basicmath Inc. ("we", "us" or "our") establishes this Privacy Policy (this "Policy") with respect to the protection of your personal information in connection with the license sales and license management service (the "Service") for the software products we sell (the "Software"), and handles personal information properly in accordance with this Policy.
The Service consists of account registration, license purchase and payment, issuance of license keys, activation, confirmation of operating status, distribution of updates, and handling of inquiries.
The Software operates in a cloud or server environment managed by you. Accordingly, we do not collect any business data or AI inputs that you enter into the Software. The information we handle is limited to account information, purchase and payment information, information on license operation, the content of inquiries, and access logs.
This Policy does not apply, however, where we provide business-oriented services to a business operator and such operator handles the information of its own customers for those customers. In that case, our use of such information is governed by the agreement applicable to such business-oriented services.
2. Personal Information We Collect
(1) Account information: information relating to your account, including your name, address, telephone number, email address, the name of the entity to which you belong, authentication information such as account ID and password, payment information, and transaction history
(2) License information: the type of license purchased, the license term, the number of licensed accounts, license keys, activation status, identifiers of the hosts on which the Software operates, the version of the Software, the number of connected accounts and users, the date and time of the most recent operational check, and other information necessary for license management
(3) Contact information: information relating to inquiries and communications (including the content of inquiries and contact details)
(4) Log information: information automatically transmitted from your browser or device (browser information, browser language settings, time zone, country, IP address, date and time of requests, user agent information, etc.)
(5) Device information: information relating to the device used (device type, OS, identifiers, browser information, etc.)
(6) Location information: information on the region where the Service is used, based on IP address and similar data
(7) Cookie and similar information: details are set out in our separate Cookie Policy.
(8) Other information: information made publicly available on the internet
Card details such as credit card numbers, expiration dates and security codes are collected and processed directly by our payment processor, Stripe, Inc.; such details do not pass through our servers and we do not retain them.
3. Handling of Data Entered into the Software
The Service does not collect the content of the business data that you enter into the Software. Such data is retained in the environment under your control.
The Software is installed in, and operates within, a cloud or server environment contracted for by you. With respect to data that the Software transmits to or receives from external services, we likewise do not collect or store its content.
The configuration and operation of the Software, and the management of data retained in your environment, are your responsibility. We collect only the information set out in the preceding section, to the extent necessary for license management and support.
4. Purposes of Use
(1) To provide, maintain and analyze the Service (including user authentication, issuance and verification of license keys, management of activation, and billing)
(2) To distribute updates of the Software and to improve, develop and research the Service and the Software
(3) To research and analyze marketing data and to consider and implement marketing measures
(4) To contact or notify you regarding the Service, such as changes to the Service or the Software and announcements of new features (including responses to inquiries)
(5) To prevent unauthorized use of licenses and other illegal or improper use
(6) To perform obligations required by laws and regulations
We may use statistical information that has been aggregated or de-identified so that individuals cannot be identified for the purposes set out above. Except where permitted by law, we retain and use statistical information in a de-identified state and will not re-identify, or attempt to re-identify, such information.
We do not use your personal information to train AI models. In addition, because we do not collect the business data you enter into the Software, such data is never used to train AI models.
We also collect and use personal information for operations of our group companies relating to each of the purposes set out above.
5. Provision to Third Parties
We may provide personal data to third parties in the following cases, to the extent necessary to achieve the purposes of use.
(1) Service providers: we may provide personal data to third parties that supply services necessary to perform or provide particular functions or services. Our principal recipients at present are Stripe, Inc. (United States) for payment processing, Twilio Inc. (SendGrid, United States) for email delivery, Firstpromoter Inc. (United States) for managing our partner referral program (when you sign up with a referral code, we share your email address and customer ID to attribute your account to the referring partner), and cloud infrastructure providers (United States and the European Economic Area) for application and database hosting. Credit card information is processed directly by Stripe, Inc. and does not pass through our servers. In addition, to assist in drafting replies to inquiries, we may share inquiry contents — with names, contact details, and other identifiers redacted — with OpenAI, L.L.C. (United States) or Google LLC (United States).
(2) Distributors and similar parties: we may provide information entered into inquiry forms, information request forms, meeting request forms or other forms to distributors, sales agents, referral partners and other business partners for the purposes of providing information, handling sales discussions, supporting implementation and other related sales activities.
(3) Transferees of business: where our business is transferred or succeeded to a third party due to corporate reorganization or similar events, we may provide personal data to such third party and to persons supporting the transfer.
