Privacy Policy

Eftax Co., Ltd. (the “Company”) sets forth this Privacy Policy (this “Policy”) with regard to the treatment of user information, including but not limited to personal information, in the course of the performance of HaloDish provided by the Company (the “Service”), as follows;

1. User Information to be Collected and Method of Collection

For purposes of this Policy, “User Information” means information identifying users, history of actions in the Service and other information created or accumulated in relation to users or their devices, that are collected by the Company pursuant to this Policy.

The User Information that the Company may collect in the course of the Service is as follows, depending on the method of collection.

(1) Information provided by the user

The information to be provided by the user for or through the use of the Service is as follows:

• name, date of birth, sex, occupation and other profile information;
• e-mail address, telephone number, address and other contact information;
• images, reviews and comments
• information transmitted by the user through entrance forms or other methods specified by the Company;

(2) Information automatically collected by the Company in the course of the user's use of the Service

The Company may collect information regarding access to or use of the Service, which includes the following.

• referer
• IP address
• information regarding server access logs
• cookies, ADID, IDFA and other identifiers

(3) Information collected by the Company with the consent respectively given by the user in the course of the user's use of the Service

If the user respectively gives the consent in the manner set forth in Section 3.1, the Company may collect the following information from the device used by the user.

• location information

(4) Use of cookies

Cookies are the function that sends small file data from a web server to User’s browser and allows Users to refer to the contents such as visit history. The Company may use cookies to improve the accessibility and convenience of the Service and may collect information such as browsing status. However, this data may not identify individual information, such as name and date of birth. If Users do not wish to use cookies, it is able to change the settings on User’s browser at any time. The procedure for enabling or disabling cookies varies depending on each browser.

(5) Acquisition of cookies and user behavioral information

The Company implements access analysis tools provided by third-party companies for the purpose of improving and enhancing the Service. These tools use cookies and other tracking technologies (such as web beacons) to measure User’s site usage and track the number of ad displays and clicks. While cookies can identify a User's browser, they cannot identify individuals. In addition, the collected data may be provided to third-party companies for data analysis, ad delivery, or social media purposes. This data is stored on the servers of the respective third-party companies and is managed in accordance with their privacy policies. If Users wish to disable (opt-out of) cookie function, please see 4.1 of “4.Outside Transmissions” for more details.

(6) Information about Online Store Purchases

When the User makes a purchase of products through the online store of the Service, payments are processed by third-party payment providers such as credit card companies. Therefore, the Company does not directly obtain information related to purchases (such as credit card numbers or account numbers).

2. Purpose of Use

Specific purposes of use of the User Information for the provision of the Service are as follows:

(1) provision, maintenance, protection and improvement of the Service, including but not limited to acceptance of registration for the Service, identification and record of user settings;

(2) measurement of traffic and actions of the user

(3) distribution, display and measuring effect of advertisements

(4) guidance and response to inquiries relating to the Service;

(5) addressing a violation of rules, regulations or policies of the Company relating to the Service (the “Rules”); and

(6) notice of modification to the Rules or related matters.

3. Method of Notice, Publication and Consent; Method of Requiring Discontinuance of Use

3.1 User's Consent

The user's consent must be obtained before collecting the following User Information;

• location information

3.2 Discontinuation of Collection or Use

The user may require the Company to discontinue the collection or use of the all or a part of the User Information by choosing the applicable setting as prescribed in the Service, and promptly upon such request the Company shall discontinue such collection or use in accordance with the rules prescribed by the Company. Certain User Information is necessary to be collected or used for providing the Service, and the Company shall discontinue such collection or use of the User Information only if the user withdraws from the Service pursuant to the procedures as determined by the Company.

4. Outside Transmissions

The following affiliated parties may save cookies in the user's devices and thereby accumulate and use the User Information.

5. Provision of Personal Information to Third Parties

The Company shall not provide to any third party (including the same outside Japan) personal information contained in the User Information without the prior consent of the user, except where such provision is required due to any of the following circumstances:

(1) Authorized Handling

The Company authorizes such third party to handle the personal information in whole or in part to the extent necessary to accomplish the purpose of the use;

(2) Business Transfer

The personal information is provided through a business transfer by way of merger or other similar transactions;

(3) Affiliated Party

The personal information is provided to an affiliated party to Section 4 hereof;

(4) Cooperation with Governmental Organizations

The Company is required to cooperate with state or local governmental organizations or their agents to perform their duties or obligations pursuant to applicable laws and regulations, and such performance is likely to be precluded if the consent of the user must be obtained; and

(5) As Permitted by Law

In addition to the foregoing, the Company is entitled to provide information pursuant to the Act on the Protection of Personal Information (the "Act") or other applicable laws and regulations.

6. Disclosure of Personal Information

Upon request from the user to disclose its personal information under the Act, the Company shall, without delay, disclose to the user such information (or, in the event of non-existence of such personal information, notify the user to that effect) after confirming that the request is made by the user itself, to the extent required to do so under the Act and other applicable laws and regulations.

7. Correction and Suspension of Use of Personal Information

7.1 Requests for Correction or Suspension

If the Company is required pursuant to the provisions of the Act by the user to (1) correct the content of personal information due to the reason that such information is false, or (2) suspend use of personal information due to the reason that such information is being handled beyond the scope of the purpose of the use previously made public, or has been collected in a fraudulent or otherwise illicit manner, then the Company shall, without delay after confirming that the request is made by the user itself, conduct an appropriate investigation and based upon the results thereof, correct the content or suspend the use of such personal information, and notify the party to that effect. In cases where the Company decides not to make such correction or suspension of the use, the Company shall notify the user to that effect.

7.2 Requests for Deletion

In the event that the Company is required by the user to delete its personal information and has determined that it is necessary to accept such request, the Company shall, after confirming that the request is made by the user itself, delete such personal information and notify the party to that effect.

7.3 Exceptions

Should the Company not be obligated to correct, or suspend use of, information under the Act and other applicable laws and regulations, Sections 7.1 and 7.2 shall not apply.

8. Inquiries

Any suggestions, questions, complaints, or other inquiries on the handling of the User Information must be submitted to:

9. Procedure to Amend this Privacy Policy

The Company may amend this Privacy Policy as necessary; provided, however, that in the event of an amendment to this Privacy Policy that legally requires the consent thereto of the users, this Privacy Policy after the amendment shall be applied only to the users that have given the consent in the manner specified by the Company. In the event of any amendment to this Privacy Policy, the Company shall inform the effective time and content of the amended Privacy Policy by posting on the website of the Company to notify the users.

[Prescribed on 13 October, 2023]

[Revised on 19 January, 2024: added 1-(6) Information about Online Store Purchases.]