The last day to shop BUYMA is July 31, 2024

Privacy Policy


Enigmo Inc. (hereinafter referred to as “we” or the “Company”) considers it an important part of our corporate social responsibility to suitably protect those information of our users (including members, membership applicants and viewers of our Website (defined below)) which may be used to identify them as individuals. Accordingly, we will collect, use and provide or disclose to other third parties our users’ personal information pursuant to the “Privacy Policy” outlined below. When you are using our “BUYMA” website ( (hereinafter referred to as the “Website”), it is important for you to read the Privacy Policy carefully before consenting to the terms and conditions set forth therein. If you are unable to provide your consent, you may not access or use the services of the Website.

Please note that “BUYMA,” as used under this Privacy Policy, refers to the international social shopping service which the Company operates under the Website. For the avoidance of doubt, the Company separately operates a Japanese-only service under the same name of “BUYMA” ( but which is different to the services provided via the Website, and which is governed by a separate set of terms and conditions of use and privacy policies. Users should take care in not confusing this Privacy Policy with that applicable to the Japanese-only service.

User Information

“User Information” means information by which an individual user can be identified, and includes the following information of such user:

  • Name, login ID, password, access nickname, home address, e-mail address, telephone number, credit card number and other credit card related information, bank account number, official personal identification records of the user (such as notarized signature certificates, company statements etc.), which has been registered with the Website (originally or subsequently via a request for amendment) or which has otherwise been made available to us by the user him/herself;
  • Service usage details and history of the user, including service contents used, dates and times of such use, frequency of such use and other details thereof; and
  • Information concerning settlement of charges in relation to usage of the Website by the user.

Collection of User Information

We may collect User Information of users using the Website in the following manner:

  • Collection through the Website :
    User Information entered into the Website by a user
  • Collection through e-mail, post, documents, telephone and other methods :
    User provided to us by a user through e-mail, post, documents, telephone and other methods
  • Collection through e-mail sent to users :
    If the e-mail software used by a user is equipped with functions to confirm the arrival and opening of e-mail, we may receive and record information on arrival and opening of our sent e-mails through such software. If a user does not approve this, he/she should turn off such function in the software, or use another e-mail software without such functionality.
  • Collection of information relating to user access to the Website :
    We may collect the history and other details regarding the use of services of the Website by a user, including information on URL, type of internet browser or mobile phone used to access the Website, IP addresses and other similar information.

Purpose of Use of User Information

We will use User Information for the purposes informed to the user at the time of collecting his/her User Information, and/or for the purposes listed below. Apart from these purposes of use, we will not use collected User Information for any other purpose, except in the cases specified in “Provision or Disclosure of User Information to Third Parties” set forth below or where we have otherwise obtained a user’s consent to such use. Further, any user may refuse to receive information provided by us at membership registration, or otherwise withdraw any consent to receive information provided by us after becoming a member. However, we reserve the right to provide certain information to our users which are necessary for service operation, regardless of such refusal or withdrawal of consent by the user.

  • To notify purchasers and personal shoppers of the status of transactions and other material matters by e-mail, etc. in order to ensure the safety and reliability of transactions through the Website (e-mail address, nickname, etc.);
  • To confirm purchase of goods and services and delivery thereto (name, home address, etc.);
  • To confirm the application for e-mail distribution services and sending of e-mails (nickname, e-mail address, etc.);
  • To confirm membership registration and provide services thereto (nickname, usage history, official personal identification records of the user, etc.);
  • To use in billing, payment and refund of prices/charges of goods and services and confirmation thereof (usage history, settlement information, etc.);
  • To send rewards and gifts to users cooperating with our surveys (name, home address, etc.);
  • To send premiums and prizes to users having applied for competitions, etc. (name, home address, etc.);
  • To communicate with users when we are alerted to breaches of the Terms of Use of the services of the Website by such users (nickname, e-mail address, etc.);
  • To communicate with users when dealing with requests and/or complaints regarding or in relation to the services of the Website by such users (nickname, e-mail address, home address, etc.);
  • To improve the lineup of goods/services and the functions of the Website for further satisfaction of users;
  • To customize the lineup of goods/services and the details of the Website to suit specific users’ needs (nickname, usage history, etc.);
  • To survey the satisfaction of users for information, goods, services, etc. ordered via the Website (nickname, usage history, e-mail address, etc.);
  • To aggregate the results of statistical processing of personal information and publish it as part of our user research results;
  • To grasp the status of use by users and make use of the results for improvement of existing services and development of new services (nickname, usage history, etc.);
  • To provide information on our various membership services and other services (nickname, e-mail address, etc.);
  • To kindly ask for cooperation in survey or participation in organized event and report the results thereto, etc. (nickname, e-mail address, etc.);
  • To grasp the status of use of goods, services, the Website, etc. by users and to provide relevant information and survey result concerning us and/or other third party companies and organizations which we consider desirable for users (nickname, e-mail address, home address, etc.); and
  • In addition to the foregoing, to solve any issues or problems relating to the operation of the services of the Website where usage of User Information is necessary.

