Privacy Policy Regarding Personal Information of Customers


Clew, Inc. (hereinafter referred to as “the Company”) recognizes the importance of personal information in operating its business and considers its thorough protection as the utmost responsibility. To provide customers with a sense of security and trust, we have established the following policy and strive to ensure that our administrative staff and affiliated offices are fully aware of it and protect personal information.

The definitions in this privacy policy are based on the Personal Information Protection Law (Law No. 57 of 2003. Hereinafter the same). The Company will also properly handle information about corporations and other organizations as if it were personal information.

  1. Compliance with Laws and Regulations
    The Company will comply with the Personal Information Protection Law, guidelines from each ministry, and other related laws and regulations to protect personal information.

  2. Handling of Personal Information
    The Company will establish a management system for personal information protection according to business reality and handle personal information appropriately and carefully in accordance with the Company’s rules.

    • Acquisition of Personal Information: The Company will obtain personal information with a clear purpose using methods such as online screens, written applications, or verbal communication. We may also acquire information from service providers, joint users, or through business successions due to mergers or other reasons. Please note that we may record calls to ensure accurate understanding of orders, opinions, requests, inquiries, and to improve future services.
    • Use & Provision of Personal Information: The Company strictly manages personal information and, except as required by law, uses it only within the scope of the purpose for which the individual’s consent was obtained. If the purpose of use includes providing to a third party, the range of that third party will be specified and disclosed.

  3. Measures for Safe Management

    • The Company will take necessary and appropriate measures to prevent leaks, loss, or damage of the personal data we handle and to manage it safely.

  4. Continuous Improvement of Personal Information Protection Management System (Compliance Program)
    The Company strives to continuously review and improve the personal information protection management system (compliance program) to always maintain it in the best condition.

Handling of Personal Information

  1. Proper Handling of Personal Information

    • The Company, in providing our shared mobility services (hereinafter referred to as “the Service”), will acquire information treated as personal information through lawful and fair means and will take necessary and appropriate measures for its safe management to prevent leakage, loss, or damage.

  2. Purpose of Use of Personal Information

    • In providing the Service, the Company will handle the personal information listed below, within the necessary scope to achieve the following purpose of use. Even after the contract for the service with the customer has ended, the Company may use personal information within the scope of the above-mentioned purpose.

Purpose of Using Personal Information

  1. For providing and maintaining the Service, providing after-sales service, calculating and billing usage fees, and other related business operations.
    Personal Information Used
    Personal information listed in the below section (2) items ① to ⑥.
No.Purpose of Use of Personal InformationPersonal Information Used From Below
1.For the provision and maintenance of services, after-sales service, calculation and billing of usage fees, and other related business implementations.(2) ①~⑥
2.For guiding products, services, campaigns, events, etc. (including advertising) of our company and partnering businesses (including third-party information providers and joint users), and for shipping products and prizes associated with services and campaigns.(2) ①②④
3.To respond to opinions, requests, inquiries, etc.(2) ①~⑥
4.For analysis of usage situations, implementation of measures to improve customer satisfaction, collection and analysis of information for product and service planning, collection and analysis of information for improving service quality, research (including research on this service, new services, and services provided by third parties conducting joint research with us), and other various analysis and surveys.(2) ①~⑥
5.For the prevention of fraudulent contracts, misuse, non-payment, and for investigation and response when they occur.(2) ①~⑥

(2) Our company uses the following personal information for the purposes described in (1):

ItemDetails
1. Information such as Name, Address, and Date of BirthName / Address / Date of Birth / Phone Number / Email Address / Information listed in ID documents like driver’s licenses and passports / App User ID, etc.
2. Contract details, usage fees, etc.Contract type / Contract signing date and other contract-related information / Invoice amounts, payment status, and other information related to usage fees, etc.
3. Payment method detailsPayment method / Credit card number / IC card information, etc.
4. Information related to the services applied forUsage history of each service / Information related to questionnaire surveys, monitor surveys, etc.
5. OthersApplication reception history, opinions, requests, inquiry contents, etc., and other information acquired in conjunction with various services
6. Location InformationLocation information obtained from a GPS installed on a bicycle, information on the route taken by the used bicycle, etc.

(3) When our company carries out tasks entrusted by other business operators, we will handle personal information within the scope necessary for the execution of said tasks.

