Privacy Policy
Last Modified: September 30, 2024
WHILL, Inc. (hereinafter referred to as "the Company") recognize that it is our corporate social responsibility to comply with the laws of each country and other relevant laws and regulations concerning the protection of personal information, and to properly manage the personal information of our customers (including those of our business partners, hereinafter the same shall apply) held by us. We have set forth the following policy for privacy (hereinafter referred to as the "Privacy Policy") to protect such personal information. This Privacy Policy explains the types of information we may collect from you, how we collect it, how we use it, how we share it, and how we handle it to maintain and protect it appropriately.
By using our websites, social media pages and App(hereinafter referred to as the "Website") or otherwise providing information to us, you consent to our collection, use, storage, and sharing of your information as described in this Privacy Policy. If you disagree with any of this Privacy Policy, please do not use our Website, contact us, or provide us with your information. This Privacy Policy may change from time to time (see "Continuous Improvement" section). Your continued use of our Website or submission of information to us after any changes are made constitutes your agreement to those changes, so please check back periodically for policy updates.
Note
If you are under 13 years of age, do not send us any information about you.
If you reside outside of Japan, by using our Website or providing us with your information, you consent to the transfer and storage of your personal information to Japan.
You may have additional rights if you reside in the following areas.
Please check your additional rights at this URL https://whill.inc/legal/privacy/local
- USA (California, Nevada, Colorado, Connecticut, Virginia, and Utah)
- Canada
- European Economic Area
Personal Information to be collected
We will acquire the following personal information about our customers:
(i) Information related to identity verification
Name, address, zip code, gender, date of birth, telephone number, e-mail address, account ID and password, SNS account information, information on official identification such as driver's license and resident certificate, etc.
(ii) Information related to transactions
Details of transactions and purchases (including services such as rentals and repairs) and history information thereof, etc.
(iii) Information related to settlement
Information related to financial institution accounts, settlement, and its methods, etc.
(iv) Information collected when using the service
Online identifiers such as cookie IDs, device information, location information (including
driving logs obtained through apps provided by the Company and IoT modules installed in
the products; the same shall apply hereinafter), driving distance information, information on the device used, browsing history, and other information on the use of the Service (access logs, IP address information, etc.)
Information on your use of the Service, such as your mileage, device information, browsing history, and other information on your use of the Service (including access logs, IP addresses, browser information, browser language settings, and the like), avatar information, etc. generated by the customer within the service.
(v) Other information
Information submitted to us in response to questionnaires, information on inquiries and history, information on caregivers of users of our services, etc.
How we collect Personal Information
When collecting personal information, we will clarify the purpose for which the information is to be used, and will collect the information properly and legally, limiting its use to the extent necessary to achieve the purpose for which it is to be used.
We collect personal information and other information from or about you in a few different ways. Specifically, we may collect or receive information: (1) directly from you through information you provide; (2) indirectly from you by observing your actions on our Website through automatic data collection technologies; and (3) from third parties such as dealers, resellers, Google or Facebook.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
Technologies used for this automated data collection include:
- Cookies;
- Pixel tracking;
- Traffic data; and
- Third-party websites, social networking services (SNS), etc.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the website, or transmitted to other users of the website or third parties (collectively, "Ideas"). Your Ideas are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the website with whom you may choose to share your Ideas. Therefore, we cannot and do not guarantee that your Ideas will not be viewed by unauthorized persons. We do not request or collect any sensitive information about you (i.e., personal information specifying racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information pertaining to personal or intimate details of an individual’s life).
