Privacy Policy

Last revised: 2026/10/14

Payke Inc. (hereinafter referred to as “the Company”) will appropriately and securely handle personal data obtained in connection with the provision of the “Payke” application (hereinafter referred to as “the Service”), which is managed and operated by the Company, in accordance with the following rules (hereinafter referred to as “these Rules”). Additionally, in the event of any discrepancies between the Japanese version of these Rules and translations in other languages, the Japanese version shall take precedence.

Definitions

In these Rules:

“Data Protection Laws” refer to all applicable laws, rules, regulations, directives, and governmental requirements related to users, encompassing all matters concerning the privacy, confidentiality, security, integrity, and protection of personal data. This includes, but is not limited to, the Data Protection Act 2018, the UK General Data Protection Regulation (“UK GDPR”), the EU General Data Protection Regulation 2016/679 (“EU GDPR”), the EU ePrivacy Directive 2002/58/EC (each of which may be amended or replaced), and the Act on the Protection of Personal Information (“APPI”) in Japan.

“Personal Data” means any data relating to an identified or identifiable individual, including but not limited to names, addresses, email addresses, dates of birth, and other information that can be used to identify a person.

“Processing” means any operation performed on personal data, including but not limited to the collection, recording, organization, structuring, storage, adaptation or modification, retrieval, reference, use, disclosure by transmission, making available through distribution or other means, alignment or combination, restriction, erasure, or destruction.

“User” means any individual who uses the Service and whose personal data is processed by the Company.

Information to be obtained

We collect the following personal data (hereinafter collectively referred to as “Acquired Information”) through the provision of the Service.

Information obtained through user input

Information Automatically Obtained Through the Use of the Service

Information obtained through inquiries, etc.

Handling of acquired information

In accordance with our "Personal Information Protection Policy," we handle acquired information for the following purposes

  1. When necessary for the provision of the Service
  2. For our legitimate business interests, e.g.:
    • Operations to improve the convenience of the Service
    • Identity verification or operations to prevent unauthorized use within the Service.
    • Processing and validating in-app purchases (including tips), managing purchase status and entitlements, reprocessing incomplete purchases, and providing user support in relation to purchases
    • Research work related to the development of new services
    • In Delivery of goods and other services related to e-commerce (EC) and online travel agency (OTA) services
    • Responding to inquiries and consultations
    • Operations related to ad serving
    • Email distribution, in-app notifications, and other email marketing related tasks
    • Preparation and submission of statistical reports (documents that do not identify specific individuals)
    • Research and analysis of foreign tourists visiting Japan (documents that do not identify specific individuals)
    • Other operations related to our legitimate business interests
  3. When necessary to comply with obligations under applicable data protection laws (including tasks related to privacy protection)
  4. When it is necessary to contact an individual to protect their life, physical health, or property

If we intend to use the acquired information for any purpose other than those described above, we will notify the user of that purpose and, if necessary, obtain consent in accordance with applicable data protection laws.

Retention Period and Scope of Use of Acquired Information

Retention Period:

Acquired information will be retained for the period necessary to achieve the purposes outlined above, for as long as the user who provided personal information continues to use the Service, for the retention period stipulated by applicable laws and regulations, or for the period necessary for the Company to conduct its business operations, whichever is longer. However, if the information is processed for statistical purposes, it may be retained for a longer period as necessary.

Scope of Use:

The location of the Company or its subsidiaries or affiliated companies, the location of the business office of a corporation or individual who has business interaction or transactions with the Company, the location of a person who receives international transmissions or other communications, the address or location of the seller of a product purchased by the User on the Service

Providing acquired information to third parties

As a general rule, the Company will not use the acquired information for any purpose other than those stated, nor provide it to any third party, except in cases of disclosure requests based on the following laws and regulations, cases of illegal access, threats, or other unlawful acts, or other special circumstances.

When using personal information, the Company fully recognizes the importance of protecting such information and will handle it strictly within the scope of its intended purpose. Additionally, if the Company entrusts the processing of all or part of the personal information it holds to a third party, it will carefully select the entrusted party and take necessary supervisory measures to ensure that the entrusted party manages the information appropriately and in accordance with the Company’s standards.

Exceptions to the provision of information to third parties

In the following cases, the recipient of personal data shall not be considered a third party:

Method of provision to third parties

When the Company provide information to third parties, the Company will do so by automated devices or other non-automated methods. Methods of provision include written documents, electronic documents, telephone, facsimile, international transmission (international telecommunications), and telecommunications.

Transfer and outsourcing of handling of acquired information

The Company may transfer or outsource the handling of acquired information, in part or in whole, to appropriate third parties. However, such outsourcing will only be carried out to the extent necessary to achieve the intended purposes of handling the acquired information. The Company will ensure that appropriate safeguards are implemented for users and that applicable data protection laws are strictly adhered to.

With respect to personal data from the EU/EEA and the UK, the European Commission and the UK Information Commissioner’s Office (ICO) have determined that Japan provides an adequate level of protection for the transfer of personal data from these regions. Accordingly, the Company may transfer personal data from the EU/EEA and the UK to Japan without the need for additional safeguards.

Information Collection Modules and Advertisements Identifiers

The Company uses the following information collection modules (including software development kits (SDKs) and other information collection and processing modules provided by third parties) for purposes such as analyzing access to and usage of the Service, delivering advertisements, processing and managing in-app purchases, and otherwise operating the Service.

