avaren Co., Ltd. (the "Company") shall handle the information of all persons ("Users") who use the services provided by the Company (the "Service") as set forth below.
Article 1 (Introduction)
By using the Service, Users are deemed to have agreed to the terms and conditions of this Privacy Policy and to have consented to the Company's processing of the information it obtains from Users for the purposes described below; please therefore read this Privacy Policy carefully. If you do not agree to the terms of this Privacy Policy, please do not use the Service.
The Company shall comply with the Act on the Protection of Personal Information (Japan) (the "APPI") and other applicable laws, regulations and guidelines, and shall handle Users' Personal Information appropriately.
This Privacy Policy applies to the information of Users obtained on the websites operated by the Company.
Article 2 (Purposes of Use, etc.)
In providing the Service, the Company obtains and uses the following information to the extent necessary to accomplish the purposes set forth in each of the following items. The types of information collected, processed or used may vary depending on the services used by the User. The information, including Personal Information, collected by the Company in the Service is as set forth below; if you do not provide such information, you may be unable to use all or part of the Service.
Account Information
Information obtained: e-mail address; where logging in with an external account, the identification information of that account; and the member ID (internal identifier) designated by the Company
How obtained: provided by the User and obtained automatically (through the member authentication mechanism)
Purpose of use: identity verification; creation, authentication and management of Accounts; prevention of use in a manner that violates the Terms of Use of the Service; sending of login links and other notices necessary for the operation of the Service; and sending of information regarding the Company's products and services (the sending of such information may be stopped at the User's request)
Information Regarding Purchases and Orders
Information obtained: Products purchased; amount; currency; the country or region determined to have been accessed from at the time of purchase; type of payment method; receipt URL; customer ID relating to payment; Viewing Rights to Digital Content obtained and the route by which they were obtained (purchase, gift or Serial Code); and records relating to issuance and redemption in Gift Purchases
How obtained: obtained automatically
Purpose of use: provision and management of Products (Viewing Rights to Digital Content); handling of payments, refunds, withdrawal of applications, etc.; issuance of Serial Codes and receipt URLs in Gift Purchases and management of their redemption; prevention of unauthorized use; responding to inquiries; surveys of usage trends; and performance of tax, accounting and other legal obligations
Information Regarding Delivery (when purchasing physical products)
Information obtained: name, delivery address, telephone number and order details
How obtained: provided by the User (obtained through the external system used for the delivery of goods)
Purpose of use: delivery of Products (including the provision of delivery address information to logistics contractors); communications such as order confirmations and shipping notices; and responding to inquiries
Information Regarding Payment
Information obtained: The Company does not obtain credit card numbers or other payment information. Such information is entered directly into the payment processors (such as Stripe, Shopify and KOMOJU) on the payment screen and is obtained and retained by the payment processors.
How obtained: provided directly by the User to the payment processor
Purpose of use: settlement of the purchase price (the handling of payment information by the payment processors is governed by the privacy policy of each such company)
Access and Country-of-Location Information
Information obtained: IP address and information regarding the country or region of location determined from the IP address
How obtained: obtained automatically
Purpose of use: determination of the Eligible Sales Regions of the Service and, based on that determination, determination of the contracting party, price display and payment methods; prevention of unauthorized use by cross-checking the result of that determination against the country or region of the billing address at the time of payment; and prevention of unauthorized access by bots and the like
Information Regarding Inquiries
Information obtained: the User's e-mail address and other information entered in the inquiry form, and any additional matters for confirmation requested by the Company
How obtained: entered by the User (Note: the e-mail address alone may be obtained automatically by the mail client.)
