Privacy Policy

Aug 3, 2023

Introduction

“Sanokuni” is a product provided by 100plus, Inc. (hereinafter referred to as “100plus” or “the Company”) that records and displays heart rate, body surface temperature, and step counts during sauna activities through a wearable device, and provides guidance for sauna activities.

We are committed to protecting the privacy of our users. This privacy policy outlines the principles applicable to the operation of “Sanokuni”.

This privacy policy is designed with the user's needs in mind, and it is important that users have a comprehensive understanding of how we collect and use personal information, and ultimately maintain control over the personal info they provide to us. This privacy policy explains how we collect, use, disclose, process, and store information provided to us when users use the “Sanokuni” app (hereinafter referred to as “the App”). “Personal information” in this privacy policy means information that can directly or indirectly identify an individual either from that information alone, or from that information combined with other information about that individual to which we have access. We strictly use your personal info in accordance with this privacy policy.

Ultimately, what we want is what is best for all our users. If you have any questions regarding our data handling practices described in this privacy policy, please make an Inquiry here (contact@100plus.co.jp). We look forward to hearing from you to answer your specific questions.

1. Types of Information Collected and Their Uses

1.1 Personal information collected and used with user permission

When we collect and use information actively provided by users while using our products and services, as well as personal information arising from the use of our products and services, we will do so in accordance with the principles of legitimacy, lawfulness, transparency, and necessity, and use such information for the purposes described in this privacy policy. If we need to use personal information for other purposes not specified in this privacy policy, or if we need to use personal information previously collected for a specific purpose for other purposes, we will notify you in a reasonable manner and obtain your consent again before using it.

Before providing us with sensitive personal data, you should consider it carefully and hereby confirm that its provisions are appropriate and agree to the processing of sensitive personal data in accordance with the purposes and methods described in this policy.

1.1.1 Recording and Displaying Activity and Fitness Information

When users use our wearable device (hereinafter referred to as “the device”), we may collect and record information regarding sauna activities, such as step counts, body movement, sauna activities and duration, heart rate, and body surface temperature. Furthermore, we may collect personal info such as nickname, gender, date of birth, height, and weight, as well as location information. This information is used to quantify sauna activities and calculate and display appropriate advice on both the wearable device and the app, helping users to better understand their sauna activities. Users' personal info is also used to generate personalized advice for sauna activities, which is displayed in the app and can be reviewed at any time. If Personal Info (such as gender, height, age, and weight) is not provided, default values will be used to generate recommendations.

1.1.2 Feedback

If you encounter any problems while using “Sanokuni”, please provide us with feedback and contact information (phone number or email address). This information will be used to better understand the issues you encounter and to contact you. If logs are uploaded to resolve an issue, we will collect information from the uploaded logs. The uploaded logs contain data during sauna activities (such as heart rate, duration, etc.). This information will only be used for troubleshooting purposes and not for any other purpose.

1.1.3 Notification

When the notification function is turned on, smartphone notifications will be synced to the wearable device. We do not read or store notifications, and the relevant information is only used to display notifications on the wearable device. Notification settings can be managed within the app.

1.1.4 Wearable Device Settings

You can change the wearable device settings in the app to adjust the wearable device's display, brightness, and other functions.

1.2 Provision of Personal Information to Third Parties

We will not provide the acquired personal information to third parties without the consent of the individual, except in the following cases:

When the user's consent is obtained
When disclosing or providing data as statistical data in a state where the user cannot be identified
When required by laws and regulations
When it is necessary for the protection of human life, body, or property, and it is difficult to obtain the consent of the individual
When it is particularly necessary for the improvement of public health or the promotion of the sound development of children, and it is difficult to obtain the consent of the individual
When it is necessary to cooperate with a national agency, local government, or an individual or entity entrusted by them in performing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the performance of such affairs
When outsourcing the handling of personal info within the scope necessary to achieve the purpose of use
In the event of business succession due to a merger or other reasons

1.3 Collection of Personal Info from Third Parties

Where permitted by law, we will collect information about you from third-party sources. For example, if you authorize logging into and using our services with a third-party account, or authorize importing your information from a third-party platform, we will collect information such as your account number and nickname.