Use of Personal Information
We will not use personal information collected beyond the scope necessary to achieve the purpose of use without the consent of the person concerned. For specific purposes of use, please refer to and confirm the Section "Guide to the Handling of Personal Information" below. However, this does not apply to the following cases:
(i) When required by law
(ii) When disclosure is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual
(iii) When disclosure is particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person
(iv) Cases in which the provision of personal information is necessary for cooperating 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 in which obtaining the consent of the individual is likely to impede the execution of the affairs concerned
(v) Cases when permitted by laws and regulations
Provision of Personal Information to Third Parties
We will not provide personal information obtained by us to any third party, except with the prior consent of the user. However, this does not apply in the following cases:
(i) When required by law
(ii) When it is necessary to protect the life, body, or property of an individual and it is difficult to obtain the consent of the customer
(iii) When it is especially necessary to improve public health or to promote the sound growth of children, and it is difficult to obtain the consent of the customer
(iv) Cases in which the provision of personal information is necessary for cooperating 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 in which obtaining the consent of the individual is likely to impede the execution of such affairs
(v) Cases when permitted by laws and regulations
We may provide your personal data to third parties located in the following foreign countries. The country-specific information that should be used as a reference in such cases is listed below at this time. In order to select an appropriate business entity for subcontract, we may entrust (provide) personal data to a subcontractor in a foreign country other than those listed below, although the subcontractor and its country of residence have not been specified at this time. In such cases, we may start entrustment to a new trustee without obtaining your consent again. Please contact the "Inquiries" listed at the end of this document for the necessary measures to ensure the continued implementation of equivalent measures by third parties located in foreign countries, which we have implemented.
i. Names of foreign countries
United States, Canada, Netherlands, China, Taiwan, Vietnam, India
ii. System for the protection of personal information in the foreign country
Please refer to the following link for information provided by the Personal Information Protection Commission
https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku
iii. Systems for the protection of personal information taken by third parties
Third parties located in the foreign country to which the information is provided have taken all measures corresponding to the eight principles of the OECD Privacy Guidelines.
We will create and provide anonymized processed information to third parties as follows. In addition, we plan to continue to create and provide similar anonymized processed information to third parties in the future.
(1) Items of personal information included in anonymized processed information
Age, gender, and questionnaire response results
(2) Method of providing anonymized processed information
Transmission by e-mail, sending of external storage media such as CD-ROM, USB, etc., uploading to a server
(3) Measures necessary to ensure proper handling of anonymized processed information, including security control measures
We will supervise employees who handle anonymized processed information to ensure that safety control measures are implemented in accordance with our internal rules.
Privacy for Minors
Our Website and products are not intended for children under the age of 13. Further, we do not knowingly collect personally identifiable information from children under the age of 13. If you become aware that a child has provided us with personally identifiable information without parental consent and/or is under the age of 13, please contact us at privacy@whill.inc.
If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will use commercially reasonable efforts to delete such information from our records.
Choices about How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly
- Opting-Out. You may opt-out of receiving email communications and other marketing materials from us (or any third-party email marketing service we may use) via links provided in each email (usually at the bottom of the email).
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website
Links to Third Party Websites or Platforms
Our Website may contain links to third party websites or platforms. These links are provided for your convenience. We are not responsible for and have no control over the content on these other websites or platforms. The inclusion of a link on our Website is not an endorsement. Please note that when you click on one of these links, you will leave our Website and will be subject to the policies and privacy practices of the other website or platform, which may differ significantly from our Privacy Notice. Please review such third parties’ privacy policies before providing any personal information to them.
We make no representations or warranties, express or implied, regarding the content of any of these linked websites or platforms. WE EXPRESSLY DISCLAIM ANY AND ALL LIABILITY FOR YOUR INTERACTION WITH SUCH THIRD PARTY WEBSITES OR PLATFORMS.
Compliance with Laws and Regulations Concerning the Handling of Personal Information
We will comply with the laws of each country and other relevant laws and regulations concerning the protection of personal information, as well as guidelines and other norms set forth by the government.
Management of Personal Information and Implementation of Safety Control Measures
The Company will properly store and manage personal information, and will take necessary measures to prevent leakage, loss, or damage of personal information and to otherwise safely manage personal information. Please contact the "Inquiries" listed at the end of this document for information on the security control measures taken by the Company.
Disclosure of Personal Information
If a customer requests the Company to notify the purpose of use, disclose, correct, add, delete, stop using, or stop providing to a third party (hereinafter referred to as "disclosure, etc.") personal information or third-party records of personal information that the Company has obtained, the Company will comply with the request as prescribed. However, this does not apply to cases in which the Company is not obligated to disclose, etc. under the applicable
personal information protection law or other laws and regulations. For specific procedures
and fees for disclosure, etc., please contact the "Inquiries" listed at the end of this document.
