IMAGR Limited – Privacy Policy


IMAGR Limited (we or us) is committed to ensuring the privacy of your information, and to meeting the requirements of the Act on the Protection of Personal Information in Japan (APPI). We want to make sure that you understand how we collect and treat personal information in the course of your use of the SMARTCART App and Service, so please read this Privacy Policy carefully. By confirming the contents of this Privacy Policy and clicking the consent button, you are acknowledging and agreeing to the processing of personal information by us.


This Policy applies to all personal information that you submit on or through the App and the Service, and any information that may be automatically retrieved through your use of the App or the Service, including through the Bluetooth pairing of your mobile device with an in-store Smartcart. This Policy should be read in conjunction with our Terms of Use and terms which are defined in those Terms shall have the same meaning when used in this Policy.


By accessing or using the Service or our websites, you consent to the collection, use, disclosure, storage and processing of your personal information in accordance with this Policy.


We collect personal information about you when you register an Account and use the Service. The personal information we collect includes:

  • the information you enter into the App, such as your Account Information;
  • information about how you use the Service, including:
    • information about the goods you purchase; and
    • location data relating to the position of the Smartcart you pair with while you are in a Store;
  • other information about how the Service is used (for example, traffic volumes, time spent on pages);
  • your IP address and/or other device identifying data (to help detect unauthorised account use); and
  • other information that you may disclose to us during the course of our relationship with you.

You are under no obligation to provide us with any such information. However, if you choose to withhold requested information, we may not be able to provide you with the Service. For example, we need to hold certain minimum information about authorised users in order to maintain access controls to the Service and for security and user verification purposes.

When you create an Account on the App, you will be directed to the website of a third-party payment processing provider's website and asked to enter payment details (for example, your credit card details). Any personal information you enter via this third party's website is subject to the third party's privacy policy and may be used only for the purposes of processing payments transacted by you in using the Service.


We will use the personal information we collect to:

  • provide the Service to you and other authorised users;
  • identify you when you sign-in to your Account and verify that your Account is not being used by others;
  • communicate with you in relation to the Service and related issues (eg, quotes for other services, support requests and billing matters);
  • communicate information about your use of the Service to the Store at which you used the Service;
  • carry out research and marketing analysis so we can better understand and serve you;
  • direct marketing and other information to you based on your purchases;
  • monitor and enforce compliance with the law and applicable terms and conditions;
  • verify and carry out financial transactions in relation to services we provide; and
  • co-operate with any government, industry or regulatory authorities.


Unless you have authorised us to do so, we will not rent or sell any personal information and will not disclose it to any third party except:

  • to the Store where you use the Service and to the Stores’ POS providers;
  • to our third party service providers (such as hosting providers and payment processing providers) in connection with the purposes described in clause 5;
  • to relevant authorities, parties and/or applicable intellectual property rights holders (or their representatives) if we consider that you are in breach of the law or our rights; or
  • where required, or permitted, by law.

We may rent or sell anonymised data (Statistical Data) to third parties. Such Statistical Data will not be capable of identifying you individually.

We may choose to sell our business. In these types of transactions, personal information is typically one of the business assets transferred to the third party purchaser. You acknowledge and agree that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set out in this Policy.


We will jointly use your personal information as described below:

  • Personal information subject to joint use
    — the personal information to be collected as described in clause 4 above.
  • Range of joint users
    — us and our related companies IMAGR Holdings Limited, IMAGR K.K., IMAGR Limited, Imagr B.V.
  • Joint users’ purposes of use
    — achieving the purposes of use described in clause 5.
  • Party responsible for managing your personal information


We use session-based cookies to collect information relating to usage of the Service and analyse traffic. Cookies are small pieces of information that are stored in a browser-related file on your computer or device when you use the Service. The cookies we use do not collect any personally identifiable information.


You can unsubscribe from any marketing communications from us by following the instructions on any communications sent to you. You can also exercise this right at any time by contacting us using the details at the end of this Privacy Policy.


You have the following rights with respect to your personal data under the APPI. You can exercise these rights by contacting us using the details at the end of this Privacy Policy. When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights. You will not have to pay a fee to access your personal data (or to exercise any of the other rights); however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  • You can contact us at any point to request notification of the purposes of use and disclosure of your personal data that we hold.
  • If your personal data that we hold is out of date, incomplete or incorrect, you can inform and make a request to us that your personal data should be revised, added or deleted.
  • If your personal data that we hold is unlawfully processed, you can request that we suspend the use, remove your personal data, or suspend the third-party provision of your personal data that we hold.


You should be aware that information transmitted over the internet is not always secure. We will take all reasonable steps to securely store any personal information we collect. This information may (for the avoidance of doubt) be transferred and stored on servers outside of Japan.


We will only retain your personal information for as long as is required for any of the purposes described in clause 5 or 6 above.


We may amend or update this Privacy Policy from time to time, with or without notice to you. Revised versions will be effective immediately once posted at You agree to be bound by the Privacy Policy that is in effect at the time you use the Service.


If you have any questions about this Privacy Policy or if you would like to exercise your rights in relation to your personal data described in clause 10, you can get in touch by writing to us at or 1-4-40, JBSL Umeda Building 9F, Fukushima, Fukushima-ku, Osaka, 553-0003 Japan.


This Privacy Policy is governed by Japanese law. For more information about privacy issues in Japan and protecting your privacy, visit the Japan Personal Information Protection Commission website: