BUOY HYDRATION, INC.
Effective Date: January 1, 2017 | Last Updated: April 7, 2026
Website: justaddbuoy.com
This Global Privacy Policy describes how Buoy Hydration, Inc. ("Buoy," "we," "us," or "our") collects, uses,
discloses, and protects personal information when you visit justaddbuoy.com (the "Site"), make a purchase, or
otherwise interact with us. It also describes the rights available to you under applicable privacy law depending on
where you are located.
We are committed to protecting your personal information and handling it transparently and lawfully, wherever in the
world you are. By using the Site, you agree to the practices described in this Policy. If you do not agree, please
discontinue use of the Site.
QUICK NAVIGATOR — YOUR JURISDICTION
Your privacy rights depend on where you are located. Please refer to the section most relevant to you:
1. INFORMATION WE COLLECT
A. Information You Provide Directly
When you make a purchase, create an account, contact us, or subscribe to communications, we may collect:
- Name and billing/shipping address
- Email address and telephone number
- Payment information — payment card data is processed by our payment processor and is not stored on our servers
- Account credentials (username and password)
- Communications you send us (e.g., customer service inquiries)
-
Health-related context you voluntarily provide if you apply for our Chronic Illness Support Program discount — see
Section 4(E) regarding our limited use of sensitive personal information
B. Information Collected Automatically
When you visit the Site, we and our service providers automatically collect certain technical and usage information
("Device Information"), including:
- IP address and general location data derived from it
- Browser type, version, and operating system
- Referring URLs and pages you visit on the Site
- Time, date, and duration of your visit
- Clickstream data and interactions with Site content
We collect this information using the following technologies:
- Cookies — small data files placed on your device that help us recognize you and remember preferences.
-
Tracking pixels / web beacons — small electronic files embedded in web pages or emails that help us analyze behavior
and measure campaign effectiveness.
- Log files — server-side records of Site activity.
- Session and behavioral analytics tools — which record how users interact with the Site in aggregate.
Cookie consent: Depending on your location, we may request your consent before placing non-essential
cookies. You can manage your cookie preferences at any time via our Cookie Preference Center or your browser settings.
See Section 6 for more detail.
C. Third-Party Tracking Technologies — Full Disclosure
The following third-party technologies are active on the Site. Each may independently collect data subject to their
own privacy policies.
Advertising & Conversion Tracking
-
Meta/Facebook Pixel & Facebook Signal — tracks conversions and site interactions to measure and
optimize Buoy's advertising on Facebook and Instagram; builds custom retargeting audiences for Buoy ads. Privacy
policy: facebook.com/privacy/policy/
-
Google Analytics, Global Site Tag, Google Conversion Linker & DoubleClick Floodlight — tracks
site usage, measures ad conversions, and links ad clicks to on-site activity to optimize Buoy's Google advertising
campaigns. Opt-out: tools.google.com/dlpage/gaoptout
-
TikTok Conversion Tracking Pixel (operated by ByteDance Ltd.; data may be transferred
internationally) — tracks conversions and site interactions to measure and optimize Buoy's TikTok advertising.