Provision or Disclosure of User Information to Third Parties

We will not provide or disclose any User Information to third parties, except as set forth below:

  • Publication and/or sharing on the Website of information which we consider necessary for provision of services in the Website:
    The registered names, home addresses, telephone numbers, etc. of purchasers will be shared with personal shoppers involved in transactions with them within the Website (personal shoppers shall use such provided information of purchasers solely within the scope necessary for such transactions, and shall be prohibited from disclosing any of such information to a third party without the prior consent of the purchaser). In addition, the BUYMA usage history of each user and other elements of User Information subject to publication (including nickname, gender, age range, assessment points, self-introduction text, activities as personal shopper, main activity areas, etc.) will be published in the Website during the specific period designated by us, together with nicknames registered thereto.
  • Provision to outsource companies:
    We may outsource certain operations, in whole or in part, to companies we consider reliable which have entered into confidentiality agreements with us regarding protection of personal information, for the purpose of User Information processing, provision of information to users, implementation of campaigns or surveys, and other related purposes. In such cases, we will provide User Information to such outsource companies only to the minimum extent necessary for achievement of the purpose, and under our strict management.
  • Provision to alliance companies and business partners:
    We may enter into alliance and/or partnership agreements for provision of services with companies we consider reliable which have entered into confidentiality agreements with us regarding protection of personal information. In such a case, we will provide User Information to such companies and/or partners only to the minimum extent necessary for provision of such services, and under our strict management.
  • Cross-reference with credit card companies and financial institutions:
    We may, for the purpose of payment settlement, etc. related to purchase via the Website, cross-reference with credit card companies and financial institutions with respect to the credit card and other settlement card numbers, users’ names, etc.
  • Recipient and storage period of credit card information:
    Credit card information we obtain from users (including name of card holder, type of card, card number and expiry date) are provided to Stripe, Inc., whereby storage period will be up to the time when a user requests for the deletion of his/her personal information (including credit card information) and we delete such information upon such request; provided, however, that notwithstanding the above, we may delete users’ personal information (including credit card information)for our own reasons.
  • Provision to assignee in the case of business portfolio assignment:
    As a corporate going concern, we may be part of a merger or may sell our business operations to another party. In such cases, we may provide User Information to the assignee party on the condition that it will comply with policies equivalent to those set forth in this Privacy Policy.
  • Provision pursuant to applicable laws and regulations, etc.:
    If we are requested to provide User Information by a competent court, government agency, regulatory authorities or other public bodies, we will provide User Information as requested insofar as there is no justifiable reason for refusal.
  • Provision with respect to dispute resolution with third party:
    User Information may be disclosed in the case where any member causes trouble to a third party and we consider such disclosure necessary for resolution thereof, or where we consider such disclosure necessary for protecting the rights and benefits of any user of our services or any other third party.
  • Provision reasonably necessary for service operation:
    In addition to the foregoing, User Information may be provided or disclosed to a third party when we consider such disclosure to be reasonably necessary for the provision, continuation or maintenance of operation of the services of the Website.

Use of “Cookies”

The Website may send text files called “cookies” to the memory of users’ personal computer and cause them to be stored thereto. The use of cookies has certain merits, such as effective provision of contents and advertisements in such categories as users may be interested in. Each user may refuse to receive cookies at his/her discretion by changing his/her cookie settings of the internet browser to issue alarms before receiving cookies. However, by refusing the use of cookies, users may be unable to utilize some functions and services of the Website.

The Website uses cookies for the following purposes:

  • When a user logs in to an authorized site, to provide services customized to such user in light of such user’s registered information;
  • To cause the most suitable advertisements for each user to be displayed on third party websites, based on the contents such user is interested in and the status of his/her use in the Website;
  • To investigate the number of users and traffic of the Website; and
  • To request a user with whom a specific period of time has passed after such user’s last use of the Website to reenter the password (re-authorization) for the purpose of improvement of services provided to the user and security protection. In addition, we may cause cookies to be sent to and kept in the memory of personal computer of users through a third party website, based on our outsourcing of the advertisement distribution for the Website to such third party.
  • We may use the advertisement distribution services of third parties such as Yahoo, in which cases such third parties may obtain and use, through the cookies, information on the visit, usage and activity histories of users on the Website.
  • Information on the visit, usage and activity histories of users on third-party advertiser websites as obtained by such third parties will be handled and used in accordance with such third parties’ privacy policies.
  • Users may stop the use by above-mentioned third parties of information on the visit, usage and activity histories of users on the Website via the opt-out function made available by such third parties.

