Privacy Policy
Last revised on November 1, 2025.
Important Notice: The English version of this document governs the contractual relationship between you and us. The Japanese version of this document is provided solely for your convenience and does not affect the contractual relationship defined in this English version of this document.
CHEQ AI Technologies Ltd. (hereinafter referred to as “us”, “we” or “Company”) has established the following privacy policy regarding the handling of personal information of users of the Company’s services (hereinafter referred to as “you” or “Users”), and is committed to protect the privacy of Users who access, visit, use or engage with our website(s) or any other online services we provide (collectively: the “Services”).
This Privacy Policy outlines our practices for collecting, using, and disclosing information about you in connection with your use of the Service. The Company complies with the Act on the Protection of Personal Information (“APPI”) and other applicable laws, regulations, and guidelines.
This Privacy Policy is part of the Terms and Conditions and is incorporated therein by reference. By using the Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy. If you do not agree to this Privacy Policy, please do not use our website or Services.
Collection and Storage of Your Personal Information
We may collect and use the following types of information about you:
Non-personal Information
Non-personal Information is non-identifiable information
that, when taken alone, cannot be used to identify you. As such, we are not aware of the identity from which the Non-personal Information is collected.
We may anonymize or de-identify information collected through the Service so that the individual User cannot be identified by such information alone. In addition, for the purpose of improving the functionality of the Service, we collect aggregated User information, as well as technical information, including some software and hardware information about your device (e.g., the device you are using, the type of browser and operating system used on the device, language settings, etc.) that is transferred from your device. We also collect information about your behaviour on the Service, including technical information. In addition, we may also collect information about your behaviour on the Service (e.g., clicks, actions, etc.). We may share or provide statistical information about our Users with outside parties or other companies. However, such information will not be used to identify individual Users, and will only be shared in an aggregated, non-personally identifiable form.
Personal Information
Personal information is information about a living person that identifies or may, with reasonable effort, identify a specific individual it may also include information that can identify an individual only by combination with other information.
We gather the following types of Personal Information for Users of our website:
- Voluntary Information: We may collect information that you voluntarily provide to us. For example, when you set up your account, respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect inquiries, comments, complaints, and reports that you communicate to us. Please note that we may also collect complaints about you that are communicated to us by other users, which may include your personal information.
- Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) as well as other information which relates to your activity through the Services.
We gather the following types of Personal Information for Users of our customers’ website:
- Device data. Information about the personal computer or mobile device you use to access the customer website. This may include technical information transmitted by the device, including certain software and hardware information such as the browser used to access the site, the device model and operating system, language preference, unique device identifiers, and the Internet Protocol (IP) address through which you accessed the customer website.
- User Activity. Information regarding a User’s activity on the customer website such as the time and frequency of access, the referrer page domain, pages viewed, and interactions between the website and the User.
For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
We do not collect any Sensitive Personal Information under the APPI, such as race, creed, social status, medical history, criminal record, or the fact a person has suffered damage by a crime, etc.
Cookies and other technologies
We may use cookies and other technologies or methods of web and mobile analysis (e.g., Pixels, Google Analytics, etc.) to gather, store, and track certain information related with your access to and activity through the Services, including when you visit our website(s).
A “cookie” is a small file containing a string of characters that a website assigns to your device while you are visiting a website. Cookies are very useful and can be used for a variety of purposes, such as saving you time and letting the web server know that you are revisiting a particular page. Such purposes include, but are not limited to, enabling you to navigate efficiently between pages, enabling certain features to be activated automatically, remembering your preferences, and making your interaction with the Service fast, easy, and smooth.
Our website(s) may use the following types of cookies:
Session Cookies which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.
Advertising Cookies – which collect information about your browsing habits in order to make advertising more relevant to you and your interests. For more information please refer to the “Advertisements” section below.
You may delete the cookies by following the instructions in your device settings, but please note that if cookies are disabled, some functions of the Service may not operate properly and You may not be able to fully utilize our website.