Privacy policy: tiktok.com/legal/privacy-policy
-
Pinterest Conversion Tracking — tracks actions taken on the Site after viewing or clicking Buoy's
Promoted Pins. Privacy policy: policy.pinterest.com/en/privacy-policy
-
Microsoft/Bing Universal Event Tracking (UET) — tracks key conversion events to measure and
optimize Buoy's advertising on Microsoft Bing. Privacy policy: privacy.microsoft.com
-
Reddit Conversion Tracking — tracks conversions from Buoy's Reddit advertising campaigns. Privacy
policy: reddit.com/policies/privacy-policy
-
Triple Whale — e-commerce analytics and attribution platform that aggregates pixel and order data
to measure advertising performance across channels. Privacy policy: triplewhale.com/pages/privacy-notice
-
Klickly Connector — commerce and affiliate advertising platform used for Buoy's own
performance-based campaigns. Privacy policy: klickly.com/docs/privacy
-
OuterSignal — audience signal and data enrichment tool used to improve Buoy's own advertising
targeting and measurement. Privacy policy: outersignal.com/legal
-
Axon (by AppLovin) — conversion data platform used to improve signal quality and attribution for
Buoy's own advertising campaigns. Privacy policy: legal.applovin.com/privacy/
Email Marketing & Customer Lifecycle
-
Klaviyo (including Klaviyo Learnq) — email and SMS marketing automation platform. Klaviyo collects
email addresses, purchase history, and site behavior to power Buoy's email and SMS campaigns. Opt-out:
klaviyo.com/legal/privacy
-
PostPilot — direct mail and postcard marketing platform. PostPilot may use purchase history and
customer data to facilitate Buoy's own direct mail campaigns. Privacy policy: postpilot.com/privacy-policy
Subscription Management
-
Skio Subscriptions — subscription commerce platform that manages Buoy's recurring order program
(Anti-Yellow Pee Club). Skio processes subscription, billing, and customer account data on our behalf and also
administers Buoy's customer loyalty and rewards program. Privacy policy: skio.com/privacy
Influencer, Affiliate & Community Programs
-
Gatsby Influencer Marketing — affiliate and influencer program management built on Shopify and
Klaviyo. If you participate in Buoy's affiliate or influencer program, Gatsby may collect relevant profile and
performance data. Privacy policy: gatsby.ai/privacy
-
Social Snowball — affiliate and ambassador program management platform. If you participate in
Buoy's ambassador or referral program, Social Snowball may collect relevant profile and referral performance data.
Privacy policy: socialsnowball.io/privacy
-
Impact — partnership and affiliate network platform used to manage and track Buoy's affiliate
partnerships. Privacy policy: impact.com/privacy-policy/
-
TYB (Thank You Brand) — community and brand loyalty platform. If you participate in Buoy's TYB
community program, TYB may collect profile and engagement data. Privacy policy: tyb.xyz/privacy-policy
-
Devotion — brand loyalty and community engagement platform. If you participate in Buoy's Devotion
program, Devotion may collect profile and engagement data. Privacy policy: available on request from Devotion.
Post-Purchase & Customer Experience
-
Rokt Aftersell — post-purchase offer and upsell platform shown in the checkout or order
confirmation flow. Rokt may collect transaction and interaction data in connection with offers presented after
purchase. Privacy policy: rokt.com/policies/privacy-policy
-
Cart Lock (by KlinKode) — cart protection and conversion optimization tool. May collect cart
interaction and behavioral data. Privacy policy: klinkode.com/cartlock-privacy-policy/
-
Order Protection — order protection and package insurance platform. Processes order and shipping
data to administer protection offers. Privacy policy: orderprotection.com/legal/privacy-policy
-
OpenBorder — cross-border e-commerce and localization platform used to facilitate international
orders, including currency conversion, duties, and taxes. Processes order and customer data for international
fulfillment. Privacy policy: available on request from OpenBorder — https://www.openborder.com/privacy
AI, Personalization & Conversion Optimization
-
Black Crow AI — real-time predictive analytics platform that uses purchase behavior and site
interaction data to make purchase predictions and optimize on-site personalization for Buoy's own marketing.
Opt-out: blackcrow.ai/privacy
-
Alia Popups — AI-powered Shopify application that manages website pop-up windows for promotional
and lead generation purposes. Privacy policy: aliaapp.com/privacy
-
Tolstoy — interactive video experience platform used on the Site. May collect viewing and
interaction data. Privacy policy: gotolstoy.com/privacy
E-Commerce Platform
-
Shopify — our online store is hosted and powered by Shopify. Shopify processes order, payment,
and customer data on our behalf. Privacy policy: shopify.com/legal/privacy
2. HOW WE USE YOUR INFORMATION
We use the personal information we collect for the following purposes:
- Order fulfillment: Processing purchases, arranging shipping, sending confirmations and invoices.
- Customer service: Responding to inquiries, returns, and other requests.
- Fraud prevention and security: Screening transactions for risk and fraud.
- Site improvement: Analyzing how visitors use the Site to improve functionality and user experience.
-
Buoy's own marketing: Sending promotional emails and SMS (where you have opted in or where permitted by law), and
running our own digital advertising campaigns including retargeting campaigns across Meta, Google, TikTok,
Pinterest, Bing, and Reddit.
-
Loyalty and subscription program: Administering rewards, points, and incentives through Skio Subscriptions, which
also manages Buoy's recurring subscription orders.