Purpose of use: responding to inquiries and verifying the identity of the User
In-Service Information and Statistical Information
Information obtained: information regarding the status of use of the Service (access date and time, page transitions, etc.), identifiers such as Cookies, browser and device type, and referrer URL
How obtained: obtained automatically
Purpose of use: maintaining and improving the stability and convenience of the Service; surveys and analysis of usage trends; and measuring the effectiveness of advertising regarding the Company's products and services
Information Regarding Errors and Defects
Information obtained: technical information regarding errors that occur during use of the Service
How obtained: obtained automatically
Purpose of use: detection and remediation of defects, and improvement of the stability of the Service
Article 3 (Provision to Third Parties)
(1) The Company may, to the extent necessary to achieve the purposes of use set forth in this Privacy Policy, entrust all or part of the handling of Personal Information to third parties (for example, payment processing agents, logistics providers entrusted with the delivery of goods, cloud service providers, providers of systems for site delivery and protection against unauthorized access, e-mail delivery providers, providers of system defect monitoring, providers of inquiry forms and other providers of customer services). In such cases, the Company shall exercise necessary and appropriate supervision over the contractors, such as by concluding agreements with the contractors regarding the handling of Personal Information.
(2) When Digital Content is purchased from outside Japan, Stripe (Sold through Link, LLC or such other entity as Stripe displays as the seller) shall be the seller, and the name, billing address, card information and other information entered by the User on the payment screen shall be obtained by Stripe on its own responsibility and handled in accordance with Stripe's privacy policy. The Company receives from Stripe information regarding the completion of payment, the receipt URL, the customer ID relating to payment and the country or region of the billing address.
(3) The Company may include in the Service tools managed and provided by third parties for the purpose of analyzing usage status and the like. The content of the information transmitted to third parties through these tools, the recipients and the purposes of use are as set forth in Article 7.
(4) The Company may be compelled to disclose Users' Personal Information pursuant to laws and regulations, legally binding court orders, or orders from investigative authorities or supervisory agencies issued through due process. In addition, in the cases set forth in the items of Article 27, Paragraph 1 of the APPI, the Company may provide Personal Information to third parties without the consent of the individual.
(5) In the event of a merger, acquisition, business transfer such as the sale of all or part of the Company's assets, bankruptcy, corporate reorganization, liquidation or any other similar proceeding involving the Company, the Company may transfer Users' information to the third party succeeding to the Company's assets and rights.
Article 4 (Security Management of Information)
The Company shall take necessary and appropriate measures and exercise supervision with respect to its officers, employees and others, and, where the handling of Personal Information is entrusted externally, with respect to its contractors, in order to prevent the leakage, loss, damage or the like of Personal Information. The Company will respond without delay regarding the specific details of the security management measures it has implemented upon contact at the contact point set forth in Article 16.
However, the Company cannot guarantee the complete security of data transmission over the Internet. The Company's liability in the event that a User suffers damage due to unauthorized access, hacking or any other cause shall be governed by the provisions of the Terms of Use.
In the event of a leakage, loss or damage of Personal Data or any other incident that poses a significant risk of harm to the rights and interests of Users, the Company shall, in accordance with the APPI and other applicable laws and regulations, report to the Personal Information Protection Commission of Japan or other competent authorities, notify the individuals concerned, and take other necessary measures.
Article 5 (Retention Period)
The Company shall not retain Users' Personal Information beyond the period necessary to accomplish the purposes of use for which the Personal Information was collected. Personal Information that is no longer needed shall be deleted from the Company's systems and other recording media, or measures shall be taken to appropriately anonymize such information so that it can no longer be identified; provided, however, that this shall not apply where retention is required in order to comply with legal obligations.
Article 6 (Requests Regarding Personal Information, etc.)
Upon receiving a request from an individual regarding retained Personal Data for notification of the purpose of use, disclosure (including disclosure of records of provision to third parties), correction, addition or deletion, suspension of use or erasure, or suspension of provision to third parties, the Company shall respond without delay, after verifying the identity of the individual, in accordance with the provisions of the APPI. For requests for notification of the purpose of use and for disclosure, the Company may charge a fee prescribed by the Company. Please note that if all Personal Information is deleted, the Account and any Viewing Rights already obtained may be forfeited. As the Company does not provide a function allowing Users to delete their Accounts and Personal Information themselves, if you wish to request deletion, please contact the contact point set forth in Article 16.
