Privacy Policy (Handling of Personal Information)
Established: September 18, 2026 | Last revised: September 18, 2026 | Effective date: September 18, 2026
Notice of Revision to Our Privacy Policy
Posted: September 17, 2026 | Effective: September 18, 2026
Thank you for using Buzzencer.
We will revise our Privacy Policy (Handling of Personal Information) as set out below. In connection with this revision, the provisions on the handling of personal information that were previously set out separately for advertisers and agencies will be consolidated into this Policy.
Principal Changes
(1) Addition to the purposes of use of technical data and usage data
"Advertising delivery" will be added to the purposes of use for technical data and usage data, including IP addresses, device information, cookies, and usage of the Services (revised Articles 3(4) and 14).
(2) New transitional measures
The practice described in (1) above applies only to information newly collected by us on or after the effective date. Information collected before the effective date will not be used for advertising delivery purposes (revised Article 18).
If it becomes necessary in the future to use information collected before the effective date for advertising delivery purposes, we will provide individual notice to you in advance and obtain your consent pursuant to Article 18, Paragraph 1 of the Act on the Protection of Personal Information of Japan.
Effective Date
September 18, 2026
On the same date, the currently posted Privacy Policy will be replaced with the revised version.
Revised Privacy Policy
The full text of the revised Policy will be available at the following URL on and after the effective date.
https://buzzencer.com/en/privacy
Contact
For questions regarding this revision, or to request suspension of use or deletion of your personal information, please contact us at support@buzzencer.com.
Twomi PTE LTD
Twomi PTE LTD ("we," "us," or "the Company") handles personal information processed through the mobile application and web service "Buzzencer" (the "Buzzencer App"), its related websites (including guild.buzzencer.com and buzzstudio.buzzencer.com), and other services operated under the "Buzzencer" brand (collectively, the "Services") in compliance with the Act on the Protection of Personal Information of Japan (the "APPI") and other applicable laws and regulations, and manages such information appropriately as set forth below.
This Policy applies to all persons who use the Services, including general members, content viewers, creators, affiliate members, guild members, guild leaders, advertisers, agencies, business partners, and job applicants.
Article 1. Name of the Business Operator
Twomi PTE LTD
Address: 1 North Bridge Road #24-02, High Street Centre, Singapore 179094
Article 2. Personal Information Protection Manager
Name / Title: Personal Information Protection Manager, Amon Iguchi (Director)
Affiliation: Twomi PTE LTD
Contact for complaints and inquiries regarding personal information: support@buzzencer.com
Article 3. Purposes of Use of Personal Information
We handle personal information within the scope of the purposes of use defined for each category below.
(1) Purposes of Use for Information Collected Directly from the Individual
① General Member and Content User Information (online salon members, Buzzstudio users, etc.)
Category: General member and content user information
Purposes of use: Account registration, identity verification, and account management; provision of online salon features and members-only content; subscription management and payment processing; provision of community features with creators (comments, messages, live streaming, etc.); content recommendation and personalization; delivery of notices and email newsletters; provision of information on new features, campaigns, and similar matters
Category: Creator content information
Purposes of use: Distribution and management of content such as posts, videos, and articles; management of content publication settings and membership plans; calculation and payment processing of creator revenue
Category: Payment and subscription information
Purposes of use: Management of subscription plans; transaction processing and issuance of receipts; handling of refunds and cancellations; preparation and retention of related books and records
② Affiliate Member Information (including registered members, partners, guild members, guild leaders, and holders of various roles)
Category: Affiliate member information
Purposes of use: Operation of the affiliate service "Buzzencer"; member registration, identity verification, and account management; issuance of promotional links and conversion tracking; provision of content for social media (images, text, videos, etc.); calculation and payment of rewards according to member rank and role; guild operation and member support; delivery of notices and email newsletters; provision of information on new features, campaigns, seminars, and similar matters; verification work for accounting audits
Category: Information relating to invitations and referrals
Purposes of use: Management of invitation and referral relationships; evaluation of contribution according to member rank and role; calculation of reward allocation; prevention of fraud and violations of terms
Category: Fan club, LP member, and viewer information
Purposes of use: Provision of fan club features and members-only content; support for creation and operation of landing pages (LPs); member management; communications and notifications
Category: Information relating to payment of rewards (financial institution account information, etc.)
