Last updated: March 2026
NEWBY Japan Co., Ltd. (“Company”) recognizes the importance of protecting customers’ personal information. In compliance with the Act on the Protection of Personal Information of Japan (the “APPI”) and other applicable laws and regulations, the Company shall appropriately handle and protect personal information in accordance with the following Privacy Policy (“Policy”).
1. Personal Information
“Personal Information” means “personal information” as defined under the APPI, namely information relating to a living individual that can identify a specific individual through descriptions contained in such information, including name, date of birth, address, telephone number, contact details, and other identifiers, as well as data relating to facial features, fingerprints, voiceprints, and insurer numbers appearing on health insurance cards or other information capable of identifying a specific individual on its own (personal identification information).
2. Methods of Collecting Personal Information
The Company may request personal information from customers when they register for services, including name, date of birth, address, telephone number, email address, bank account information, credit card information, and driver’s license information.
The Company may also collect transaction records and payment-related information containing customers’ personal information from the Company’s business partners, including information providers, advertisers, and advertising distributors.
3. Purpose of Collection and Use of Personal Information
The purposes for which the Company collects and uses personal information are as follows:
- To provide and operate the Company’s services
- To respond to inquiries from customers, including identity verification
- To send emails regarding new features, updates, campaigns, and information concerning other services provided by the Company
- To contact customers as necessary regarding maintenance, important notices, and other matters
- To identify customers who violate the Terms of Use or attempt to use the services for fraudulent or improper purposes, and to refuse their use of the services
- To allow customers to view, modify, or delete their registration information and review their usage status
- To bill customers for paid services
- For purposes incidental to the foregoing purposes of use
4. Changes to the Purpose of Use
The Company may change the purpose of use of personal information only where such revised purpose is reasonably deemed to be related to the original purpose of use.
In the event of any change to the purpose of use, the Company shall notify customers of the revised purpose or publicly announce it on the Website by the method prescribed by the Company.
5. Security Management of Personal Information
The Company shall exercise necessary and appropriate supervision over its employees to ensure the secure management of personal information against risks such as loss, destruction, falsification, and leakage.
Where the Company outsources all or part of the handling of personal information, the Company shall exercise necessary and appropriate supervision over the contractor to ensure the secure management of such information.
6. Provision of Personal Information to Third Parties
The Company shall not provide personal information to any third party without obtaining the customer’s prior consent, except in the following cases or where otherwise permitted under the APPI or other applicable laws and regulations:
- Where necessary to protect a person’s life, body, or property and obtaining the individual’s consent is difficult
- Where particularly necessary for improving public health or promoting the sound development of children, and obtaining the individual’s consent is difficult
- Where cooperation with a governmental authority, local government, or a person commissioned thereby is necessary for the execution of duties prescribed by law, and obtaining the individual’s consent may interfere with the execution of such duties
- Where the following matters have been announced or disclosed in advance and the Company has submitted the required notification to the Personal Information Protection Commission:
- The purpose of use includes provision to third parties
- The categories of data to be provided to third parties
- The means or methods of provision to third parties
- The customer may request suspension of the provision of personal information to third parties
- The method for accepting such requests
Notwithstanding the foregoing, the following cases shall not constitute provision to a third party:
- Where the Company outsources all or part of the handling of personal information within the scope necessary to achieve the purpose of use
- Where personal information is provided in connection with a business succession due to merger or other reasons
- Where personal information is jointly used with specific parties, provided that the customer is notified in advance, or is placed in a position to easily become aware, of:
- the fact of joint use,
- the categories of personal information jointly used,
- the scope of parties jointly using the information,
- the purpose of use by such parties, and
- the name of the person or entity responsible for managing the personal information
7. Disclosure of Personal Information
Where the Company is requested by an individual to disclose personal information, the Company shall disclose such information to the individual without delay.
However, the Company may decide not to disclose all or part of the information where disclosure falls under any of the following circumstances, and in such case, the Company shall notify the individual without delay of its decision not to disclose:
- Where disclosure may harm the life, body, property, or other rights or interests of the individual or a third party
- Where disclosure may significantly interfere with the proper conduct of the Company’s business
- Where disclosure would otherwise violate laws or regulations
A handling fee of JPY 1,000 shall be charged for each request for disclosure of personal information.
Notwithstanding the foregoing, information other than personal information, such as history information and characteristic information, shall in principle not be disclosed.
8. Correction and Deletion of Personal Information
Where a customer’s personal information held by the Company is incorrect, the customer may request correction, addition, or deletion of such personal information (“Correction, etc.”) in accordance with the procedures prescribed by the Company.
Where the Company determines that it is necessary to comply with such request, the Company shall make the relevant Correction, etc. without delay.
The Company shall notify the customer without delay when it has made such Correction, etc., or when it has decided not to do so.
9. Suspension of Use of Personal Information
Where a customer requests suspension or deletion of personal information (“Suspension of Use, etc.”) on the grounds that the information is being handled beyond the scope of the stated purpose of use or was obtained through improper means, the Company shall conduct the necessary investigation without delay.
Based on the results of such investigation, where the Company determines that it is necessary to comply with the request, the Company shall implement the Suspension of Use, etc. without delay.
The Company shall notify the customer without delay when it has implemented the Suspension of Use, etc., or when it has decided not to do so.
Notwithstanding the foregoing, where Suspension of Use, etc. would involve substantial costs or would otherwise be difficult to implement, and where alternative measures necessary to protect the customer’s rights and interests can be taken, the Company shall take such alternative measures.
10. Amendments to This Privacy Policy
The contents of this Policy may be amended without prior notice to customers, except where otherwise provided by laws and regulations or this Policy.
Unless otherwise specified by the Company, the amended Privacy Policy shall become effective upon posting on the Website.
11. Contact Information
Requests for disclosure, opinions, questions, complaints, and other inquiries regarding the handling of personal information should be directed to the contact information provided in the Company’s “Notation Based on the Act on Specified Commercial Transactions” or submitted through the inquiry form available on the Website.
12. Continuous Improvement
The Company shall review its operations concerning the handling of personal information as appropriate and strive for continuous improvement. The Company may amend this Policy as necessary.