Privacy Policy

1. Acquisition of Personal Information
Happy Elements Holdings Limited (“Company”) shall acquire personal information by legal and fair means.
2. Purposes of Use of Personal Information
The Company shall use the acquired personal information for the below purposes of use.
(1)To provide services of the Company and the affiliated companies of the Company (collectively “Company Group”);
(2)To provide support and communications for customers and information on the products and services of the Company Group;
(3)To perform services related to hiring;
(4)To answer different kinds of inquiries;
(5)For marketing activities;
(6)Use by processing in a form where an individual cannot be identified as materials for analysis of use and improvement of services;
(7) For advertising use, IDFA may be acquired with iOS application or Android advertising ID may be acquired with Android application. As well, for the purpose of improvement of services for applications, such ID and applications may be linked with data in the Company’s possession or permanent device ID. Such IDs can be reset from the settings of devices; and
(8) For other purposes determined separately in the services of the Company
3. Restrictions based on Purposes of Use
The Company shall handle the acquired personal information within the scope required to achieve the purposes of use except in cases falling under any of the below.
(1)If there is the consent of the subject customer;
(2)If disclosure or provisions is required under laws and regulations;
(3)If required for the protection of the life, wellbeing or assets of a person, and the consent of the subject person is difficult to obtain; or
(4)If it is necessary to cooperate with the performance of a public service conducted by the national or local government, and there is a possibility that obtaining the consent of the subject person might interfere with the performance of the relevant services.
4. Delegation to Third Parties
If the Company delegates the handling of personal information to a third party, the Company shall appropriately manage or supervise the delegated party.
5. Joint Use of Personal Data
The Company shall jointly use the personal data in its possession as follows.
Items for personal data to be used jointly Name, address, date of birth, telephone number, email address, inquiries from customers, applications, other use of the services of the Company Group and other items required in “Purposes of Use of Joint Users” below
Scope of joint users Company Group
Purposes of use of joint users (1) Marketing activities
(2) Advertising and sales promotion activities
(3) Inquiries from customers
Name of the person having responsibility for the management of personal data Happy Elements Asia Pacific Co., Ltd.
6. Disclosure to Third Parties of Personal Information
The Company shall not provide personal information to any third party without the prior consent of the subject person except as provided for in laws including the Personal Information Protection Act. Provided, however, that the same shall not apply in the following cases.
(1)If disclosed or provided in a form where an individual cannot be identified such as statistical data;
(2)If delegating services to a third party within the purposes of use provided for in Section 2; or
(3)If entrusting personal information of a customer who is using for-charge services at a financial institution, etc. with the purpose of invoicing the user fees to the customer using for-charge services.
7. Management of Personal Information
The Company shall appropriately and safely manage the personal information of the customer.
8. Amendment of Privacy Policy
The Company may amend the Privacy Policy.
For amendment to the Privacy Policy, the amended Privacy Policy shall become effective at the time of being posted on the website of the Company(http://www.happyelements.jp/).
If personal information is provided to the Company after the amendment of the Privacy Policy by a customer, it shall be treated as the customer consenting to the amended Privacy Policy.
9. Disclosure of Personal Information or Revision, Addition or Deletion of Content
If there is a request for disclosure, or revisions, addition or deletion of content (“Disclosure, etc”) for personal information in the possession of the Company, the Company shall promptly respond to such request to a reasonable extent. The person desiring the Disclosure, etc. shall contact the inquiries contact in Section 10.
10. Inquiries contact
Happy Elements Asia Pacific Co., Ltd.
6F Ark Hills South Tower, 1-4-5, Roppongi, Minato-ku, 106-0032 Japan