Privacy Policy

NyuuLy K.K. (address: 4F, Daini Toranomon Building, 1-5-12, Akasaka, Minato-ku, Tokyo; "NyuuLy" or "we") will properly handle personal information in accordance with the laws, regulations, and guidelines that apply to NyuuLy and in accordance with this Privacy Policy.

1. Personal Information NyuuLy Obtains

(1)Personal information of users of our "Info Hub", "Ask Me", "Compass", "Welcome pack", "Me", "Work Japan", "Mobile" and other services including applications (the "Services")

a.Information provided by users when using the Services:

Identification and contact details (such as name, address, date of birth, phone number, and email address)
Identity verification information (details from identification documents; if the document is a My Number Card, this includes all details except the My Number, as well as the card's electronic signature and digital certificate)
Payment method information (such as credit card, debit card, or bank account details)
Information related to user inquiries (including opinions and requests)

b.Information obtained through users' use of the Services:

Usage details (such as communication history and usage history)
Usage environment (such as network, communication devices, IP addresses, browser type, internet service provider, date and time stamp, referring/exit pages, and possibly the number of clicks)
Billing information (such as charges and payment status)

(2)Personal information of shareholders (details recorded in the shareholder register)

(3)Personal information of NyuuLy's directors and employees (including job applicants, interns, prospective hires, contract employees, and temporary staff, "Employees")

(4)Other personal information related to business partners and inquiries made with us

2. How Personal Information will be Used

Unless otherwise provided by law or regulation, we will process your personal information for the following purposes:

(1)Personal information of users

To provide the Services, including identity verification, confirming satisfaction of application requirements, credit management, billing and payment collection, and handling issues, accidents, or Services disruptions
To prevent and address fraudulent contracts, unauthorized use, and non-payment
To make announcements and send information, materials, promotions, advertisements and other communications related to the Services (including Services other than those the user currently uses)
To ensure the safety and security of the Services
To manage and monitor Services usage
To perform analysis and market research including usage trends
To improve and enhance the Services
To handle inquiries and provide user support regarding the Services
To operate, maintain, and manage networks and systems
To plan, develop, and implement new services
To address violations of our terms of services, policies, and other applicable rules or agreements
To create statistical data related to the Services that does not identify individual users, and use such data for any purpose

(2)Personal information of shareholders

To exercise rights and fulfill obligations under applicable laws and regulations
To prepare and submit legally required disclosure documents
To respond to inquiries from shareholders

(3)Personal information of Employees

To screen job applicants and perform onboarding procedures
To manage personnel and labor management related to the appointment or employment of Employees

(4)Other personal information

To manage relationships with our business partners
To handle inquiries directed to us
To manage and record visitors to our offices

3. Legal Bases for the Processing of Personal Information

NyuuLy will process your personal information based on the following legal grounds:

(1)To perform obligations under contracts between NyuuLy and you or to carry out procedures requested by you before the execution of any such contract

(2)Your consent for the processing of your personal information for a specific purpose

(3)NyuuLy's pursuit of its legitimate interests

NyuuLy's legitimate interests refer to the following:

Operation and expansion of NyuuLy's business
Provision of the Services
Analysis and market research of the Services

4. Sharing and Transferring of Personal Information

NyuuLy may provide users' personal information to third parties within the scope of the purposes listed below:

(1)When a user applies for a contract and chooses identity verification via the electronic signature and digital certificate on a My Number Card, we provide the following information to verify these details:

Local Government Information System Organization
Business entities certified under Article 17-1(6) of the Act on Certification Business of Local Governments in Relation to Electronic Signatures (limited to those contracted with NyuuLy).

(2)If a user fails to pay charges for the Services after the due date, we may transfer the overdue debt and provide the transferee with the user's name, address, date of birth, and unpaid amount to collect the debt.

(3)When requested by an international telecommunications carrier, we may provide the name, address, and phone number of the person who has signed or applied for a contract, in accordance with the carrier's terms and conditions.

(4)When a user transfers to another mobile carrier via "mobile number portability" (MNP), we may provide the user's name, date of birth, mobile phone number, and other necessary information for MNP to the carrier and other telecommunications carriers with whom we have agreements such as interconnection agreements.

(5)If we determine it is necessary to confirm the contents of identification documents submitted by an applicant for the Services, we may provide the information on those documents to police or other administrative agencies.

(6)When emergency call agencies (National Police Agency, Fire and Disaster Management Agency, Japan Coast Guard) request information about the caller, we may provide the name, address, and other relevant details of the subscriber or user of the mobile voice Services used for the emergency call.

(7)Information detected through our "Dangerous SMS Blocking" settings (such as the date/time sent, sender's phone number, and message content) may be shared with mobile carriers with whom we have agreements such as interconnection agreements, and their partner organizations, to implement countermeasures against dangerous SMS.

(8)Even after contract termination, if there is unpaid debt, we may exchange personal information among mobile and/or BWA Services providers. This information includes personal information related to the payment status that we acquired from the assignee of those unpaid receivables.

