Privacy Policy

(Last updated July 14, 2025)

1. Basic Policy

GumpNetworks Corp. (hereinafter, “the Company”) regards the protection of customers’ privacy as one of our highest priorities as a provider of information processing services. We handle personal data appropriately and strive to ensure rigorous security management.

2. Scope of Application

This Policy applies to all personal data that the Company obtains and uses in connection with our services, websites, and mobile applications (collectively, the “Services”).

3. Compliance with Laws and Guidelines

The Company complies with the Act on the Protection of Personal Information of Japan (APPI) and related guidelines. For users located in the EU/EEA, we also comply with the EU General Data Protection Regulation (GDPR) and other applicable laws and regulations.

4. Personal Data We Collect

  • Basic information: name, address, telephone number, email address
  • Authentication information: account ID, hashed passwords
  • Device information: IP address, browser type, cookies, advertising IDs
  • Log information: access timestamps, activity history
  • Other: metadata embedded in uploaded files, etc.

5. Purposes of Use

  • To provide, maintain, and improve the Services
  • To conduct identity verification, authentication, and security measures
  • To provide support and respond to inquiries
  • To invoice and process payments
  • To send information about new features and campaigns (where consent has been obtained)
  • To investigate and address violations of laws or the Terms of Use
  • To create and publish statistical and analytical data (only in a form that does not identify individuals)

6. Provision to Third Parties

The Company will not provide personal data to third parties except in the following cases:

  • When we have obtained the individual’s consent
  • When required by laws and regulations
  • When urgently necessary to protect life or property
  • When providing data to contractors after concluding confidentiality agreements in connection with outsourcing

7. Management of Contractors

When outsourcing services such as cloud storage, email delivery, or payment processing, we select contractors that appropriately handle personal data and supervise them through contracts that stipulate security measures, restrictions on sub-outsourcing, and audit rights.

8. Joint Use

The Company may share personal data as described below:

  • Items shared: name, contact details, and Service usage information
  • Scope of joint users: the Company’s group companies
  • Purposes of use: cross-group service integration
  • Party responsible for management: the Company’s Personal Information Protection Manager

9. Cross-Border Transfers

When storing personal data on servers located outside Japan or providing it to overseas contractors, we evaluate the personal data protection regime of the destination jurisdiction and ensure adequacy pursuant to APPI Article 28 and GDPR Articles 45–49.

10. Security Measures

  • Organizational measures: appointment of responsible officers; internal audits
  • Human measures: employee training; non-disclosure undertakings
  • Physical measures: entry/exit control; locked storage of media
  • Technical measures: TLS communication; access control; encryption (e.g., AES-256-GCM)

11. Use of Cookies and Similar Technologies

We use cookies, LocalStorage, and advertising IDs to analyze usage and optimize advertising. You can disable cookies in your browser settings, but some features of the Services may become unavailable.

12. Statistical, Anonymized, and Pseudonymized Data

We may create statistical data, anonymized information, or pseudonymized information that cannot identify individuals and use or provide such data for service improvement and marketing.

13. Procedures for Requests Concerning Your Data

For personal data held by the Company, you may request “notification of purpose of use,” “disclosure,” “correction/addition/deletion,” “suspension of use/erasure,” and “suspension of third-party provision.” For details, please contact the office below.

  • Contact: Personal Information Protection Manager
  • Email: privacy@gump.co.jp
  • Phone: 045-285-2422 (Weekdays 10:00–17:00 JST)

14. Continuous Improvement

The Company will continuously review and improve this Policy in light of legal amendments, social changes, and technological developments. When making important changes, we will notify you on our website and obtain consent where necessary.