Use of each advertising identifier

The Company uses the iOS advertising identifier “Identifier for Advertisers” (“IDFA”) and the Android OS advertising identifier “Google Ad ID” to display behaviorally targeted advertisements.

Users may opt out of viewing behavioral targeting ads using their respective ad identifiers. To opt-out, please follow the steps below.

Credit Card Information

The purpose of use of credit card information entered by users in connection with applications for e-commerce (EC)-related services and travel product reservations, the entity acquiring such information, and whether the Company obtains such information are as follows:

For in-app purchases made through the Apple App Store or Google Play (including tips), payment information is processed by Apple Inc., Google LLC, or the payment service providers designated by the relevant app store. Neither the Company nor Qonversion obtains or retains users' full credit card numbers or other complete payment card credentials. The Company and Qonversion do, however, obtain or process receipt information, purchase tokens, purchase history, and other transaction information for the purposes of validating purchases, managing purchase status and entitlements, preventing fraudulent use, and providing user support.

International Data Transfer

The Company may provide users' personal data to, or entrust the handling of users' personal data to, third parties located outside Japan. Details regarding Qonversion are as follows.

  1. Recipient countries
    • The United States of America (where Qonversion Inc. is located) and the United Kingdom (where the data centers used by Qonversion are located)
  2. Personal information protection systems in the recipient countries
    • United States of America: There is no comprehensive federal law covering the protection of personal information in general. Personal information is protected by the Federal Trade Commission Act (FTC Act) and other sector-specific federal laws, as well as by state laws such as the California Consumer Privacy Act (CCPA).
    • United Kingdom: Personal data is protected by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. The United Kingdom has been designated by Japan's Personal Information Protection Commission as a foreign country with a personal information protection system recognized as providing a level of protection for individual rights and interests equivalent to that of Japan.
  3. Measures taken by the recipient to protect personal information
    • For the measures taken by Qonversion to protect personal information, please refer to Qonversion's privacy policy listed in "Information Collection Modules and Advertisements Identifiers" above.

In accordance with this Policy, users consent to the provision of acquired information to, or the entrustment of the handling of acquired information to, third parties located in the foreign countries listed above.

Restrictions on use by minors under 13 years of age

Minors under the age of 13 are not permitted to use the Service. If you believe that we are retaining information about a minor under the age of 13, please contact the Privacy Desk listed in Section 18 (Inquiries Regarding Information Obtained).

Request for Disclosure, etc.

Please note that the rights described in this Privacy Policy may have limitations depending on the specific circumstances regarding the data subject's data and applicable law.

The Company will respond to the following requests from users or their representatives regarding their acquired information to the extent required by APPI , UK GDPR, EU GDPR, or other applicable data protection laws. For further information on the procedure, please contact the contact listed in section 18 (inquiries regarding acquired information). For such requests, a fee corresponding to the actual costs may be charged in accordance with the applicable data protection law.

By agreeing to the Terms of Use and this Privacy Policy, users consent to the handling of their acquired information by the Company in accordance with Japanese law, applicable data protection laws, and the provisions of these Rules.

Voluntary provision of certain acquired information

If you do not wish to provide the Company with certain acquired information, you may stop using the Service or uninstall the application.

Alternatively, you may disable location tracking, adjust your social media settings, or disable social login.

However, some functions of the Service may become unavailable.

Secure management, access and deletion of acquired information

With respect to the handling of acquired information, the Company have established internal regulations in accordance with the laws and guidelines set forth by the Japanese government, and we ensure that our employees are familiar with these regulations and take safety control and precautionary measures.

If a user requests that the acquired information provided by the user be updated, we will make every effort to respond promptly. However, we may refuse to respond to repeated requests without legitimate justification or if the request involves an excessive technical burden (e.g., deletion of data from backup data).

What to do in the event of a data breach

The Company takes all possible measures to protect users' personal data. However, in the unlikely event of a data breach, such as a leak or unauthorized access to personal data, we will take the following actions in accordance with the provisions of the GDPR.

  1. Reporting to the Supervisory Authority: In the event of a data breach, we will report it to the competent supervisory authority within 72 hours of becoming aware of it.
  2. Notification to users: If a data breach has the potential to seriously impact users, we will also promptly notify them and provide them with detailed information on how to mitigate the impact.

Amendments to these Rules and Regulations

The Company may revise these Rules at its discretion to comply with laws, government guidelines, or other regulatory requirements. Such revisions will take effect upon being posted on the Company’s website and the Service. However, if a significant revision is made that may have a substantial impact on users, the Company will provide a reasonable notice period in advance. Users will be notified through the Service in a clear and understandable manner, and the revised Rules will be posted on the website. In such cases, the revised Rules will become effective after the notice period has elapsed.

Inquiries and complaints regarding acquired information

For inquiries or complaints regarding acquired information, users may contact the Personal Information Protection Desk at the details provided below:

Contact Information:
Personal Information Protection Desk
〒902-0068 Clarion House 203, 2-5-16 Makabi, Naha City, Okinawa, Japan
Privacy Officer, Payke Corporation
Personal Information Protection Manager: Keisuke Furuta
Email: admin_support@payke.co.jp

 

Enacted and Enforced on January 1, 2016
Revised on May 21, 2018
Revised on August 6, 2018
Revised on April 1, 2019
Revised on March 23, 2021
Revised on July 8, 2024
Revised on Feb 7, 2025
Revised on Oct 14, 2026