Privacy Policy

Date of Issue: September 18, 2025
Effective Date: September 18, 2025

Preamble

KoiNavi (hereinafter referred to as "this Product") attaches great importance to the protection of user privacy and personal information, and we appreciate your trust. Based on laws and regulations, we will take appropriate security protection measures and do our utmost to keep user personal information in a safe and controllable state, providing reasonable and efficient privacy protection. Based on this, we have established this "Privacy Policy" (hereinafter referred to as "this Policy") to explain how we collect, use, store, protect, and provide user information externally, and to clarify the rights enjoyed by users.

This Policy applies to the website, application, products, and services of KoiNavi developed and operated by OLA PARTY JAPAN Co., Ltd. and its affiliates (hereinafter referred to as "we"). If our affiliates establish a separate privacy policy when providing some services of this Product to users, and the provisions regarding the collection, use, storage, and protection of personal information differ from this Policy, such separate provisions shall apply. This Privacy Policy does not apply to services provided independently by other third parties to users, nor does it apply to products or services for which separate legal statements and privacy policies are established within KoiNavi. If a third party provides services through us on this Product, personal information provided by the user to the third party is not covered by this Privacy Policy.

Before using our products or services, please be sure to carefully read and fully understand this Privacy Policy, especially the clauses displayed in bold, as they involve important rights of users. Please use the relevant products or services after fully understanding and agreeing to them. Once a user starts using the products or services provided by us, it is deemed that they have fully understood and agreed to the contents described in this Policy.

Part 1 Definitions

Platform Operator: OLA PARTY JAPAN Co., Ltd. and its affiliates.

User: Hereinafter referred to as "you" or "user", referring to individuals or organizations that register, log in, use, browse, or obtain services based on this Agreement.

Personal Information: Information about a living individual falling under any of the following items: (1) Information that can identify a specific individual by name, date of birth, or other descriptions contained in such information (excluding individual identification codes) (including information that can be easily collated with other information to thereby identify a specific individual); (2) Information containing an individual identification code.

Sensitive Personal Information: Personal information that, if leaked or used illegally, is highly likely to infringe on the personal dignity of a natural person or threaten the safety of their person or property, including biometric information, religious beliefs, specific identity, medical health information, financial account information, behavioral trajectory information, etc., and personal information of minors under the age of 14. (In this Policy, specific sensitive personal information is indicated in bold and underlined.)

Deletion of Personal Information: Refers to the act of removing personal information from the system related to daily business functions and keeping it in a state where it cannot be retrieved or accessed.

Unless otherwise provided, definitions in this Policy have the same meaning as definitions in the "User Service Agreement".

Part 2 Privacy Policy

This Policy is intended to help users understand the following:

Article 1 [How We Collect and Use Personal Information]

When users use our products and/or services, we may need to collect and use two types of personal information:

  1. Necessary information collected and used with user permission to provide the basic functions of our products and/or services. If users refuse to provide such information, they will not be able to use our products and/or services normally.
  2. Information collected and used with user selective permission to provide additional functions of our products and/or services. If users refuse to provide such information, they may not be able to use relevant additional functions normally or achieve the functional effects we intend to achieve, but it will not affect the normal use of the basic functions of the products and/or services.

We specifically remind you of the following points:

(1) Registration and Login

Users can log in and use the service using a third-party account. With the user's consent, we will obtain public information registered on the third-party platform (avatar, nickname, and other information permitted by the user) and link it with the KoiNavi account, allowing the user to log in directly and use this Product and related services.

Providing the following additional information allows us to provide better services and experiences: avatar, nickname, gender, period since acquaintance, relationship, etc. However, even if the user does not provide this information, it will not affect the basic business functions of the Service.

(2) Intelligent Services

When users access, use, or browse our services, we collect content input by the user in the interaction process with KoiNavi (including text and images) and perform analysis and calculation based on the interaction method between the user and KoiNavi, user choices, and the above information to better understand user questions and context and provide more relevant information content.