Purposes of use: Processing of reward payments; confirmation and communication relating to payments; preparation and retention of related books and records
Category: Inquiry information
Purposes of use: Handling of inquiries and support operations
③ Business Partner Information (advertisers, agencies, affiliates, subcontractors, etc.)
Category: Business partner information
Purposes of use: Transaction screening; ordering and receiving orders; invoicing and payment; business communications; introduction of new services and campaigns by email and direct mail; conducting surveys; verification work for accounting audits
④ Other
Category: Job applicant information
Purposes of use: Recruitment activities (document screening, interviews, evaluation, communications with applicants, etc.)
Category: Employee information
Purposes of use: Management of human resources and labor affairs, social insurance, employee benefits, etc.
(2) Purposes of Use for Information Collected Directly from the Individual by Means Other than in Writing
Category: Call and chat records from member and inquiry support
Purposes of use: Confirmation of content; improvement of support quality; identity verification
Category: Entry/exit records and recorded video and audio information (where applicable)
Purposes of use: Security management of our facilities for crime and disaster prevention
(3) Purposes of Use for Information Collected Indirectly from Public Sources or Third Parties
Category: Personal information provided by affiliates or outsourcing clients
Purposes of use: Provision of services under partnership or contracting agreements; communications; conversion tracking and settlement
Category: Information regarding invitees provided by inviters
Purposes of use: Management of invitation and referral relationships; calculation of reward allocation
Category: Social media and third-party account data
Purposes of use: Login authentication via third-party platforms (Google, Apple, etc.); account linkage
(4) Technical Data and Usage Data (Automatically Collected)
We automatically collect the following data in connection with your use of the Services:
- IP address, device ID and model, OS type and version, application version
- Performance logs, crash data, advertising ID
- Cookies and device identification numbers (see Article 12 for details)
- Usage of the Services (login date and time, content viewed, actions performed, referral source, etc.)
We use this data for purposes including stable operation of the Services, quality improvement, personalization, security monitoring, and advertising delivery.
However, use for the purpose of advertising delivery (including the selection, optimization, and delivery of advertisements and any profiling associated therewith; the same applies hereinafter) is carried out only with respect to technical data and usage data newly collected by us on or after the effective date of this Policy. We do not use data collected before the effective date for the purpose of advertising delivery (see Article 18).
Article 4. Legal Bases for Processing Personal Information (for International Users)
In accordance with the applicable laws of the jurisdiction in which the user resides, we process personal information on one or more of the following legal bases:
- The valid and explicit consent of the user
- Performance of a contract with the user (provision of services, payment processing, etc.)
- Our legitimate interests (fraud prevention, security, service improvement, marketing, etc.)
- Compliance with applicable laws and regulations
Article 5. Restrictions on the Use of Personal Information
We will not handle personal information beyond the scope necessary to achieve the purposes of use without obtaining the prior consent of the individual. However, this does not apply in the following cases:
(1) Where required by laws and regulations
(2) Where necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual
(3) Where specially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the individual
(4) Where it is necessary to cooperate with a national government organ, a local government, or a party entrusted by either of them in performing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the performance of such affairs
Article 6. Proper Acquisition and Use of Personal Information
We acquire and use personal information properly, and will not acquire it by deception or other wrongful means.
Article 7. Security Control Measures
We take necessary and appropriate measures for the security control of personal data, including the prevention of leakage, loss, or damage, and exercise necessary and appropriate supervision over employees and subcontractors who handle personal data.
(1) Establishment of a Basic Policy
To ensure the proper handling of personal data, we have established a basic policy covering matters such as "compliance with relevant laws, regulations, and guidelines" and "contact points for questions and complaint handling."
(2) Development of Rules Governing the Handling of Personal Data
We have established handling regulations covering handling methods, responsible persons and personnel, and their duties at each stage of acquisition, use, storage, provision, and deletion/disposal, and have organized basic handling procedures.
(3) Organizational Security Control Measures
We have appointed a person responsible for the handling of personal data, clarified the scope of employees and data handled, and established a reporting and communication system for cases where a violation or sign of a violation of laws or regulations is identified. We conduct regular self-inspections of handling status, as well as audits by other departments or external parties.
(4) Human Security Control Measures
We provide regular training to employees on matters to be observed in handling personal data, and include confidentiality obligations in our work rules.
(5) Physical Security Control Measures
We implement measures including access control for areas where personal data is handled, restrictions on bringing in equipment, prevention of viewing by unauthorized persons, prevention of theft or loss of equipment, electronic media, and documents, and prevention of leakage during transport.
