Privacy Policy

1. Introduction
Shiftory Consultancy CO. L.L.C and its group companies（hereinafter referred to as "the Company," "we," or "us"） are entrusted with user personal information. "Personal Information" refers to information that can identify an individual, such as names, addresses, and telephone numbers, as well as information that can identify an individual when combined and cross-referenced with other information. It also includes Cookies of users who use our website. We pay the utmost attention to the handling of the Personal Information we receive. We would like to explain our Basic Policy on the Protection of Personal Information, which forms the basis of our commitment.
The Company acquires Personal Information in an appropriate manner.
The Company will notify users of the purpose of use and handle Personal Information within the scope of that purpose.
The Company takes necessary and appropriate measures to safely manage the acquired Personal Information.
The Company will not provide or disclose Personal Information to third parties, except in prescribed cases.
The Company will respond appropriately when a user contacts the designated window regarding inquiries, corrections, suspension of use, or deletion of their Personal Information.
This policy describes the Personal Information the Company collects, how we use and share that information, and the choices users have regarding their data.

Effective Date: November 1, 2025

2. Overview
A. Scope of Application
This policy applies to users of the services provided by the Company（including users who browse the Company's website, use our E-commerce services, and other services), regardless of country or region.

The specific subjects of this policy are as follows. In this policy, those subject to this policy are collectively referred to as "Users."
・Customers browsing the Company's website
・Customers transacting through the Company's E-commerce services

B. Data Controller and Data Transfer
Shiftory Consultancy CO. L.L.C is the Data Controller for personal data collected in connection with the use of services provided by the Company.

3. Data Acquisition, Collection, and Use

A. Data We Acquire/Collect and Purposes/Methods of Use

1） Information Provided by Users
Inquiries
We acquire names, telephone numbers, email addresses, etc. This information is used for investigation and response to inquiries, and for user identity verification.

Shipping and Payment Information
When transacting in E-commerce, we acquire names, addresses, and telephone numbers. This information is used to ship products and invoices to Users, to provide information on products and services via newsletters and emails, and to improve and enhance the services, products, marketing, and user experience provided by the Company.
In addition, we ask Users to input credit card information for payment. However, since settlements are processed by a payment agency, the Company does not retain credit card information.

2） Information Generated Through Use of Services
Cookies
Cookies are pieces of information sent to a User's browser and stored on the User's computer to identify the User on the server side. We use Cookies to improve user convenience by saving settings, to maintain sessions and ensure security, to provide more relevant information by measuring advertising effectiveness, and to improve usability such as browser display functions.
We also use Cookies to understand the frequency of visits and usage patterns of the Company's services to provide better services.
Users can choose whether to allow cookies, but if they refuse to save cookies, they may not be able to use some of the Company's services, such as those requiring login.

Access Logs
Information such as IP address, browser type, and browser language is automatically generated and saved when a User uses the Company's services. This information is used to analyze the user environment for better service provision and to prevent fraudulent activities that interfere with normal service provision.

B. Sharing and Disclosure of Personal Information

1） Provision to Third Parties
The Company will not provide Personal Information to third parties without the User's consent, except as permitted by applicable laws or when providing Personal Information in connection with business succession due to mergers or other reasons.
However, we may provide Personal Information to necessary third parties if there is a disclosure request based on laws and regulations, in the event of illegal acts such as unauthorized access, or when there is a special reason necessary to protect the rights, property, or safety of the Company or third parties.

2） Entrustment of Personal Information
The Company may entrust all or part of the Personal Information acquired from Users to contractors (including contractors located in foreign countries） within the scope necessary to achieve the purpose of use.
In such cases, we will sufficiently examine the eligibility of the contractor, stipulate matters regarding confidentiality obligations in the contract, and establish a system to ensure that information is managed appropriately.

3） Joint Use of Personal Information
The Company will jointly use Personal Information within the Company's group companies within the scope necessary to achieve the purpose of use.
The person responsible for management in joint use is Shiftory Consultancy CO. L.L.C.

C. Retention and Deletion of Personal Information
The Company retains Personal Information for the period necessary to achieve the purpose of use.

Users may request the Company to inquire about, correct, suspend the use of, or delete their Personal Information.
Upon receiving a request, the Company will verify the User's identity through prescribed procedures and respond promptly.
Please note that a disclosure fee may be charged in accordance with procedures separately established by the Company when requesting disclosure.

For inquiries, corrections, suspension of use, deletion, etc., of Personal Information, please contact us at:
info@shiftoryconsultancy.com

4. Updates to this Policy
The Company may update this policy. By using the services provided by the Company after an update, the User agrees to the updated policy to the extent permitted by law.