Privacy policy
Note on this translation: This English version is provided for the convenience of non-Japanese readers. It is a translation of the original Japanese Privacy Policy published at https://fanqlo.jp/policies/privacy-policy. In the event of any discrepancy between this English version and the original Japanese, the Japanese version shall prevail.
Personal Information Protection Policy
FANQLO Inc. (the "Company," "we," or "us") complies with the Act on the Protection of Personal Information (Act No. 57 of 2003; the "APPI"), the guidelines concerning the protection of personal information, and other related laws and regulations, with respect to the handling of personal information we acquire. Unless otherwise defined in this Policy, the definitions of "personal information" and other terms follow those set out in the APPI.
1. Secure Management of Personal Information
We implement appropriate organizational, physical, personnel, and technical measures for the protection of personal information, and take the measures necessary and appropriate to prevent leakage, loss, or damage of the personal information we handle, and otherwise to ensure its secure management.
2. Matters Observed in Acquiring Personal Information
With respect to the acquisition, use, and provision of personal information, we observe the following.
(1) Acquisition of Personal Information
To the extent necessary for operating the internet-based information website we manage (the "Site") and for providing related services, we may acquire personal information from the following parties:
1. General users of the Site (the "Users");
2. Persons who place advertisements on the Site (the "Advertisers");
3. Persons who engage in content production, PR activities, appearances, and other similar activities through our SNS accounts, events, etc. (the "Content Partners").
(2) Purposes of Use
Except where provided by law or where the individual's consent has been obtained, we will not use the personal information we acquire beyond the extent necessary to achieve the following purposes:
1. Operation, maintenance, and management of the Site;
2. Provision and introduction of services through the Site;
3. Surveys to improve the quality of the Site;
4. Business communications with Content Partners and management of program participation;
5. Provision of benefits and rewards to Content Partners;
6. Aggregation and analysis of Content Partners' activity results (including insight data) and reporting to Advertisers;
7. Matching between Advertisers and Content Partners;
8. Appearance in reaction videos and similar content, posting on our official SNS accounts, and advertising use following prior confirmation.
(3) Provision of Personal Information
Except as provided by law, we will not disclose or provide personal information acquired with the individual's consent to any third party without the individual's prior consent. Upon the individual's request, we will disclose, correct, add to, or delete personal information, or notify the individual of the purpose of use, in accordance with applicable laws, and will respond appropriately to opinions and inquiries.
3. Management of Content Partners' Personal Information
We handle the personal information acquired from Content Partners as follows.
(1) Types of Information Acquired
1. Name (including real name and professional/handle name);
2. Contact details such as email address, telephone number, and SNS account direct messages (DMs);
3. Address (for shipping benefits and products);
4. Bank account information (where reward payments arise);
5. Performance data such as SNS account information, follower counts, and insight data;
6. Photographs and footage of the individual (profile images, appearances in reaction videos, etc.).
(2) Purposes of Use
1. Management of program participation and business communications;
2. Shipping of benefit products, and calculation and payment of rewards;
3. Aggregation and analysis of activity results and KPIs, and reporting to Advertisers;
4. Posting of content on our official SNS accounts, websites, etc., and advertising use following prior confirmation.
(3) Method of Obtaining Consent
Agreements with Content Partners may be formed not only in writing but also through electronic means such as SNS DMs and email. In connection with program participation, we confirm a participant's consent after clearly stating the purpose of use, the content to be posted, the media to be used, the period of use, and the scope of secondary use. Where we make secondary use of content produced and posted by a Content Partner (SNS posts, videos, etc.), we obtain separate, individual permission for such secondary use via DM or email, apart from tagging or mentions.
(4) Acquisition of Insight Data
In the course of our work, we may request the provision of post insight data (reach, impressions, engagement, etc.) for SNS accounts owned by Content Partners. Insight data we acquire is used only for reporting results to Advertisers and for our internal analysis, and is not used for any other purpose without the individual's consent.
(5) Storage and Management
Acquired personal information is stored in a secure environment with managed access permissions, and is appropriately managed so that only personnel who require it for business purposes can access it.
(6) Retention Period
After a program ends, taking into account statutory retention obligations (in principle, 7 years for information relating to reward payments), we will promptly dispose of or delete the information once we determine that the purpose of use has been achieved.
4. Handling of Reaction Videos and Event Filming
We handle the production of reaction videos (the "Video Content") and their posting on our official SNS accounts and other media as follows.
(1) Subjects
Those who appear in the Video Content are Content Partners, including influencers, ambassadors, campaign participants, and event participants.
(2) Handling of Portrait Rights and Copyright
1. We respect the portrait rights of Content Partners and obtain the individual's prior consent before filming, publishing, or otherwise using Video Content.
