Habitone Privacy Policy

This “Habitone” Privacy Policy (this “Policy”) explains how DUMSCO Co., Ltd. (the “Company”) handles information related to users of the “Habitone” service (the “Service”) obtained through the Service (“User Information”). Before using the Service, please review and agree to the contents of this Policy.

For matters not stipulated in this Policy, the Company’s Privacy Policy (the “General Policy”) shall apply. In the event of any inconsistency between the General Policy and this Policy, this Policy shall prevail.

1. User Information Obtained and Transmitted Through the Service and Purpose of Use

User Information Obtained and Transmitted When users utilize the Service, the Company obtains the following User Information through the application related to the Service (the “App”) from the users’ devices.

A:     Basic User Information

Date of birth, gender, username, email address

B:     Information Input and Recorded by Users for Using the Service

Heart rate data, steps taken, sleep, responses to questionnaires regarding health, psychological state, lifestyle habits, usage of in-app contents

C:     Device Information

Device identifier, advertising identifier, cookies, device information (model, version, hardware information), activity logs within the App, browser information

The foregoing information may include “sensitive personal information” as defined in Article 2, Paragraph 3 of the Act on the Protection of Personal Information, such as the results of health examinations conducted by physicians, guidance, diagnosis, and prescriptions provided by physicians to users.

Purpose of Use

The purposes of use of User Information obtained by the Company are as follows, depending on the type of User Information as described above. Please note that the Company may change the purposes of use to a reasonable extent deemed related to the purposes of use then current before the change.

Purpose of Use A B C
(1) Providing services to users and customizing the contents of the provided services
(2) Announcements and communications regarding the Company’s services
(3) Account authentication at login and other identity verification of users
(4) Responses to inquiries and consultations from users
(5) Notifications of changes or modifications to the Company’s terms and conditions
(6) Provision of update information on the services
(7) Implementation of surveys and satisfaction surveys related to the Company’s services or services being considered for provision by the Company in the future
(8) Investigation and analysis of the usage status of the Company’s services
(9) Improvement of the Company’s services and development of new functions and new services
(10) Creation, use, or publication of statistical data processed into a format that does not identify individuals
(11) Academic research at universities and other external institutions
(12) Responding to actions that violate the Company’s terms and conditions
(13) Resolution of operational issues of the services
(14) Other actions necessary for the provision of services
(15) Achievement of purposes specified in the General Policy in addition to the above

Provision to Third Parties

The Company will not provide acquired personal data to third parties without obtaining the user’s consent, except as permitted by the Act on the Protection of Personal Information and other laws and regulations. Notwithstanding the provisions of the General Policy, the Company may provide personal data obtained through the Service to universities and other external institutions for academic research purposes with the user’s consent.

Notwithstanding the above, if the Company obtains from a third party personal data in connection with the delegation of the handling of all or part of personal data by that third party, the Company will handle such personal data only within the scope of the purposes specified by the third party and will not provide such personal data to parties other than the third party, except as permitted by the Act on the Protection of Personal Information and other laws and regulations.

2. Information Collection Modules

The App includes the following information collection modules provided by third parties for the purposes specified below. An information collection module is a series of programs integrated into the application that has functions for obtaining User Information. The Company provides User Information, such as device identifiers, advertising identifiers, device information, activity logs within the App, and error information, to the providers of the information collection modules through the App. However, the User Information to be provided to the providers of the information collection modules does not include information that can identify individuals.

Purpose of Use