Privacy Policy

Article 1 (Personal Information)

“Personal Information” means any information relating to an identified or identifiable natural person, including information defined under applicable data protection laws such as the Act on the Protection of Personal Information (Japan) and the General Data Protection Regulation (EU) 2016/679 ("GDPR").

Article 2 (Methods of Collecting Personal Information)

The Company may request personal information such as name, date of birth, address, phone number, email address, bank account number, credit card number, and driver’s license number when Users register. The Company may also collect transaction records and payment information from partners (including information providers, advertisers, and ad distributors).

In addition, the Company automatically collects and stores access logs for the purposes of service analytics, fraud prevention, security monitoring, and service improvement. Such access logs may include IP addresses (which may be stored in hashed or pseudonymized form), session identifiers, device information, browser information, referring URLs, pages viewed, and access timestamps.

Access log data is retained for up to 12 months from the date of collection unless a longer retention period is required for legal or security purposes. After the retention period expires, such data will be securely deleted or anonymized.

Article 3 (Legal Basis for Processing – GDPR)

Where the GDPR applies, the Company processes personal data on the following legal bases:

• Performance of a contract (Article 6(1)(b))
• Compliance with legal obligations (Article 6(1)(c))
• Legitimate interests in operating, improving, and securing the Service (Article 6(1)(f))
• User consent where required (Article 6(1)(a))

Article 4 (Purpose of Collecting and Using Personal Information)

• To provide and operate the Service
• To respond to inquiries (including identity verification)
• To send emails regarding new features, updates, campaigns, and related services
• To ensure system security and prevent fraudulent or abusive activity
• To analyze usage trends and improve service functionality
• To allow Users to view, modify, or delete their registration information
• To charge fees for paid services
• For purposes incidental to the above

Article 5 (Data Retention)

The Company retains personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements.

Article 6 (Provision of Personal Information to Third Parties)

The Company will not provide personal information to third parties without prior consent except where required by law or necessary for legitimate service operation (including outsourcing, business transfers, or joint use arrangements).

Article 7 (International Data Transfers)

If personal data is transferred outside the User’s country, including to countries outside the European Economic Area, the Company will implement appropriate safeguards such as standard contractual clauses or equivalent legal mechanisms.

Article 8 (Rights of Data Subjects – GDPR)

Where applicable under the GDPR, Users have the following rights:

• Right of access
• Right to rectification
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent at any time

Users may exercise these rights by contacting the Company.

Article 9 (Security Measures)

The Company implements appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.

Article 10 (Cookies and Tracking Technologies)

The Service may use cookies and similar technologies for authentication, analytics, and security purposes. Users may control cookie settings through their browser preferences.

Article 11 (Changes to Privacy Policy)

The Company may update this Policy from time to time. The revised Policy shall take effect upon publication on the website.

Article 12 (Contact Information)

• Company: Engineering Brain
• Email: support@engineering-brain.com