-
Predictive personalization: Using Black Crow AI to tailor on-site experience and optimize our marketing based on
predicted purchase behavior.
- Subscription management: Managing your Anti-Yellow Pee Club or other subscription orders.
- Chronic Illness Support Program: Verifying eligibility and administering discounts for qualifying customers.
- Legal compliance: Meeting our obligations under applicable law in all jurisdictions where we operate.
Legal Basis for Processing (EEA, UK & Switzerland)
Where the GDPR or UK GDPR applies, we rely on the following legal bases (see also Section 11):
- Contract performance — processing necessary to fulfill your order or manage your account.
- Legitimate interests — fraud prevention, security, direct marketing to existing customers, improving the Site — balanced against your rights.
- Consent — marketing emails/SMS (where required), non-essential cookies, and processing of sensitive data.
- Legal obligation — compliance with applicable law.
3. SHARING YOUR INFORMATION
We share personal information only in the following circumstances:
-
Service providers: Vendors performing services on our behalf, including those listed in Section 1(C), Shopify,
payment processors, and shipping carriers. These parties are contractually obligated to use your data only for the
services they provide to us.
-
Advertising platforms: We share limited data (such as hashed email addresses or pixel-derived identifiers) with
Meta, Google, TikTok, Pinterest, Microsoft, and Reddit solely to run and measure Buoy's own advertising campaigns.
-
Loyalty, subscription, and affiliate programs: Relevant data may be shared with Skio Subscriptions, Gatsby, Social
Snowball, Impact, TYB, and Devotion for subscription management and program administration.
-
Business transfers: If Buoy is involved in a merger, acquisition, or sale of assets, your information may be
transferred as part of that transaction, subject to standard confidentiality protections.
-
Legal requirements: We may disclose information when required by law, court order, or government request, or to
protect the rights, property, or safety of Buoy, our users, or the public.
We do not sell, rent, or disclose your personal information to unaffiliated third parties for those third parties'
own independent direct marketing purposes.
4. INTERNATIONAL DATA TRANSFERS
Buoy is based in the United States. When you interact with us from outside the United States, your personal
information may be transferred to and processed in the United States or other countries where our service providers
operate.
We take appropriate steps to ensure that international transfers of personal data are subject to appropriate
safeguards. Depending on the destination country, these may include:
- Standard Contractual Clauses (SCCs) approved by the European Commission or UK ICO (for transfers from the EEA or UK).
- An adequacy decision by the European Commission or relevant authority.
- Binding corporate rules or other recognized transfer mechanisms.
TikTok (operated by ByteDance Ltd.) may transfer data internationally, including outside the United States, subject
to TikTok's own privacy policy and transfer mechanisms.
5. DATA RETENTION
We retain personal information for as long as necessary to fulfill the purposes described in this Policy, comply with
our legal obligations, resolve disputes, and enforce our agreements. Our standard retention periods are:
- Order information: Retained for the duration required by applicable tax, accounting, and consumer protection laws in relevant jurisdictions (typically 6–10 years).
- Device Information and analytics data: Typically retained for up to 26 months.
- Marketing preferences and consent records: Retained for the duration of the customer relationship and for such period thereafter as required to demonstrate compliance.
- Sensitive personal information (Chronic Illness Program): Retained only as long as necessary to administer the program and verify eligibility, then deleted.
You may request deletion of your personal information at any time as described in the relevant jurisdiction section below.
6. COOKIES AND TRACKING PREFERENCES
You can control cookies through your browser settings. Note that disabling certain cookies may affect Site
functionality. Depending on your location, we will provide a Cookie Preference Center to allow granular control over
non-essential cookies before they are set.
Platform-specific opt-out links are listed in Section 1(C) for each provider. Additional opt-out resources:
- Digital Advertising Alliance: optout.aboutads.info
- Network Advertising Initiative: optout.networkadvertising.org
- Google Analytics: tools.google.com/dlpage/gaoptout
Global Privacy Control (GPC): We honor GPC signals as a request to opt out of data sharing where
required by applicable law.
7. SECURITY
We implement appropriate technical and organizational measures to protect your personal information against
unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit,
access controls, and regular security assessments.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify
the relevant supervisory authority and, where required, you as an individual, in accordance with applicable law.