(6) Technical Security Control Measures
We limit the scope of personnel and data handled through access controls, and have implemented mechanisms to protect information systems and equipment handling personal data from unauthorized external access and malicious software.
(7) Understanding of the External Environment (Data Storage Location)
Personal data is stored in the AWS Asia Pacific (Tokyo) Region (ap-northeast-1) as storage dedicated to Buzzencer. We implement security control measures with an understanding of the personal information protection regime of that jurisdiction.
Article 8. Provision to and Entrustment with Third Parties
We may provide or entrust personal information to third parties other than us only in the following cases:
(1) Where necessary for our subcontractors to provide specific services such as system operation, conversion tracking, reward payment, or support
(2) Where statistical data is disclosed for the purpose of providing statistical information, after being processed into a form in which individuals cannot be identified or specified
(3) Where disclosure is lawfully requested by laws and regulations, a court, or another governmental authority
(4) Where consent has been obtained from the customer for a specific purpose
Principal subcontractors
- Everflow: Affiliate conversion tracking system
- Payment processors such as Shopify and PayPal: Payment processing (we do not retain full card numbers; we manage tokens only)
- OneTrust: Cookie consent management system
When we outsource all or part of our operations, we carefully select subcontractors on the condition that they maintain a management structure capable of properly protecting personal information, conclude confidentiality agreements with them, and strictly manage our customers' personal information.
Article 9. Retention Periods for Personal Information
We retain personal information within the scope necessary to achieve the purposes of use. The principal retention periods following account deletion are as follows:
- All personal information (for legal claims and regulatory compliance): 6 months from the date of account closure
- Customer support communications and records: 2 years from the date of the relevant communication
- Payment and transaction records (under tax and accounting laws): 7 years from the transaction date
- Information related to suspected violations of laws or terms: 5 years from the date of account closure
Upon expiry of the retention period, personal information is deleted or restricted from further use. Where possible, it may be anonymized or aggregated and used for service improvement.
Article 10. Disclosure and Related Requests
"Retained personal data" means personal information with respect to which we have the authority to respond to all requests from the individual for notification of the purpose of use, disclosure, correction, addition or deletion of content, suspension of use or erasure, suspension of provision to third parties, and disclosure of records of provision to third parties. For requests of this nature, please contact the inquiry desk at the end of this page.
(1) Notification of the Purpose of Use and Disclosure
When an individual requests notification of the purpose of use or disclosure of retained personal data, we will notify or disclose it without delay. If no personal information identifying the individual exists, we will inform the individual accordingly. However, we may be unable to notify or disclose in any of the following cases:
- a) Where doing so is likely to harm the life, body, property, or other rights or interests of the individual or a third party
- b) Where doing so is likely to significantly impede the proper execution of our business
- c) Where doing so would violate laws or regulations
(2) Correction, Addition, or Deletion
If, as a result of disclosure, correction, addition, or deletion is requested on the grounds that the content is not factual, we will conduct the necessary investigation without delay, make corrections based on the results, and notify the individual of the outcome without delay.
(3) Right to Refuse Use or Provision
If suspension of use, erasure, or suspension of provision to third parties is requested on grounds such as handling beyond the scope of the purpose of use, wrongful acquisition, provision to third parties without consent, cessation of the need for use, occurrence of a significant leak, or the likelihood of harm to the rights or interests of the individual, we will conduct the necessary investigation without delay, take necessary measures based on the results, and notify the individual without delay after taking such measures. However, we may be unable to comply where any of items a) through c) of the proviso to paragraph (1) applies, in which case we will notify the individual without delay and endeavor to explain the reason.
Article 11. Voluntary Nature of Providing Personal Information
Whether you provide personal information to us is entirely voluntary. However, if necessary items are not provided, we may be unable to provide the relevant services in a proper condition.
Article 12. Cookies and Other Automatic Collection Tools
Our Services may use the following tools to collect cookies and device identification numbers. These are intended to improve convenience when you revisit our site or app and to measure affiliate conversions (determining conversions via promotional links), and do not infringe your privacy or adversely affect your computer.
