Privacy Policy for HAPPY HOLIDAYS

Privacy Policy for HAPPY HOLIDAYS

This Policy sets out how Fenrir Inc. (“Company” or “we”) collects and uses the personal information of users of “HAPPY HOLIDAYS” (“Software”) provided by us and its corporate site (collectively “Software and Site”). This Policy shall apply to all users who directly or indirectly contact us through the Software and Site.

When you or a user (“User”) contact us via another company’s service, we will manage the personal information received according to our Privacy Policy (https://www.fenrir-inc.com/jp/privacy-en/) (“Fenrir Privacy Policy”). However, for your use of another company’s service, that company’s privacy policy to which you agreed separately shall apply.

In addition to the Fenrir Privacy Policy, this Policy, upon your acceptance, shall apply to your use of the Software and Site. If there are differences in provisions between those two Policies, this Policy shall supersede the Fenrir Privacy Policy.

The Japanese version of this Policy shall be the official text and supersede a difference or inconsistency with any translated versions of other languages.

Article 1. Collection and Purpose and Basis of Use of Personal Information

The Company will receive the following information from Users (“Personal Information”). We shall use your Personal Information only for the purpose of use notified to you at your provision or within the scope of the purposes of use listed below. We shall not use it for any other purposes without your prior consent. Your Personal Information will be promptly erased when it is no longer needed for use.

  1. Information to Collect
    We will collect the information, such as the details exemplified below.

    1. Installation information
      • Conversion information (about through which service you are motivated to install the Software)
    2. Access information (which will be recorded when you access the Company-managed server)
      • IP address
      • Device information (identification numbers of the device in your use and the application you downloaded)
      • Browser information
      • Web viewing status (URLs you access)
      • OS (operating system) and system setting information
      • Time stamp information
      • Cookie information
      • Information on your use status of the Software
    3. Software use information
      • Identification information of the mobile device in your use
      • Information on the network you connect
        • Access time
        • IP address
      • Activation information
        • Time of activating the application
        • Version of the application in your use
      • Operating information
        • Transition of all screens
        • Positions and timing of taps on all screens
        • Types of all buttons or tabs pushed down
        • Timing of pushing down of all buttons or tabs
    4. Information on inquiries
      • Details of the inquiry
      • Name of company, department, organization, etc.
      • Address
      • Name
      • Contact information (email address/telephone number)

  2. Purpose of Use of Information Collected

    1. For providing products and services, sales promotion, and marketing activities
      • Survey and analysis of the use status of the Software
      • Planning, development, and improvement of the Company’s products and services
    2. For responding to inquiries
      • Responds to various inquiries
    3. Legal procedures
      • Investigation and settlement of claims and disputes related to the Company or any User’s use of our services
      • Information provision permitted by law or required by national or local public authorities

  3. Basis of Use of Information Collected
    We will use the Personal Information based on one or more of the following grounds.

    1. With the User’s consent
      We will collect User’s Personal Information with their consent. Users have the right to withdraw their consent at any time.

    2. To respond to the User’s request
      We will collect the User’s Personal Information when processing is necessary for the performance of a contract or a particular process to respond to the User’s request before executing the contract. Our response to the User’s request includes responding to their inquiries and our recruiting activities.

    3. To comply with our legal obligations
      We will collect the Users’ Personal Information to comply with our legal obligations to follow.

    4. To protect the vital interests of the User or a third party
      We will collect the User’s Personal Information to protect their vital interests or those of third parties. The User’s vital interests include enabling them to save steps from entering the same data or information multiple times, displaying optimal content for each User, and offering advertising based on their interests.

    5. To protect the public interests
      We will collect the User’s Personal Information to the extent necessary to protect the public interest.

    6. To pursue the legitimate interests of the Company or a third party
      We will collect the User’s Personal Information to pursue the legitimate interests of the Company or a third party. Our legitimate interests include preventing, detecting, and addressing any misconduct relating to our services, providing customer service, conducting surveys and analysis to improve our services and security, and conducting direct marketing.

    7. For the use of Cookies
      We may use cookies on Company-operated and related web pages. A cookie is a text file stored in a computer system via an internet browser. With a cookie, the usage history and the content entered, which are transmitted between your browser and our server, can be stored on your computer, and the information and advertisements displayed on our websites can be optimized.

      You may turn off cookies through the Company’s website by setting your internet browser.

    8. For the use of the Software
      The Software will be provided via an Apple or Google platform. When downloading the Software from an Apple or Google store or executing a contract for value, you must agree to an Apple or Google privacy policy.

      In addition, the Software may communicate with the Company-managed server. In that case, the access information accompanying your access will be recorded.

      The Software and Site use the following third-party services as analysis tools. For details, see their respective privacy policies below.

Article 2. Other Provisions

Other provisions shall be governed by the Fenrir Privacy Policy.

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Supplemental Provisions

Established on December 1, 2023.