Privacy Policy

This Privacy Policy is made in Japanese and translated into English. The Japanese text is the original and the English text is for reference purposes. If there is any conflict or inconsistency between these two texts, the Japanese text shall prevail.

Date of revision: October 31, 2022

Privacy Policy

This Privacy Policy is made in Japanese and translated into English. The Japanese text is the original and the English text is for reference purposes. If there is any conflict or inconsistency between these two texts, the Japanese text shall prevail.

This Privacy Policy sets forth the handling of personal information of users (hereinafter referred to as "Customers") of this website and services (hereinafter referred to as "our Services") provided by LUCA Japan Company, Limited ("LUCA Japan", "we", "us", or "our"). We recognize the importance of personal information and believe that it is our social responsibility to protect personal information. We will comply with laws, regulations, and internal rules regarding personal information, and will properly acquire, use, and manage personal information handled by us in accordance with this Privacy Policy.  

Article 1 (Personal Information)
Personal information" means "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, including subsequent amendments, hereinafter referred to as the "Personal Information Protection Act"). The term "personal information" as used in the Act on the Protection of Personal Information (Act No. 57 of 2003, as amended, hereinafter referred to as the "Personal Information Protection Act") refers to information about living individuals that includes information that can identify specific individuals by name, date of birth, address, telephone number, contact information, or other descriptions, as well as personal identification codes.
 
Article 2 (Acquisition of Personal Information)
We may obtain personal information in the following ways.
i. By having Customers enter or provide the information directly through this Web site.
ii. By having Customers directly fill out or provide the information on the account opening application form, questionnaire, etc.
iii. By having Customers directly input or provide information when using our services.
iv. By hearing from Customers through the provision of our services (for Customer calls, we may record the call for the purpose of improving the accuracy of customer service and customer correspondence).
v. By obtaining information on transaction records and settlements, including Customers' personal information, between customers and business partners, etc., including our business partners (including information providers, advertisers, and advertisement distributors, etc.), etc.
vi. Through acquisition of personal information from third parties such as database service providers.

Article 3 (Purpose of Use of Personal Information)
We use the personal information we obtain for the purposes described below.
i. To operate, provide, and improve the Company and its services
To ensure the smooth use of our services by our Customers
To compile statistical data on the use of our services To analyze Customer access history and behavior on our services, and use the results to improve the functionality of our services and conduct sales activities, etc. For planning and provision of future products or services of the Company
To respond to inquiries from Customers (including to confirm the identity of the customer).
To authenticate your identity when you log in or after logging in when you use our services
To automatically display registration information on the input screen to simplify Customer data entry
To provide various after-sales services to Customers
To provide Customers with notices and other necessary communications related to our services
To identify Customers who violate the Terms of Use or who attempt to use the service for fraudulent or unfair purposes, and to refuse their use of the service.
To allow Customers to view, change, or delete their own registration information, or view the status of their usage.
ii. To distribute advertisements Notification by e-mail or other means of new features, updates, campaigns, etc. of the service you are using and information on other services provided by the Company, and sales and marketing activities. To conduct targeted advertising (analyzing information such as service usage and access logs, etc., and displaying information and advertisements regarding products, services, etc., that match the preferences of customers) for Customers.
iii. Other purposes Notification of changes to this Privacy Policy and other important notices. To take measures to protect your rights, property, or safety, such as preventing, detecting, investigating, or responding to fraud, unauthorized access, or other wrongful acts.  

Article 4
(Personal Information to be Obtained)
We obtain the following information from Customers.
i. Name
ii. Date of birth
iii. Address
iv. Telephone number
v. E-mail address
vi. Information for determining the Customer’s suitability for our services
vii. Deposit account information
viii. Personal numbers or corporate numbers (including the personal numbers or corporate numbers (Act on the Use, etc. of Numbers to Identify Specific Individuals in Administrative Procedures (Act No. 27 of 2013, including subsequent amendments). (Act No. 27 of 2013, including subsequent amendments) (as defined in the Act on the Use, etc. of the Number to Identify Specific Individuals in Administrative Procedures (Act No. 27 of 2013).
ix. Information you register on our website or in applications provided by us
x. Information related to various inquiries to the Company xi. Any other information provided by the Customer to the Company Any other information provided by the customer to the Company.

Article 5 (Change of Purpose of Use)
1. The Company shall change the purpose of use of personal information only when it is reasonably deemed that the purpose of use is relevant to the purpose of use before the change.  
2. In the event of a change in the purpose of use, the Company shall notify the Customer or publicly announce on this website the purpose of use after the change by the method prescribed by the Company.

Article 6 (Security Control)
1. We will provide necessary and appropriate supervision of our officers and employees to ensure that personal information is securely managed against risks such as loss, destruction, alteration, and leakage of personal information.
2. We will assign an individual responsible for the management of personal information to properly manage the personal information of our Customers.  
3. Please contact the contact point specified in Article 20 for information on the security control measures taken by the Company.

Article 7 (Entrustment of Handling of Personal Information)
We may outsource all or part of the personal information to subcontractors within the scope necessary to achieve the purpose of use. In such cases, we will thoroughly screen the contractors for eligibility, stipulate confidentiality obligations in the contract, establish a system to ensure that the information is properly managed, and provide necessary and appropriate supervision.  

Article 8 (Provision of Personal Information to Third Parties)
1. We may provide your personal information to XEN Technologies Pte. For more information on Singapore's system for the protection of personal information, please visit the website of the Personal Data Protection Commission (https://www.ppc.go.jp/files/pdf/singapore_report.pdf).
2. Except in the case of the preceding paragraph and the following cases, we will not provide personal information to any third party without obtaining the prior consent of the Customer. However, this excludes cases permitted under the Personal Information Protection Law and other laws and regulations.
i. When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual
ii. Cases in which the disclosure is particularly necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person concerned
iii. Cases in which it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned
iv. Cases in which personal information is provided as a result of the succession of business due to merger or other reasons v. Other cases permitted by laws and regulations

Article 9 (Joint Use)
1. In order to provide the Service to customers, we may share Customers' personal information with our alliance partners for the Service to the extent necessary to achieve the purpose of use stipulated in Article 3.
2. In the event that we share Customers' personal information with our affiliated partners in accordance with the preceding paragraph, we shall publicly announce in advance the name of such affiliated partner, the purpose of sharing, the items of information to be shared, and the person responsible for managing the information to be shared.

Article 10 (Preparation and Use of Statistical Data)
We may create statistical data based on personal information obtained from our Customers, taking measures to ensure that specific individuals cannot be identified and that such personal information cannot be restored. Such statistical data may be used and provided to third parties in an appropriate manner in accordance with the Personal Information Protection Law.

Article 11 (Sensitive Information)
We will not acquire, use, or provide to third parties sensitive information as defined in the Guidelines for the Protection of Personal Information in the Financial Sector, etc. (information regarding personal information requiring special consideration, membership of labor unions, family origin, legal domicile, health care, etc.), except as permitted by law or regulation.

Article 12 (Disclosure of Personal Information)
1. When we are requested by an individual to notify the individual of the purpose of use or to disclose personal information or records of provision to a third party, we will notify or disclose such information to the individual without delay. However, if notification or disclosure falls under any of the following items, we may choose not to notify or disclose all or part of the information, and if we decide not to notify or disclose the information, we will notify the individual to that effect without delay. A fee of 1,000 yen (excluding tax) per case will be charged for notification of the purpose of use or disclosure of personal information or records of provision to a third party.
2. Notwithstanding the preceding paragraph, in principle, the Company will not disclose non-personal information, such as historical information and characteristic information.

Article 13 (Correction and Deletion of Personal Information)
1. If the Customer's personal information held by the Company is incorrect, the Customer may request the Company to correct, add, or delete the personal information ("Correction, etc.") in accordance with the procedures prescribed by the Company.
2. If the Company receives a request from a Customer as described in the preceding paragraph and deems it necessary to respond to such request, the Company shall correct the relevant personal information without delay.
3. When we make a correction, etc. based on the preceding paragraph, or when we decide not to make a correction, etc., we will notify the customer of this without delay. However, this shall not apply in cases where the Company is under no obligation to take action in accordance with the Personal Information Protection Law or other laws and regulations.