We may also use a tool called Google Analytics to collect information about your use of the Services. Cookies used by Google Analytics collect information such as the number of visitors, the website from which they linked to our website, and the pages they visited on our website. We use the information from Google Analytics to improve our website; Google Analytics does not collect your name or other personally identifiable information, but rather the IP address assigned to you on the date of your visit. We do not combine information collected through our use of Google Analytics with personally identifiable information. For more details about Google Analytics, please refer to Analytics Terms of Services and Google Privacy Policy.
How we use the information
We use and share Personal Information in the manners described in this Privacy Policy. In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for any of the following utilization purposes:
- To set up your account and to provide our Services (e.g., to provide analytics which allow websites, app developers, advertisers and third-party ad platforms to better understand the effectiveness of their various content);
- To identify and authenticate your access to certain features of the Services;
- To communicate with you (including to request your feedback on the Service) and to keep you informed of our latest updates (including sending e-mails, flyers, and other direct mailings);
- To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests;
- To support and troubleshoot the Services and to respond to your queries;
- To investigate and resolve disputes in connection with your use of the Services
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena similar legal process or respond to a government request.
With whom we share the information and for what purpose
We do not rent, sell, or share your Personal Information with third-parties except as described in this Privacy Policy. When we provide Personal Information to a consignee, we will thoroughly examine the eligibility of the consignee, stipulate confidentiality obligations in the contract, and exercise necessary and appropriate supervision over the consignee.
We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers; (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.
In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) processing such information to assist us with our business operations; (iii) performing research, technical diagnostics, personalisation and analytics.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.
Third-party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.
You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.
International transfer
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside of Japan, including, but not limited to the US and the EU. The data protection and other laws of these countries may not be as comprehensive as those in Japan, nor under the Personal Information Protection Commission (“PPC”) adequacy decision − in these instances we will take steps to ensure that a similar level of protection is given to Personal Information, including through adequate contractual measures. You hereby consent to the transfer of Personal Information to countries outside of Japan.
For how long we retain the information
Unless you instruct us otherwise, we may retain your personal data for a period of time consistent with the original purpose for which it was collected or for as long as necessary to fulfill our legal obligations. Information about a particular device will be retained for the duration of the session during which such information is collected. Without derogating from the foregoing, in any other case we will retain the information for a maximum period of 485 days.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Your privacy rights
You have certain rights with respect to your personal data in accordance with your local data protection laws. Such rights vary depending on the applicable law, but may include the following rights:
- Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
- Right to see what Personal Information about you we have;
- The right to request us to erase personal data concerning you (only if permitted under applicable data protection law).
- Right to restrict us from processing Personal Information pertaining to you in some cases (including, for example, if the personal data was collected on the basis on legitimate interest, or was collected illegally); and
- Right to export Personal Information in a portable format.
If you wish to exercise any of these rights, contact us at: dataprivacy@cheq.ai;
When handling your request, we may ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services.
In some cases, processing a request may be subject to a fee of up to 300 yen per case.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: dataprivacy@cheq.ai.
We will respond promptly and appropriately to complaints and consultations received from Users regarding the handling of Personal Information.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority
How we protect your information
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access. If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at: dataprivacy@cheq.ai.
Advertisements
Only in the context of your use of our website, we may also use our third-parties and share with them Users’ information to assist us in evaluating the success of our advertising campaigns and help us retargeting our Users. You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
Corporate transaction
We may share information, including Personal Information, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.
Minors
The Services are not designated to individuals under the age of 16. If you are under 16 years old, you should not use the Services, or provide any Personal Information to us.
We reserve the right to access and authenticate all personal information collected from Users. If we become aware that someone under the age of 16 has shared information with us, we will destroy such information. If you believe that a minor has shared information with us, please contact us at dataprivacy@cheq.ai.
Updates or amendments to the Privacy Policy
We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website(s) (as reflected in the “Last Revised” heading). In the event of a material change to the Privacy Policy, we will notify you through the Services or via email. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Services, following the notification of such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
How to contact us
If you have any questions regarding the Services or about this Privacy Policy, or that you wish to exercise any of your rights, please contact us at dataprivacy@cheq.ai;
Our data protection officer:
We have appointed a Data Projector Officer, who is our Global Director of Cyber Security, who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, you may contact our data protection officer at: dataprivacy@cheq.ai.