8. CHILDREN'S PRIVACY
Our Site and products are not directed to children under the age of 16 (or the applicable age of digital consent in
your jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have
collected personal information from a child without verifiable parental consent, we will take steps to delete that
information promptly. If you believe we have inadvertently collected information from a child, please contact us at
the address in Section 9.
9. CONTACT US
For questions about this Privacy Policy, to exercise any privacy right, or for any privacy-related inquiry:
Buoy Hydration, Inc.
Attn: Privacy Compliance
11620 Wilshire Blvd. Suite 875
Los Angeles, CA 90025
Email: [email protected]
For EEA/UK data subject requests, you may also contact our EU/UK representative (details to be provided upon
appointment) or lodge a complaint with your local supervisory authority.
10. CALIFORNIA RESIDENTS (CCPA/CPRA)
This section applies to California residents and supplements the rest of this Policy. It is provided pursuant to the
California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 ("CCPA/CPRA") and
California Civil Code § 1798.83 ("Shine the Light").
A. Right to Know
You have the right to request disclosure of: the categories and specific pieces of personal information we have
collected about you; the categories of sources from which it was collected; the business or commercial purpose for
collection; and the categories of third parties with whom we share it.
B. Right to Delete
You have the right to request deletion of personal information we have collected from you, subject to certain
exceptions (such as completing a requested transaction, detecting security incidents, or complying with legal
obligations).
C. Right to Correct
You have the right to request that we correct inaccurate personal information we maintain about you.
D. Right to Opt Out of Sale or Sharing
We do not sell personal information for monetary consideration. We do not share personal information with third
parties for cross-context behavioral advertising for those parties' own marketing purposes. Our advertising pixel use
is for Buoy's own first-party campaigns only.
Nonetheless, to limit any third-party tracking you may use the opt-out links in Section 1(C), the DAA tool at
optout.aboutads.info, or the NAI tool at optout.networkadvertising.org. We also honor Global Privacy Control (GPC)
signals.
E. Right to Limit Use of Sensitive Personal Information
To the extent we collect sensitive personal information (such as health-related context provided for the Chronic
Illness Support Program), we use it only for the purpose for which it was provided and do not use it to infer
characteristics about you or for other secondary purposes.
F. Right to Non-Discrimination
We will not discriminate against you for exercising any CCPA/CPRA right. We will not deny goods or services, charge
different prices, or provide a different level of quality because you exercised a privacy right.
G. How to Submit a Request
Contact us using the information in Section 9. We will verify your identity before processing your request. We will
respond within 45 days; if additional time is needed (up to 90 days total), we will notify you. You may designate an
authorized agent to submit requests on your behalf by providing written authorization signed by you.
H. Shine the Light (Cal. Civ. Code § 1798.83)
Buoy does not disclose personal information to unaffiliated third parties for their own direct marketing purposes.
Accordingly, there is no information to disclose under § 1798.83.
11. EEA, UNITED KINGDOM & SWITZERLAND RESIDENTS (GDPR / UK GDPR / nFADP)
This section applies to individuals in the European Economic Area (EEA), the United Kingdom, and Switzerland and
supplements the rest of this Policy. It is provided pursuant to the EU General Data Protection Regulation ("GDPR"),
the UK GDPR and Data Protection Act 2018, and the Swiss new Federal Act on Data Protection ("nFADP").
A. Data Controller
Buoy Hydration, Inc. is the data controller of personal information collected through the Site. Contact details are in
Section 9. We will designate a representative in the EEA and/or UK as required by applicable law.
B. Legal Bases for Processing
We process your personal information under the following legal bases:
- Article 6(1)(b) GDPR — Performance of a contract: Order processing, account management, subscription management.
- Article 6(1)(f) GDPR — Legitimate interests: Fraud prevention, site security, analytics, direct marketing to existing customers where permitted by applicable e-privacy law, running Buoy's own advertising campaigns.
- Article 6(1)(a) GDPR — Consent: Non-essential cookies, email/SMS marketing where consent is required, processing of sensitive personal information.
- Article 6(1)(c) GDPR — Legal obligation: Tax record-keeping, responding to regulatory requests.
- Article 9(2)(a) GDPR — Explicit consent: Health-related information provided for the Chronic Illness Support Program.