1.4 Non-Personally Identifiable Information

We may also collect information that cannot identify a specific individual (information that is explicitly not personal info), such as your usage frequency, usage duration, page views, and the number of clicks on various features. The purpose of such collection is to improve the services provided to you. The type and amount of information collected depends on how you use our products and/or services.

This information is aggregated and used to provide you with more useful information and to understand which parts of our products and services you are most interested in. Aggregated data is not personal info and cannot be used to identify you. However, if non-personally identifiable information is combined with personal info, it will be treated as personal info as long as it remains combined.

2. Joint Use, Outsourcing, and Third-Party Provision of Personal Info

2.1 Joint Use

We do not sell personal info to third parties.
We may jointly use your personal info with third parties (see definition below) to provide or improve our products or services, including providing products or services based on your request. If you do not wish to have this info jointly used, please send an Inquiry to here (contact@100plus.co.jp).

2.1.1 Joint Use Actively Selected or Requested by You

Based on your explicit consent or request, we will jointly use personal info with specific third parties designated by you within the scope of your consent/request.

2.1.2 Joint Use of Personal Info with Third-Party Service Providers

Our Privacy Policy does not apply to products and services provided by third parties. Depending on the product or service you use, those provided by the "Sanokuni" app may include third-party products or services, such as those related to settings of smart wearable devices. In addition, when you use such products or services, information may also be collected by third parties. For the above reasons, we strongly recommend that you read the third-party privacy policies just as you would read ours. We are not responsible for, nor do we control, how third parties use the personal info they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

2.2 Provision Associated with Outsourcing

100plus will not provide your info to any third party in connection with outsourcing, except in the following cases.

When your explicit consent is obtained.
If 100plus is involved in a merger, acquisition, or sale of all or part of its assets that may affect personal info, we will notify you in an appropriate manner, such as by sending an email and/or posting a prominent notice on our website, regarding changes in ownership and use, as well as your choices regarding your personal info.
In circumstances explained in this Privacy Policy, or circumstances notified to users by other means.

2.3 Provision to Third Parties

100plus may provide personal information to third parties under the following circumstances.

When it is necessary to announce the winners of promotions, contests, or sweepstakes. In this case, only limited information will be disclosed.
When the user's explicit consent has been obtained, or when the user has disclosed information through our services such as social media pages or public forums.
When disclosing or providing information as statistical data in a state where the user cannot be identified.
Provision to third parties based on laws and regulations or reasonable grounds, such as laws, legal procedures, lawsuits, or requests from relevant government agencies.

3. Preservation and Protection of Personal Information

3.1 Security Measures

We are committed to keeping your personal information secure. To prevent unauthorized access, disclosure, or other similar risks, we have put in place all legally required physical, electronic, and managerial procedures to safeguard the information we collect from mobile devices. We guarantee that we will protect your personal information in accordance with applicable laws.

All personal information is stored on secure servers and protected in controlled facilities.

We conduct due diligence to ensure that our business partners and third-party service providers are capable of protecting your personal information. We also ensure that these third parties maintain appropriate security standards by establishing suitable contractual restrictions and conducting audits and assessments as necessary. In addition, our employees, as well as the employees of our business partners and third-party service providers who access your personal information, are subject to enforceable contractual confidentiality obligations.

To raise awareness among employees about the importance of personal information protection, we conduct security and personal information protection training and testing. We will take all feasible and legally required measures to protect your personal information. However, please understand that the use of the internet is not completely secure, and for this reason, we cannot guarantee the safety or integrity of any personal information transferred from you or to you via the internet.

We will handle personal data breaches in accordance with the requirements of applicable data protection laws. This includes, where necessary, notifying the relevant data protection supervisory authority and data subjects of the breach.

3.2 What You Can Do

By setting a unique password for 100plus services and not disclosing your password or account information to anyone (except those formally authorized), you can avoid password leaks to other websites that could compromise the security of your account on 100plus.

When using products or services other than "Sanokuni", or when viewing or using other products or services provided by third parties, all personal information you provide to such third parties is subject to the third party's privacy statement or related policies. If you use products or services other than "Sanokuni", we have neither the ability nor a direct obligation to protect the personal information you have provided to third parties. Please protect your personal information appropriately and carefully read the privacy statements and related policies provided by third parties.