(4) Group companies: we may provide personal data to our group companies. In such case, our group companies will use the data in accordance with this Policy.
(5) Cases based on laws and regulations: other than as set out above, we will not provide personal data to third parties without obtaining prior consent, except in any of the following cases: (a) where required by laws and regulations; (b) where necessary for the protection of the life, body or property of a person and it is difficult to obtain consent; (c) where specially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain consent; (d) where it is necessary to cooperate with a national agency, a local government, or a party entrusted by either of them in performing duties prescribed by laws and regulations, and obtaining consent is likely to impede the performance of such duties; or (e) where otherwise permitted by laws and regulations.
6. Transfers to Third Parties in Foreign Countries
In addition to Japan, we may provide personal data to third parties located in the following countries. In order to select appropriate providers as circumstances require, we may also entrust processing to providers in countries other than those listed below, although such providers and the countries in which they are located cannot be specified at present. In such case, we may commence a new entrustment without obtaining consent again.
(i) United States (information published by the Personal Information Protection Commission: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/ )
(ii) EU member states and Iceland, Norway and Liechtenstein, which form part of the EEA ( https://www.ppc.go.jp/enforcement/infoprovision/EU/ )
Where we provide personal data to a third party in a foreign country that has implemented equivalent measures, we take the measures necessary to ensure the continued implementation of such measures. In addition, transfers from within the EU are made to a country with an adequacy decision or subject to appropriate safeguards such as Standard Contractual Clauses (SCCs). For details, please contact us at the contact point below.
7. Joint Use
(1) Items jointly used: the information set out in Section 2 (Personal Information We Collect)
(2) Purposes of use: the purposes set out in Section 4 (Purposes of Use)
(3) Scope of joint users: our group companies
(4) Party responsible for management: basicmath Inc. (head office: 2F Ogawa Kyoto Building, 255 Kugikakushi-cho, Shimogyo-ku, Kyoto; General Affairs Department, Minami Kato)
8. Retention Period
We retain personal information only for the period necessary to provide the Service, or for dispute resolution, safety and security reasons, compliance with legal obligations, or other legitimate purposes. The retention period varies depending on factors such as (i) the purpose of use, (ii) the volume, nature and sensitivity of the information, (iii) the potential risk of harm from unauthorized use or disclosure, and (iv) applicable legal requirements.
License information and transaction information are retained for the period necessary to verify the validity of licenses, provide support, and comply with statutory record-keeping obligations.
Records relating to orders and payments are retained for ten years from the date of the order in order to comply with statutory bookkeeping obligations, and are deleted once that period expires. These records (including the payment records and invoices held by Stripe, Inc.) are retained for the same period even if you close your account; upon closure, however, we sever their link to the account and reduce the personal data we hold to the minimum of your name and email address. Card details stored with Stripe, Inc. are deleted when you close your account.
9. Security Measures
We take necessary and appropriate measures to prevent leakage, loss or damage of personal data and otherwise to manage it securely, including TLS encryption, access control, multi-factor authentication, strict management of license signing keys, vulnerability management, and the establishment of incident response procedures. For details, please contact us at the contact point below.
10. Requests for Disclosure and Other Rights
You have the following rights.
(1) The right to access your personal information and information about how it is processed
(2) The right to request correction of inaccurate personal information
(3) The right to request deletion
(4) The right to request restriction of processing
(5) The right to request transfer to a third party
(6) The right to withdraw consent previously given
(7) The right to object to the manner of processing
(8) The right to lodge a complaint with the supervisory authority in your jurisdiction
These rights may be exercised by contacting us at the contact point below and completing the prescribed procedures. In order to prevent unauthorized access, alteration or deletion, we may verify your identity. If you do not have an account, or if fraudulent or malicious conduct is suspected, we may ask you to submit additional personal information for verification purposes. We cannot respond if your identity cannot be verified. Even where a right is exercised, we will not treat you unfairly, except where the exercise of such right makes it unavoidably impossible for us to provide the Service or where there is other justifiable cause.
11. Child Users
The Service is not directed at children under 13, and we do not knowingly collect personal information from children under 13. If you believe that a child under 13 has provided personal information, please contact us at the contact point below. After verification and investigation, we will delete such data from our records where we deem it appropriate. Persons under 18 require the consent of a parent or other legal representative in order to use the Service.
12. Cookies
We use cookies and similar tracking or analytics technologies in providing the Service. For details, see our separate Cookie Policy.
13. Legal Bases for Processing
We have determined the information concerned and the legal basis for processing for each purpose of use as follows (purpose - information concerned - legal basis).