C. Your Rights
Subject to applicable conditions and exceptions, you have the following rights:
- Right of access (Article 15): Obtain a copy of your personal data and information about how it is processed.
- Right to rectification (Article 16): Request correction of inaccurate or incomplete personal data.
- Right to erasure (Article 17): Request deletion of your personal data where there is no overriding legal basis to continue processing.
- Right to restriction of processing (Article 18): Request that we restrict processing of your personal data in certain circumstances.
- Right to data portability (Article 20): Receive your personal data in a structured, commonly used, machine-readable format, or have it transmitted to another controller, where technically feasible.
- Right to object (Article 21): Object to processing based on legitimate interests or for direct marketing purposes (including profiling).
- Rights related to automated decision-making (Article 22): Not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects.
- Right to withdraw consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.
D. How to Exercise Your Rights
Submit a request using the contact details in Section 9. We will respond within one month, with a possible extension
of a further two months for complex or numerous requests (we will notify you of any extension). There is no charge for
exercising your rights unless requests are manifestly unfounded or excessive.
E. Right to Lodge a Complaint
If you are not satisfied with our response or believe our processing of your personal data violates applicable law, you have the right to lodge a complaint with your local supervisory authority, such as:
- EEA: The data protection authority in your EU Member State.
- UK: The Information Commissioner's Office (ICO) — ico.org.uk.
- Switzerland: The Federal Data Protection and Information Commissioner (FDPIC) — edoeb.admin.ch.
F. Profiling and Automated Decision-Making
We use Black Crow AI to make purchase predictions and personalize on-site experience. This processing involves
profiling but does not result in decisions that produce legal or similarly significant effects on you. You have the
right to object to this profiling — contact us at the address in Section 9.
G. International Transfers
As described in Section 4, your personal data may be transferred to the United States or other third countries. For
transfers from the EEA and UK, we rely on Standard Contractual Clauses (SCCs) as adopted by the European Commission
(for EEA transfers) and equivalent mechanisms approved by the UK ICO (for UK transfers). Copies of applicable SCCs are
available on request.
12. CANADIAN RESIDENTS (PIPEDA / PROVINCIAL PRIVACY LAWS)
This section applies to Canadian residents and supplements the rest of this Policy. It is provided pursuant to the
Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy legislation
(including Quebec Law 25 / Law 64 where applicable).
A. Accountability
Buoy Hydration, Inc. is responsible for personal information under our control. Our Privacy Officer can be reached at [email protected].
B. Purposes and Consent
We collect, use, and disclose personal information only for the purposes identified in Sections 1 and 2 of this
Policy, or as permitted or required by law. In most cases, we obtain your express or implied consent at the time of
collection. Where required by law (e.g., for sensitive information or certain secondary uses), we will seek your
express consent.
C. Withdrawal of Consent
You may withdraw consent to our use of your personal information at any time, subject to legal or contractual
restrictions and reasonable notice. Withdrawing consent may mean we are unable to provide certain services to you. To
withdraw consent, contact us at [email protected].
D. Your Rights Under PIPEDA
- Right of access: Request access to your personal information and information about how it is used and disclosed.
- Right to correction: Request correction of inaccurate or incomplete personal information.
- Right to withdraw consent: As described above.
- Right to complain: Lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca, or with the applicable provincial commissioner.
E. Quebec Residents (Law 25)
Quebec residents have additional rights under Quebec Law 25, including the right to data portability (to receive a
copy of your personal information in a structured, commonly used, technological format), the right to de-indexation
(in certain circumstances), and specific consent requirements for the use of technology that identifies, locates, or
profiles you. We will obtain your explicit consent before using such technology for non-essential purposes.
13. AUSTRALIAN RESIDENTS (PRIVACY ACT 1988 / AUSTRALIAN PRIVACY PRINCIPLES)
This section applies to Australian residents and supplements the rest of this Policy. It is provided pursuant to the
Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
A. Collection Notice
We collect personal information for the purposes described in Section 2 of this Policy. In some cases (such as Device
Information), collection occurs automatically when you use the Site. You may choose not to provide personal
information but this may limit your ability to use certain features of the Site or make purchases.
B. Your Rights Under the APPs
- Access: Request access to the personal information we hold about you (APP 12).
- Correction: Request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading (APP 13).