Article 14 (Suspension of Use of Personal Information, etc.)
1. The Company may request the suspension of use or deletion of personal information (hereinafter referred to as "suspension of use, etc.") from the individual on the grounds that the personal information is handled beyond the scope of the purpose of use, that the personal information was obtained through wrongful means, or that the rights and interests of the individual may be harmed by the handling of the personal information; or (hereinafter referred to as "Suspension of Use, etc."). If the person requests the suspension of use or deletion of his/her personal information (hereinafter referred to as "suspension of use, etc.") for any reason, the Company will conduct the necessary investigation without delay.  
2. If, based on the results of the investigation in the preceding paragraph, it is determined that the request is permitted under the Personal Information Protection Law, we will cease use of the relevant personal information without delay.
3. In the event that the Company suspends the use of personal information in accordance with the preceding paragraph or decides not to suspend the use of personal information, the Company will notify the Customer of this decision without delay.
4. Notwithstanding the preceding two paragraphs, in cases where the Suspension of Use, etc. involves a large amount of cost or it is otherwise difficult to implement the Suspension of Use, etc., and alternative measures necessary to protect the rights and interests of the Customer can be taken, these alternative measures shall be implemented. However, this shall not apply in cases where we are not obligated to take such measures under the Personal Information Protection Law or other laws and regulations.

Article 15 (Modification of Privacy Policy)
1. The contents of this Privacy Policy may be changed by posting on this Web site or by other appropriate means of dissemination, except as otherwise provided in laws and regulations or in this Policy.
2. Unless otherwise specified by the Company, the revised Privacy Policy shall take effect from the time it is posted on the Website.

Article 16 (Use of Cookies and Other Technologies)
Our services may use cookies and similar technologies. If the Customer wishes to disable cookies, the Customer may do so by changing the settings on your web browser. However, if the Customer disables cookies, the Customer may not be able to use some of the features of our services.

Article 17 (SSL (Secure Sockets Layers)/TLS (Transport Layer Security))
1. When we ask Customers to provide personal information through this website or our services, we may use SSL (Secure Sockets Layer)/TLS (Transport Layer Security) encryption or equivalent security technology to prevent eavesdropping by third parties during the transmission process. SSL (Secure Sockets Layer/TLS (Transport Layer Security) encryption or equivalent security technology may be used to prevent eavesdropping by third parties during transmission.
2. Depending on Cutomer’s computer environment, the Customer may not be able to use these technologies. In such cases, we may indicate that security cannot be ensured during communication.

Article 18 (Use of Google Analytics)
We may use Google Analytics to monitor the use of this website. Google Analytics uses first-party cookies to collect information about your visits to this site without identifying you personally. The manner in which access information is collected and used is set forth in the Google Analytics Terms of Service and the Google Privacy Policy. For more information about Google Analytics, please visit the following page: https:// marketingplatform.google.com/about/analytics/ (Google Analytics™ is a trademark of Google Inc.)

Article 19 (Provision of Accurate Information)
1. We shall be notified without delay of any change in the Customer’s name, address or other personal information.
2. When a Customer changes his/her personal information, the Customer shall send the Company a document, etc., together with the original or a copy of a document that confirms the details of the change.

Article 20 (Inquiries)
For requests for disclosure, opinions, questions, complaints, details of procedures stipulated in Articles 12, 13 or 14, and other inquiries regarding the handling of personal information, please contact us by e-mail at the following address.  

Article 21 ( Advertisement distribution by third-party distributors )
In order to use the advertising distribution service provided by a third party, as described below, the third party may acquire and use information such as your visit and action history to the website operated by the Company ("Visit and Action History Information") by means of cookies, etc.
The Company shall not be liable for any loss or damage arising from the use of such information. The third party may acquire and use information such as your visit and action history to our website ("Visit and Action History Information") through cookies, etc. as follows The Visits and Activity History Information acquired by such third party through such tools will be handled in accordance with the privacy policy of such third party. Please refer to the websites of the third-party providers for information on the use of the Visits and Activity History Information and how to stop (opt-out) of the cookie function.
Name: Facebook SDK
Privacy Policy: https://www.facebook.com/policy.php/
Opt-out: https://www.facebook.com/policies/cookies/

FINOLAB  
LUCA Japan K.K., Otemachi Building, 4th Floor, 1-6-1 Otemachi, Chiyoda-ku, Tokyo 100-0004, Japan  
E-mail address: privacy@luca.inc

Date of Establishment: February 4, 2022
Date of revision: October 31, 2022
LUCA Japan Company, Limited. FINOLAB,  
Otemachi Building 4F, 1-6-1 Otemachi, Chiyoda-ku, Tokyo 100-0004
Japan Representative Director Keiko Sydenham