Privacy policy

TWP&Partners LLC (a Japanese limited liability company, Godo Kaisha) (“TWP&Partners,” “we,” “us,” or “our”) appropriately handles personal information in accordance with our personal information protection policy.

1. Information We Collect

(1) Information You Provide to Us

Identifiers such as your name, date of birth, and other information that can identify a specific individual.
Account information such as your address, phone number, email address, password, and other information used in connection with your account.
Payment information such as credit card information and bank account information.

(2) Information Collected Automatically When You Use the Service

User Content and Metadata
When you use the Service, data you upload and metadata necessary to provide the Service may be generated. Such data is recorded within our systems.
Log Data
When you access the Service, we automatically collect log information. This log data may include IP address, browser type, language settings, and similar information.
Device Information
We collect information about the devices used to access the Service, including device type, operating system type, device identifiers, and similar information.
Location Information
For security purposes and certain time- and language-related features, we may infer an approximate area using your IP address obtained from browser and device information.
Cookie Information
We use cookies to improve user convenience. We may store collected information as cookies in a secure area on your device.
Audio/Video Information
When you use audio/video communication features, we may receive, collect, and store audio and video data generated through such communications.

2. Purposes of Use

We use the information we collect for the purposes set forth in our Terms of Service and/or for the following purposes:

To provide the Service
To communicate and share information regarding the Service
To send emails related to the Service
To process billing and payments and verify payment status
To investigate and analyze Service usage and related trends
To use for marketing purposes, such as providing information about the Service
To resolve operational issues and troubleshoot problems
To prevent fraud and misuse and to implement security measures
To respond to inquiries regarding the Service

3. Disclosure of Collected Information to Third Parties

We may provide collected information to third parties in the following cases:

Where disclosure is permitted under the Act on the Protection of Personal Information of Japan (APPI), such as when requested by a court, supervisory authority, or other governmental/public authority.
Where we provide information to credit card issuers, payment processors, and other financial institutions (collectively, “Credit Card Issuers, etc.”) for the purpose of detecting and preventing fraudulent use of credit cards.

4. Third-Party Provision

We may provide personal information to third parties in the following cases:

When we provide personal information to a third party based on your instructions or consent
Where disclosure is permitted under Japan’s APPI, such as when requested by a court, supervisory authority, or other governmental/public authority
When we provide information to Credit Card Issuers, etc. for the purpose of detecting and preventing fraudulent credit card use.
If you use a card issued by a Credit Card Issuer, etc. located outside Japan, information such as your identifier, card identifier, phone number, email address, registered address, shipping address, payment amount, account activity information, and credit card registration date/time may be transferred to the country where such Credit Card Issuer, etc. is located.

5. International Data Transfers

Transfers from the EEA, etc. (GDPR Chapter V)
If users located in the European Economic Area (EEA), etc. use the Service, their personal data will be transferred from the EEA, etc. to Japan. Such transfers are conducted based on the European Commission’s adequacy decision for Japan (GDPR Article 45) and do not require additional transfer safeguards. Under the adequacy decision, transfers from the EU to Japan are treated similarly to intra-EEA transfers.
Transfers from the United Kingdom (UK GDPR)
If personal data of users located in the United Kingdom is transferred to Japan, such transfers are conducted based on the UK adequacy regulations (UK adequacy). The UK–Japan adequacy arrangement continues to be confirmed as a framework supporting data flows in cooperation areas, including public and private sector research and the public sector.

6. Cookies

We use both session-based cookies and persistent cookies.

These cookies contain information necessary for login and are used when you log in to our Service.

6. Retention Period and Deletion

Retention and Deletion of Service Data
We retain, during the contract term and to the extent necessary for providing the Service, service data that users or administrators enter or generate through use of the Service, as well as metadata that we generate in connection with such data (e.g., item IDs, timestamps, permissions, indexes).
Deletion After Termination
Within 120 days from the effective date of cancellation or contract termination, we will logically delete or physically delete such service data from production storage.
Operational Logs
For security and availability purposes, we may retain operational logs (such as access logs, operation logs, and audit logs) for a certain period as long as necessary, even after termination.

7. Children’s Personal Information

Age Requirement
We do not permit individuals under the age of 16 to use the Service. We do not knowingly collect or use personal data from individuals under 16.
If We Collect Information by Mistake
If we become aware that personal data has been provided by an individual under 16, we will, within a reasonable scope, promptly stop processing such data and take appropriate measures such as deletion. If necessary, we may suspend or delete the relevant account.
Consistency with Applicable Laws
This section will be interpreted and operated in accordance with applicable laws. If age classifications or requirements differ depending on the region, we will comply with the laws of that region and take any necessary additional measures.

8. Changes to This Policy

Implementing Changes
We may change this Policy in response to amendments to laws or guidelines, changes to the Service, or operational needs. The updated Policy will apply with the effective date and last updated date clearly indicated.
How We Notify You
If we change this Policy, we will notify you (in advance or after the fact) of the effective date and the main changes via email (to your registered email address) or on our website.
Material Changes
For material changes (e.g., addition of collected items, significant changes to purposes of use, new categories of third-party recipients, significant changes to retention periods, etc.), we will provide notice with a reasonable notice period (30 days).
For minor changes (e.g., clarifying wording or correcting typos), posting on our website will be effective.
Where Consent Is Required
If a change requires user consent under applicable law (e.g., adding a new purpose that relies on consent as a legal basis), we will obtain clear consent before the change takes effect. If a user does not consent, we will not process data for that change.
Acceptance by Continued Use
After the notice period for material changes has passed, if you continue to use the Service, you will be deemed to have agreed to the updated Policy. However, this does not apply where explicit consent is required by law.

9. Contact Us

For opinions, requests, or questions regarding our handling of personal information or our security measures, please contact us at:

Email: info-risa@tw-partners.biz