Privacy Policy

The following information is published in accordance with the “Act on the Protection of Personal Information” of Japan.

LCL, Inc. (hereinafter referred to as the “Company”) has established the following privacy policy regarding the handling of customers' important personal information in the various services provided by the Company (hereinafter collectively referred to as the “Services”) and is committed to protecting it.

Article 1 Definition of personal information

Personal information refers to information about an individual that can be used to identify them through descriptions such as their name, date of birth, telephone number, address and e-mail address. This also includes information that, when combined with other data, can be used to identify a specific individual even if it alone is insufficient for such identification.

Article 2 Obtainment of personal information

The Company obtains personal information by the following methods:

(1) Customer information (names, email addresses, telephone number, address etc.,): By directly receiving it from users, customers, etc. (Retention period: as long as necessary for business or required by law)
(2) Informative Data (as defined in Article 3, Paragraph 1 below): By automatically recording it when users, customers, etc. use websites or applications (Retention period: as long as necessary for business or required by law)
(3) Informative Data (as defined in Article 3, Paragraph 1 below): By receiving it from a third party that has previously obtained it (Retention period: as long as necessary for business or required by law)

Article 3 Obtainment and use of data regarding the use of websites or applications

(1) About Informative data

In this Policy, “Informative Data” refers to information about users' personal computers, smartphones, mobile phones, and other information communication devices, as well as behavioral history and other information related to an individuals, that is recorded through cookies, local storage, web beacons, device identifiers, and similar technologies, and which, by itself, cannot be used to identify a specific individual. The Company may obtain and use Informative Data.Informative Data may be automatically matched with personal information on the system for carrier payments, etc., or matched with personal information for appropriate responses to inquiries from users, business partners, etc., as well as for the purpose of system management, fraud prevention, verification and control, and security enhancement, etc. In this case, Informative Data will also be handled as personal information.

Informative Data obtained by the Company includes:

(i) Information related to device identification of an information communication device, such as a device ID
(ii) User agent
(iii) Information regarding the operating system of the information communication device and its connection to the Internet
(iv) Referrer
(v) IP address
(vi) URLs viewed and time stamps of time viewed
(vii) Number of page views and other relevant information recorded on the Company's services
(viii) Purchase amount, reservation number, departure and arrival locations, and other reservation information (which shall be limited to the information that alone cannot identify any specific individual) collected on an affiliate site redirected from the Company's site
(ix) Other server log information

(2) About cookies, etc.

Cookies, local storage, IndexedDB, etc., are technologies that enable a website provider to store data on the user's computer through the browser (hereinafter, these and other technologies with similar mechanisms shall collectively be referred to as “cookies, etc.”).

The Company uses (i) cookies, etc. essential for the operation of its website, (ii) cookies, etc. that help the Company analyze how its website is used, and (iii) cookies, etc. that allow the Company to provide effective contents and advertisements (including targeted advertisements) relevant to users' interests.

When a user visits the Company's website, cookies, etc. may be issued to the user's device by the Company or by a third party. Cookies, etc. issued by a third party are managed by the third party and handled in accordance with the privacy policy of the third party.

The Company may store and use cookies, etc. in its data management platform (DMP).

If you wish to opt out (disable) of cookies, etc. issued by DMPs and third parties, please refer to the following page.

External transmission (opt-out)

(3) About device identifiers

The Company may collect device identifiers (including advertising identifiers such as IDFA issued by Apple and AAID issued by Google) from smart device terminals that have downloaded the Company's iOS or Android applications. The Company uses device identifiers to analyze users' access status, provide services that meet their needs, improve service quality, and optimize marketing research and advertisement delivery. Advertising identifiers such as IDFA and AAID will be used solely to optimize advertisement delivery.

To stop targeted advertising using an advertising identifier such as IDFA or AAID, please opt out (disable) from the “Settings” of user's device.

Article 4 Purpose of use of personal information

The Company use personal information for the following purposes, or to the extent necessary to achieve them. In the unlikely event that the purposes of use must be changed, the Company will notify its customers or publicly announce the change.
(1) Customer information (use for contractual performance,etc., use with the consent of the user, customer, etc., or use for the purpose of legitimate interests of the Company or a third party (such as the provision and enhancement of the Company's services))
• To receive and process registration applications for the Services, identify users, and provide, safeguard and improve the Services
• To provide notifications regarding the contents of the Services, updates, and changes to the terms and conditions, etc.
• To provide information regarding the Services and respond to inquiries about the Services
• To address violations of the Company's terms for the Services or other applicable regulations
• To create statistical data on the use of the Services
• To develop plans, make recommendations regarding the Services and implement them
• To distribute or display advertisements of the Company or third parties
• To send products to customers who have won campaigns, etc.
• To utilize it for other marketing purposes
(2) Informative Data (use for contractual performance, etc., use with the consent of the user, customer, etc., or use for the purpose of legitimate interests of the Company or a third party (such as the provision and enhancement of the Company's services))
• To provide, safeguard and improve the Services
• To create statistical data on the use of the Services
• To develop plans, make recommendations regarding the Services and implement them
• To distribute or display advertisements of the Company or third parties
• To distribute or display advertisements or other information related to new products and services according to interests and preferences by analyzing obtained information such as browsing history
• To utilize it for other marketing purposes

