Privacy Policy

Cerebro Pharma Co., Ltd. (hereinafter referred to as “our company”) establishes a privacy policy (hereinafter referred to as “this policy”) regarding the handling of users' personal information in services provided by our company (hereinafter referred to as “this service”) as follows.

Article 1 (Definition of personal information)

“Personal information” in this policy refers to personal information as stipulated in the Act on the Protection of Personal Information (Personal Information Protection Law), and refers to name, date of birth, address, telephone number, email address, and other information that can identify a specific individual. It also includes health information, information on taking supplements, and other sensitive personal information.

Article 2 (Method of Obtaining Personal Information)

The Company obtains personal information in the following ways in this service.

(1) Obtained directly from users or through agencies, etc.
We obtain personal information directly from users by means of input forms (inquiries, employment applications, membership registration, product purchases, etc.) on websites and apps, entering data such as number of steps, meals, physical condition, etc. within the application, and responding to questionnaires, and by means of email, telephone, mail, writing, etc. Also, when a user applies for this service through an agent, information necessary to conclude a contract and provide this service may be obtained from that agency.

2. Acquisition through Mina Portal collaboration
The following information will be acquired through this API only when the user has agreed to cooperate with the Mina Portal API provided by the Digital Agency within this service and has performed their own authentication. This information will be managed appropriately in accordance with relevant laws and regulations stipulated by the Digital Agency.

Article 3 (Types of personal information to be acquired)

The information we obtain is as follows.

Basic member information: name, address, email address, phone number, etc.
Payment and usage information: purchase history, payment methods, and information on purchases made through agents
Information derived from Mina Portal (including sensitive personal information): Specific medical examination information (height, weight, blood pressure, blood sugar level, etc.), drug information (prescription history, etc.), medical expenses notification information obtained based on user consent‍
App usage information： Health management information inputted and measured through the CEREACTS app, cognitive function check results

Article 4 (Purpose of Use of Personal Information)

We use personal information to the following extent.

This service (including websites and apps related to this service) Provision, operation, and improvement of
Member identity verification and authentication
Product sales, order processing/delivery management, payment settlement and after-sales support
Marketing activities, advertising, and effect analysis
Creation of statistically processed information in a form that does not allow specific individuals to be identified
Responses to various inquiries from users
Service provision, support, contract procedures, etc. through agents
Contact applicants, selection, and employment management after hiring decisions
Exercise of rights and performance of obligations based on laws and regulations, and operations incidental thereto
Other purposes incidental to the above purposes of use

Article 5 (Provision of Personal Information to Third Parties)

We will not provide personal information to third parties without the user's consent, except in the following cases.
1. When required by law
2. When it is necessary for the protection of a person's life, body, or property, and it is difficult to obtain the person's consent
3. When it is particularly necessary to improve public health or promote the healthy development of children, and it is difficult to obtain the consent of the individual
4. When it is necessary for a national agency, local public body, or a person entrusted by these to cooperate in carrying out the affairs stipulated by law, and there is a risk that obtaining the consent of the person concerned will interfere with the execution of the affairs
For the smooth operation of this service and user support, we will provide personal information to third parties as follows.
1. Provision to distributors
  In order to provide services, support, contract procedures, etc., we may provide agents with customer information about the agency concerned and information on taking supplements sold.
2. Provision to subcontractors
  It is provided to subcontractors such as delivery companies, settlement agencies, system operation companies, etc. to the extent necessary for business execution. The contractor will take the same safety management measures as our company.
3. Provision or receipt through information cooperation services
  Based on user consent, we may receive or provide personal information through information linkage services such as the Mina Portal API provided by the Digital Agency. In this case, we will strictly manage the information in accordance with relevant laws and regulations, guidelines, and regulations stipulated by the Digital Agency.

Article 6 (Entrustment of personal information)

We may outsource all or part of the handling of personal information to an outside party to the extent necessary to achieve the purpose of use. In this case, we will supervise the contractor as necessary and appropriate in accordance with the Personal Information Protection Law.

Article 7 (Management of Personal Information and Information Security)

We comply with ISMS (ISO/IEC 27001), take technical, organizational, and physical safety management measures, and thoroughly train employees and supervise contractors and agents. In the event of an accident such as personal information leakage, etc., we will promptly report and respond to users and competent authorities.

Article 8 (Disclosure, Correction, Suspension of Use, Deletion, etc. of Personal Information)

Users can request disclosure, correction, addition, deletion, suspension of use, deletion, and suspension of provision of their personal information to third parties (hereinafter referred to as “disclosure, etc.”) in accordance with the procedures prescribed by the Company. This also includes specific health information, etc. obtained through the Mina Portal API.
The reception desk and hours for requests for disclosure etc. are as follows.
Claim desk: info@cerebro-p.com
Reception hours: Weekdays 9:00-18:00 (excluding weekends and holidays)
When there is a request for disclosure etc. from a user, after verifying the identity, we will investigate and respond within 14 days as a general rule in accordance with relevant laws and regulations, and notify the requester of the results without delay.
If, as a result of the investigation, it is determined that it is difficult to respond to the request due to legal reasons, etc., the Company shall explain the reason without delay.
Even if the user cancels the link with the Mina Portal API and wishes to delete the acquired data, we will respond in accordance with the procedures in this section.

Article 9 (Use of Cookies, etc.)

We may use cookies and other similar technologies to improve user convenience and analyze usage conditions. Users can restrict or refuse the use of cookies by setting their browser.
We use Google Analytics provided by Google LLC to understand and analyze the usage status of this service and website. Google Analytics collects user access information (IP address, pages viewed, time spent, date and time of access, etc.), but it is not possible to identify individuals from this information.
In addition to being able to refuse the use of cookies by using browser settings, etc., it is also possible to disable data collection by Google Analytics by using the following opt-out function provided by Google.
[Opt out link]https://support.google.com/analytics/answer/181881?hl=ja

Article 10 (Handling of Sensitive Information)

We use health information, supplement administration information, and sensitive personal information obtained through recruitment and inquiries (as stipulated in the Personal Information Protection Act). We will acquire, use, and manage with particular care after obtaining the consent of the person in question in accordance with laws and regulations and guidelines.

Article 11 (Compliance with Laws and Regulations)

We will comply with the Act on the Protection of Personal Information applicable to the personal information we hold, other Japanese laws and regulations, guidelines set by the government, and related guidelines.

Article 12 (Continuous Improvement)

We will continuously review and improve the handling of personal information and the information security management system.

Article 13 (Changes to the Privacy Policy)

We may change this policy as necessary. The details after the changes will be announced by an appropriate method, such as posting on our website, emails, and notifications using the notification function within the CEREACTS app.
If content changes are made that require the consent of the user under law (adding items to obtain sensitive personal information, changing the purpose of use, etc.), the consent of the user will be obtained again.
If a user does not agree to the revised policy, we may stop providing this service to that user. In this case, we will promptly take measures such as deleting the personal information of the relevant user in accordance with Section 8.
The revised policy will take effect from the time it is published (or the effective date notified individually).

Article 14 (Contact Information Desk)

For inquiries regarding this policy, please contact the following office.
[Contact point]
Email address: info@cerebro-p.com
Reception hours: Weekdays 9:00-18:00 (excluding weekends and holidays)

Basic Information Security Policy

For more informationPDFsPlease browse.

Date of enactment: December 1, 2025

Last updated　　 : February 16, 2026

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