Privacy policy

This Privacy Policy (hereinafter referred to as the “Policy”) sets forth how FlatoX Inc. (hereinafter, the “Company”) collects, uses, and manages users’ personal information in connection with the provision of the “Wabble” service (hereinafter, the “Service”).

1. Accountability for Personal Information

The Company will manage and protect users’ personal information handled through the Service in an appropriate manner and in compliance with applicable laws and regulations.

2. Information We Collect

In providing the Service “Wabble,” the Company may collect the following types of information:

• 1. Name (including nickname)
• 2. Email address
• 3. Telephone number
• 4. Date of birth
• 5. Photos and videos posted by the user
• 6. Identifiers generated by cookies
• 7. Device information (OS, device type, device ID, etc.)

• 8. Activity history when using the Service

  • – Launch times, tap/swipe operations, posting/browsing history, actions of removing stickers, etc.

• 9. Contact information (when a user invites friends via the phonebook integration feature)

  • – Telephone numbers, email addresses, names as registered on the device, etc.
  • – By providing such information, the user is deemed to have obtained any necessary consent regarding any third-party personal information included in the contact list.
• 10. Location information when necessary (only if the user has granted permission)
• 11. Other information specified separately by the Company at the time of collection

3. Purposes of Use

The Company uses collected personal information for the following purposes:

• 1. To register and authenticate users for the Service
• 2. To manage user accounts and record/analyze usage history

• 3. To share or display on social networks the photos, videos, etc. posted by users

  • – Posted content is shared or made public to other users depending on the visibility settings configured by the user
• 4. To analyze how the app is used and user behavior, in order to improve and enhance the functionality, quality, and convenience of the Service

• 5. To analyze user behavior (e.g., actions such as removing stickers) and provide features that estimate relationships between users (such as “best friends ranking”)

  • – The scope and details of such ranking features will be announced to users according to the implementation status
• 6. To analyze app usage and user behavior in order to provide personalized content and advertising
• 7. For advertisement delivery, measurement of advertising effectiveness, and targeted advertising

• 8. To offer friend-invitation features using a user’s device contact list

  • – The Company will use only the necessary information for such invitations and will manage the information to avoid unnecessary retention

• 9. To conduct joint promotions and announcements with partner companies (only if the user agrees)

• 10. To respond to user inquiries, to address trouble or wrongdoing, etc.
• 11. To investigate and respond to conduct that violates the Company’s terms or applicable laws and regulations
• 12. To notify users of changes to the Service, discontinuation or termination of the Service, termination of agreements, etc.
• 13. For other activities related to or ancillary to the above purposes

4. Retention Period of Personal Information

The Company retains personal information only for the period necessary to fulfill the intended purposes. Once that period ends or the purposes have been achieved, the Company will promptly dispose of or delete the information by a secure method, unless otherwise required by law.

5. Provision to Third Parties and Joint Use

The Company does not provide personal data to third parties (including parties outside Japan) without the user’s consent, except in the following cases:

• 1. When entrusting the handling of personal information to service providers

  • – For example, server operations, payment processing, log analysis, implementing contact-list-based invitation features, etc.
  • – The Company will enter into confidentiality agreements with such providers and appropriately supervise them.
• 2. If the Company or the Service undergoes a business succession, such as acquisition or merger

• 3. When personal data is shared with business partners

  • – The scope of data to be shared, its purpose, and the entities with whom it is shared will be announced separately
• 4. When provision is permitted by law
• 5. When the user has given prior consent

6. Cross-Border Data Transfers

The Company may use cloud services or servers located outside of Japan. In such cases, data will be transferred under appropriate protective measures in accordance with applicable laws and regulations.

7. User Rights

Depending on the jurisdiction in which users reside (e.g., Japan, the State of California in the United States, etc.), users may have the following rights:

• – Right of Access: The right to request disclosure of personal information the Company holds
• – Right to Rectification or Erasure: If personal information is inaccurate or incomplete, the user may request its correction or deletion
• – Right to Restrict Processing: Under certain conditions, the user may request that processing of personal information be restricted
• – Right to Data Portability (where applicable): The right to receive personal information in a machine-readable format or request its transfer to a third party
• – Right to Object (where applicable): The right to object to the processing of personal information
• – Rights under the CCPA (for California residents): For example, the right to opt out of the sale of personal information

If you wish to exercise any of these rights, please contact the “Contact Information” listed below. Unless otherwise permitted by law, we will respond within a reasonable timeframe.

8. Advertising and Analytics Tools

The Company may use the following tools for analyzing Service usage and optimizing advertisements:

• 1. Google Analytics

  • – Uses cookies to collect traffic data. IP addresses and other data may be sent to Google. For more details, please refer to Google’s privacy policy.

• 2. Other Advertising Services (e.g., Google Ads, Facebook Ads)

  • – May use non-personally identifiable behavioral data, etc. to deliver advertisements.

Users may disable cookies in their browser settings to refuse data collection by these tools, but doing so may limit certain features of the Service.

9. Security Measures

In order to protect users’ personal information, the Company implements organizational, technical, personnel, and physical security measures. Details about these measures will be provided individually only if and to the extent required by applicable laws.

10. Use by Minors (Prohibition for Under 13)

• 1. Prohibition for Under 13

  The Service is not intended for use by individuals under the age of 13 (12 or younger), and the Company does not knowingly collect personal information from children under 13. In addition, the Service is designed so that individuals under 13 cannot register as users. If it is discovered that a user under 13 is using the Service, the Company will promptly delete the user’s account and any related personal information.

• 2. Users Aged 13 and Above but Under 18

  Even if you are 13 or older, if you are under the age of 18 (a minor), you are deemed to have obtained prior consent from a parent or legal guardian before using the Service. Please review the Terms of Use and this Policy with a parent or guardian before using the Service.

• 3. Compliance with COPPA (Children’s Online Privacy Protection Act) and Similar Regulations

  The Company does not anticipate use by individuals under 13 in the United States (COPPA-protected age group). By prohibiting use by individuals under 13, the Company aims to avoid the obligation to obtain parental consent under COPPA. In the event it is confirmed that a user is under 13, the above deletion procedures will be followed.

11. Amendments to This Policy

The Company may update this Policy from time to time. If we make changes that we believe you should be aware of, we will notify you accordingly.

This Privacy Policy may be modified at any time. In the event of any changes, we will notify you in a reasonable manner. Such notification may occur through any of the following methods:

• – Updating the “Last Updated” date at the bottom of the Privacy Policy displayed on our website or mobile app.
• – Posting a notice on the homepage of our website or via in-app notifications, among other possible methods.

12. Contact Information

For inquiries regarding this Policy, the handling of personal information, or user rights, please contact us at:

Email: info@wabble.link

We may request users to present a valid form of identification (e.g., driver’s license) for verification purposes. Additionally, a fee may be charged for disclosure requests, in which case you will be notified in advance.

13. Name, Address, and Representative of the Business

Business Name: FlatoX Inc.
Address: Osaka Ekimae Daini Building 12-12, 1-2-2 Umeda, Kita-ku, Osaka 530-0001, Japan
Representative: Customer Support Team

Last Updated: February 20, 2025