This Privacy Policy (“Policy”) explains how SFM Co., Ltd. (“Company,” “we,” “us,” or “our”) handles information in connection with the HbA1c measurement application “FLD HbA1c” (“App”), designed for health management and available on smartphone devices (“Device”). This Policy also applies to all related services (“Service”) provided through the App.
1. Collection and Use of Personal Information
(1) The App uses your Device’s camera and processing functions to analyze your skin using advanced optical technology. It calculates your HbA1c value for health management purposes and displays the results on your Device screen. For reference, your pulse rate and oxygen saturation are also displayed.
(2) By default, we do not collect or use personal information that can identify you, unless an exception stated in this Policy applies.
(3) We will not obtain or use privacy-related information in ways that infringe on your rights, nor will we share personal data with third parties except as permitted in this Policy.
(4) We will not collect or use personal information, or share it with third parties, for purposes unrelated to providing the Service, unless permitted under this Policy.
(5) We do not collect or use the health information displayed on your Device—even in anonymized, pseudonymized, or statistical form.
2. Compliance with Laws
(1) The App is designed to comply with applicable laws and regulations, including Japan’s Act on the Protection of Personal Information, the EU’s General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).
(2) We may collect, use, or share personal information with third parties only within the necessary scope for providing the Service, using lawful and fair means, and only with your proper consent.
3. Types of Information We May Collect
“User Information” means any information that may identify you, your activity within the Service, or data related to your Device that we collect under the exceptions described in this Policy. Depending on the method of collection, this may include:
(1) Information you provide directly
The information that may be provided by users in order to use this service, or through their use of this service, includes the following:
Profile details (name, date of birth, gender, occupation)
Contact details (email address, phone number, postal address)
Payment details (credit card, bank account, electronic payment information)
Still image data and video data including the user’s likeness and actions
Information entered or submitted by the user through input forms or other methods specified by the Company
(2) Information from linked services
If you connect the Service to third-party services (e.g., social media), we may collect:
Your user ID on the linked service
Other information you agree to share through the service’s privacy settings
(3) Information collected automatically
We may collect data on how you access and use the Service, such as:
Referrer URLs
IP address
Server access logs
Device identifiers (cookies, ADID, IDFA, etc.)
(4) Information collected with your explicit consent
With your separate consent, we may collect:
With the user’s explicit consent, the Company may collect the following information from the device while in use.
Location data from your Device
4. Purpose of Use
We may use User Information for the following purposes:
Providing, maintaining, and improving the Service, including registration, identity verification, authentication, recording user settings, and processing payments
Measuring traffic and usage patterns
Generating content or results within the Service
Delivering, displaying, and measuring the performance of advertisements
Responding to inquiries and providing Service-related information
Addressing violations of our Terms or other policies
Notifying users about updates to our Terms or policies
5. Sharing with Third Parties
We will only share personal information with third parties when legally permitted and after taking appropriate measures, including obtaining your consent where required, ensuring confidentiality and security, and clarifying the purpose of use.
6. Use by Minors
The App is not age-restricted, but use by individuals aged 18 and over is recommended.
7. Security
All analysis is performed within the App, and no data is sent or received externally. We use advanced encryption to protect against unauthorized access, tampering, or hijacking.
We take appropriate measures to prevent the leakage, loss, or damage of personal data.
8. Requests Regarding Your Personal Information
In accordance with Japanese law, you may request disclosure, correction, deletion, suspension of use, or notification of the purpose of use of your retained personal data (“Requests for Disclosure”). We will verify your identity before responding and will process your request promptly.
A fee of ¥10,000 (excluding tax) will be charged for certain requests, such as disclosure or notification of the purpose of use.
For instructions on making such requests, please contact us using the details below.
9. Contact Information
For any comments, inquiries, complaints, or other questions regarding the handling of user information in connection with this Service, please contact us at the following address.
Address
141-0031
Gotanda City Trust Building 2F, 1-23-7 Nishigotanda, Shinagawa-ku, Tokyo, Japan
SFM Co., Ltd.
Representative: Osamu Shoji
Personal Information Protection Manager: Kyosuke Baba
Email: appsupport@smartface.co.jp
10. Changes to this Policy
Any updates to this Policy will be announced on the SFM App Store or through the Service.
Where required by law, we will obtain your consent before applying changes that require it.
Effective Date:
August 1, 2025