When uploading images, we request permission for storage/camera rights. If the user refuses permission, image information cannot be uploaded, but it will not affect the use of other functions of KoiNavi.

In the process of browsing KoiNavi, we collect device information (including device model, operating system version, device settings, IMEI/MEID/Android ID/IDFA/IDFV/OAID/MAC address/IMSI/ICCID/UDID/GUID (device identifier), device serial number, device environment) when the user uses KoiNavi.

(3) Charge and Consumption Functions

When users use the charge and consumption functions of KoiNavi, we collect charge records and consumption record information to allow users to query their transaction records and to maximize the protection of user property and virtual property safety. In the payment process, we may collect the user ID of the third-party payment channel. The above information falls under sensitive personal information, but the collection of such information is essential for realizing relevant functions, otherwise transactions cannot be completed. We cannot obtain user personal property information based solely on such information, nor can we identify the identity information of a specific natural person.

(4) Customer Service and Dispute Resolution

When users contact us to make complaints, appeals, or consultations, we require the provision of necessary personal information to verify the user's true identity to ensure the safety of the user's account and system. To facilitate communication with users, quickly solve problems, or record the processing plan and results of related problems, we may store communication records and related content with users (including account information, other information provided by the user to prove facts, or contact information left by the user). If the user refuses to provide the above information, we may not be able to quickly feed back the results of complaints, appeals, or consultations.

(5) Security Assurance

To ensure the safe operation of software and services, protect network security, prevent cybercrime, identify user account anomalies, and prevent fraud, we collect user network access log information and user log information, device information, device location information (including IP address, GPS location and WLAN access points, Bluetooth and base stations (sensor information) that can provide related information), software version number, network access method, type and status, carrier, SSID and BSSID, network quality data, running process information, overall application operation status, overall installation/usage status, performance data, application source, and other log information (including usage time and frequency details, device statistical information, main operation paths, error logs, crash records, language and time zone, Internet Protocol (IP) address, Internet Service Provider (ISP), reference/exit pages, operating system, date/time stamp, and clickstream data).

(6) Restrictions on Use of Personal Information

Unless prior consent is obtained from the user, KoiNavi will not handle personal information beyond the scope necessary to achieve the purpose of use. Even if personal information is acquired due to mergers or other reasons, we will not handle personal information beyond the scope of the purpose of use before succession without obtaining prior consent from the user. However, the following cases are excluded:

  1. When required by laws and regulations.
  2. When necessary to protect the life, body, or property of a person and it is difficult to obtain the consent of the person.
  3. When particularly necessary for improving public health or promoting the healthy growth of children and it is difficult to obtain the consent of the person.
  4. When it is necessary to cooperate with a national agency, a local government, or a person entrusted by them in executing affairs prescribed by laws and regulations and obtaining the consent of the person is likely to impede the execution of such affairs.

Please note that according to applicable laws and regulations, if we process personal information by taking technical measures and other necessary measures so that the recipient of the data cannot re-identify specific individuals and cannot restore it, separate notification to or consent from the user is not required for the use of such processed data.

If the operation of KoiNavi products or services is stopped, we will immediately stop collecting user personal information, notify users by individual delivery or public announcement of the operation stop notice, and delete or anonymize the personal information held related to the stopped business.

Article 2 [How We Use Cookies and Similar Technologies]

Cookies and similar technologies such as device information identifiers are widely used technologies on the Internet. When users use Douyin (TikTok) and related services, we may send one or more Cookies or anonymous identifiers to the user's device to collect and identify information regarding access to and use of this Product. We promise not to use Cookies for any purpose other than those described in this Policy. Cookies and similar technologies are mainly used to realize the following functions or services.

(1) Ensuring Safe and Efficient Operation of Products and Services

We may set Cookies or anonymous identifiers for authentication and security assurance to confirm whether users are safely logged into the service or have encountered unauthorized access, fraud, or other illegal acts. These technologies also help improve service efficiency and speed up login and response speeds.

(2) Providing a Smoother Access Experience

Using such technology allows users to omit steps such as re-entering personal information and search content (e.g., saving search records, form filling).

