Privacy Policy

1. Basic principles regarding personal information

ADrim Inc. (hereafter referred to as “our company”) shall respect the privacy of users when using our social media service “WeNative” (hereafter referred to as “this service”) and will strive to protect the personal information of users based on the following policies.

2. Acquisition of personal information

Our company will collect the personal information of users. This information includes:

  • Names
  • Country and City
  • Time zone
  • Native languages
  • Learning languages
  • Age
  • Email addresses
  • Profile photographs
  • Availabilities
  • Voice and video data

Also, our company uses a live video platform operated by TokBox Inc. to provide users with ability to chat through live video with partners. The live video sessions with partners are automatically recorded on their server to provide our company access to that data.

In addition, when using this service, information to be used in various areas, including the following, will be automatically collected and generated.

  • Access log
  • Device information
  • IP Address
  • Cookie information
  • Statistical data

Furthermore, this information will be used in the analysis of the management and utilization of this service and does not include information that can be used to identify individual users.

3. Use of personal information

The purpose of use and scope of the application of personal information is as follows. Our company may amend the purpose of use of personal information provided within a reasonable scope, and when this purpose is changed our company will either notify users or make a public announcement.

  1. To provide this service and authenticate the identity of users
  2. To provide information for the purpose of providing member services to companies who supply product advertisements, etc.
  3. To implement questionnaires and campaigns to improve services provided by our company
  4. For the free supply of various information in emails from this company, and replies to inquiries
  5. To respond to actions that violate the rules and policies, etc., (hereafter referred to as “rules, etc.”) relevant to this service
  6. To notify users of changes to rules, etc. relevant to this service
  7. To help to improve this service and develop new services
  8. To create statistical data about this service that has been formatted so that individual users cannot be identified
  9. For other purposes incident to those stated above

4. Release to third parties

  1. As a general principle, the personal information of users will not be released to third parties without the consent of the user. Personal information will only be released after specifying its destination and what information will be sent, and after obtaining the consent of the user. However, this does not apply in the following circumstances:
    1. To comply with laws and regulations
    2. When it is required to protect a person’s life, body, or property, and it would be difficult to obtain the user’s consent
    3. When it is especially required to improve public health or to promote the sound growth of a child and it would be difficult to obtain the user’s consent
    4. When it is required for cooperation with a state organ, a local government, or an external party who has taken on work from either of these, so that these organizations may execute work prescribed by law and regulations, and obtaining the consent of users could potentially impede the execution of this work
  1. The provisions regarding the supply of information to third parties as prescribed above shall not apply to the following, regardless of the provisions of the preceding paragraph.
    1. When entrusting the handling of personal information, in whole or in part, within the scope necessary for the achievement of the purpose of use
    2. When personal information is supplied as a result of the succession of business after a merger or otherwise
    3. For joint use as prescribed in the Act for the Protection of Personal Information

5. Disclaimer

Our company bears no responsibility for the acquisition of personal information by third parties under the following circumstances:

  1. When a user discloses personal information to another user via the features of this service or any other method
  2. When a user can be identified by chance through activity data and information entered by another user
  3. When a separate user acquires information that can be used to identify the user (ID, password, etc.)

6. Cookie use

This service may use cookies and other similar technology. This technology helps our company to understand the utilization, etc., of this service, and plays a part in the improvement of this service. If you do not want us to store cookies on your computer, you can disable cookies on your browser settings. However, you may become unable to use parts of this service if you disable cookies.

*Cookies are information files sent from the server to the user’s browser and then stored on the user’s hard disk.

We use cookies, image files (web beacons), etc. from third-party companies  and obtain statistical site usage information in order to study customer trends and provide optimal ad delivery.

In addition, some of the cookies and web beacons mentioned above include third-party companies obtaining information directly, and any cookie information collected there is not provided or disclosed to us, but is managed in accordance with the privacy policy prescribed by the third-party company. This information cannot be used to identify individuals and is handled in the form of anonymous data. It is also not used for anything other than the stated purpose.

7. Access logs

Information about users who have accessed this service’s website is recorded in the form of an access log. The access log includes information such as the user’s IP address, host name, browser, OS, time of access, etc.

Access logs are used in statistical analysis related to the maintenance and utilization of this service and have never been used for any other purpose.

