Privacy Policy | Tsunagu Post

If there is any conflict between this English translation and the Japanese version, the Japanese version prevails.

UpLink Co., Ltd. (hereinafter, the “Company”), which operates Tsunagu Post (hereinafter, the “Service”), establishes this Privacy Policy (hereinafter, this “Policy”) regarding the handling of users’ personal information in the Service as follows.

1. Information We Collect

In providing the Service, the Company may collect the following information.

Information related to account registration (email address, display name, password hash, etc.)
Content registered and stored within the Service (notes, messages, memos regarding assets and contracts, etc.)
Information regarding contacts, Friends, and groups
Information related to Friend registration (email address, SNS accounts, and other contact details that the Friend personally registers at the time of Friend registration)
Settings related to notifications and activity monitoring, and usage preferences such as language and time zone
Inquiry contents
Access logs, usage data obtained through Cookies and similar technologies, and device and browser information

Notes and other content may include health status, medical history, and other sensitive personal information (要配慮個人情報). The Company treats the user’s registration and use of such information in the Service as the user’s consent to the Company’s collection of that sensitive personal information.

2. Purposes of Use

Collected information is used within the scope of the following purposes.

Provision, operation, authentication, and security of the Service
Communication with users and notification of important announcements
Provision of activity monitoring and notification features, and delivery of notes to Friends when prescribed conditions are met (provision to third parties)
Prevention of unauthorized use, handling of disputes, and responses required by law
Service improvement and statistical analysis (including processing into a form that does not identify individuals)

3. Provision to Third Parties

Except in any of the following cases, the Company will not provide personal information to third parties.

When the user has given consent
When required by law
When necessary to protect a person’s life, body, or property, and it is difficult to obtain the individual’s consent
When providing to a contractor within the scope necessary to achieve the purposes of use (the Company will supervise such contractors)

Note delivery is made to Friends whom the user has designated and consented to in advance, and is carried out as provision to third parties based on the user’s prior consent. If a delivered note contains personal information of other persons, it is premised that the user has obtained the necessary consent and authority for such provision as well.

4. Entrustment and Overseas Transfer

The Company may entrust infrastructure, payment processing (Stripe), email delivery, analytics, and other operations to external service providers, some of which may constitute third parties located in foreign countries. When providing personal data to a third party in a foreign country, the Company will take necessary measures in accordance with applicable law, including either (i) obtaining the individual’s consent after providing information regarding the name of the foreign country, the personal information protection system of that country, and the measures taken by that third party, or (ii) establishing a system with that third party that meets applicable standards and continuously confirming the status of its implementation.

5. Retention Period

Personal information is retained for the period necessary to achieve the purposes of use and, when no longer needed, is deleted or anonymized in accordance with applicable law.

6. Security

The Company takes organizational, personnel, physical, and technical measures that are reasonably necessary to prevent leakage, loss, or damage of personal information and otherwise ensure its secure management.

7. Users’ Rights

Based on the Act on the Protection of Personal Information, users may request notification of the purposes of use of retained personal data, disclosure (including provision of electromagnetic records), correction, addition, or deletion of content, and suspension of use, erasure, or suspension of provision to third parties. Procedures for such requests, methods of identity verification, and fees follow the guidance provided within the Service. Complaints regarding the handling of personal information are accepted at the inquiry contact described above.

8. Cookies, Etc.

The Company may use Cookies and similar technologies to improve convenience and understand usage. These may be disabled through browser settings; however, some features may become unavailable.

9. Changes to This Policy

The Company may amend this Policy in response to amendments to laws or changes in its business. The amended content takes effect from the time it is posted on the Service.

10. Data Deletion upon Cancellation

When an account is cancelled, the Company sets the account to read-only, and data associated with the user (account information, Friend relationships, notes, settings, etc.) is deleted on the first day of the month following the month in which the cancellation was performed. Restoration after deletion is not possible. Cancellation may be revoked until the last day of the month in which the cancellation was performed. Please refer to the Terms of Service for details.

11. Inquiries

For inquiries regarding this Policy, please contact us through the inquiry channel within the Service (or such other contact as the Company may separately designate).

12. Operator Information (Matters to Be Made Public Regarding Retained Personal Data)

The operator of the Service is as follows.

Name: UpLink Co., Ltd. (株式会社アップリンク)

Representative: Masashi Sonomura, Representative Director

Address: 〒601-8474 京都府京都市南区四ツ塚町78。

The purposes of use of retained personal data, procedures for requests for disclosure and related matters, and the contact for complaints are as set forth in this Policy and in the guidance within the Service. An overview of security control measures will be provided without delay upon request.

13. Handling of Friends’ Personal Information

This Policy also applies to personal information of persons registered as Friends (hereinafter, “Friends”). The Company uses contact and other information that Friends personally register at the time of Friend registration within the scope of purposes including sending notifications to Friends, delivering notes, identity verification, and matters incidental thereto. Friends may, in the same manner as users under Section 7, request disclosure, correction, suspension of use, and related actions with respect to retained personal data of Friends held by the Company. When a Friend cancels Friend registration, the Company will delete that Friend’s information without delay, except where retention is required by law.