HOPI Privacy Policy

Article 1 (User Information and Personal Data)

1. User information refers to information about users (including visitors to the Company's website, hereinafter the same) who use each service provided by the Company through the Company's website or app (hereinafter referred to as "the Service").
2. Personal data refers to that defined in Section 2(1) of the Singapore Personal Data Protection Act (PDPA) (including any amendments thereto).

Article 2 (Information Collected by the Company in the Service)

The Company may collect the following user information in the Service. To use the Service, it is necessary to provide the Company with user information in items 1 and 2. If you do not provide this information, you may not be able to use all or part of the Service.

1. Device information (information unique to the information terminal used by the user, type of OS, individual identification method of the terminal, computer name, advertising ID, etc. The advertising ID may be linked to an internal identifier assigned by the Company to the user.)
2. Online identifiers such as cookie IDs, terminal information used, referral source, browsing history and other service usage status (including access logs, IP addresses, browser information, browser language settings)
3. Information from inquiries to the Company's customer support
4. Feedback information from users such as evaluations or complaints
5. Other information directly obtained from users through their use of the Service or inquiries to the Company

Article 3 (Purpose of Use of User Information)

The Company shall use the collected user information for the following purposes and shall strive to use the information appropriately within the scope of these purposes:

1. Operation of the Service (including providing all kinds of information to users from the Company for purposes such as responding to inquiries, push notifications, and other postings within the Service)
2. Contacting users regarding matters that significantly affect the operation of the Service (including but not limited to major changes to the Service content, temporary suspension)
3. Contacting users to seek consent regarding the handling of personal data
4. Creation of statistical information regarding the usage status of the Service, publication in the Service or the Company's web services, and provision to third parties
5. Use for general research and development to improve convenience in the Service, including marketing analysis related to the Service (when outsourcing part of research and development work to third parties, it will be done after processing so that specific individuals cannot be identified)
6. Response to violations of the Company's terms and other regulations related to the Service
7. Monitoring of fraudulent activities by users
8. Accurate understanding of inquiry contents to the Company and response, sending information, and other communications
9. If a user indicates an intention to harm their own safety or the safety of others through the Company's services, the Company may share that information with relevant third parties such as emergency response agencies or public institutions to take appropriate measures. This measure is limited to cases where it is necessary to protect the life or physical safety of the user or others. The Company will handle such information appropriately, minimizing it to the necessary extent, in accordance with relevant laws and regulations, balancing respect for individual privacy and security assurance.

Article 4 (Provision of User Information (Including Third-Party Provision under the PDPA))

The Company shall not disclose all or part of user information (including personal data) to any third party other than the user himself/herself, except in the following cases. The user agrees that the Company may provide all or part of the user information to third parties in the following cases. Also, in cases that correspond to the provision of personal data to third parties under the PDPA, necessary procedures such as creation of records of provision of personal data to third parties will be carried out in accordance with the provisions of the same Act.

1. When providing user information to these specialist businesses for the purpose of aggregating and analyzing user information, distributing advertisements, etc. for the improvement of the Service, related business development, marketing of affiliated companies, etc.
2. When there is consent from the user regarding the disclosure or use of personal data
3. When a third party such as a business partner requires personal data for the purpose of providing services desired by the user (provided that such third party or business partner may not use the personal data provided by the Company beyond the scope necessary for service provision)
4. When required by law, when it is necessary to cooperate with a national or local government agency or a person entrusted by such an agency in executing affairs prescribed by laws and regulations, or when legitimately requested for disclosure by these entities

Article 5 (Joint Use of Acquired Personal Data)

1. When business partners who jointly conduct business with the Company become necessary to provide the Service to users, personal data of users may be jointly used with those business partners. In this case, the Company will separately announce to users the fact of joint use, its purpose, the scope of information, the scope of business partners, the name and address of the person responsible, and in the case of a corporation, the name of its representative, before jointly using the information.
2. The Company may outsource all or part of the handling of personal data to a subcontractor in cases such as outsourcing part of the payment processing or Service operations to the extent necessary to achieve the purpose of use. In such cases, the Company will thoroughly examine the suitability as a subcontractor, stipulate matters related to confidentiality obligations, etc. when concluding a subcontracting agreement, and create a system to ensure that information is properly managed, including supervision of the subcontractor.

