Cognitive & Visual Function Self-Checker Privacy Policy

FOVE, Inc. (the “Company”, “we”, “us”, or “our”) handles information relating to users (including corporate representatives, where the user is a corporation; collectively, “Users”) of the Cognitive & Visual Function Self-Checker service (the “Service”), which utilizes the Cognitive & Visual Function Checker devices we provide (the “Device”). We handle such information (“User Information”) as set forth below.

Article 1. General Provisions

1. To protect User Information, we comply with the Act on the Protection of Personal Information of Japan (“APPI”) and other applicable laws and regulations, and endeavor to handle and protect User Information, including personal information, appropriately.

2. This Cognitive & Visual Function Self-Checker Privacy Policy (this “Policy”) applies to use of the Service.

3. Where our websites publish any other privacy policies or personal information protection policies, or where the terms of use for the Service provide for handling of User Information, such provisions also apply. If any such provisions conflict with this Policy, this Policy will prevail.

Article 2. Information We Obtain and How We Obtain It

1. In connection with the Service, we obtain User Information, including “personal information” as defined in Article 2(1) of the APPI, as described below.

(1) Information provided directly by Users or automatically/indirectly via the Device (“User-Provided Information”)
We obtain: name, age, date of birth, gender, address, phone number, email address; pre-check items for cognitive/visual self-checks and healthcare checks (e.g., specific conditions/history, whether the User wears glasses or contact lenses); date of use of the Self-Checker and the medical institution or pharmacy used (medical institutions include hospitals, clinics, etc.; pharmacies include those attached to drugstores); gaze data obtained from the Device (including gaze direction, pupil/iris size, interpupillary distance, and images of the eyes/iris); vital data (including pulse wave, heart rate, EEG, body temperature, blood pressure, etc.); cognitive-function test results; visual-function test results; details of User requests and inquiries; and other User Information we specify.

(2) Information provided by third parties (“Third-Party-Provided Information”)
With the User’s separate consent, we obtain from third parties such as medical institutions and pharmacies the User’s name/test ID, age, gender, phone number, and other User Information.

(3) Information we collect during use of the Service

A. Device information: when the Service is used on a device or mobile device, we may collect device identifiers and similar information.

B. Log, activity history, and usage information: IP address, request timestamp, in-Service operation logs, and other usage information may be automatically generated and stored.

C. Cookies and anonymous IDs: the Service may use cookies and similar technologies. Cookies are industry-standard technologies for identifying a User’s browser. Cookies can identify a browser but not an individual User. Users may disable cookies in device settings; however, some or all features of the Service may become unavailable.

2. We obtain User Information by appropriate means and not by deception or other improper methods. If we obtain User Information by any method other than through the User’s use of the Service, we will notify or publicly announce the purpose of use in advance.

3. Providing personal information to us is voluntary. However, if necessary items are not provided, we may be unable to provide the Service appropriately.

Article 3. Purposes of Use

1. We handle User Information obtained through the Service within the purposes below and do not use it beyond these purposes without the User’s consent.

2. We may change the purposes of use within a scope reasonably related to the purposes before the change, and will announce any changes to Users on this site or by other clear means.

Article 4. Provision to Third Parties

2. Except as provided in the preceding paragraph, Article 5, and Article 6, we will not provide User Information to third parties without the User’s consent. However, we may provide User Information without consent to the extent permitted by applicable laws and regulations in the following cases:

(1) Where required by law;

(2) Where necessary to protect life, body, or property and obtaining consent is difficult;

(3) Where particularly necessary to improve public health or promote the sound development of minors and obtaining consent is difficult;

(4) Where necessary to cooperate with a national or local government agency, or a party entrusted by such agency, in performing duties prescribed by laws and where obtaining consent may impede such duties;

(5) Where the recipient is an academic research institution, etc., and needs to handle User Information for academic research purposes (including where academic research is part of the purpose), except where such handling would unduly infringe individual rights or interests;

(6) Where User Information is succeeded as part of a business transfer due to merger, corporate split, or business transfer.

