The English legal text is under legal review. The Japanese legal document shown on this page is the controlling version until an approved English version is published.
Privacy Policy
U.S. Legal Review Draft
This English text is a U.S.-oriented draft prepared from the Japanese legal text for review by qualified counsel. It is not a final approved legal document. Until an approved English version is published, the Japanese legal text remains the controlling version.
SustinaPlus remains a Japan-first service. Wallet and payment features are limited to JPYC on Polygon where enabled, and power generation facility registration is designed for Japan-based facilities and Japanese verification systems.
Energy Connect Co., Ltd. ("Company," "we," "us," or "our") handles personal information in connection with SustinaPlus in accordance with this Privacy Policy. This U.S.-oriented draft is based on the Japanese Privacy Policy and adds review items that may be relevant to U.S. users. It is not a final approved U.S. privacy notice.
Categories of Information We May Collect
- Account information such as name, email address, password-related authentication data, locale, and support history.
- Transaction information such as purchase history, payment status, marketplace activity, JPYC/Polygon transaction references, wallet addresses, and reward information.
- Power generation and facility information submitted by renewable energy producers, including Japan-based facility identifiers and documents.
- Partner, host, project, and reward fulfillment information, including contact and shipping information where needed to provide benefits.
- Device, browser, cookie, log, security, and authentication information used to provide, protect, and improve the service.
- Communications with us, including inquiries, complaints, and legal or compliance requests.
Purposes of Use
We use personal information for the following purposes, except where consent or applicable law requires a different handling method.
- Providing, operating, maintaining, and improving SustinaPlus.
- Administering accounts, authentication, security, wallet-related records, and customer support.
- Processing transactions, marketplace activity, rewards, partner benefits, notices, and inquiries.
- Reviewing power generation facility registration and related submissions.
- Conducting surveys, analysis, research, development, fraud prevention, and service improvement.
- Sending service notices, legal notices, product updates, and marketing communications where permitted.
- Exercising rights and performing obligations under contracts, laws, regulations, and platform rules.
Sharing and Disclosure
We do not disclose personal information to third parties except as described below or as otherwise permitted by law.
- With hosts or partners where a user requests or qualifies for project benefits, program benefits, reward fulfillment, shipment, verification, or related support.
- With service providers and processors that support hosting, security, payment, email, analytics, customer support, fraud prevention, legal, accounting, or operational functions.
- Where required or permitted by law, regulation, court order, government request, dispute resolution, safety, security, or rights protection.
- In connection with a merger, business transfer, financing, restructuring, or similar corporate transaction, subject to appropriate safeguards.
U.S. State Privacy Review Notice
If a U.S. state privacy law applies to us and to your information, you may have rights such as access, correction, deletion, portability, opt-out of certain sales or sharing, limitation of sensitive personal information, and non-discrimination for exercising rights. This draft should be reviewed by counsel before any final U.S. rights process or "Do Not Sell or Share" mechanism is published.
As currently drafted for review, SustinaPlus does not intentionally sell personal information for money. If advertising, analytics, or partner integrations are determined to constitute a "sale," "sharing," targeted advertising, or profiling under applicable U.S. law, this policy and the user controls must be updated before approval.
Children's Privacy
SustinaPlus is not directed to children under 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected such information without required consent, we will take reasonable steps to delete or disable it. U.S. child-directed or mixed-audience use requires separate COPPA review before launch.
Cookies and Similar Technologies
We may use cookies, local storage, and similar technologies to maintain sessions, protect accounts, analyze usage, and improve the service. Browser settings may allow you to disable cookies, but some features may not function properly. Any U.S. targeted-advertising or cross-context behavioral advertising use requires separate legal review and updated controls.
Security and Retention
We take reasonable measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. No internet or blockchain-related service can be guaranteed to be completely secure. We retain information for as long as reasonably necessary for service operation, legal compliance, dispute resolution, security, fraud prevention, accounting, and legitimate business purposes.
International Processing
The Company is established in Japan. If you access SustinaPlus from the United States or another country, your information may be processed in Japan and other countries where service providers operate. Those countries may have data protection rules different from those in your location.
Requests and Contact
To request access, correction, deletion, suspension of use, disclosure of third-party transfer records, or other privacy assistance, contact us through the support request form or the contact address listed in the Company Profile. We may need to verify your identity before responding.
Changes to This Policy
We may update this policy as needed for service changes, legal review, security, or operational reasons. The updated policy will be posted or otherwise notified through a method designated by the Company.
Energy Connect Co., Ltd.
Original Japanese policy established May 31, 2024; amended March 21, 2026. U.S. legal review draft prepared from the Japanese original.