8. Use of statistical data

Our company creates statistical data based on the personal information provided, in a format that cannot be used to identify individual users, and may use this data without any restriction.

9. Amendments to the Privacy Policy

Our company occasionally reviews how personal information is handled, is continuously striving for improvement, and as such may make amendments to this Privacy Policy as necessary.

10. Responsibility for the management of personal information

The personal information provided by our users is managed responsibly by our company. If you have any questions or comments regarding the handling of personal information on this service, please contact us using the address below.

[Email address] [email protected]


This GDPR PRIVACY POLICY (this “Privacy Policy”) states the policy for processing of personal data obtained from persons (the “User” or “Users”) residing in EU that use the social media service “WeNative” (the “Service”) of our company (the “Company”). Upon the User’s agreement to this Privacy Policy, the User shall be deemed to have given a voluntary and express consent to the subject matters of the User’s consent stipulated in this Privacy Policy (including, without limitation, the purposes of processing of personal data and transfer of personal data to third countries).

1. Definitions

The following terms as used herein shall have the meanings as set forth below. Definitions of the terms that are not defined herein shall be subject to the definitions provided in GDPR.

  • EU

European Union that includes the member states of European Union, as well as Iceland, Lichtenstein and Norway under Agreement on the European Economic Area (EEA). -GDPR

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC(General Data Protection Regulation).

  • Applicable Privacy Laws

Applicable privacy laws including GDPR and domestic laws related thereto of relevant countries.

  • personal data

“personal data” as defined in GDPR.

  • processing

“processing” as defined in GDPR.

  • controller

“controller” as defined in GDPR.

2. Scope of this Privacy Policy

This Privacy Policy shall be applied to the processing of the personal data of the Users in relation to the Service that shall be governed by the Applicable Privacy laws.

3. Users under the age of 16

If any User under the age of 16 uses the Service, it shall make sure to obtain the guardian’s consent to this Privacy Policy or to give the consent to this Privacy Policy under the guardian’s permission thereto.

4. Controller

The Controller for the processing of the personal data shall be the Company, whose contact details are as follows.

  • [Name] ADrim Inc.
  • [Address]Kabutocho Yachiyo Bldg. 6F, 20-5 Nihonbashikabutocho, Chuo-ku, Tokyo, 103-0026, Japan

5. Collected Personal Data

The Company may obtain the following personal data from the Users.

  • Email address
  • User name and password
  • Country and City
  • Time zone
  • Native languages
  • Learning languages
  • Age
  • Profile photo
  • availability
  • Voice and video data
  • Access log
  • Device information
  • Cookie information
  • IP address

The Company may collect the personal data in the following cases.

  • When the User subscribes for the Service
  • When the User otherwise use the Service

6. Purpose and legal basis of Data Processing

  1. The Company shall process the personal data only for the purposes as set forth below.
    1. Performance of contract, or response to requests of Users prior to executing contract: The Company may process the personal data of the User entering into a contract regarding the Service, for the purpose of performing the contract. The Company may also process the personal data of the User prior to entering into such contract, for the purpose of taking steps in response to the Users requests.
    2. Communication: The Company may use the personal data for the purpose of (i) communication regarding the Service, (ii) notification of information important for the User’s account and/or use of the Service, and (iii) responding to complaints. If the User makes an account for the Service, the Company saves relevant personal data so that the User is not required to enter the personal data each time. Such processing of the personal data is necessary for performance of contracts and/or legitimate interests pursued by the Company, namely, for performing the Company’s normal operation.
    3. Marketing: If the Company contacts the User by email for the purpose of marketing (including announcement and implementation of campaigns), the Company shall obtain the User’s prior consent. At any time the User may require the termination of the distribution of such email to the User. Such processing of personal data is (i) necessary for legitimate interests pursued by the Company, namely, to communicate with the User and provide products or services, or (ii) based on the User’s prior consent.
    4. Improvement of services: The Company may conduct a questionnaire survey to Users and use the personal data of the Users obtained through the questionnaire survey. Such processing of the personal data is necessary for legitimate interests pursued by the Company, namely, for improvement, etc. of services of the Company.
    5. Customer Service: If the User uses a customer service, the Company may use the personal data of the User for providing the customer service. Such processing of the personal data is necessary for performance of contracts and/or legitimate interests pursued by the Company, namely, for performing the Company’s normal operation.
  2. In cases where the Company intends to further process the personal data for a purpose other than that for which the personal data were collected, the Company shall provide the User prior to that further processing with information on that other purpose.

