Sungate Innovation, Inc. (the “Company”) is committed to maintaining robust privacy protections for its users. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service.

“Site” refers the website “Grace Wallet”, which can be accessed at ( https://www.gracewallet.com ) or through our mobile application.　 The Company is operating and managing the Site on behalf of Grace Member’s Community (GMC) for their members. “Service” refers the Company’s services accessed via the Site, in which users can collect the various information related to the lifeline in Japan.

The terms “we,”” us,” and “our” refer to the Company. “You” refers to you, as a user of our Site or our Service. By accessing our Site or our Service, you accept our Privacy Policy and Term of Use (including, enforcing Omnipay, Inc.'s Terms and Conditions), and you consent our collection, storage, and disclosure of your Personal Information as described in this Privacy Policy.

We collect “Non-Personal Information” and “Personal Information”. Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Personal Information includes your name, email address, mobile number, other contact information, which you submit to us through the registration process at the Site and/or Mobil application.

Information collected Via Technology

To activate the Service, you do not need to submit any Personal Information other than your email address. To use the Service thereafter, you need to submit further Personal Information. However, in an effort to improve the quality of the Service, we track information provided to us by your browser or by our software application when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected the Service, the time and date of access, and other information that does no personally identify you. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our server and are stored on the user’s computer hard drive. Sending a cookie to user’s browser enables us to collect Non-Personal information about user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis.

Information you provide us by registering for an account

In addition to the information provided automatically by your browser when you visit the Site, to become a subscriber to the Service you will need to create a personal profile. You can create a profile by registering with the Service and entering your email address, and creating user name and password. By registering, you are authorizing us to collect, store and your email address in accordance with this Privacy Policy.

Personal Information

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We do share Personal Information with the vendors who are performing services for the Company, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy. In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers. We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable government request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or public as required or permitted by law.

Non-Personal Information

In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertiser and other third parties at our discretion. In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfer may occur and are permitted by this Private Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Private Policy. If our information practices change at any time in the future, we will post the policy changes to the Site you may opt out of the new information practice. We suggest that you check the Site periodically if you are concerned about how your information is used.

We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out or your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewall, and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.

We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, only to the extent necessary, and through secure means, for the purposes listed above (where applicable), to the following entities or parties, whether located here or overseas:

1. The Company’s related corporations, subsidiaries and affiliates and overseas branches and offices;
2. Counterparties and their respective banks in relation to transactions for your account;
3. Third party recipients of reference letters;
4. Referrers who have referred you to the Company;
5. Agents, contractors, vendors, installers, or third party service providers who provide administrative or operational services to the Company, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to the Company;
6. Agents, contractors, vendors or other third party service providers in connection with products and services offered by the Company;
7. Our professional advisers such as our auditors and lawyers;
8. Third parties who provide corporate advisory services or due diligence services in connection with you, any Connected Person or your account held with the Company;
9. Relevant government regulators, government ministries, exchange, statutory boards or authorities or law enforcement agencies who have jurisdiction over the Company or any Company or over any transaction entered into by you;
10. Any person to whom the Company is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to the Company, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which the Company or any of the Companies are expected to comply, or any disclosure pursuant to any contractual or other commitment of the Company with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside the Japan and may be existing currently and in the future; and / or
11. Any other party to whom you authorise us to disclose your Personal Data.

You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. You can also indicate that you do not wish to receive marketing communications from us by sending email to our customer service listed below.

As part of the Service, we may provide links to our compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to use of third-party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

The Company reserves the right to change this policy and our Terms of Service at any time. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or placing a prominent notice on our Site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.

If you have any questions regarding this Privacy Policy or the practices of the Site, please contact us by sending an email to: privacy@gracewallet.com

Sungate Innovation, Inc.
3-17-11-805 Shibaura Minato-ku, Tokyo 105-0023