The Sugar dating service for your second love life at Universe Club Singapore




Personal Information Protection Policy

As a matchmaking service and business, Universe Club understands that it is a serious social responsibility to protect the personal information of our customers, users, and employees.

We have established the following policy for the protection of personal information and declare that the entire company is dedicated to ensuring the proper handling of such information.

Personal Information

Personal information refers to information that can be used to identify a specific individual, such as a customer’s name, age, address, telephone number, e-mail address, and place of employment.
It is also defined as information that may not identify an individual on its own, but can be used to do so by cross-checking with other information.

  1. Personal information will be collected and disclosed by appropriate means only to the extent necessary for contracted operations, employment, and employee management. Furthermore, we will not handle personal information beyond what is necessary to achieve the specified purpose of use and will take measures to ensure that it is done.
  2. We will take reasonable safety measures through education, audits, and upgrades to protect personal information from risks such as unauthorized access, loss, destruction, falsification, and leakage of personal information, and will continuously improve our system to protect personal information.
  3. We will comply with the laws and regulations applicable to the personal information held by us, as well as other standards.
  4. We will respond to questions and complaints regarding personal information in an appropriate and prompt manner.
  5. Based on societal needs, individual requirements, and the latest developments in IT, we will review our personal information protection systems in a timely and appropriate manner and continue to make improvements to them.

July 2, 2021 (established)
Universe Club
Representative Kida Satoshi

Regarding the Handling of Personal Information

In accordance with the “Personal Information Protection Policy,” Universe Club handles personal information, etc. used for our business as per the following:

  1. Regarding the Handling of Personal Information and Personally Relevant Information
    (1) Personal information handled by the Company shall be acquired for business purposes that fall under any of the following, and thus handled appropriately within the scope of the purpose of use.

    Personal Information Purpose of Use
    Personal information of customers Disclosure of personal information for membership, based on the customer’s own consent
    Responding to customer inquiries and providing consultation services
    Identity verification of customers for all matching services managed by the Company, including Universe Club and THE SALON.
    Contact for questionnaires, campaigns and other information provided to customers
    Countermeasures against disruptions and unauthorized usage, and prevention of potential problems
    Personal information of business partners Sending quotations and purchase orders to business partners
    Personal information of membership applicants Contacting applicants for membership interviews
    Notification of acceptance or rejection of membership application
    Personal information of employees Personnel and HR management (to be specified in a separate agreement)
    Personal information obtained through inquiries To respond to inquiries
    Personal information obtained through contracted work To fulfill contracts for commissioned work

    (2) Specific personal information, etc. handled by the Company will be handled appropriately within the scope of specific affairs related to social security, tax, and disaster countermeasures.

    (3) When the Company obtains personal-related information as personal data, it will be handled appropriately within the scope of the following purposes of use.

    Personally Relevant Information Purpose of use
  2. Provision of Personal Information, etc. to Third Parties

    (1) We will not disclose or provide personal information to any third party except for the purpose of business execution and the following (1) through (7).

    • (1) With the consent of the person concerned
    • (2) When required by law
    • (3) When it is necessary to cooperate with a national agency, a local government, or a person or organization authorized by either of the above in executing duties stipulated by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of the duties concerned.
    • (4) When it is necessary for the protection of the life, physical well-being, or property of an individual and it is difficult to obtain the consent of the individual.
    • (5) When it is particularly necessary for improving public health or promoting the proper development of minors, and when it is difficult to obtain the consent of the individual.
    • (6) Regardless of membership status, when a customer violates laws and regulations, harms the interests of the Company or others, acts against public order and morals, or otherwise violates or attempts to violate the terms of use of the Company’s services, the Company will take the necessary measures to deal with such acts.
      For the purpose of preventing the recurrence of problems and non-payment of fees, and protecting the fairness and interests of all users, we will provide the name, telephone number, e-mail address, transaction history, and other information that we separately specify to the Association of Social Networking Clubs, which we are a member of.
    • (7) When personal data is provided in connection with the succession of a business due to a merger or other reasons.
    • (8) Where the business operator handling the personal data is an academic research organization, etc., and the provision of such personal data is unavoidable for the publication of the results of academic research or for teaching (except where there is a risk of unjustified infringement of the rights and interests of individuals).
    • (9) Where the business operator handling the personal data is an academic research organisation, etc., and it is necessary to provide the personal data for academic research purposes (including where part of the purpose of providing the personal data is for academic research purposes, except where there is a risk of unjustified infringement of the rights and interests of individuals). (limited to cases where academic research is conducted jointly by the personal data handling business operator concerned and the third party concerned). (ii) When the personal data is provided for the purpose of academic research.
    • (10) Where the third party is an academic research institute, etc., and the third party needs to handle the personal data for academic research purposes (including where part of the purpose of handling the personal data is for academic research purposes, except where there is a risk of unjustified infringement of the rights and interests of individuals).

    In the event that personal information is provided to or received from a third party (excluding national organizations, local governments, independent administrative agencies, etc., and local independent administrative agencies, the same shall apply hereafter), a record of the necessary matters shall be made in accordance with the Personal Information Protection Law, and the information shall be retained for the period specified by the Personal Information Protection Committee Rules.

    (2) The Company may provide specific personal information, etc. only in cases that fall under each item of Article 19 of the Number Law in Japan, and will not provide specific personal information, etc. in other cases.

