Privacy Policy

WellBe, Inc. (hereby referred to as "We") provides the services operated by us (hereby referred to as the "Service") to its users. The following privacy policy (hereby referred to as this "Policy") defines how and for what purposes User Information (defined below) will be handled when the Service is used by users.

This Policy is part of our Terms of Service and applies to your use of our services. Therefore, the definitions of terms used in this Policy have the same meanings as those used in our Terms of Service.

The cases in which we provide personal information to third parties are set forth in this Policy. Our managed and operated websites (including both PC and mobile websites, hereby referred to as the "Site") contain links to other websites. This Policy applies only to information collected by the Site, and we are not responsible for the privacy policies or content of other websites. Users should read the privacy policies of each linked website and confirm the handling of their personal information.

Article 1 (User Information to be Collected and Method of Collection)

In this Policy, "User Information" means personal information ("personal information" as defined in the Act on the Protection of Personal Information. The same shall apply hereinafter), information that can indirectly identify individual users, action history on communication services (including web page browsing history and search history), and other information which is generated or stored by users or in relation to users' devices such as smartphones and PCs and is collected by us in accordance with this Policy. The User Information we collect in the Service is as follows, depending on the collection method.

1. Information to be provided by the users
The information that users are requested to provide in order to use the Service is as follows.

• Name
• Phone number
• Email Address
• Gender, date of birth
• Other information entered by the User in the input form prescribed by us

2. Information that users allow to be linked to other services and provided by other services
If a User has given permission to link with external services such as social network services when using the Service, the following information will be collected from such external services based on what was agreed upon when the User gave permission.

• ID used by the User in the relevant external service
• Other information that the User has authorized the linked party to disclose according to the privacy settings of the external service in question.

3. Information we collect when the User uses the Service
We may collect information about how the User access and use the Service. This may include the following information.

• device information
• log information
• cookies and anonymous IDs
• location information

Article 2 (Purpose of Use)

1. We use personal information for the following purposes.

1. To provide, maintain, protect, and improve the Service, including member registration, reservation acceptance, identity verification, and fee calculations related to the Service
2. To perform procedures such as withdrawal or cancellation of membership from the Service and subsequent management of such procedures
3. To provide information on the Service and to respond to inquiries
4. To request, contact, and send gifts for questionnaires, and campaigns related to the Service
5. To deal with violations of our Terms and Services or policies regarding the Service
6. To notify of changes to the Terms and Services, etc
7. To license publication in various media edited and operated by us, etc
   *Reviews and survey responses submitted by users may be published in various media edited and operated by us. However, unless otherwise agreed by the user, such information will be processed into information that cannot be used to identify a specific individual by itself, such as gender and age information excluding name and address information, before being published
8. To research and analyze the usage of the Service (e.g., to conduct various marketing surveys such as questionnaire surveys and monitoring surveys, and to analyze attribute information and behavioral history obtained by us)
   *When we outsource analysis work to an advertising-related business, we may add log information related to Internet usage, such as user attribute information, location information, and action history held by the advertising-related business to the personal information held by us, and receive analysis results compiled from such information alone, which cannot be used to identify a specific individual by us; and
9. For purposes of use incidental to the above purposes of use

2. We will not use personal information for purposes beyond those stated in this Policy at the time of collection. If we intend to use personal information beyond the scope of the original purpose of use, we will obtain the prior consent of the User.

Article 3 (Security Control Measures for User Information)

We regularly conduct internal training and other activities to raise awareness and educate our employees regarding security, privacy, and the protection of personal information. We also take every precaution to protect the User Information we collect, both online and offline. Furthermore, we use firewalls, intrusion detection, SSL, and other technologies to ensure that User Information is handled with the utmost care and is accessible only by those authorized to do so for business purposes.

Article 4 (Provision to Third Parties)

1. We will not provide personal information among User Information to any third party without obtaining the prior consent of the User, except in cases where disclosure is permitted under the Act on the Protection of Personal Information or other laws and regulations. However, this shall not apply in the following cases

1. When providing information necessary for the execution of a contract to a user to a company or other entity such as a store member to which the User has made a reservation or given consent
2. When we outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use
3. Cases in which personal information is provided as a result of the succession of business due to merger or other reasons
4. When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the user's consent is likely to impede the execution of such affairs; or
5. Other cases permitted under the Act on the Protection of Personal Information and other laws and regulations

2. We may provide users' personal information to third parties located in the following foreign countries. The country-specific information that should be used as a reference is as follows. To select an appropriate business entity for entrustment, we may entrust (provide) personal information to an entrusted business entity in a foreign country other than those listed below, although we are unable to identify the entrusted business entity or its country of residence at this time. In this case, we may start entrustment to a new trustee without obtaining the User's consent again.

