Privacy policy

BASE FOOD, Inc., a stock company incorporated under the laws of Japan with its head office located in Japan (hereinafter referred to as the “Company”), has established the following privacy policy with respect to the handling of user information, including personal information of purchasers of products and services (hereinafter collectively referred to as “Products”) and users of services (hereinafter collectively referred to as “Users”) provided by the Company through its website (URL: [https://basefood.hk/] and [https://shop.basefood.hk/]);hereinafter referred to as the “Policy”).

Article 1 Compliance with Laws and Regulations

The Company recognizes the importance of protecting personal information, and shall comply with the Personal Data Protection Law of Japan (hereinafter referred to as the “Personal Data Protection Law”), the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (hereinafter referred to as the “Ordinance”), and the guidelines issued by the relevant regulatory authorities, and other relevant laws and regulations.


Article 2 User Information to be Collected and Method of Collection

  1. User Information

In this Policy, “User Information” means User’s information provided to the Company or collected by the Company at the time of purchase of Products through the Website, at the time of application, or  browsing or visiting the Website by the User, information pertaining to User’s identification, credit card information, history of activities on communication services, and information on e-mails that the User sends and receives from the Company in connection with the User’s use of the Website, and other information generated from or recorded on the User’s smartphone, computer and other terminals (hereinafter referred to as “Terminals”), in relation to the User or User’s Terminals, etc., and which are collected by the Company in accordance with this Policy.

  1. Collection Method

The Company collects User Information in the following manners:

  1. by receiving User Information directly from the User;
  2. by having the User directly enter and register User Information when using, browsing, or visiting the Website;
  3. methods in which User Information is collected when a User uses, browses, or visits the Website;
  4. by receiving User Information indirectly from third parties; and
  5. methods of obtaining User Information published in publications, on the Internet, etc.

In addition, the Company may collect information relating to individuals that does not constitute Personal Information by itself, such as attribute information (e.g., age, gender, occupation, residential area, etc.), telephone numbers, cookie information, access logs, IP addresses, advertising identifiers (AAID/IDFA), and information relating to individuals such as, location information, action history, and those logs relating to Internet usage (hereinafter collectively referred to as “Informative Data”) from Users or third parties (including, but not limited to, public DMP providers and affiliate service providers). If the User provide us with Personal Information when using the Company’s Products, the Company may link such information with the User’s Informative Data, in which case such Informative Data will also be treated as Personal Information.


Article 3 Secure Management of Information

  1. The Company will keep the User Information accurate and up-to-date within the scope of the purposes of use specified by the Company in accordance with Articles 4 and 5 (hereinafter referred to as "Purposes of Use"), and will take necessary security control measures such as maintenance of security systems, development of management systems and thorough employee training to prevent illegal access, loss, damage, alteration or leakage of User Information, and will strictly control User Information. 
  2. In the event that the Company outsources all or part of the handling of Personal Information, the Company shall exercise necessary and appropriate supervision to ensure the security management of personal information at the outsourced company.


Article 4 Purpose of Use

The Company will use the User Information for the following purposes:

  1. to provide, maintain, protect, and improve the Products;
  2. to provide information concerning the Products and to respond to inquiries, etc.;
  3. to respond to any violation of contracts, the Terms of Use, or this Policy regarding the Products;
  4. to notify the User of changes to the Terms of use, this Policy, etc., regarding the Products, etc.;
  5. to conduct sales and marketing activities by mail, telephone, e-mail, SMS, etc., in order to provide information that may be useful to Users, such as information related to the Products, functional improvements, etc.;
  6. to conduct surveys through questionnaires and monitor such surveys (including direct contact with respondents to capture the effects of such surveys and monitor surveys), in other requests for cooperation and participation in various events, and to report the results of such events, etc.;
  7. for the Purposes of Use that have been publicly announced and agreed to by the User, when providing the Products, etc.;
  8. to deliver targeted advertisements and other advertisements using the User's browsing history across the Company’s Website, monitor the User’s behavior online, including purchase history, input information, etc. (including cases in which advertisements are delivered by third party service providers such as contractors, business partners of the Company).

*  The Company may propose various services, provide information, and distribute advertisements to Users on such services, by identifying users of advertising-related business operator who use services provided by such advertising-related business operator among the customers of the Services, by linking user data held by Facebook, twitter, and other advertising-related business operator with e-mail addresses, telephone numbers, and other contact information held by the Company;

  1. to analyze attribute information, action history, Informative Data, etc. obtained by the Company to understand customer preferences, customer satisfaction, etc. with regard to the Company's Products.