100plus cannot be held responsible for security deficiencies caused by the disclosure of personal information due to your own negligence, resulting in third-party access to such personal information. Notwithstanding the above, you must immediately notify us in the event of unauthorized use of your account by other internet users or any other security breaches.

With your cooperation, we can protect your personal information.

3.3 Retention Policy

We retain your personal information only for the period necessary to fulfill the purposes for which we collected it, such as for our legitimate business interests and to meet legal or reporting requirements. Once the purpose of collecting personal information is achieved, a deletion request from the user is confirmed, or the operation of the corresponding product or service is terminated, we will cease to retain the personal information and delete or anonymize it. An exception is made for personal information processed for public interest, scientific or historical research, or statistical purposes. We will continue to retain this type of information longer than the standard retention period if permitted under applicable law, even if further data processing is unrelated to the original purpose of collection.

4. User Rights

4.1 Control Settings

We recognize that privacy concerns vary from person to person. Therefore, we provide examples of methods that "Sanokuni" offers users to restrict the collection, use, disclosure, or processing of personal information, and to control privacy settings.

You can pair and unpair your wearable device via [Home] > [Connect with sauna device].
Your device data will be synced via [Home] > [Data Sync]. Data will not be synced by any other method.
You can turn on or off permissions for notifications via [Home] > [Connect with sauna device] > [Heart Rate Notification Settings].

4.2 User Rights Regarding Personal Information

Subject to applicable laws and regulations, you have the right to access, correct, and erase your personal information held by us (hereinafter referred to as "Request").

Please submit your Inquiry to us here (contact@100plus.co.jp).

Requests must meet the requirements of applicable laws and the following conditions.

Requests must be submitted through the dedicated request channel of 100plus detailed above, and must be in writing to protect your information security (except where local law explicitly allows verbal requests).
You shall provide sufficient information to enable 100plus to verify your identity and confirm that you are the data subject or have the legal authority to act on behalf of the data subject.

Once we have obtained sufficient information to confirm that your request can be processed, we will proceed to respond to your request within the timeframe set under applicable data protection laws. Details are as follows:

Subject to applicable law requirements, a copy of the personal data collected and processed by us will be provided free of charge upon your request. If you request additional related information, we may charge a reasonable fee based on actual administrative costs, where permitted by applicable law.
If the information we hold is inaccurate or incomplete, you have the right to correct or supplement your personal information based on the purpose of use.
Subject to applicable law requirements, you may have the right to request the deletion or removal of your personal information. We will consider the grounds for your deletion request and take reasonable steps, including technical measures. Please note that due to applicable legal and/or technical limitations, it may not be possible to immediately delete information from backup systems. In this case, we will securely store the personal information and isolate it from further processing until the backup can be deleted or anonymized.

We reserve the right to refuse to process requests that are meaningless, manifestly unfounded, excessive, infringe on the privacy rights of others, highly unrealistic, require disproportionate technical effort, are not required under local law, concern publicly available information, or concern information provided under confidential conditions. If we believe that certain aspects of a request to delete or access information may prevent us from legally using the information for the aforementioned fraud prevention and security purposes, the request may be denied.

4.3 Termination of Service or Account

Deletion of your "Sanokuni" account paired with the app can be executed via [My Page] > [Delete Account]. Deleting your account will delete all "Sanokuni" data. Furthermore, you will no longer be able to use the full range of products and services, so please proceed with caution.

5. Updates to This Privacy Policy

We may update this Privacy Policy to reflect changes based on periodic reviews of our business and services. If we make material changes to the Privacy Policy, we will notify you through in-app dialogs so that you are aware of what information we collect and how we use it. Such changes to the Privacy Policy will apply from the date they are updated. We recommend that you check the in-app Privacy Policy regularly for the latest information on our protection of personal information. If we collect additional personal information from you, or if we use or disclose your personal information for a new purpose, we will seek your explicit consent.

6. Inquiry

The Inquiry feature is provided as a means of contacting management if you have any questions or requests regarding this app.

Since the Inquiry feature communicates via email, replies will be sent to your email address, but we will not use your email address for any other purpose.

You can also send inquiries directly to our email address.

100plus Inc.
Email: contact@100plus.co.jp

Last updated: November 24, 2023