Google Analytics (GA)
Purpose: Website access analysis and understanding of usage
Opt-out: Available at https://tools.google.com/dlpage/gaoptout
Everflow
Purpose: Affiliate conversion tracking
Opt-out: Please contact our support desk (support@buzzencer.com)
OneTrust
Purpose: Cookie consent management (managing consent to and refusal of cookie use)
Opt-out: Available via the cookie settings banner on the site
Our Services use data encryption such as SSL (Secure Sockets Layer) in areas where personal information is entered, and we strive to ensure security. However, due to the nature of internet communications, security cannot be completely guaranteed. We ask for your understanding in this regard.
Article 13. Rights of International Users
Depending on the jurisdiction in which the user resides, the following rights may apply.
(1) General Data Subject Rights
To the extent permitted by applicable laws and regulations, we recognize and respect the following rights:
- The right to be informed about the purposes of use and handling status of personal information
- The right to request access to one's own personal information
- The right to request correction of inaccurate or incomplete data
- The right to request deletion of data, including after the purpose of use has been achieved (the right to be forgotten)
- The right to data portability (provision in a structured data format)
- The right to restriction of, or objection to, processing
- The right to object to automated decision-making and profiling
- The right to withdraw consent (where processing is based on consent)
- The right to lodge a complaint with the competent authority
(2) Japan (Act on the Protection of Personal Information: APPI)
In accordance with the APPI, upon request from a user in Japan, we will cease providing to third parties personal information that could be used to identify the user.
(3) Brazil (LGPD)
Users in Brazil have the rights to confirmation of processing, access, correction, deletion, portability, disclosure of shared information, and withdrawal of consent under Article 18 of the LGPD. They also have the right to lodge a complaint with the Brazilian National Data Protection Authority (ANPD).
(4) Vietnam (Decree No. 13/2023/ND-CP)
Users in Vietnam have the rights to be informed, to consent to processing, and to access, correct, delete, restrict processing, and object.
To exercise these rights, please contact the desk below.
Contact for complaints and inquiries regarding personal information: support@buzzencer.com
Following verification of identity, we will respond to requests in accordance with the periods and conditions prescribed by applicable laws and regulations.
Article 14. Automated Processing
We may use automated processing, including profiling, to support certain features of the Services, such as personalization of content (recommendation of creators and content, etc.), conversion tracking, performance analysis, security monitoring, and the provision of relevant advertising. Where automated processing is used, we implement appropriate safeguards to protect the relevant rights and interests of users.
Of these, the provision of relevant advertising (including profiling for the purpose of advertising delivery) is carried out only with respect to information newly collected by us on or after the effective date of this Policy. We do not conduct profiling for advertising delivery purposes using information collected before the effective date (see Article 18).
Article 15. No Sale of Personal Information
We do not sell or share personal information as those terms are defined under applicable U.S. state privacy laws, including the California Consumer Privacy Act (CCPA), for monetary consideration or for the purpose of cross-context behavioral advertising.
Article 16. Children's Privacy
The Services are intended only for individuals aged 13 and over. We do not knowingly collect, use, or process personal information from children under 13. If a child under 13 has provided personal information, their legal guardian should contact support@buzzencer.com. We will promptly delete such data.
Article 17. Changes to This Policy
We may update this Policy from time to time. In the event of a material change, we will notify users through a notice on the Services or by email or other means before the change takes effect.
Article 18. Transitional Measures (Handling in Connection with This Revision)
This Article governs the handling of personal information collected by us before the effective date of this Policy ("Previously Collected Information").
(1) Non-application of Advertising Delivery Purposes
We do not use Previously Collected Information for the purpose of advertising delivery (including the selection, optimization, and delivery of advertisements and any profiling associated therewith). The handling for advertising delivery purposes set forth in Article 3(4) and Article 14 applies only to information newly collected by us on or after the effective date.
(2) Future Changes in Handling
If it becomes necessary for us to use Previously Collected Information for advertising delivery purposes, we will provide individual notice to the relevant individuals in advance and obtain their consent pursuant to Article 18, Paragraph 1 of the APPI. Where such consent is not given, Previously Collected Information will not be used for advertising delivery purposes.
(3) Announcement of This Revision
We will announce the content of this revision and its effective date by posting it on the Services before the effective date. We may also send a notice to your registered email address.
Contact
Twomi PTE LTD
1 North Bridge Road #24-02, High Street Centre, Singapore 179094
Contact for complaints and inquiries regarding personal information: support@buzzencer.com
In the event of any inconsistency between the Japanese and English versions of this Policy, the Japanese version shall prevail.