Information exchanged:
Name, address, date of birth, gender, phone number before contract termination, contact number, and non-payment status
Purpose:
To use this information during subscription screening to prevent repeated non-payment and to protect fairness and benefits for all users (depending on the non-payment status, applications may be declined.)

For details on business entities with which we exchange information, please refer to the TCA (Telecommunications Carriers Association) website.

(9)When a user pays fees by credit or debit card, we may provide necessary information to the card issuer for fraud detection and prevention.

Except for the above, NyuuLy will not provide users' personal information to any third parties without obtaining prior consent from users unless permitted under applicable law. When transferring or receiving personal information to or from third parties, NyuuLy will confirm and record such information as required by applicable law.

5. Matters Related to Protecting Users' Rights and Interests

(1)Voluntary suspension of use

If a user requests, we will stop using his or her personal information to send marketing communications, such as email ads.

(2)Outsourcing and scope of outsourced operations

We may outsource the following operations related to the use of users' personal information for the purpose of providing the Services:

Product delivery Services
Management of information related to user inquiries
Management of emails related to user inquiries
Issuance of invoices for corporate users

(3)Sources and methods of obtaining personal information

We obtain users' personal information from the following sources or by the following methods:

Direct provision by the user (including by our business partners as agent, or attorneys)
User's use of the Services
Provision by other mobile carriers or telecommunications operators with whom we have agreements such as interconnection agreements (for Mobile Number Portability (MNP) transfer procedures)
Provision by mobile and/or BWA Services providers that exchange information with us regarding unpaid fees
Inquiries to credit information agencies, etc.
Inquiries, notifications, or other communications from administrative, judicial, or other public authorities

6. Provision of Personal Information to Third Parties Located Overseas

We may provide users' personal information to third parties located outside Japan. In such cases, we will obtain the user's consent before providing the information, except in the following situations:

(1)when the third party is located in a country recognized as having a personal information protection system equivalent to Japan's level for safeguarding individual rights and interests, or

(2)when the third party has established and maintains a framework necessary to continuously implement measures equivalent to those required for handling personal data by Japanese personal information handling businesses (hereinafter referred to as "Equivalent Measures").

In the case of (2) above, we will take necessary steps to ensure that the third party continues to implement Equivalent Measures. If you wish to confirm these details, please make a request to the Support Desk (please see item 10 below).

7. Rights of Users

Under applicable laws and regulations, you have the following rights regarding your personal information that will be collected or processed by NyuuLy. If you wish to exercise any of these rights, please contact the Support Desk.

(1)The right to know how your personal information is being collected and how it is being used

(2)The right to correct any of your personal information that is inaccurate

(3)The right to have your personal information deleted

(4)The right to restrict the processing of your personal information

(5)The right to dispute the processing of your personal information

(6)The right to receive your personal information in a structured, generally usable, and machine-readable format, or to forward such personal information to another administrator

(7)If the processing of your personal information is based on your consent, the right to withdraw such consent

(8)The right to file a complaint with the appropriate supervisory body regarding the processing of your personal information

(9)The right not to receive any assessment or decision through profiling or other automated processing that will result in legal consequences for you or have a serious impact on you. NyuuLy will not engage in any automated processing (including profiling) of your personal information.

8. Data Security

NyuuLy implements information security measures and other safety management practices to protect personal information from unauthorized access, loss, destruction, alteration, or leakage. In the event of a security incident, a user report, or findings from internal audits indicating the need for improvement, we will promptly take corrective action to strengthen our safety management measures.

9. Retention Period

NyuuLy will retain your personal information for the period required to carry out the purposes of use set forth in this Privacy Policy.

10. Support Desk

If you have any questions or requests regarding this Privacy Policy, please contact NyuuLy at the following email address:

contact@nyuuly.com

11. Links to Other Websites

NyuuLy's website may include links to other websites operated and managed by third parties. NyuuLy will not be liable for any collection, use, management, or other handling of your personal information by such third-party websites.

12. Use of Google Analytics

NyuuLy uses Google Analytics for Services analysis and improvement. Upon such use, Google may set cookies in your browser or read existing cookies to collect data.

In addition, browsers that are using the Services automatically send certain non-personal information to Google (for example, the web address or IP address of the accessed page). NyuuLy may use such information for purposes such as understanding the site usage status and improving the site usage experience.

By using the Services, you are deemed to have given permission for such data processing performed by Google and NyuuLy within the bounds of the above method and purpose.

For information about how Google collects and uses access information, please see Google Analytics Services Terms of Services and Google Privacy Policy.

13. Use of Meta Pixel

NyuuLy uses Meta Pixel to track user actions on our website. This data helps us measure the effectiveness of our advertising campaigns and improve user experience. This information is shared with Meta.

For more details, see Meta's Privacy Policy.

14. Use of Microsoft Clarity

NyuuLy uses Microsoft Clarity to track user actions on our website. This data helps us measure the effectiveness of our advertising campaigns and improve user experience. This information is shared with Microsoft.

For more details, see Microsoft's Privacy Policy.

15. Amendment of this Privacy Policy

NyuuLy may amend or update this Privacy Policy at any time. Any amended or updated version of this Privacy Policy will be posted on this page.