(3) Recommendation, Display, and Push of Content or Users You May Be Interested In

  1. We use such technology to understand user preferences and usage habits and conduct data analysis to improve product services and recommend information or functions that users may be interested in.
  2. We use Cookies to record browsing behavior, recommend information to users, investigate abnormal situations such as crashes and delays, and explore better service methods.

(4) Deletion of Cookies

Most browsers provide a function for users to delete browser cache data. Users can perform corresponding data deletion operations in the browser settings function. If deletion is performed, users may not be able to use services or corresponding functions provided by us that depend on Cookies.

Article 3 [How We Share, Transfer, and Publicly Disclose Personal Information]

(1) Sharing

We assume a confidentiality obligation for user information and will not share or provide user personal information externally. However, the following cases are excluded:

  1. Sharing with Explicit Consent: We share user personal information with third parties after obtaining the user's explicit consent.
  2. Sharing for Legal Reasons: We may share or provide user personal information to judicial or administrative agencies based on laws and regulations, litigation and dispute resolution needs, or requests from administrative or judicial agencies.
  3. Sharing with Affiliates: To provide products and services to users based on KoiNavi, recommend content and information that users may be interested in, identify account anomalies, and protect the safety of KoiNavi user accounts and property, user personal information may be shared with our affiliates and/or their designated service providers. We share only necessary personal information and are bound by the purposes declared in this Policy. If sensitive personal information is shared or if an affiliate changes the purpose of use and processing of personal information, we will seek user permission again.
  4. Sharing with Certified Partners: To provide more complete and high-quality products and services, we may entrust certified partners or introduce third-party services to realize some technical functions (in the form of code embedding, plugins, SDKs, etc.). We share user information only for lawful, legitimate, necessary, specific, and clear purposes declared in this Policy, and guarantee that the above third-party services can only access user personal information necessary for performing their duties and use industry-leading technologies to protect the safety of user personal information.

To realize related functions of the platform and ensure the safe and stable operation of the application, our products may include third-party SDKs or other similar applications. If users use such services provided by third parties on our platform, users are deemed to agree that the third party directly collects and processes their information. The collection and processing of information by the aforementioned service providers shall comply with their own privacy policies and not this Policy. To maximize the protection of user information security, we strongly recommend checking the privacy policy of the third party before using third-party SDK services. We strive to review the business entry qualifications of third parties and require such service providers to comply with laws and regulations and ensure safety. If any risk is found in such SDKs or other similar applications, we recommend immediately stopping related operations and contacting us. For the names, affiliated companies, types of personal information collected, purposes of use, and links to privacy policies of third-party SDKs introduced in KoiNavi, please refer to the "List of Third-Party Libraries Introduced in APP".

(2) Transfer

We will not transfer user personal information to any company, organization, or individual. However, the following cases are excluded:

  1. Transfer with Explicit Consent: We transfer user personal information to third parties after obtaining the user's explicit consent.
  2. Cases Related to Merger, Acquisition, Bankruptcy Liquidation: In cases involving the transfer of personal information, we will require the transferee to comply with this Policy, otherwise we will require the transferee to seek permission from the user again.

(3) Public Disclosure

We will publicly disclose user personal privacy information only in the following cases:

  1. Based on the user's explicit permission or user's voluntary choice.
  2. Disclosure based on provisions of laws and regulations.
  3. When it is determined that the user has violated laws and regulations or seriously violated relevant agreements and rules of KoiNavi, or to protect the personal and property safety of KoiNavi users or the public from infringement, we may disclose user personal information based on laws and regulations or with the user's consent.

(4) Cases Exempt from Obtaining Consent for Sharing, Transfer, and Public Disclosure of Personal Information

Please understand that in the following cases, we may share, transfer, and publicly disclose personal information without obtaining user permission.

  1. When required by laws and regulations.
  2. When necessary to protect the life, body, or property of a person and it is difficult to obtain the consent of the person.
  3. When particularly necessary for improving public health or promoting the healthy growth of children and it is difficult to obtain the consent of the person.
  4. When it is necessary to cooperate with a national agency, a local government, or a person entrusted by them in executing affairs prescribed by laws and regulations and obtaining the consent of the person is likely to impede the execution of such affairs.