1. Foreign Names
   ・Socialist Republic of Vietnam
2. Personal data protection system of the foreign country concerned
   Please click on the links below for information provided by the Privacy Committee.
   https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_vietnam/
3. Personal information protection measures to be taken by the third party
   We confirm that the third party to which the information is provided has a system in place that conforms to the laws and regulations concerning the protection of personal information in the country concerned.

3. When providing personal information to a third party located in a foreign country that has taken measures equivalent to those required to be taken by business operators handling personal information under the Act on the Protection of Personal Information , we take the necessary measures to ensure the continued implementation of such measures. For details of such measures, please contact the inquiry desk specified in Article 8.

Article 5 (Disclosure of Personal Information)

1. In the event that a user requests disclosure of personal information or records provided to a third party in accordance with the provisions of the Act on the Protection of Personal Information, we will confirm that the request is made by the user himself/herself and disclose the information to the user without delay (if the relevant personal information does not exist, we will notify the user to that effect). However, this does not apply to cases in which we are not obligated to disclose the information under the Act on the Protection of Personal Information or other laws and regulations. Please note that a handling fee may be charged for the disclosure of personal information.

2. When we receive a request from a user, under the provisions of the Act on the Protection of Personal Information, to correct, add, or delete (hereby referred to as "Correction, etc.") the content of his/her personal information on the grounds that the content is not true, we will conduct the necessary investigation without delay after confirming that the request is made by the user himself/herself and make the Correction, etc. based on the results of the investigation. However, this shall not apply in cases where we are not obligated to disclose the information under the Act on the Protection of Personal Information or other laws and regulations.

3. When we receive a request from a user to suspend the use, erase, or suspend the provision to a third party of his/her personal information (hereby referred to as "Suspension of Use") in accordance with the provisions of the Act on the Protection of Personal Information, we will conduct the necessary investigation and make Suspension of Use based on the results of the investigation without delay after confirming that the request is made by the user himself/herself. However, this shall not apply in cases where we are not obligated to disclose the information under the Act on the Protection of Personal Information or other laws and regulations. In addition, the user may not be able to receive the Service as a result of the actions described in this paragraph.

Article 6 (Voluntary provision of personal information)

The provision of personal information by the user is voluntary, but if the user does not enter the items required for the Services, the user may not be able to receive the Services.

Article 7 (Google Analytics and Cookies)

The Site uses Google Analytics to analyze and improve the Site. In doing so, Google may set cookies on your browser or read existing cookies to collect data. In addition, your web browser while using the Service will automatically send Google certain non-personal information (e.g., the web address or IP address of the page you are accessing). The Site may use such information for purposes such as understanding site usage, improving the site usage experience, and presenting user trends in the form of content.
By using the Site, you grant Google and the site administrator permission to process such data in the manner and for the purposes described above.
The way Google collects and uses access information is set forth in the Google Analytics Terms of Service and Google's Privacy Policy.
A cookie is a code that allows a website (or a third-party service such as Google Analytics) to store information in the browser of the device used by the user and retrieve it later. However, please be assured that the website administrator cannot determine the user's name, date of birth, telephone number, e-mail address, etc. from the cookies set by the Site.
If you do not wish to accept Google Analytics cookies, please refer to the following link
■Google Analytics Opt-out Add-on
https://tools.google.com/dlpage/gaoptout

Article 8 (Contact for Inquiries)

Please direct any comments, questions, complaints, or other inquiries regarding the handling of User Information to the following contact point.
https://wellbe-asia.com/contact/

Article 9 (Procedures for Changing Privacy Policy)

We will review the operational status of the handling of User Information from time to time and strive for continuous improvement and may change this Policy as necessary. In the event of any changes, we will notify users of such changes using a notice on the website designated by us. However, in the case of changes to the content of this Policy that require the consent of users under laws and regulations, we shall obtain the consent of users in the manner prescribed by us.

Supplementary Provisions
Enacted and enforced on June 30, 2023