  3. Management of Contractors, etc.

    In order to achieve the purpose of use indicated in Paragraph 1, the Company may entrust personal information, etc. to a subcontractor with whom the Company has concluded a contract. The entrusted company will be required to handle, manage, and protect the information appropriately, and will be prohibited from disclosing or providing the information to any third party or using the information for any purpose other than those stated in Paragraph 1.

  4. Management of Personal Information, etc.

    • (1) Establishment of general policy
      General policy on ‘compliance with relevant laws and guidelines’, ‘contact point for questions and complaints’, etc., to ensure proper handling of personal data.
    • (2) Disciplinary rules for the handling of personal data.
      Personal data handling regulations are established for each stage of acquisition, use, storage, provision, deletion/disposal, etc., including handling methods, responsible persons/persons in charge and their duties.
    • (3) Safety management measures for the organization
      Establish a person responsible for the handling of personal data, clarify the employees who handle personal data and the scope of personal data handled by such employees, and establish a system for reporting to the person responsible in the event that the fact or indication of a breach of the law or handling rules is detected.
      External audits of the JAPHIC mark using the guidelines on the Act on the Protection of Personal Information (Personal Information Protection Commission) as the audit criteria.
    • (4) Human security management measures
      Regular training of employees on precautions for the handling of personal data Include matters relating to the confidentiality of personal data in the rules of employment.
    • (5) Physical security management measures
      In areas where personal data is handled, access control is implemented for employees and measures are taken to prevent access to personal data by unauthorized persons.
      Implement measures to ensure that personal data is not easily revealed when carrying such equipment, electronic media, etc., including within the workplace.
    • (6) Technical security control measures
      Implementing access control to limit the scope of persons in charge and the personal information databases, etc. handled, and introducing a mechanism to protect information systems handling personal data from unauthorized external access or unauthorized software.
    • (7) After withdrawing from the Service, registered information will be retained for a period of time, but will not be displayed on the member page. This is to prevent members from being affected in the event of an operational error or to conduct an investigation in the event of fraud. We will also retain your name, contact information, dating history, etc. after membership withdrawal to prevent confusion in service operations.
  5. Use of Statistical Data

    We may create statistical data based on the personal information we have collected. It will be processed such that individuals cannot be identified.

    The Company may use such statistical data as indicated above without any restriction.

  6. Inquiries about Personal Information and Procedures for Disclosure, etc.

    • (1) If the person in question or his/her representative requests notification of the purpose of use, disclosure, record of provision to a third party, correction, addition, or deletion of content, suspension of use, deletion, or suspension of provision to a third party (hereinafter referred to as “disclosure, etc.”) with respect to personal information and specified personal information, etc., the Company will respond to the request in good faith. (hereinafter referred to as “Disclosure, etc.”), we will respond in good faith to such requests.
    • (2) When an inquiry is made, we may need to verify the identity of the person making the inquiry or that of their representative.
    • (3) We may not be able to respond to your inquiry or request for disclosure, etc. if we are unable to verify your identity or that of your representative.
    • (4) Requests for disclosure of personal information, etc. from the individual or their representative, and responses to disclosure of personal information from the Company will be responded to within a reasonable period of time.
  7. Procedures for Disclosure, etc.

    1. (1) Please contact the following consultation desk by e-mail with the following information.

      1. E-mail address at the time of registration
      2. Telephone number at the time of registration
      3. Real name
      4. Please select your preference from the following and describe in detail the contents and items of the personal information subject to disclosure that you are requesting.

        • Notification of purpose of use
        • Disclosure
        • Record of provision to a third party
        • Correction of contents
        • Addition of contents
        • Deletion
        • Refusal to provide information to a third party
        • Refusal of use
        • Other

        * If the application includes “correction of content” or “addition of content,” please describe in detail how the correction or addition will be made.

      5. If you would like to contact us from an email address other than the one you registered with, please attach the following:

        ・A scanned copy of your personal ID (driver’s license, passport, or other official ID)

        * If you contact us from your registered email address, we will confirm your identity by matching your email address.

        * For the purpose of crime prevention, we cannot accept the deletion of personal information within 6 months of withdrawal.

    2. (2) Please indicate if the inquiry is from a representative. We will ask you separately to send a letter of attorney and personal seal registration certificate to verify the representative’s identity. As the original document is required in this case, please mail it to us directly.
    3. (3) Personal information received through this application procedure for disclosure, etc. will be used to contact the customer who made the inquiry and to verify their identity. It will not be used for any other purpose. The personal information received will be stored for one year after the completion of the response to the request for disclosure, etc., and will then be destroyed.

      * The procedures for disclosure, etc. of specific personal information are the same as above, but in compliance with the Number Law, the specific personal information protection manager will make a decision on whether disclosure is possible before doing so.

    Payment and collection of shipping costs for Requests for Disclosure, etc.

    After confirming the details of your application, we will inform you of the bank transfer account if we deem it possible to complete your request.

    After confirming the payment of 1,100 yen (please pay the handling fee), we will disclose, delete, etc. the information.

  8. Contact for disclosure, etc. of personal information, complaints, and consultation

    For inquiries, please contact: Universe Club Personal Information Inquiry Desk
    By mail: We will inform you by e-mail.

  9. About Authorized Personal Information Protection Organizations

    We are a business subject to the JAPHIC Mark Certification Organization, an authorized personal information protection organization under the Act on the Protection of Personal Information. JAPHIC Mark Certification Organization, which is an authorized personal information protection organization under the Act on the Protection of Personal Information.

    For inquiries about complaints and consultation regarding personal information, please click here.

    *Japanese only.
    *This is not a contact for inquiries regarding our products or services.

Universe Club
Satoshi Kida