This Privacy Policy (“Policy”) applies to the HbA1c (Hemoglobin A1c) estimate application software “FLD HbA1c” (“Application”) developed and provided by SFM Inc. (“Company”) for the purpose of health management via smartphone devices (“Devices”). This policy governs the use of the services provided by the Application (“Services”).

1. Collection and Use of Personal Information

(1) The Application uses the device’s camera and computational capabilities to analyze light from human skin using advanced optical technology to display HbA1c levels on-screen. Heart rate and oxygen saturation levels are also displayed as reference.

(2) The Services generally do not collect or use personally identifiable information, except as otherwise stated in this Policy.

(3) The Services do not collect or provide personal data to third parties through inappropriate methods that infringe on users’ rights.

(4) The Services do not collect or use personal information or provide personal data to third parties beyond the purposes stated, except as provided in this Policy.

(5) The Company does not collect or use health management data displayed on the device, nor any anonymized, pseudonymized, or statistical pseudonymized information.

2. Compliance with Laws

(1) The Application is designed to comply with privacy laws, including Japan’s Personal Information Protection Law, GDPR, and CCPA.

(2) The Company may obtain and use personal minimized data or provide it to third parties within the scope necessary for service delivery and with proper user consent.

3. User Information and Collection Methods

“User Information” refers to data generated or stored in connection with users or their devices, which the Company may exceptionally collect.

(1) Information provided by users:

– Name, birth date, gender, occupation

– Contact info: email, phone number, address

– Payment details: credit card, bank, e-money

– Photos, videos, or user-input data via forms

(2) Information from other services if linked:

– Service IDs and shared info based on privacy settings

(3) Automatically collected data during use:

– Referrer, IP address, server logs

– Cookies, ADID, IDFA, and similar identifiers

(4) With user consent:

– Location information

4. Purpose of Use

Collected user information is used for:

（(1) Registration, identity/authentication, settings, payments, and general service provision and improvement

(2) Traffic and behavior analysis

(3) Generating in-app content

(4) Ad delivery and performance analysis

(5) Customer support

(6) Enforcement of Terms of Use

(7) Notifications regarding changes to Terms

5. Sharing Information with Third Parties

Information sharing is done only in accordance with laws, user consent, confidentiality and security standards, and clearly defined purposes.

6. Use by Minors

While no age restrictions exist, use is recommended for those 18 and older.

7. Security

(1) Information is processed within the app only. No external data transmission. Advanced Security measures are implemented to prevent unauthorized access or data breaches.

(2) The Company strives to prevent data leaks, loss, or damage.

8. Requests for Disclosure of Personal Data

(1) Users may request disclosures, corrections, deletions, or cessation of use or provision to third parties in accordance with Japan’s laws. Identity verification and proper procedures will be required.

(2) A fee of 10,000 JPY (excluding tax) will be charged per disclosure request.

(3) Please contact the inquiry window listed in this Policy for more details.

9. Contact Information

SFM Co., Ltd.
Address: Gotanda City Trust Bldg 2F, 1-23-7 Nishi-Gotanda, Shinagawa-ku, Tokyo 141-0031, Japan
Representative: Osamu Shoji
Privacy Officer: Kyosuke Baba
Email: appsupport@smartface.co.jp　

10. Changes to This Policy

(1) Any changes will be published on the official website and/or the Services.

(2) If consent is required, it will be obtained on the first launch following the change.

Effective Date: May 18th, 2025