Privacy Policy

Article 1 (Personal Information)

"Personal information" means "personal information" as defined in the Act on the Protection of Personal Information (the "APPI"): information relating to a living individual that can identify the specific individual by name, date of birth, or other description contained in the information (including information that can be readily cross-referenced with other information and thereby identify the specific individual), or that contains an individual identification code.

Article 2 (Collection of Personal Information)

The Company collects personal information to the extent necessary to achieve its purposes of use. The personal information the Company collects is as follows:

• Customer personal information: name, telephone number, email address, enquiry content, etc.
• Business-partner personal information: the name, telephone number, email address, enquiry content, etc. of the contact person.

Article 3 (Purposes of Collecting and Using Personal Information)

The Company collects and uses personal information for the following purposes:

• To respond to enquiries from users (including identity verification);
• To operate and improve this Site;
• To prevent unauthorised use and to ensure security;
• To respond as required under laws and regulations;
• Purposes incidental to the above.

Article 4 (Change of Purpose of Use)

The Company will change the purpose of use of personal information only where the changed purpose is reasonably deemed to be related to the purpose before the change. Where the purpose of use is changed, the Company will notify users of the changed purpose by the method prescribed by the Company, or announce it on this website.

Article 5 (Management and Protection of Personal Information)

Personal information will be managed strictly. Except in the cases below, the Company will not disclose or provide data to third parties without the user's consent. The Company also takes preventive and corrective measures against risks such as unauthorised access to, and loss, destruction, alteration, or leakage of, personal information:

• Where necessary to protect a person's life, body, or property, and it is difficult to obtain the user's consent;
• Where particularly necessary to improve public health or promote the sound upbringing of children, and it is difficult to obtain the user's consent;
• Where it is necessary to cooperate with a national or local government body (or a party commissioned by them) in performing duties prescribed by law, and obtaining the user's consent is likely to impede those duties;
• Other cases permitted by law.

Article 6 (Entrustment of Handling of Personal Information)

The Company may entrust all or part of the handling of personal data to the extent necessary to achieve the purposes of use. In such cases, the Company will sufficiently examine the suitability of the contractor, stipulate matters such as confidentiality obligations in the contract, and exercise necessary and appropriate supervision over the contractor.

Article 7 (Provision of Personal Information)

Except where disclosure is permitted under the APPI or other laws, the Company will not provide personal information to third parties without obtaining the user's prior consent. However, the following do not constitute provision to a third party as described above:

• Where the Company entrusts all or part of the handling of personal information within the scope necessary to achieve the purposes of use;
• Where personal information is provided in connection with a business succession due to merger or other reason;
• Where personal information is jointly used in accordance with the provisions of the APPI.

Article 8 (Joint Use of Personal Information)

The Company may jointly use users' personal information within the scope necessary to achieve the purposes of use, in the scope and for the purposes set out below.

〈Purpose of joint use〉

• To respond appropriately to enquiries (including identity verification and, where necessary, routing to the appropriate handler among the joint users)

〈Scope of personal information jointly used〉

• Name, telephone number, email address, enquiry content, and other information provided by the user, obtained through the contact form.

〈Scope of parties jointly using the information〉

• Frilona Oy Ab, Bulevardi 9 A1, 00120 Helsinki, Finland; Representative: Martin Tkaczick
• andfika Co., Ltd., 5-3-13 Shimo-Meguro, Meguro-ku, Tokyo, Japan; Representative: Sachiko Imaizumi
• Metro Seika Co., Ltd., 2-4-14 Matsugaoka, Nakano-ku, Tokyo, Japan; Representative: Sachihiro Morozumi

〈Party responsible for managing the jointly used personal information〉

• Frilona Oy Ab (operator of this website; address and representative as stated in Article 14).

Article 9 (Disclosure of Personal Information)

When a user (limited to the individual concerned) requests disclosure of personal information held by the Company, the Company will disclose it to the user without delay. However, where disclosure would fall under any of the following, the Company may decide not to disclose all or part of it, and where it decides not to disclose, it will notify the user to that effect without delay:

• Where there is a risk of harm to the life, body, property, or other rights or interests of the user or a third party;
• Where there is a risk of significant impediment to the proper conduct of the Company's business;
• Where it would otherwise violate laws or regulations.

Article 10 (Correction, etc. of Personal Information)

Where personal information held by the Company is inaccurate, the user may request the Company to correct, add, or delete ("correction, etc.") the personal information. Upon receiving such a request, the Company will conduct the necessary investigation without delay, and where it determines that the request is justified, will carry out the correction, etc. without delay. Where the Company decides whether or not to carry out the correction, etc., it will notify the user without delay.

Article 11 (Suspension of Use, etc. of Personal Information)

The user may request the Company to suspend use, erase, or cease third-party provision of personal data held by the Company ("suspension of use, etc."). Upon receiving such a request, the Company will conduct the necessary investigation without delay, and where it determines that the request is justified, will carry out the suspension of use, etc. of the personal data. However, where the suspension of use, etc. requires substantial cost or is otherwise difficult, and an alternative measure necessary to protect the user's rights and interests can be taken, the Company will take that alternative measure. Where the Company decides whether or not to carry out the suspension of use, etc., it will notify the user without delay.

Article 12 (Use of Cookies and Other Technologies)

This Site uses Umami, a privacy-friendly analytics tool, to analyze usage and improve its service. Umami does not use cookies and does not collect personally identifiable information. The information obtained is limited to aggregated statistical data (such as page views, referral sources, the approximate country/region of users, and browser type) and is not used to identify any specific individual. Analytics data is hosted on servers located in the EU.

This Site is hosted on the Lovable platform. Lovable collects basic analytics data about visits to published sites, including page views, visit duration, bounce rate, traffic sources, and device type. This information is aggregated and is not used to identify any specific individual.

This Site does not use cookies or tracking technologies for the purpose of advertising delivery or advertising-effectiveness measurement.

For details of how Umami handles data, please refer to its policy: https://umami.is/privacy

For details of how Lovable handles data, please refer to its policy: https://lovable.dev/privacy

Article 13 (Changes to the Privacy Policy)

The Company will review the content of this Policy from time to time and endeavour to improve it. The content of this Policy may be changed, except for matters otherwise provided by law or in this Policy. The changed Privacy Policy takes effect when notified to users by the method prescribed by the Company, or posted on the Company's website.

Article 14 (Contact)

For enquiries regarding the Company's handling of personal information, please contact:

• Company name: Frilona Oy Ab
• Address: Bulevardi 9 A1, 00120 Helsinki, Finland
• Representative: Martin Tkaczick