Continuous Improvement
We are committed to continuous improvement for the appropriate use and protection of personal information, and may change this Privacy Policy from time to time as necessary. Any changes to this Privacy Policy will be made public through notification to customers, posting on the Website operated by the Company, or other easily understandable means.
Guide to the Handling of Personal Information
Purposes of Using Personal Information
1. Purpose of use of personal information
The Company will use the personal information provided to the Company for the purposes of use (hereinafter referred to as "Purposes of Use") specified for each of the following categories of customers (including persons in charge of business partners, hereinafter the same).
The Company will not use such information for any purpose other than the Purposes of Use without the consent of the individual concerned. However, the Company may change the Purposes of Use to the extent reasonably deemed relevant to the Purposes of Use prior to such change, and in the event of such change, the Company will notify customers, etc. or publicly announce such change by posting a notice on the Website operated by the Company or by other easily understandable means. The meaning of terms used herein shall be in accordance with the applicable Personal Data Protection Laws of each region.
(1) Orders regarding our services (including sales, rentals, repairs, and all other services provided by the Company; hereinafter called as “Service”), inquiries (including requests for information materials, test drive applications, and all other inquiries to the Company, hereinafter called as “Inquiries”) for the Company's Services, or personal information of customers who have registered as members of the Company or the Company's Services.
- To send catalogs, mail magazines, direct mail, etc.
- To respond to Inquiries and contact customers
- To inquire about past Inquiries
- For delivery and collection of products, etc., billing for our Services, and handling of other orders for our Services
- To maintain and manage our Services, including after-sales Service
- To formulate measures to improve customer satisfaction
- To operate and improve our Services, and to plan, research and develop new services
- To improve the accuracy and quality of responses at the WHILL Contact Desk
- To conduct surveys, campaigns, and sweepstakes planning
- To send alert information about our products
- To provide or send information on various special offers and events
- For sales activities of our dealers
- To authenticate and manage customers when they register as members and use our Services
- To prevent and respond to fraudulent activities, etc.
- For distribution and guidance of advertisements and other information related to our products and Services
- To research and analyze marketing data, and to consider and implement marketing measures
- To provide, solicit, advertise and otherwise market the Company's or third parties' products and services in accordance with the interests and concerns of customers based on analysis of their attributes and behavioral history in the Company's or third parties' media
- To provide services using statistical information that does not identify individuals
- To provide personal information to third parties as described in the Company's Privacy Policy or by providing information on the handling of personal information
(2) Customers who use WHILL Smart Care or WHILL Premium Care among our Services (customers in this item refer to customers as defined in the WHILL Smart Care and WHILL Premium Care Terms and Conditions). Personal information of the customer
- For the purposes set forth in (1)
- For WHILL Smart Care service (road service and insurance service)
- For WHILL Premium Care service (road service, insurance service and monitoring service)
(3) Personal information of customers who participated in events hosted or sponsored by the Company
- To provide information on upcoming events
- To provide information on related events
(4) Personal information received through questionnaires, user surveys, monitoring surveys, etc.
- For product planning, research and development, quality improvement, and formulation of measures to improve customer satisfaction
(5) Personal information of business partners
- For business communication and sending of materials
(6) Personal information related to employment
- To contact you regarding employment opportunities
- For business communication
(7) Personal information of retired employees
- For management of retired employees
(8) Specified personal information
- For administrative procedures for social security and tax
(9) Others
- For this purpose of use and the purpose of use specified at the time of acquisition of personal information
2. Joint Use and Provision to Third Parties of Personal Information
(1) In the course of providing and operating our Services, we share necessary customer information, such as personal information and payment status, among our group companies for purposes such as responding to customer Inquiries and conducting marketing research.