(4) Our company, with utmost consideration for the rights and interests of individuals, may handle personal information for purposes other than the original intended purpose in the following cases: ① When based on laws and regulations. ② When necessary to protect the life, body, or property of a person and obtaining the individual’s consent is difficult. ③ When it is particularly necessary to promote public health or wholesome child development and obtaining the individual’s consent is difficult. ④ When there’s a need to cooperate with a national institution, local public body, or its delegated parties in carrying out tasks stipulated by laws and regulations, and obtaining individual consent might obstruct the execution of such tasks.

(5) Our company may provide the following information for services related to compensation for accidents that occurred during service provision: ① Personal information provided to third parties: Personal information mentioned in (2) ①, ②, ④, ⑤, ⑥. ② Destination of third-party provision: Insurance companies designated/contracted by our company. ③ Purpose of third-party provision: To offer various compensation services for accidents that occur during service provision.

(6) Our company may provide the personal information (including information used) of service users listed in (2) ①-⑥ in the following cases: ① To cooperate with a national institution, local public body, or its delegated parties in executing tasks stipulated by laws (including the execution of joint projects with national or local bodies or delegated tasks from them). ② When providing to universities and research institutions for collaborative research. ➂ To consider recurrence prevention and other safety measures related to accidents occurring during service use, and to provide to insurance companies, external research institutions, and other third parties involved in safety measures. ④ To provide within the necessary scope when reporting the business status to business stakeholders (including port owners and managers) and company shareholders and other fund providers.

-5 When our company collaborates with third parties for marketing and business development, we may provide information to the partnering entity for joint marketing and business development efforts (including provisions aimed at delivering advertisements for products/services provided by partners).

(7) Regardless of the provisions in (1) to (6), our company, with utmost consideration for the rights and interests of individuals, may provide personal information to third parties in the following cases:
① When consent is obtained from the individual.
② When based on laws and regulations.
③ When necessary to protect a person’s life, body, or property and obtaining consent is difficult.
④ When particularly necessary for promoting public health or wholesome child development and obtaining consent is difficult.
⑤ When there’s a need to cooperate with a national institution, local public body, or its delegates in executing tasks as stipulated by laws, and obtaining individual consent might obstruct the execution of such tasks.
⑥In cases of mergers, company splits, business transfers, or other reasons leading to business succession including personal information.
⑦When our company entrusts all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
⑧In other cases where providing personal information to third parties is permitted by law.

  1. Shared Use
    (1) Personal information subject to shared use: The personal information mentioned in 2.(2) ①-⑥ (2) Range of users sharing the information: Affiliated business partners providing the sharing service (https://www.clewbike.com) (3) Entity responsible for the management of the aforementioned personal information: Clew, Inc. (https://www.clewbike.com)

  2. Disclosure and Correction of Personal Information
    (1) For inquiries regarding contract status for each service and corrections related to personal information, please contact the administrative office of the respective service. Please note that we will verify the identity of the individual or the authorized agent (either a legal representative or an agent appointed by the individual) making the inquiry.
    (2) Upon request for disclosure of personal information from the individual (or their agent), our administrative office will respond promptly. (3) If there’s a request from the individual (or their agent) for corrections (including edits, additions, deletions, cessation of use, or stopping provision to a third party) of their personal information, we will investigate without delay. If the information is found to be inaccurate or the handling of the information is deemed inappropriate, we will make the necessary corrections promptly. However, based on legal provisions, there are cases where we may not perform corrections, even upon request.
    (4) If there’s a request from the individual (or their agent) for corrections of their personal information, our administrative office will respond promptly.

  3. Collection and Use of Access Logs For the purpose of providing better service, we use Google Analytics to collect access data to our website. As a result, some pages use cookies provided by Google Analytics. This information is not linked with the personal information specified in (2). The data collected via our site by Google Analytics is managed under Google’s privacy policy, and we are not responsible for any damages arising from the use of Google Analytics. For details on Google Analytics terms of service and Google’s privacy policy, please visit the provided links. If you don’t wish your data to be used by Google Analytics, please use the Google Analytics Opt-out Add-on.

  1. Consultation on Personal Information Handling If you have opinions or requests regarding our handling of personal information, please contact the following: Clew, Inc. Personal Information Inquiry Desk Email Address: support@clew.jp

Clew, Inc. CEO: Osamu Nishimoto Address: 〒600-8413 Kyoto City, Shimogyo-ku, Karasuma Dori Bukkoji Sagaru, Omasa Cho 680-1