Article 4 [How We Store Personal Information]

(1) Storage Location

Personal information collected and generated by us during operation is stored within Japan. If it is necessary to transmit it overseas, we will do so in accordance with relevant national regulations or after obtaining user consent.

(2) Storage Period

We store user personal information only for the period necessary to achieve the purposes described in this Policy. However, this does not apply if storage is required by laws and regulations. The storage period of personal information is determined with reference to the following criteria, whichever is longer.

  1. To comply with provisions of applicable laws and regulations.
  2. To comply with court judgments, rulings, and other legal procedure regulations.
  3. To comply with requests from administrative agencies or legally authorized organizations.
  4. For purposes reasonably necessary for the execution of this Agreement or this Policy, maintenance of social public interest, and protection of personal safety and other legitimate rights and interests of KoiNavi and affiliates, other users, or employees.

If user personal information exceeds the storage period, we will delete or anonymize such personal information.

Article 5 [How We Protect Personal Information]

Article 6 [How We Handle Minors' Personal Information]

KoiNavi attaches great importance to the protection of minors' personal information. If you are a minor, we recommend reading this Policy accompanied by a guardian and using our services and providing information with the consent of your guardian.

If a guardian does not agree to the use of services or provision of information based on this Policy, please immediately stop using the service and notify us.

When collecting personal information of minors with the consent of parents or legal representatives, we will use or publicly disclose such information only when permitted by law, with the explicit consent of parents or legal representatives, or when necessary to protect minors.

If you are a guardian of a minor and have questions regarding the personal information of the minor you protect, please contact us at the contact information described in Article 9 "How to Contact Us" of this Policy. We will protect the confidentiality and safety of minor users' information based on relevant national laws and regulations and the provisions of this Policy. If we discover that we have collected personal information of a minor without obtaining verifiable consent from the guardian in advance, we will strive to delete the relevant data promptly.

Article 7 [How You Manage Your Personal Information]

We attach great importance to the management of personal information by users and do our utmost to protect users' rights to query, access, modify, delete, withdraw consent/cancel authorization, cancel accounts, make complaints/reports, and set privacy functions regarding their personal information, enabling users to have the ability to guarantee their privacy and information security.

(1) Change or Withdrawal of Permission Scope

Change or Withdrawal of Sensitive Permission Settings

Users can close storage permissions/album permissions in the device's own operating system to change the scope of consent or withdraw permission. If permission is withdrawn, we will stop collecting information related to such permission.

Withdrawal of Consent/Cancellation of Authorization

Users can contact us at the contact information described in Article 9 "How to Contact Us" of this Policy to withdraw consent/cancel authorization.

Information Processing Upon Change or Withdrawal of Permission

User information is required to realize specific business functions and services. If a user withdraws consent or cancels authorization, we cannot continue to provide the functions and services corresponding to the withdrawal or cancellation and will stop processing the corresponding personal information. However, the user's decision to withdraw consent or cancel authorization will not affect the processing of personal information performed based on the user's permission previously.

(2) Access, Deletion, and Correction of Personal Information

Access to Personal Account Information

Users can query and access their avatar, nickname, and gender, and perform query, access, and correction in [Personal Profile].

Query, Access, Correction, and Deletion of Information

From the perspective of security and identification, users may not be able to voluntarily modify some submitted information. If modification of such information is definitely required, please contact us at the contact information described in Article 9 "How to Contact Us" of this Policy. We will promptly review the problem and respond promptly after professional staff verifies the user's identity.

(3) Account Cancellation

Users can apply for account cancellation by the following method:

Self-service Cancellation Application: Apply from [My Page] - [Account Cancellation].

Users can apply for cancellation only if they meet KoiNavi's account cancellation conditions, and can complete cancellation after passing the review by KoiNavi staff and confirmation by the user. Users shall understand and agree that account cancellation is an irreversible act. If an account is canceled, unless otherwise provided by laws and regulations, we will delete or anonymize information regarding the user.

