisers, and ad delivery destinations; hereinafter referred to as "Partners"), from such Partners.

Article 3 (Purpose of Collecting and Using Personal Information)

The Company collects and uses personal information for the following purposes:

• 1. To provide and operate the Company's services
• 2. To respond to inquiries from users (including identity verification)
• 3. To send emails regarding new features, updates, campaigns, etc., for services the user is using, and to provide information about other services offered by the Company
• 4. To contact users as necessary regarding maintenance, important notices, etc.
• 5. To identify users who violate the Terms of Use or attempt to use the service for fraudulent or improper purposes, and to refuse service to such users
• 6. To enable users to view, modify, delete their own registered information, and view their usage status
• 7. To bill users for usage fees for paid services
• 8. For purposes incidental to the above purposes

Article 4 (Change of Purpose of Use)

1. The Company may change the purpose of use of personal information only when it is reasonably deemed to be related to the original purpose.
2. If the purpose of use is changed, the Company shall notify the user of the new purpose by the method specified by the Company or publish it on this website.

Article 5 (Provision of Personal Information to Third Parties)

1. The Company shall not provide personal information to third parties without the user's prior consent, except in the following cases. However, this excludes cases permitted by the Personal Information Protection Act or other laws and regulations.

• 1. When necessary to protect human life, body, or property, and obtaining the individual's consent is difficult
• 2. When particularly necessary for improving public health or promoting the sound development of children, and obtaining the individual's consent is difficult
• 3. When cooperation is necessary for a national agency, local government, or their entrusted party to perform duties prescribed by law, and obtaining consent would likely impede the performance of such duties
• 4. When the following matters have been notified or publicly announced in advance, and the Company has notified the Personal Information Protection Commission:
  • 1. The purpose of use includes provision to third parties
  • 2. The items of data to be provided to third parties
  • 3. The means or method of provision to third parties
  • 4. Cessation of provision to third parties upon the individual's request
  • 5. The method for accepting the individual's request

2. Notwithstanding the preceding paragraph, the recipient of the information shall not be deemed a third party in the following cases:

• 1. When the Company entrusts all or part of the handling of personal information to a third party within the scope necessary to achieve the purpose of use
• 2. When personal information is provided due to a business succession resulting from a merger or other reason
• 3. When personal information is jointly used with specific parties, provided that the individual has been notified in advance or placed in a position to readily ascertain the following: the fact of joint use, the items of personal information subject to joint use, the scope of parties jointly using the information, the purpose of use by such parties, and the name of the party responsible for managing the personal information.

Article 6 (Disclosure of Personal Information)

1. When requested by an individual to disclose their personal information, the Company shall disclose it to the individual without delay. However, disclosure may be refused in whole or in part if disclosure would fall under any of the following categories. If disclosure is refused, the individual shall be notified without delay. A fee of 1,000 yen per request shall be charged for disclosure of personal information.

• 1. When disclosure could harm the life, body, property, or other rights and interests of the individual or a third party.
• 2. When disclosure could significantly impede the proper execution of the Company's business.
• 3. When disclosure would otherwise violate laws or regulations

2. Notwithstanding the preceding paragraph, information other than personal information, such as usage history and characteristic information, shall not be disclosed in principle.

Article 7 (Correction and Deletion of Personal Information)

1. Users may request the Company to correct, add, or delete (hereinafter referred to as "correction, etc.") their personal information held by the Company through the procedures established by the Company, if such personal information is incorrect.
2. If the Company receives a request from a user under the preceding paragraph and determines that it is necessary to comply with the request, the Company shall correct, add, or delete the relevant personal information without delay.
3. If the Company corrects, adds, or deletes personal information based on the preceding paragraph, or decides not to do so, the Company shall notify the user without delay.

Article 8 (Suspension of Use of Personal Information)

1. If the Company receives a request from the individual to suspend or erase the use of their personal information (hereinafter referred to as "Suspension of Use, etc.") on the grounds that the personal information is being handled beyond the scope of the purpose of use or was obtained by improper means, the Company shall conduct the necessary investigation without delay.
2. Based on the results of the investigation in the preceding paragraph, if the Company determines that it is necessary to comply with the request, it shall suspend the use of the relevant personal information without delay.
3. When the Company suspends use, etc. based on the preceding paragraph, or decides not to suspend use, etc., it shall notify the user without delay.
4. Notwithstanding the preceding two paragraphs, if suspending use, etc. would incur substantial costs or is otherwise difficult, and if alternative measures necessary to protect the user's rights and interests can be taken, the Company shall implement such alternative measures.

Article 9 (Changes to the Privacy Policy)

1. The content of this Policy may be changed without notice to users, except where otherwise stipulated by laws and regulations or this Policy.
2. Unless otherwise specified by the Company, the revised Privacy Policy shall take effect upon its posting on this website.

Article 10 (Contact Information)

For inquiries regarding this Policy, please contact the following office:
Address: 6-10-12 Nishi-Nippori, Arakawa-ku, Tokyo 136-0033
Company Name: Haya pass Co., Ltd.
Representative Director: E Katayama
Department in Charge: Personal Information Handling Office
Email Address: privacy@haya-pass.co.jp