- Anonymity: Where practicable, interact with us anonymously or using a pseudonym (APP 2).
- Complaint: Lodge a complaint with us, and if not resolved to your satisfaction, with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
C. Cross-Border Disclosure
We may disclose personal information to overseas recipients, including service providers in the United States. Before
doing so, we take reasonable steps to ensure the recipient does not breach the APPs in relation to the information,
including through contractual protections. By using the Site, you acknowledge this may occur.
D. Access and Correction Requests
Submit requests using the contact details in Section 9. We will respond within 30 days. If we refuse access or
correction, we will give you reasons in writing.
14. BRAZILIAN RESIDENTS (LGPD — Lei Geral de Proteção de Dados)
This section applies to Brazilian residents and supplements the rest of this Policy. It is provided pursuant to the
Brazilian General Data Protection Law (Lei nº 13.709/2018, "LGPD").
A. Controller and DPO
Buoy Hydration, Inc. is the controller of personal data collected through the Site. Our Data Protection Officer (DPO)
or appointed contact can be reached at [email protected].
B. Legal Bases (Art. 7 and Art. 11, LGPD)
We process personal data under the following legal bases:
- Consent (Art. 7, I): For marketing communications, non-essential cookies, and sensitive personal data.
- Contract performance (Art. 7, V): To process your order and manage your account.
- Legitimate interests (Art. 7, IX): For fraud prevention, security, and Buoy's own advertising campaigns, balanced against your rights.
- Compliance with legal obligation (Art. 7, II): To fulfill our legal obligations.
C. Your Rights Under the LGPD (Art. 18)
- Confirmation of processing: Confirm whether we process your personal data.
- Access: Access the personal data we hold about you.
- Correction: Correct incomplete, inaccurate, or outdated personal data.
- Anonymization, blocking, or deletion: Of unnecessary, excessive, or non-compliant data.
- Portability: Receive your personal data in a machine-readable format.
- Deletion: Of personal data processed with your consent.
- Information about sharing: Information about entities with which we share your data.
- Information about consent denial: Information about the consequences of denying consent.
- Revocation of consent: Withdraw consent at any time.
- Complaint to the ANPD: Lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd.
D. International Transfers
Transfers of personal data to countries outside Brazil occur in accordance with Art. 33 of the LGPD, including
reliance on Standard Contractual Clauses, the ANPD's adequacy decisions, or other permitted mechanisms.
15. JAPANESE RESIDENTS (APPI — Act on the Protection of Personal Information)
This section applies to residents of Japan and supplements the rest of this Policy. It is provided pursuant to the
Act on the Protection of Personal Information (Act No. 57 of 2003, as amended, "APPI").
A. Business Operator
Buoy Hydration, Inc. is the personal information handling business operator (kojin joho toriatsukai jigyo-sha).
Contact us at [email protected] for all APPI-related inquiries.
B. Purpose of Use
We use personal information for the purposes described in Section 2 of this Policy. In accordance with the APPI, we
will notify you of the purpose of use at the time of collection and will not use personal information beyond the
stated purposes without your prior consent.
C. Provision to Third Parties
We will not provide personal information to third parties without your prior consent, except as permitted by the APPI
(e.g., outsourcing to service providers, business succession, or as required by law). Where we share data with service
providers (委託先), we supervise them appropriately.
D. Your Rights Under the APPI
- Disclosure: Request disclosure of retained personal information (hozon kojin johō) we hold about you.
- Correction: Request correction, addition, or deletion of retained personal information that is incorrect.
- Cessation of use or erasure: Request we stop using or erase your retained personal information in certain circumstances.
- Cessation of third-party provision: Request we stop providing your personal information to third parties in certain circumstances.
- Complaint: Lodge a complaint with the Personal Information Protection Commission (PPC) at ppc.go.jp.
E. Cross-Border Transfers
Personal information may be transferred to the United States and other countries. We take appropriate measures to
ensure that overseas recipients handle personal information in accordance with standards equivalent to the APPI,
including through contractual protections with third-party service providers.
16. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal
requirements, or international operations. We will post the revised policy on this page with an updated effective
date. For material changes, we will provide more prominent notice (such as an email notification or a banner on the
Site) where required by applicable law. We encourage you to review this policy periodically. Continued use of the Site
after any changes constitutes your acceptance of the revised policy.