2. Copyright in Video Content produced, filmed, edited, or otherwise created by the Company shall belong to the Company. Where content is independently created by a Content Partner, ownership and usage rights shall be determined separately through consultation.
3. Within the scope of their consent, Content Partners grant permission for the Company to post Video Content on its official SNS accounts, websites, and related media, and to make secondary use of such content, including editing, clipping, reposting, and promotional use.
4. Where advertising use is contemplated, including use in banner advertisements, SNS advertisements, promotional materials, websites, landing pages, or similar media, the Company shall clearly communicate the intended media, period of use, and content to the Content Partner in advance and obtain individual confirmation.
(3) Method of Obtaining Consent
The Company shall clearly communicate the intended media, purpose of use, period of use, and scope of secondary use, and shall obtain consent through electronic means such as SNS direct messages, email, online forms, electronic contracts, or other electronic communication methods.
Consent shall be deemed established when the Content Partner expresses agreement through such communication methods.
Where filming targets an unspecified number of individuals at an event or similar occasion, the Company shall provide advance notice through signage, announcements, or other appropriate means. Where publication in a form that allows an individual to be identified is anticipated, the Company shall, where reasonably practicable, obtain individual confirmation from the person concerned.
(4) Handling of Minors
Where a Content Partner is a minor, participation shall be permitted only after obtaining verifiable consent from a parent or legal guardian.
The Company reserves the right to request documentation or other evidence reasonably necessary to verify such consent. If such consent cannot be verified, the Company may decline, suspend, or terminate the individual's participation in the program.
(5) Response to Deletion or Correction Requests
If a Content Partner requests the deletion or correction of already-published Video Content, the Company shall review the request in good faith and respond within a reasonable period.
Please direct any such requests or inquiries to the contact listed below.
5. Changes to the Purposes of Use
In principle, we will not change the purposes of use specified in the preceding sections, except where the individual's prior consent has been obtained. This shall not apply, however, where we change the purpose within a scope reasonably deemed to have a substantial relationship to the pre-change purpose of use, after publicizing the post-change purpose in advance.
6. Provision to Third Parties and Outsourcing of Handling
Except where based on laws and regulations, where we outsource the handling of personal information to the extent necessary to achieve the purposes of use, or where otherwise permitted by law, we will not disclose or provide personal information to third parties without the individual's prior consent.
Where we outsource all or part of the handling of personal information to a third party, we will sufficiently examine the suitability of that party and will exercise the necessary and appropriate supervision over the outsourced entity so as to ensure the secure management of the entrusted personal information.
7. Improvement and Review of Handling
We conduct inspections of our handling, management systems, and initiatives regarding personal information, and continuously improve and review them.
8. Procedures for Disclosure and Similar Requests
Where the individual concerned requests disclosure of their personal information or of third-party provision records, we will disclose such information without delay based on the request. Where a request is made for correction, suspension of use, or suspension of provision to third parties, we will carry out such correction, suspension of use, or suspension of provision to the extent required by law. Where a request is made for the provision of information regarding our security control measures, we will disclose such information without delay. Please note that if we suspend the use of, or delete, part or all of the personal information, we may regrettably become unable to provide services in accordance with your request.
If you wish to make such a request, please complete the required items on the request form prescribed by us and send it, together with identity verification documents (or, in the case of an agent, documents verifying the authority of representation), to the contact listed at the end of this Policy. We will respond appropriately after reviewing the content.
9. Disposal of Personal Information
When the necessity of personal information is lost in light of its purpose of use, we will erase or dispose of the personal information. Such erasure and disposal will be carried out by methods that are necessary and appropriate to prevent risks such as external leakage, to the extent necessary for the performance of our business.
FANQLO Inc.
Gotanda Sun Heights 2F, 1-26-2 Nishi-Gotanda, Shinagawa-ku, Tokyo, Japan
Representative Director: Ayumi Saito
Established: August 3, 2024 Revised: May 21, 2026
Contact for Inquiries about this Personal Information Protection Policy
FANQLO Inc. — Personal Information Inquiry Desk
Personal Information Protection Manager: Ayumi Saito
info@fanqlo.jp
Notes for the English Version
The following notes are not part of the original Japanese Privacy Policy. They are added for readers outside Japan and are provided for informational purposes.
1. Governing language. This English text is a reference translation. The legally binding version is the Japanese-language Privacy Policy on this website, which prevails in the event of any difference in meaning or interpretation.
2. Location of data handling. The Company is based in Japan. Personal information we collect — including from individuals located outside Japan — is stored and processed in Japan and handled in accordance with Japanese law (the APPI). By using this Site or providing your information, you understand that it will be transferred to and handled in Japan.
In the event of any discrepancy between the Japanese and English versions, the Japanese version shall prevail.