*   In cases where the Company outsources analysis work to advertising-related business operator, the Company will add log information related to Internet usage, such as user attribute information, location information, and action history held by the relevant advertising-related business operator to the Personal Information held by the Company, and the Company may receive the results of analysis based on the aggregation of such information in the form that any specific individual may not be identified by that information alone;

  1. to exercise rights or perform obligations based on contracts or laws;
  2. to provide after-sales service and respond to various inquiries; and
  3. for other purposes of use incidental to the purposes of use listed above.

Article 5 Change of Purpose of Use

The Company may change the Purposes of Use of User Information set forth in Article 4 to the extent reasonably deemed to be relevant, and will notify the User or make a public announcement in the event of such change.


Article 6 Definition of Personal Information

In this Policy, among User Information, Personal Information shall mean “personal information” as defined in Article 2, Paragraph 1 of the Personal Information Protection Law or “Personal Data” as defined in Article 2 of this Ordinance.

*  “Personal Information” as defined in Article 2, Paragraph 1 of the Personal Information Protection Law means:

information about a living individual that falls under any of the following items:

  1. information that can identify a specific individual by name, date of birth, or other description, etc., contained in the information (including information that can be easily cross-checked with other information and thereby identify a specific individual),
  2. information that contains personal identification codes.

*  “Personal Data” as defined in Article 2 of this Ordinance means any data:

  1. relating directly or indirectly to a living individual;
  2. from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
  3. in a form in which access to or processing of the data is practicable.

Article 7 Restrictions on Use of Personal Information

Except as permitted by the Personal Information Protection Law, this Ordinance, and other related laws and regulations, the Company will not handle Personal Information beyond the scope necessary to achieve the Purposes of Use without the consent of the User. However, this does not apply in the following cases:

  1. when required by law;
  2. when it is necessary for the protection of human life, human health, or property, and it is difficult to obtain the User's consent;
  3. when it is especially necessary to improve public health or to promote the sound growth of children, and it is difficult to obtain the User's consent;
  4. when it is necessary to cooperate with a government or local public body in any jurisdiction or a person or entity entrusted by such government or local public body to execute affairs prescribed by law, and obtaining the User’s consent is likely to impede the execution of such affairs; and
  5. when the Company discloses Personal Information to a person who is obligated to maintain confidentiality, such as a lawyer, etc., and when the Company deems it necessary to do so for the provision of the Products, etc.

Article 8 Provision of Personal Information to Third Parties, Direct Marketing and Extraterritorial Transfer

  1. The Company will provide Personal Information to the following parties in writing or by electromagnetic means in accordance with each item below. The Personal Information provided may include Informative Data.

■ Provision to third parties involved in the Company's advertising distribution operations.

(ⅰ) Purpose of provision.

To determine what kind of advertisements, information, services, etc. are most effective for Users, or to deliver targeted advertisements, etc.

(ⅱ) Recipient.

Third parties who involves in the Company's advertising distribution operations

Provided, however, that if the User does not wish for the Company to use the User’s Personal Information for the purpose of delivering advertisements in accordance with this Article, the User may notify the Policy Administrator as set forth in Article 13. Upon receipt of such notice from the User, the Company will stop using the User’s Personal Information for the purpose of delivering advertisements in accordance with this Article without charging the User any fees.

  1. Except as provided in the preceding paragraph or when disclosure is permitted under the Personal Information Protection Law, this Ordinance, or other laws and regulations, the Company will not provide Personal Information to any third party without obtaining the prior consent of the User. However, this shall not apply in the following cases:
  1. when the Company entrusts all or part of the handling of Personal Information to a third party within the scope necessary to achieve the Purposes of Use. When it becomes necessary to provide Personal Information to a subcontractor, the information will be provided only after appropriate supervision of the subcontractor with respect to information management;
  2. when Personal Information is provided as a result of succession of business due to merger or other reasons; 
  3. when it is necessary to cooperate with government or local public body of any jurisdiction, or a person or entity entrusted by either of them, in the execution of their legally mandated duties, and obtaining the User’s consent may impede the execution of such duties;
  4. when disclosing Personal Information to third parties to whom the Company outsources such research and analysis work to the extent permitted by law, for the purpose of research and analysis of the usage of services operated by the Company; and
  5. other cases permitted by the Personal Information Protection Law, this Ordinance, or other laws and regulations.
  1. The Company may transfer Personal Information outside of Japan or Hong Kong as necessary to carry out the purposes for which the personal data was collected or for purposes directly related thereto. Provided, however, that all such transfers of Personal Information will be made in compliance with the requirements of the Personal Data Protection Law, this Ordinance, and other laws and regulations.