To provide, maintain and analyze the Service - account information, license information, contact information, log information, device information, location information, cookie and similar information - where necessary to perform a contract
To distribute updates of the Software and to improve, develop and research the Service - account information, license information, contact information, log information, device information, cookie and similar information - where necessary for the legitimate interests of us, of third parties, and of society more broadly
To research and analyze marketing data and to consider and implement marketing measures - account information, license information, contact information, log information, device information, location information, cookie and similar information - where necessary for legitimate interests
To contact or notify you regarding the Service - account information, contact information, log information, device information, cookie and similar information - where necessary to perform a contract
To prevent unauthorized use of licenses and other illegal or improper use - all items - where necessary to comply with legal obligations
To perform obligations required by laws and regulations - all items - where necessary to comply with legal obligations, such as retaining transaction information to comply with record-keeping obligations
14. Notice Regarding the CPRA
We do not "sell" personal information, nor do we "share" it for targeted advertising (cross-context behavioral advertising). We also do not handle sensitive personal information beyond the scope of the purposes of use set out in this Policy.
15. Contact Point
For inquiries regarding this Policy, requests for disclosure, and other communications concerning the handling of personal information, please contact us at the following.
basicmath Inc.
2F Ogawa Kyoto Building, 255 Kugikakushi-cho, Shimogyo-ku, Kyoto 600-8423, Japan
E-mail: privacy@mitsumono.ai
16. Changes to This Policy
We may update this Policy from time to time. Except where applicable law requires notice by another method, we will make the revised Policy and its effective date known by means such as posting them on our website.
Detailed information on the processing of Personal Data
Access to third-party accounts
This type of service allows this Website to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Stripe account access
Company: Stripe, Inc.
Place of processing: United States
Personal Data processed: email address +5
This service allows this Website to connect with the User's account on Stripe, provided by Stripe, Inc.
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website.
For more information, please check the privacy policies of the relevant services.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Meta ads conversion tracking (Meta pixel)
Company: Meta Platforms, Inc.
Place of processing: United States
Personal Data processed: Trackers +1
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on this Website. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Meta Advanced Matching is an advertising service provided by Meta Platforms, Inc. that allows the Owner to send hashed first-party conversion Data to Meta in order to improve conversion measurements.
Personal Data processed:
city
country
date of birth
email address
first name
gender
last name
phone number
province
state
Trackers
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Meta Audience Network is an advertising service provided by Meta Platforms, Inc. In order to understand Meta's use of Data, consult Meta's data policy.
This Website may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Meta Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
Personal Data processed:
Trackers
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics 4
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: number of Users +3
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Website.
This type of service allows this Website to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Website.
For details of which data are collected, please refer to the privacy policy of each service.
First Promoter
Personal Data processed: Trackers
We use FirstPromoter to manage our affiliate and referral program. When you visit our website through an affiliate link or participate in our referral program, FirstPromoter may place cookies or use similar technologies to attribute referrals, track conversions, prevent fraud, and calculate commissions for affiliates.
The information collected may include referral identifiers, browser information, IP address, device information, visit timestamps, and conversion events. This information is used solely for operating and improving our affiliate program.
Personal Data processed:
Trackers
Contacting the User
Contact form
Company: this Website
Personal Data processed: email address +1
By completing the contact form with their information, the User authorizes this Website to use these details to respond to the inquiries (like quotes, and any other requests).
Personal Data processed:
email address
Usage Data
Service provided by:
this Website
Mailing list or newsletter
Personal Data processed: email address +2
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed:
email address
Trackers
Usage Data
Handling payments
Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe
Company: Stripe, Inc.
Place of processing: United States
Personal Data processed: email address +4
Stripe is a payment service provided by Stripe, Inc.
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Sendgrid
Company: Sendgrid
Place of processing: United States
Personal Data processed: email address +2
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Meta Custom Audience
Company: Meta Platforms, Inc.
Place of processing: United States
Personal Data processed: email address +1
Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Website with the Meta Audience Network.
Users can opt out of Meta's use of Trackers for ads personalization by visiting this opt-out page.
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Trackers +1
Google Tag Manager is a tag management service provided by Google Ireland Limited.
This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare
Company: Cloudflare, Inc.
Place of processing: United States
Personal Data processed: Trackers +1
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.
Personal Data processed:
Trackers
various types of Data as specified in the privacy policy of the service
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further Information for Users in the European Union
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This policy relates solely to this Website, if not stated otherwise within this document.