* Information recorded in cookies does not include users’ names, e-mail addresses, telephone numbers, home addresses or any other information enabling identification of any specific individual.

Modification of User Information by the Company

If there occurs any change in any registered User Information of a user which are necessary for delivery of goods or billing purposes, such as the name of municipality, postal code, name of financial institution or expiry dates of credit cards, we may modify the registered User Information of the user as appropriate.

Management and Security of User Information; Cross-Border Transfer

  • We will keep in custody any and all User Information we received in a server(s) protected by firewall located in environments inaccessible by general users, and endeavor to prevent any improper access, loss, destruction, falsification or unauthorized disclosure. We may outsource the handling of personal information to companies we consider reliable which has entered into confidentiality agreements of personal information with us, but in such cases the User Information will remain protected in accordance with our Privacy Policy.
  • If you are located in the European Economic Area, or a country with applicable data protection or privacy laws which restricts cross-border transfer of personal information (including User Information), please be aware that we may transfer your User Information to countries which may not guarantee the same level of protection for personal information as the one in which you are currently residing.By providing us with your User Information, you will be deemed to have expressly consented to any cross-border transfer of your User Information to the Company, outsourcing companies, alliance companies, business partners, credit card companies (including Stripe, Inc.), financial institutions and/or any other third party specified under “Provision or Disclosure of User Information to Third Parties” above, each of which may be located in such countries which may not guarantee the same level of protection for personal information as the one in which you are currently residing.While we will only transfer User Information to the extent necessary for the provision and operation of our services, and will endeavor to take all reasonable steps to provide an adequate level of personal information protection in line with those data protection or privacy laws applicable to your country of residence (and at the very least, provide protection in accordance with this Privacy Policy), please be explicitly aware of such cross-border transfer.
  • [Caution!]We will not be responsible for protection of users’ personal information, etc. at websites of third party entities or individuals linked with the Website. Users are strongly recommended to carefully examine such websites for themselves and only access and/or use them after confirmation of their safety and reliability. Where we judge it necessary to take data-protective measures for prevention of unauthorized access to User Information, we use an industry-standard cipher system named SSL (Secure Socket Layer) for transfer of such data.
  • [Caution!]If you provide your personal information via a SSL-incompatible browser for registration, application or ordering in the Website, you may be exposing yourself to the risk of your personal information being read or stolen by third parties not under our control in the course of transferring such information to us. Please use such SSL-incompatible browsers only if you are fully aware of, and are willing to accept, the inherent risks thereto.
  • If, notwithstanding our security measures, you or a third party sustain damages due to any unjust activity of a hacker, etc., we will not be liable for such damage. With respect to information enabling the identification of yourself, please be very careful of its protection so that it may not be lost, forgotten or unwittingly obtained by third parties.

User Information of Minors

With respect to users who are minors, it is necessary for their parents or legal guardians to consent to the terms and conditions of the Privacy Policy, Terms of Use, etc. and comprehensively agree to the minors’ use of the Website based on such Privacy Policy, Terms of Use, etc.

Access from Abroad

Please do not access the Website from foreign countries or areas in which the use, management, operation and/or contents of the Website are illegal or inappropriate under applicable laws and regulations.

Improvement of the Privacy Policy and Confirmation of the Latest Content of the Privacy Policy

We will endeavor to improve the contents of the Privacy Policy. For the latest content of the Privacy Policy, please refer to our website below:

  • (for personal computers/smart phone):

Each user should read the latest Privacy Policy without fail before accessing the Website or using our services. By accessing the Website or using our services, you will be regarded as having agreed to the terms and conditions of our latest Privacy Policy.

Discretion in Provision of User Information

Each user has complete discretion in deciding whether or not to provide personal information to us. However, if you do not provide your personal information to us, you may be unable to receive our responses and/or our services (including consideration of whether or not to employ, for job applicants).

Procedures for Disclosure, Correction, Suspension of Use, etc. of User Information

Each user may confirm or modify his/her personal information as registered in the Website, by logging in to the Website using the log-in ID and password registered.
For other procedures regarding disclosure, correction, suspension of use, etc. of User Information, please contact the personal information protection manager specified below.

Contact for Inquiry about Users’ Personal Information

Contact for inquiry about personal information of users:

  • Responsible person: General Manager, Corporate Operation Department (as personal information protection manager)
  • Tel:81-3-6894-7772

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