Privacy Policy

1. Basic policy

Sun Digital Health Co., Ltd. (“the Company”) recognises the importance of personal information and complies with the Act on the Protection of Personal Information (APPI) and other relevant laws in handling and protecting it.

2. Purposes of use

The Company uses personal information it obtains for the following purposes.

• Providing, operating and improving products and services, including myWaves
• Responding to enquiries and providing support
• Shipping orders and processing payments
• Improving services through analysis of usage and trends
• Service improvement and scientific research, limited to statistical and anonymised data that does not identify individuals
• Information and marketing about new products and services, which you may opt out of
• Responses required by law

3. Information we collect

In providing our services we may collect the following.

• Personal information: name, address, email address, telephone number, user ID and similar
• Technical information: IP address, browser, operating system, device identifier, location and similar
• Usage information: browsing and click history, search queries, access times, referring URLs and similar
• Device-derived data, which may include sensitive personal information: brainwave data measured and uploaded by the myWaves device, and sleep-related data. This includes data obtained through Apple HealthKit or Google Health, or directly through an Android app.
• Statistical and anonymised data processed so that individuals cannot be identified

4. Sensitive personal information

Brainwave data collected as device-derived data may include information relating to your health and may constitute sensitive personal information under the APPI. By agreeing to this Privacy Policy you consent to the Company obtaining such information.

5. How information is collected

• Information you enter directly, such as creating an account or submitting a form
• Automatic collection through cookies and logs
• From partners, such as payment and analytics providers
• Data uploaded from the myWaves device
• Sleep data obtained through Apple HealthKit, Google Health or an Android app

6. Disclosure to third parties

We do not provide personal information to third parties without your consent, except in the following cases.

• Where required by law
• Where necessary to protect life, physical safety or property
• Where provided to a contractor to the extent necessary to perform work on our behalf, such as shipping, payment or hosting providers

7. Security measures

To prevent unauthorised access, leakage and alteration, we take the following measures.

• Access control and password management
• Encryption of communications, such as SSL
• Encryption of data, both at rest and in transit
• Management within a secure cloud environment
• Staff training and oversight of contractors

8. Cookies

We may use cookies and similar technologies to improve usability, analyse usage and deliver advertising. You can refuse cookies in your browser settings, although some functions may then be unavailable.

9. Marketing and opt-out

We provide product and service information by email only with your consent or where permitted by law. To stop receiving it, use the unsubscribe link in any email or contact info@sdh.co.jp.

10. Where data is stored

We store and process personal information on servers located in Japan and the United States. Specifically, we use Amazon Web Services (AWS) data centres in Japan and the United States, with appropriate safeguards including encryption and access control. Handling outside Japan is managed appropriately in accordance with the APPI.

11. Disclosure, correction and suspension of use

You may request disclosure, correction, addition, deletion or suspension of use of your personal information held by us. Contact us at the address below. There is normally no fee, although actual costs may be charged where permitted by law.

12. Minors

Our services are not directed at minors. A minor using our services should obtain the consent of a guardian. If we learn that we have obtained personal information from a minor without that consent, we delete it promptly.

13. Changes to this policy

We may revise this Privacy Policy as necessary. Revisions appear on this page and the last-updated date is changed accordingly.

14. Contact

For questions about this Privacy Policy, contact Sun Digital Health Co., Ltd., JEI Hamamatsucho Building 4F, 2-2-12 Hamamatsucho, Minato-ku, Tokyo 105-0013, Japan, or email info@sdh.co.jp.