top of page

​Privacy Policy

SMARTHOLDER Co., Ltd. (hereinafter referred to as "the Company") establishes the following Privacy Policy (hereinafter referred to as "this Policy") for the handling of users' personal information in the services provided on this website (hereinafter referred to as "the Services").

Article 1 (Personal information)

"Personal information" refers to "personal information" as defined in the Personal Information Protection Act, and is information about a living individual, including name, date of birth, address, telephone number, contact information, etc. This refers to information that can identify a specific individual through descriptions, etc., and information that can identify a specific individual from such information alone, such as data related to appearance, fingerprints, voice prints, and health insurance card health insurance card number (personal identification information). .

Article 2 (Method of collecting personal information)

When a user registers for use, we may ask for personal information such as name, date of birth, address, telephone number, email address, bank account number, credit card number, driver's license number, etc. In addition, information regarding transaction records and payments, including user personal information, made between users and business partners (including information providers, advertisers, advertising distribution destinations, etc.), including information providers, advertisers, etc., may be stored in the Company's business partners (hereinafter referred to as " (hereinafter referred to as "partners"), etc.


Article 3 (Purpose of collecting and using personal information)

The purposes for which our company collects and uses personal information are as follows.

  1. To provide and operate our services

  2. To respond to inquiries from users (including verifying identity)

  3. To send emails informing users of new features, updated information, campaigns, etc. of the service they are currently using, and other services provided by our company.

  4. To contact you as necessary, such as maintenance and important notices.

  5. To identify users who violate the Terms of Use or who attempt to use the service for fraudulent or improper purposes, and to refuse their use.

  6. To allow users to view, change, or delete their own registered information, and view usage status.

  7. To bill users for usage fees for paid services

  8. Purposes incidental to the above purposes of use

Article 4 (Change of purpose of use)

The company will change the purpose of using personal information only when it is reasonably deemed to be related to the purposes before the change.

Article 5 (Provision of personal information to third parties)

Except as provided in the following cases, the Company shall not provide personal information to third parties without the user's consent. However, this excludes cases permitted under the Personal Information Protection Law and other laws and regulations.

  1. When required for the protection of a person's life, body, or property, and it is difficult to obtain the user's consent.

  2. When necessary for the improvement of public health or the promotion of the healthy upbringing of children, and it is difficult to obtain the user's consent.

  3. When it is necessary to cooperate with a national institution, local government, or a person entrusted by them in executing the affairs prescribed by law, and obtaining the user's consent may hinder the execution of such affairs.

  4. When the Company notifies the user in advance or publicly announces the following items and reports to the Personal Information Protection Commission: 

       a. Purpose of use, including provision to third parties. 

       b. Items of data provided to third parties. 

       c. Means or methods of providing data to third parties. 

       d. Responding to user requests to stop providing personal information to third parties. 

       e. Contact point for user inquiries.

  5. Notwithstanding the provisions of the preceding paragraph, the provision of information to those who do not fall under third parties is not              considered third-party provision.
       a. When the Company entrusts all or part of the handling of personal information within the scope necessary to achieve the purpose of use.

       b. When personal information is provided as a result of the succession of business due to a merger or other reasons.

       c. When personal information is used jointly with specific parties, the items of personal information to be jointly used, the scope of the joint

           users, the purpose of use by the parties, and the name of the party responsible for managing the personal information are notified to the                individual in advance or are made readily available to the individual.

Article 6 (Disclosure of personal information)

  1. When the user requests the disclosure of personal information from the Company, the Company shall disclose it to the user without delay. However, if any of the following cases apply, the Company may not disclose all or part of the information and will notify the user accordingly:
      a. When there is a risk of harming the life, body, property, or other rights and interests of the user or a third party
      b. When there is a risk of significantly impeding the proper execution of the Company's business
      c. When it would violate the law

  2. Notwithstanding the provisions of the preceding paragraph, the Company shall not disclose information other than personal information, such as browsing history and characteristic information.

Article 7 (Suspension of use of personal information, etc.)

When the Company is requested by the user to stop using or delete personal information on the grounds that it is being handled beyond the scope of the stated purpose of use or has been obtained by fraudulent means, the Company shall conduct the necessary investigation without delay.


Based on the results of the investigation in the preceding paragraph, if it is determined that the user's request is valid, the Company shall promptly suspend the use of personal information or delete it.


The Company shall notify the user without delay in the event of suspension of use or deletion, or if it decides not to suspend use or delete personal information, and the reasons for such decisions.


Notwithstanding the provisions of the preceding two paragraphs, in cases where suspension of use or deletion of personal information would require a significant cost or is otherwise difficult, and alternative measures can be taken to protect the rights and interests of the user, the Company shall take such alternative measures.

Article 8 (Changes to privacy policy)


  1. The contents of this Policy are subject to change, except for matters specified separately in this Policy or required by law, without prior notice to the user.

  2. Except as otherwise provided by the Company, the Privacy Policy after the change shall take effect from the time it is posted on this website.


Article 9 (Inquiries)

For inquiries regarding this policy, please contact the contact point below.

Head office location: 307 Eastern Cross Akiba, 1-29-3 Taito, Taito-ku, Tokyo 110-0016
Company name: SMARTH
OLDER Co., Ltd.
Person in charge: Yang An
Email address:

The End

Last updated: November 24, 2023

bottom of page