7. Provision of Information to Third Party

The Company may provide the personal data of the Users to the following parties, to the extent necessary for pursuing the purpose of processing. As set forth in Section 8.2, such third parties may include parties residing or located in countries outside EU.

  • Accountants, lawyers and other professional advisers
  • Providers of the services related to the Service, including, without limitation, data storage, maintenance and payment service

8. Transfer of Personal Data to Third Countries

  1. When the Company receives personal data from the User, the personal data are transferred from EU region to Japan.
  2. In addition to the foregoing, the Company may, to the extent necessary for pursuing the aforementioned purposes of processing, transfer personal data of the Users to countries outside EU, including, without limitation, Japan, and further process the same. The User may not have the right as a data subject same as that under GDPR in countries outside EU, and the Company shall take steps regarding the User’s personal data in accordance with the Applicable Privacy Laws, including, without limitation, execution of standard contractual clauses under GDPR.
  3. Upon the User’s agreement to this Privacy Policy, the User shall be deemed to have given a voluntary and express consent to the transfer of personal data to third countries set forth in this Section 8.

9. Storage Period

The Company shall store the personal data of the Users to the extent necessary for the purpose of processing thereof, and delete the personal data when the storage becomes unnecessary for such purpose.

10. Cookies

Cookies or similar technologies may be used in the Company’s service. Such technologies help the Company to recognize the status of use of the Company’s service, etc. and contribute to improvement of the service. When a User intends to disable cookies, the User may disable cookies by changing the web browser’s settings. Please note that when cookies are disabled, a part of the service may be unavailable.

11. Disclosure, Modification, Deletion, etc. of Personal Data

  1. If a User that is the subject of the personal data requires any of the following, please notify the contact address of the Company of that effect. The Company will properly respond to that request pursuant to the User’s right under the Applicable Privacy Laws.
    1. Access to personal data
    2. Modification of personal data
    3. Deletion of personal data
    4. Restriction on processing of personal data
    5. Objection to processing
    6. Exercise of right to data portability
  2. For the request under Section 11.1, please submit the following documents by email.
    1. Document for identification of the User as specified by the Company
    2. Document for identification of the representative of the User as specified by the Company
  3. To avoid undue modification, divulge, etc. by a third party of the personal data, the Company will response to the request by mail or email, only if the identity confirmation is made by the submitted documents. Although the Company will make effort to promptly respond, please note that it may takes time until response, for the confirmation of the applicable registered personal data and for assuring accuracy.
  4. The Company will not return the request form or identification documents received from the User or its representative. Please understand that the Company will keep the request form properly, and delete the identification documents in an appropriate manner when the purpose of use thereof is achieved.

12. Withdrawal of Consent

For the processing of the personal data based on the User’s consent, the User shall have the right to withdraw the consent for the personal data at any time.

13. Lodgment of Complaint with Supervisory Authority

In addition to the aforementioned rights, the User may lodge a complaint with a supervisory authority at any time. However, the Company appreciates a notification to the Company prior to contacting the supervisory authority, so that the Company may have the opportunity to respond to the complaint of the User.

14. Necessity of Provision of Personal Data

Since the personal data to be provided by the User are necessary for the Company to provide the Service, the Service may be unavailable to the User that does not provide the data.

15. Inquiries

For questions or complaints, or for the exercise of the rights under Sections 11 and 12, please contact the following contact addresses.

  • [Contact] ADrim Inc.
  • [Address] Kabutocho Yachiyo Bldg. 6F, 20-5 Nihonbashikabutocho, Chuo-ku, Tokyo, 103-0026, Japan

16. General Provisions

  1. The Company shall retain the right to regularly amend this Privacy Policy. The User shall regularly check and confirm the applicable provisions at its responsibilities.
  2. In the event of conflict between the Applicable Privacy Laws and any provision of this Privacy Policy, the provision shall be deemed replaced by a provision of the same meaning that reflects the original intention, to the maximum extent permitted by laws. In that case the remaining provisions hereof shall continue to be applied without change.