Article 5 Provision to third parties, Entrustment, and Joint Use of Personal Information

1. The Company will not provide personal information obtained from customers to third parties without obtaining the prior consent of the customer.
2. The Company may entrust subcontractors, such as advertising partners, service providers and marketing research companies, to handle all or part of the personal information to the extent necessary to achieve the purpose of use of personal information. In doing so, the Company will thoroughly assess the suitability of each subcontractor, include confidentiality obligations in the contract, and establish a system for appropriate information management.
3. If the Company needs a business partner to provide the Services to its customers in the future, it may jointly use customers' personal information with that business partner. In this case, the Company will announce to the customers the purpose of joint use, the name of the business partner (scope of joint users), the categories of personal information used jointly, and the name of the administrator responsible for the management of the personal information.

Article 6 Procedures to respond to requests (hereinafter collectively referred to as “Disclosure Request”) based on the rights of the individual whose personal information is held (the right to request disclosure, correction or deletion, or restrictions on handling, or to raise an objection, the right to data portability, the right to withdraw consent, and rights otherwise recognized by laws or regulations)

1. If a customer makes a Disclosure Request pursuant to the provisions of applicable laws or regulations, the Company will respond to the Disclosure Request without delay after confirming that the request was made by the customer themself, but only if the Company is obligated to respond under the applicable laws or regulations. In connection with the Disclosure Request being made, the Company may require the customer to pay a fee in accordance with the procedures separately established by the Company.
2. If a customer (1) requests correction of the content of personal information based on the provisions of applicable laws or regulations on the grounds that the personal information is untrue, or (2) requests discontinuation of use, deletion, or discontinuation of the provision of personal information to a third party based on the provisions of applicable laws or regulations, or (3) makes any other request based on the provisions of applicable laws or regulations, the Company will confirm that the request was made by the customer themself, conduct the necessary investigation without delay, and based on the results of the investigation, in light of the provisions of the applicable laws or regulations, if the request is found to have a reason, the Company will correct the content of personal information, discontinue use, or discontinue the provision of personal information to a third party, or take other necessary actions, and notify the customer accordingly.
3. If a customer requests notification of the purpose of use of personal information, the Company will notify the customer of it without delay in accordance with laws and regulations after confirming that the request has been made by the customer themself.
4. When making a request in any of the preceding items, please send the following information and other materials prescribed by the Company:
(1) Name, address, phone number and email address
(2) Content of request, background, and supporting documents
(3) Documents that can verify the identity of the person who made the request
5. If the customer falls under any of the following items, the Company may not be able to respond to their request under Paragraphs 1 to 3. In this case, the Company will notify the customer accordingly and explain the reasons.
(1) Where there is a risk of harm to the life, body, property or other rights or interests of the customer or a third party.
(2) Where there is a risk of causing extreme hindrance to the proper operation of the Company's business.
(3) Where meeting the request would violate laws or regulations.
(4) Where the Company is unable to confirm that the request is from the customer themself.
(5) Where there are other reasonable grounds for refusing the request.
6. Customers may have a right to make a complaint to the supervising body under applicable laws or regulations.

Article 7 Safety management measures

The Company has taken necessary and appropriate measures to secure personal data that it retains. For details about the safety management measures, please contact us using the Contact Form.

Article 8 Discretion in providing personal information

Provision of personal information to the Company is at the discretion of the individual. However, please note in advance that not providing personal information may result in disadvantages to the individual due to hindrances in the provision of the services.

The consent to the handling of personal information may be withdrawn at any time, which, however, will not affect the handling of the personal information handled by the Company before the withdrawing of consent.

Article 9 Links

Business operators other than the Company, which are linked to the Company's website, may obtain personal information on their own websites. In such cases, this Privacy Policy will not apply, and the Company will assume no obligation or responsibility for the handling of personal information by those business operators.

Article 10 Contact for Inquiries

If you have any comments or questions about this Privacy Policy, or any other inquiries regarding the handling of personal information, or any requests under Article 6, please contact us using the Contact Form.

Article 11 Revision

If the Company revises this Privacy Policy, it will promptly announce the date of the revision and the details of the revision on its website.

Established on July 1, 2025

Personal information handling business operator

LCL, Inc.

Ebisu First Square 8F, 1-18-14 Ebisu, Shibuya-ku, Tokyo

Keigo Hirata, Representative Director