3. Where we provide User Information to a third party based on the User’s consent, we will create and retain records regarding: (1) the fact that prior consent was obtained; (2) the name and address of the recipient and, for corporations, the representative’s name (or, if provided to an unspecified large number of recipients, a statement to that effect); (3) the name or other identifying information of the individual identified by the User Information; and (4) the items of User Information provided.

4. Notwithstanding paragraph 2, for medical research or public health purposes we may provide Anonymized Information (User Information irreversibly and appropriately processed so individuals cannot be identified) to third parties.

5. When we create Anonymized Information and when we provide it to third parties, we will, in advance, publish on our websites or by other appropriate means the categories of User Information included and the methods of provision, etc.

6. We may use, or provide to third parties, statistical information created from User Information that does not identify individuals (and which is neither personal information nor Anonymized Information). Users consent in advance to such use or provision.

Article 5. Outsourcing of Handling

We may entrust all or part of the handling of User Information obtained from Users to third-party service providers within the scope necessary to achieve the purposes of use. In such cases, we will enter into confidentiality and similar agreements consistent with this Policy in advance and will exercise necessary and appropriate supervision to ensure proper security management by such providers.

Article 6. Joint Use

We may jointly use User Information obtained from Users with partner companies or other third parties within the scope necessary to provide partner services, etc. In such cases, we will, in advance, publicly announce: the items of information to be jointly used; the scope of joint users; the purposes of use by such users; the name of the entity responsible for managing the information; and the address and representative’s name of such entity. For details of the public announcement, please see [here].

Article 7. Information Collection Modules

To analyze Service usage and advertising effectiveness relating to the Service and other services, the Service may include the following, and other Company-selected, information collection modules. We may provide User Information to the providers of such modules embedded in the Service. These modules collect User Information without including information that identifies individuals, and the collected information is managed in accordance with each provider’s privacy policy and other rules. User Information may thus be sent to, and stored on, Google LLC servers located in the United States through cookies and similar technologies.
Name: Google Analytics
Provider: Google LLC

Reference:www.google.com/intl/ja/policies/privacy/partners/

Article 8. Security Management Measures

1. To prevent leakage, loss, or damage of User Information (including Anonymized Information as defined in Article 4(4); the same hereinafter in this Article) and to protect User Information, we implement necessary and appropriate measures for secure management, such as restricting access to personal information files, limiting access rights to the minimum necessary, and introducing security software to prevent unauthorized access from outside.

2. Our Representative Director serves as the User Information Protection Manager and implements appropriate management and continuous improvement of User Information handling.

Article 9. Users’ Rights to Disclosure, Correction, etc.

For procedures regarding requests to disclose, correct, add to, delete, suspend use, erase, or cease third-party provision of User Information on the Service (collectively, “Disclosure, etc.”), please refer to “Guidance on Requests for Disclosure, etc. of User Information (PDF)” . Please note that we may be unable to respond where we have no legal obligation under the APPI or other laws, where substantially the same request is repeatedly made without reasonable grounds, or where the request would require excessive technical work.

Article 10. Changes to this Policy

1. We will review our handling of User Information from time to time and endeavor to make continuous improvements. Accordingly, we may amend this Policy as necessary.

2. We will notify Users of the amended Policy by posting on the Service or on our websites or by other clear means. However, where changes require User consent under applicable laws, we will obtain consent by methods separately prescribed by us.

Article 11. Contact for User Information Handling

For opinions, questions, or complaints regarding our handling of User Information, and for other inquiries regarding User Information, please contact privacy@fove-inc.com. Except as required by law, we are not obligated to respond to inquiries.

Contact for User Information:

FOVE, Inc. Customer Support Center — privacy@fove-inc.com

Hours: Weekdays 10:00–17:00 (JST) (excluding Saturdays/Sundays/national holidays)

Personal Information Management Officer
Shintaro Karaki, Representative Director, FOVE, Inc.
(Contacts received outside business hours will be handled on or after the next business day. Depending on the inquiry, responses may take time.)

We will ensure that our officers and employees fully understand the spirit and intent of this Policy and handle User Information with the utmost care in daily operations to protect personal information.

Date of establishment: December 1, 2021

Revised: October 1, 2022

Revised: April 1, 2023

Revised: February 2, 2026