Article 7 (Transmission of Information to External Parties and Use of Information Collection Modules)
The Company uses the services (information collection modules) provided by the following third parties for the purposes of providing the Service, surveying usage trends, ensuring the security of the Service and processing payments. Through these services, the following information is transmitted from the User's device to the relevant third party. The names of the recipient providers, the content of the information transmitted and the purposes of use are as set forth below. For the handling of information by each provider, please refer to the privacy policy and other documents of each provider.
Access Analysis Tool
Recipient: Google LLC (Google Analytics (GA4))
Information concerned: information regarding the status of use of the Service (access date and time, page transitions, etc.), identifiers such as Cookies, browser and device type, referrer URL, IP address, and the member ID (internal identifier) designated by the Company
Purpose of use: The Company's purposes of use are the analysis of usage trends to improve the quality of the Service and the measurement of the effectiveness of advertising regarding the Company's products and services. For the purposes of use by Google LLC, please refer to its privacy policy (https://policies.google.com/privacy). The collection of information by Google Analytics can be stopped by means of the Google Analytics Opt-out Add-on (https://tools.google.com/dlpage/gaoptout).
Error Monitoring Tool
Recipient: Functional Software, Inc. (Sentry; privacy policy: https://sentry.io/privacy/)
Information concerned: technical information regarding errors that occur during use of the Service, and the member ID (internal identifier) designated by the Company
Purpose of use: detection and remediation of defects, and improvement of the stability of the Service
Bot Protection Tool
Recipient: Cloudflare, Inc. (Cloudflare Turnstile; privacy policy: https://www.cloudflare.com/privacypolicy/)
Information concerned: IP address, information regarding the browser and device, and information regarding operations on the relevant screen
Purpose of use: detection and prevention of unauthorized registration and access by automated programs
Payment-Related Tools
Recipient: Stripe, Inc. and its affiliates (Stripe; privacy policy: https://stripe.com/privacy); Shopify Inc. and its affiliates (Shopify; when purchasing physical products; privacy policy: https://www.shopify.com/legal/privacy); and DEGICA Co., Ltd. (KOMOJU; privacy policy: https://ja.komoju.com/privacy/)
Information concerned: IP address, information regarding the browser and device, information regarding operations in the payment procedure, and the member ID (internal identifier) designated by the Company
Purpose of use: execution of payment processing, and detection and prevention of fraudulent payments
Authentication and Membership Platform Tool
Recipient: Google LLC (Firebase Authentication; privacy policy: https://policies.google.com/privacy)
Information concerned: e-mail address; where logging in with a Google account, the identification information of that account; IP address; and information regarding the browser and device
Purpose of use: authentication of members and management of Accounts
Inquiry Form
Recipient: Tally BV (Tally; privacy policy: https://tally.so/help/privacy-policy)
Information concerned: information entered in the inquiry form, IP address, and information regarding the browser and device
Purpose of use: receipt of and response to inquiries
Article 8 (Stopping the Transmission of, and Deleting, Personal Information)
The Service does not provide a function (such as a so-called Cookie consent banner) for individually stopping the transmission of information described in the preceding Article. If you wish to stop the transmission of information, please disable or delete Cookies through your browser settings or use the opt-out means described in the preceding Article; provided, however, that in such case you may be unable to use some functions of the Service.
In addition, the Service does not provide a function allowing Users to directly delete Personal Information on the Company's servers themselves. If you wish to have your Personal Information deleted, please contact the contact point set forth in Article 16 in accordance with the provisions of Article 6.