Article 9 Disclosure of Personal Information

When a User requests disclosure of Personal Information in accordance with the Personal Information Protection Law, this Ordinance, or other laws and regulations, the Company will disclose the information to the User without delay after confirming that the request is made by the User himself/herself (if the Personal Information does not exist or is not otherwise disclosed, the Company will notify the User to that effect). However, this shall not apply in cases where the Company are not obligated to disclose such information under the Personal Information Protection Law, this Ordinance, or other laws and regulations.


Article 10 Correction, Suspension of Use, Suspension of Provision to Third Parties, etc. of Personal Information

  1. In the event that the Company is required by the Personal Information Protection Law, this Ordinance, or any other law or regulation to (1) correct, add to, or delete (hereinafter referred to as "Correct") any Personal Information due to its untruthfulness, or (2) to suspend the provision of Personal Information to any third party, or delete any Personal Information (hereinafter referred to as "Suspend the Use") because the Personal Information is used for purposes other than those previously disclosed or because the Personal Information was collected through deception or other wrongful means; or (3) to suspend the provision to third parties because it has been provided to third parties in violation of the Act or Article 8 herein, the Company will conduct necessary investigation without delay upon confirmation that the request is from the User. Based on the results of the investigation, the Company will decide whether to Correct the content of the Personal Information, Suspend the Use of it, or stop providing it to third parties, and notify the User to that effect. If, based on reasonable grounds, the Company decides not to Correct, Suspend the Use, or discontinue the provision of Personal Information to third parties, the Company will notify the User to that effect. However, this shall not apply in cases where the Company is under no obligation to Correct, Suspend the Use, or suspend provision to third parties under the Personal Information Protection Law, this Ordinance, or other laws and regulations.
  2. If the Company is requested by a User to notify the purpose of use of his/her Personal Information in accordance with the Personal Information Protection Law, this Ordinance, or other laws and regulations, the Company will notify the User of the purpose of use of the Personal Information after confirming that the request is made by the User himself/herself. If the Company decides not to notify the User of the purpose of use based on reasonable grounds, the Company will notify the User to that effect. However, this shall not apply in cases where the Company are not obligated to notify the User of the purpose of use under the Personal Information Protection Law, this Ordinance, or other laws and regulations.


Article 11 After Termination of Handling of Products, etc.

Even if the handling of Products is terminated, etc., the Company may continue to store and use various types of information obtained by the Company only to the extent necessary for the Purposes of Use.


Article 12 Use of Cookies and Other Technologies

Cookies and similar technologies may be used in the Products. If the User wishes to disable cookies, the User may do so by changing the settings on the User’s web browser. However, if the User disables cookies, the User may not be able to use some of the features of the Company’s Products.


Article 13 Contact for Inquiries

For requests for notification of the Purposes of Use of Personal Information, disclosure, correction , suspensionof use, suspension of provision to third parties, opinions, questions, complaints, and other inquiries regarding the handling of the User information, please contact the following person by e-mail. (hereinafter referred to as the “Policy Administrator”) by e-mail.

Privacy Policy Administration Section, BASE FOOD, Inc.

5-25-2, Nakameguro, Meguro-ku,Tokyo, 1530061, JAPAN

e-mail address : contact_hk@basefood.co.jp

Please note that it may take 1-2 weeks to reply to the User’s inquiry.


Article 14 Procedures for Change of this Privacy Policy

  1. The Company will review the operation of the handling of the User information from time to time and strive for continuous improvement, and may change this Policy as necessary at its own discretion.
  2. In the event of any changes, the Company will notify the User by e-mail or by posting the changes on the website where the Products are handled.  Changes to this Policy will become effective when they are posted on the website of the Products. Users who purchase or use the Products after the changes take effect will be deemed to have agreed to the changes in this Policy.
  3. Notwithstanding the provisions of the preceding two paragraphs, in the event of a change in the content of this Policy that requires the consent of the User as required by law, the User's consent shall be obtained in a manner prescribed by the Company.

Article 15 Language

This Policy is prepared in English and Chinese (Traditional Chinese). The English and Chinese (Traditional Chinese) versions shall have equal force and effect, but if there is any discrepancy between the two language versions, the English version shall prevail.



Enacted on 25th July, 2023