After account cancellation, all content already posted by the user will be changed to anonymous posts. If content deletion is required, please process it yourself before applying for cancellation.

Account cancellation does not mean that acts and related responsibilities before cancellation are exempted or mitigated in any form.

(4) Complaints and Reports

Users can make complaints or reports according to the system published by us. If you believe that your rights regarding personal information may have been infringed, or if you discover clues of infringement of rights regarding personal information, please contact us at the contact information described in Article 9 "How to Contact Us" of this Policy.

(5) Response to Above Requests

When a user makes the above request, we may require the user to provide identification to ensure account security. If the user refuses to provide corresponding proof documents, we may not be able to respond to the request.

Please understand that due to technical limitations, laws and regulations, or regulatory requirements, we may not be able to respond to all user requests. We will respond to user requests within a reasonable period.

In the following cases, based on laws and regulations, we cannot respond to user requests.

  1. Related to national security, national defense security, and national interests.
  2. Related to public safety, public health, and important public interests.
  3. Related to criminal investigation, prosecution, filing, trial, and execution of judgment, etc.
  4. When there is sufficient evidence to show that the user has subjective malice or is abusing rights.
  5. When responding to the request would significantly damage the legitimate rights and interests of other individuals or organizations.
  6. Related to trade secrets.

Article 8 [How This Policy is Updated]

To provide better services to users and respond to platform business adjustments and future developments, this Policy may be updated from time to time. However, for updates, we will obtain user permission in an individual and clear manner, and unless we do so, we will not reduce user rights based on this currently effective Privacy Policy.

After version updates or announcements, we will notify users of content updates in a reasonable, appropriate, and clear manner so that users can quickly grasp changes in their rights. Users can also check the full text of this Policy from [My Page - Privacy Terms].

For significant changes, we will adopt a clearer notification method (including but not limited to notifying users of policy update content via email, SMS, announcement, special prompts on the homepage or browsing pages, etc.).

"Significant changes" in this Policy include but are not limited to:

  1. When significant changes occur in our service model. For example, changes in the purpose of processing personal information, types of personal information processed, usage methods of personal information, etc.
  2. When significant changes occur in our ownership structure, organizational structure, etc. For example, business adjustment, change of owner due to bankruptcy/merger, etc.
  3. When significant changes occur in the main targets of sharing, transfer, or public disclosure of personal information.
  4. When significant changes occur in user rights regarding personal information processing and their exercise methods.
  5. When changes occur in the responsible department, contact information, and complaint channels responsible for personal information security processing.
  6. When the personal information security impact assessment report indicates that high risks exist.

If the user does not agree to the updated privacy policy, they have the right to immediately stop using KoiNavi's products and services. If the user continues to use KoiNavi's products and services, it is deemed that they have accepted the changes to the relevant provisions of this Policy by KoiNavi.

Article 9 [How to Contact Us]

If you have questions, opinions, or suggestions regarding this Policy, please contact us by the following methods.

(1) KoiNavi Customer Service

Email: [email protected]

(2) KoiNavi Personal Information Protection Department

Email: [email protected] or mail to the following address:
Aoyama Allamanda Work Court, Placeo Aoyama Building 3F, 2-7-13 Kita-Aoyama, Minato-ku, Tokyo

We will promptly review the problem and respond within 15 business days after verifying the user's identity.

Japanese law applies to the validity, interpretation, modification, performance, and dispute resolution of this Agreement. Any dispute arising from this Agreement shall be handled based on Japanese law. If you are not satisfied with our response, especially if your legitimate rights and interests have been damaged by our personal information processing behavior, you can also seek a solution by filing a lawsuit with the court having jurisdiction over the location of OLA PARTY JAPAN Co., Ltd.

Registered Address of OLA PARTY JAPAN Co., Ltd.:
Aoyama Allamanda Work Court, Placeo Aoyama Building 3F, 2-7-13 Kita-Aoyama, Minato-ku, Tokyo