i. Items of personal information to be shared
Information as described in “Personal Information to be collected" of the Privacy Policy
ii. Purpose of use of shared personal information
Purposes described in 1-(1) above
iii. Scope of joint users
Our affiliated group companies
iv. Party responsible for management of joint use
WHILL, Inc. (@Harber Premium Building 2F, 2-1-11 Higashishinagawa, Shinagawa-ku,Tokyo Japan, President: Satoshi Sugie)
(2) With respect to customers who order our Services, make Inquiries, or register as members, we will share personal information held by us with dealers who have jurisdiction over the area where the customer resides (dealers of our products who are officially authorized by us to sell our products; the same shall apply hereinafter). Please note that we may send various information to our customers through the dealers.
i. Items of personal information to be shared
Information as described in “Personal Information to be collected" of the Privacy Policy
ii. Purpose of use of shared personal information
Purposes described in 1-(1) above
iii. Scope of joint users
Dealers (Please refer to our website https://whill.inc/jp/select-locator-map for information on dealers by region)
iv. Party responsible for management of joint use
WHILL, Inc. (@Harber Premium Building 2F, 2-1-11 Higashishinagawa, Shinagawa-ku,Tokyo Japan, President: Satoshi Sugie)
(3) With respect to customers who use our Services, we will share personal information held by us with Service Partners (hereinafter defined).
i. Items of personal information to be shared
E-mail address and phone number when customer creates WHILL ID (An identifier that is managed to recognize a customer who has registered to use our Services)
ii. Purpose of use of shared personal information
To operate the rental service of the product and check the rental status of the Service of the Service Partners that manage the rental products.
iii. Scope of joint users
Service Partners (Facilities that provide device rental Services via WHILL ID and the management company thereof.)
iv. Party responsible for management of joint use
WHILL, Inc. (@Harber Premium Building 2F, 2-1-11 Higashishinagawa, Shinagawa-ku,Tokyo Japan, President: Satoshi Sugie)
(4) We will share the personal information of customers who use our rental services with our partner companies as follows
i. Items of personal information to be shared
Name and address
ii. Purpose of use of personal information to be shared
To confirm the rental status of the product in question by the subcontractor, which
is the owner of the product to be rented.
*This company operates a rental service for the Company's products sold to its partner companies and leased by the partner companies.
iii. Scope of joint users
Cooperating company (Century Tokyo Corporation) (Please refer to the following website for more information on the cooperating company)
iv. Party responsible for management of joint use
WHILL, Inc. (@Harber Premium Building 2F, 2-1-11 Higashishinagawa, Shinagawa-ku,Tokyo Japan, President: Satoshi Sugie)
(5) The Company may provide personal data concerning customers who use the Company's WHILL Smart Care or WHILL Premium Care (customers in this section shall mean customers as defined in the WHILL Smart Care and WHILL Premium Care Terms and Conditions) to third parties as follows, and customers shall consent to such provision of personal data to third parties.
i. Third parties to whom personal data may be provided
- Road service companies with which we are affiliated
- Insurance companies with which we are affiliated
ii. Purpose of use by the third party to whom personal data is provided
- To respond to WHILL Smart Care service (road service and insurance service)
- For WHILL Premium Care service (roadside service, insurance service and monitoring service)
iii. Details of information provided to third parties
Name, address, location information (including driving logs obtained through our apps and IoT modules installed in the products)
3. Outsourcing the handling of personal information
To the extent necessary to achieve the Purposes of Use, we may outsource all or part of the handling of personal information to a subcontractor. In this case, we will select a business operator that sufficiently protects personal information, stipulate the handling of personal information in a contract or other agreement, require the proper handling of personal information entrusted by us, and supervise the entrusted business operator in a necessary and appropriate manner.
4. Voluntary nature of personal information provision
However, failure to provide the necessary information may impede our Services and the fulfillment of the Purpose of Use.
5. Management of Personal Information
We will keep the personal information provided by you as accurate and up-to-date as possible.
6. Collection of personal information by methods other than in writing directly from the person in question
We may collect personal information from you directly in a manner other than in writing. For example, we may collect personal information in the following ways:
- (a) When we record the contents of a telephone call
- (b) When we take photographs or videos
- (c) When we record the content of an interview
- (d) When we talk with you during an interview.
7. Contact for Inquiries, complaints and consultation regarding personal information
Inquiries, complaints, or consultations regarding personal information should be directed to the following contact: privacy@whill.inc