Article 9 (Use of Cookies)
On the websites provided by the Company as the Service, the Company may use Cookies in order to provide better services to Users. Information obtained through Cookies does not, by itself, immediately identify a specific individual, but it may be possible to identify a specific individual by combining it with other information. The Company uses information obtained through Cookies and the like within the scope of the purposes of use set forth in this Privacy Policy. If a User does not wish to receive Cookies, the User may refuse to accept Cookies through the User's browser settings; provided, however, that in such case the User may be unable to use some functions of the Service. Note: A Cookie is information sent from a server computer to the User's browser and stored on the hard disk of the computer used by the User.
Article 10 (Cross-Border Transfer of Information)
In providing the Service, the Company uses the external providers described in Articles 7 and 13, and information regarding Users is transferred to the United States of America, Ireland, Canada and Belgium, where these providers are located. The systems for the protection of personal information in these countries can be confirmed on the website of the Personal Information Protection Commission of Japan (https://www.ppc.go.jp/enforcement/infoprovision/laws/).
The measures taken by each transferee provider for the protection of personal information are as set forth in the privacy policies and other documents published by each such company (as described in Articles 7 and 13).
By using the Service, Users shall be deemed to have consented to the cross-border transfer described above.
Article 11 (Policy Regarding Children)
The Service is intended to be used by minors only with the consent of their legal representatives; however, at present, the Service does not provide a function for verifying the age of Users or whether the consent of a legal representative has been obtained. If the Company becomes aware that it has obtained Personal Information from a minor, the Company shall, as necessary, confirm whether the consent of the legal representative has been obtained, and if such consent cannot be confirmed, the Company shall, as promptly as possible, delete the information obtained or take other appropriate measures.
In addition, the Service is not directed at children under the age of 13 (or under the age of 14 for persons residing in the Republic of Korea), and the Company does not knowingly obtain Personal Information from such children. If the Company becomes aware that it has obtained Personal Information of such children, the Company shall take the same measures as described in the preceding paragraph.
Article 12 (Rights of California Residents)
California Civil Code Section 1798.83 permits residents of California to request certain information from the Company regarding the disclosure of personal information to third parties for direct marketing purposes. The Company does not disclose or share Users' Personal Information for third parties' direct marketing purposes.
Where the California Consumer Privacy Act (California Civil Code Section 1798.100 et seq., including as amended by the California Privacy Rights Act (CPRA); hereinafter the "CCPA") applies to the Company, residents of California have the following rights with respect to their personal information held by businesses.
The right to know the categories and specific pieces of personal information about them that the Company has collected, the categories of sources from which it was collected, the purposes for collecting or sharing it, and the categories of third parties with whom it is shared
The right to request a copy of their personal information held by the Company by electronic means
The right to know whether the Company has "sold" or "shared" (as defined in the CCPA) their personal information, and the right to opt out of such sale or sharing (the Company does not sell Users' Personal Information to third parties for consideration)
The right to know whether the Company has disclosed their personal information to third parties for a business purpose, and the categories of personal information disclosed
The right to request the deletion of their personal information where the requirements of applicable law are met, and the right to request the correction of inaccurate personal information
The right to request that the use and disclosure of their Sensitive Personal Information be limited to the extent necessary
The right not to be subjected to discriminatory treatment for exercising these rights
If you wish to exercise one or more of these rights, please contact the Company using the contact information set forth in Article 16. You may also designate an agent registered with the California Secretary of State to contact the Company on your behalf. The agent must have obtained written permission to contact the Company on your behalf. Where verification is possible, the Company will match the identifying information provided by the User against the Personal Data already held by the Company; provided, however, that if the Company cannot verify the User's identity from the information it already holds, the Company may request additional information.
Article 13 (Rights of Residents of the Republic of Korea (South Korea))
Users residing in the Republic of Korea may have the following rights under the Personal Information Protection Act of Korea.