Article 6 (Disclosure, Correction, and Cessation of Use of Personal Data)

1. When requested by a user to disclose personal data based on the provisions of the PDPA, the Company will disclose personal data without delay after confirming that the request is from the user himself/herself, only in cases where the Company has an obligation to disclose under the PDPA. Note that you may be required to pay a disclosure fee according to the procedure separately specified by the Company for the disclosure of personal data.
2. When requested by a user to correct, add, or delete the user's personal data, and when the content of the user's personal data is not factual or in other cases specified by the provisions of the PDPA, the Company will, after confirming that the request is from the user himself/herself, investigate and correct, etc. the personal data and notify the user to that effect.
3. If a user's personal data is being provided to a third party in violation of this Privacy Policy or the provisions of the PDPA, the user may request the Company to stop providing personal data to third parties.
4. When requested by a user to disclose records of provision of personal data to third parties, the Company will disclose such records without delay after confirming that the request is from the user himself/herself, only in cases where the Company has an obligation to disclose under the PDPA. Note that you may be required to pay a disclosure fee according to the procedure separately specified by the Company for such disclosure.

Article 7 (Cookies, etc.)

1. The Company may send cookies to the browser used by users through the Service and use that technology. This allows the Company to obtain browsing history, service usage history, referral sources, attribute information that cannot identify individuals, etc. Users can disable or reject the acceptance of cookies by changing their browser settings themselves. Please note that if you disable or reject cookies, some parts of the Service may not function properly.
2. The Company uses Google Analytics provided by Google. The Company may receive and use the results of Google collecting and analyzing users' browsing history based on cookies set by the Company or Google to understand users' usage status and use it for the Company's services. For information on Google's handling of data in Google Analytics, please refer to their website.
3. Regarding personal-related information (as defined in the PDPA) such as cookies, the Company will not provide such personal-related information to third parties, except in cases where it is expected that the third party receiving the information will acquire it to identify individual users, where there is consent from the user, or where it is specified in this Privacy Policy. In such cases, the Company will obtain consent from the user (including cases where consent is given in this Privacy Policy), and in accordance with the PDPA and related ordinances, the Company will individually specify the third party to whom the information will be provided to the user, specify the personal-related information subject to provision, and create a record of such third-party provision.
4. If a user has settings that allow the receipt of cookies, third parties such as ad delivery businesses may acquire cookie information such as browsing history of users using the Service and ads may be delivered on the ad space of ad delivery businesses, etc.
5. In relation to the preceding paragraph, ad delivery businesses, etc. may use cookies, access data, Company identifiers, and user attribute information to deliver ads tailored to users' interests and preferences. Users may be able to stop the use of cookies and access data by ad delivery businesses, etc. by accessing the opt-out pages of ad delivery businesses, etc. and disabling (opting out). In such cases, ads tailored to users' interests and preferences may no longer be delivered, or the same ad may be repeatedly delivered.
6. If you want to disable (opt out), please access the privacy policies and opt-out pages of each ad delivery business, etc., and follow the procedures on the sites of each ad delivery business, etc. to make settings.

Article 8 (Revision)

When changing this Privacy Policy, the Company will notify in advance the content of the changed Privacy Policy and the effective date by posting on the website of the Service or by other means deemed appropriate by the Company. However, if a change that requires the user's consent under the law is made, the Company will obtain consent in a manner deemed appropriate by the Company in accordance with the provisions of the law. If a user uses the Service after the date specified in the notification, they will be deemed to have agreed to the changed Privacy Policy unless its effect is denied by law.

Article 9 (Special Notice to Users in the EU)

As the servers operated by the Company are located in Japan, we may directly collect user information from countries/regions within the EU. The transfer of user information to Japan is based on the adequacy decision for cross-border data transfer obtained by Japan. For details on Japan's adequacy decision, please refer to the European Commission's website, etc.

If you are a person located in the EU, etc., and GDPR applies, you have the following rights. Whether or not a user is subject to the application of this article will be determined after the Company's prescribed investigation. For exercising these rights, please contact the inquiry point of contact mentioned above.

1. The Company will provide a copy if there is a request from the user for access to user information.
2. Users can request the Company to correct inaccurate user information.
3. Users have the right to obtain from the Company without undue delay the erasure of user information concerning them in certain cases.
4. Users have the right to restrict the use, etc. of user information by the Company in certain cases.
5. Users have the right to receive user information concerning them in a structured, commonly used and machine-readable format.
6. Users have the right to object to processing of their user information based on the necessity for the purposes of legitimate interests pursued by the Company or by a third party.
7. Users have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them. The Company does not perform automated processing, including profiling, on users' user information.
8. Users have the right to lodge a complaint with a supervisory authority at any time.
9. In cases where this Privacy Policy requires the user's consent for the Company to use the user's user information, the user has the right to withdraw that consent at any time.

Article 10 (Governing Law and Jurisdiction)

In the event that doubts or problems arise between users, the Company, and third parties in relation to the Service, they shall consult in good faith each time and seek resolution.

This Privacy Policy shall be interpreted in accordance with Singapore law, and all disputes related to this Privacy Policy shall be resolved by arbitration in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (SIAC), with English as the language of arbitration, by one arbitrator. However, if the Company makes a claim against a user, it may file a lawsuit in a court of jurisdiction chosen by the Company.