Article 1 (Definition of Personal Information)

In this Policy, personal information means personal information as defined under applicable personal information protection laws, including information relating to a living individual that can identify a specific individual by name, date of birth, address, telephone number, email address, or other descriptions, and information containing personal identification codes.

Article 2 (User Information Collected and Collection Methods)

The Company may collect user information through the following methods.

1. Inquiry forms (HubSpot): name, email address, telephone number, company name, inquiry details, and other information entered by users.
2. Access analytics tools (Google Analytics 4): cookies, anonymized IP address, browser type, viewed pages, access time, and other access log information.
3. Information provided by subcontractors when the Company engages subcontractors.

Article 3 (Purposes of Use)

The Company uses collected personal information for the following purposes.

1. Responding to inquiries and contacting users
2. Providing, operating, and improving the Company's services
3. Providing information and notices about the Company's services
4. Analyzing usage and creating statistical data to improve services
5. Developing and planning new services
6. Performing contracts and billing fees
7. Preventing and responding to unauthorized use
8. Other operations incidental to the purposes above

Article 4 (Changes to Purposes of Use)

The Company may change the purposes of use only to the extent reasonably recognized as related to the previous purposes. If the Company changes the purposes of use, it will notify users or publish the changed purposes on this website by the Company's prescribed method.

Article 5 (Provision to Third Parties)

Except in the following cases, the Company will not provide personal information to third parties without prior user consent.

1. When required by laws and regulations
2. When necessary to protect human life, body, or property and obtaining consent is difficult
3. When especially necessary to improve public health or promote the sound growth of children and obtaining consent is difficult
4. When cooperation with a national agency, local government, or entrusted party is necessary for executing legally prescribed affairs and obtaining consent may impede execution

Article 6 (Joint Use)

The Company may jointly use personal information with the following businesses.

• HubSpot, Inc.: user information collected through forms is managed on HubSpot for inquiry management and marketing activities.
• Google LLC: access log information collected through Google Analytics 4 is used for access analysis and ad performance measurement.

Article 7 (Information Collection Modules)

This website uses the following information collection modules.

• Google Analytics 4 (Google LLC): used to analyze website usage. Cookies are used to collect data, but the data does not include information that identifies individuals. Please refer to Google's Privacy Policy for details.
• HubSpot Tracking Code (HubSpot, Inc.): used to understand website visitor behavior and provide more appropriate information. Please refer to HubSpot's Privacy Policy for details.

Article 7-2 (Information Collected through Instagram Account Connection)

In TAMESHY CLUB, the gifting programme operated by the Company, we collect the following information through the Instagram API provided by Meta Platforms, Inc., and only where a participating creator has voluntarily connected their Instagram account.

Connecting the account is optional. Declining to connect does not affect participation in the programme or delivery of the product.

• Instagram user ID and username
• Media ID, permalink, timestamp and media type of posts
• Reach, saves and shares of posts
• Access token (with an expiry date)

Article 7-3 (Use, Provision and Deletion of Information Obtained through Connection)

Collection is limited to the posts identified to the creator as being part of the programme. We process only posts whose permalink matches, and collect no information about any other post. We do not collect the contents of direct messages, personal information about followers, or draft posts.

The information collected is used solely to report on the programme, specifically to produce the performance report submitted to the brand that commissioned it. We do not use it for advertising targeting, do not sell it to third parties, and do not repurpose it for other programmes.

The performance report is provided only to the brand that commissioned the programme, and to no other third party.

The connection may be revoked at any time. Once access for our app is removed from the Instagram settings screen, the access token held by the Company becomes invalid and no further information is collected. For deletion of stored data, please see “Data Deletion” on our website.

This connection uses the Instagram API with Instagram Login and is operated in accordance with the Meta Platform Terms and Developer Policies of Meta Platforms, Inc.

Article 8 (Disclosure)

When a user requests disclosure of personal information, the Company will disclose it without delay after confirming that the request is from the user. However, if disclosure falls under any of the following, the Company may withhold all or part of the information and will notify the user without delay if it decides not to disclose.

1. When disclosure may harm the life, body, property, or other rights and interests of the user or a third party
2. When disclosure may significantly hinder the proper execution of the Company's business
3. When disclosure would violate laws or regulations

Article 9 (Correction and Deletion)

If a user's personal information held by the Company is incorrect, the user may request correction, addition, or deletion according to procedures prescribed by the Company. When the Company receives such a request, it will conduct necessary investigation without delay, make corrections based on the result, and notify the user.

Article 10 (Suspension of Use)

If a user requests suspension or deletion of personal information because it is handled beyond the scope of the purposes of use or was acquired by improper means, the Company will conduct necessary investigation without delay. If the Company determines that it is necessary to comply with the request, it will suspend use or delete the personal information without delay and notify the user.

Article 11 (Changes to Privacy Policy)

Except as otherwise provided by laws or this Policy, the content of this Policy may be changed without notice to users. Unless otherwise specified by the Company, the revised Privacy Policy becomes effective when posted on this website.

Article 12 (Contact Desk)

For inquiries regarding this Policy, please contact the following.