The right to be informed of the processing of their personal information (Article 4, Item 1 of the Personal Information Protection Act)
The right to confirm the status of processing of their personal information and to request access thereto (including the issuance of copies) (Article 35 of the Personal Information Protection Act)
The right to request the suspension of processing of their personal information (Article 37 of the Personal Information Protection Act)
The right to request the correction or deletion of their personal information (Article 36 of the Personal Information Protection Act)
The right to obtain remedies through prompt and fair procedures for any damage arising from the processing of their personal information (Article 39 of the Personal Information Protection Act)
In addition, pursuant to Article 26, Paragraph 2 of the Personal Information Protection Act of Korea, the names of the principal contractors to which the Company entrusts the handling of personal information in providing the Service, the details of the entrusted work and the scope of entrustment are as follows.
Google LLC (Firebase / Google Cloud): provision of the membership platform, database and servers (operated in the Tokyo region)
Cloudflare, Inc.: site delivery, content delivery and storage, determination of the country of access, and protection against unauthorized access
Stripe, Inc. and its affiliates (Stripe Payments Company, Stripe Technology Europe, Ltd. and Sold through Link, LLC): payment processing for Digital Content (for purchases from overseas, Sold through Link, LLC is the seller (Merchant of Record))
Twilio Inc. (SendGrid): sending of authentication e-mails and the like
Google LLC (Google Analytics): measurement and analysis of the status of use of the Service
Functional Software, Inc. (Sentry): error monitoring
Tally BV (Tally): provision and operation of the inquiry form
Shopify Inc.: provision of the online store for physical products, and management of order, payment and delivery address information
All of the above contractors are located outside the Republic of Korea (principally in the United States of America, Ireland, Canada, Belgium and Japan), and Users' personal information is transferred to such contractors via the Internet from time to time in the course of providing the Service. The items transferred, the purposes of use by the transferees and the retention periods are as set forth in Articles 2, 5 and 7 of this Privacy Policy. Users may refuse the cross-border transfer by notifying the contact point set forth in Article 16; provided, however, that in such case Users may be unable to use the Service.
If you wish to exercise these rights, please contact the contact point set forth in Article 16. Users may also file a report or apply for dispute mediation with the Personal Information Protection Commission of Korea (Article 62 of the Personal Information Protection Act), the Personal Information Dispute Mediation Committee (Article 40 et seq. of the same Act) or other relevant authorities.
Article 14 (Rights of Residents of Taiwan)
Users residing in Taiwan may have the following rights under the Personal Data Protection Act of Taiwan (Article 3).
The right to request an inquiry into or access to their personal data
The right to request the issuance of copies of their personal data
The right to request the supplementation or correction of their personal data
The right to request the cessation of the collection, processing or use of their personal data
The right to request the deletion of their personal data
The period during which the Company uses personal data is as set forth in Article 5; the regions are Japan and the countries or regions described in Article 10; the parties are the Company and the contractors described in Articles 3 and 7; and the method is by electronic means. If a User does not provide personal data, the User may be unable to use all or part of the Service.
If you wish to exercise these rights, please contact the contact point set forth in Article 16.
Article 15 (Amendment)
The Company may amend all or part of this Privacy Policy. In the case of material changes, the Company shall give notice by posting on the Site, together with the effective date of the updated Privacy Policy. If a User continues to use the Service, etc. after the Company has posted or published the updated Privacy Policy or given notice of the changes, the User shall be deemed to have agreed to the application of the updated Privacy Policy. If you do not agree to the amended Privacy Policy, please discontinue use of the Service, etc.
Article 16 (Contact Point)
Contact point for inquiries regarding Personal Information:
avaren Co., Ltd.
Representative and Personal Information Protection Officer: Tesshin Kirihara, Representative Director
E-mail address: [email protected]
Telephone number: 090-6478-1106 (Business hours: weekdays 10:00–18:00)
Address: 2-12-7 Harayama, Midori-ku, Saitama-shi, Saitama 336-0931, Japan
Established on October 8, 2026