日本語

The Japanese version of this policy is the authoritative text. This English version is a translation; where the two differ in any respect, the Japanese version prevails.

Privacy Policy

Last revised: 18 September 2026

NAMINOL LLC (NAMINOL合同会社, “we” or “the Company”) operates FilmedSurf, a marketplace for surf footage (“the Service”). We handle users’ personal information in compliance with Japan’s Act on the Protection of Personal Information (APPI) and other applicable laws.

1. Operator and contact point

2. Information we collect

3. Purposes of use

4. Collection requiring your consent (device features)

Collection that involves access to device features — location, push notifications, saving to your camera roll — takes place only after you have granted permission through your operating system’s dialog. You can withdraw these permissions at any time from your device or app settings.

5. Provision to third parties and outsourcing

We entrust the handling of personal information to the following providers, to the extent necessary to operate the Service. We supervise those providers appropriately.

Some features of the Service also send data to the AI providers below, to the extent required for that processing. What we send includes still frames extracted from footage you uploaded, in which people may appear.

Provision to credit card companies. Separately from the outsourcing above, in connection with credit card processing we may provide a filmer’s name, representative’s name, gender, date of birth, address, contact details, business description, and other information to credit card companies (including JCB Co., Ltd. and JCB group card companies), to the extent necessary to enter into and perform merchant agreements and to verify that the filmer (as seller) is not a member of anti-social forces. This is provision to a third party, not outsourcing: the receiving card companies use that information for their own purposes. The basis for this provision is your consent under Article 16(3) of the Terms of Service.

Except for the outsourcing and third-party provision described above and where necessary to operate the Service, we do not provide personal data to third parties without your prior consent, other than as required by law.

6. External transmission (Telecommunications Business Act)

Our app and website transmit information recorded on your device, and information about your actions and access, to the external providers below, in order to understand usage, improve quality, and detect faults (Article 27-12 of Japan’s Telecommunications Business Act).

If you would like these transmissions stopped, please contact support@naminol.com.

7. Provision to third parties abroad (cross-border transfer)

Most of the providers and recipients above host their servers primarily in the United States, or are located in the United States or other countries (Stripe, AWS, Clerk, Anthropic, Runway, ElevenLabs, Mixpanel, Sentry, and others). Under Article 28 of the APPI, we transfer data to these third parties abroad only after putting in place, and continuing to maintain, the measures necessary to protect your rights and interests — that is, arrangements such as appropriate contractual terms that meet standards equivalent to Japan’s APPI — and we verify that those measures are being implemented. We will provide, on request, the names of the countries concerned and information about their personal data protection regimes (support@naminol.com).

8. Retention periods and retention of poster information

We retain personal data for as long as necessary to achieve the purposes of use, or for the period required by law, and thereafter delete or anonymise it appropriately. We may retain a poster’s registration details, IP address, access logs, and similar for a certain period in order to respond to reports of rights infringement and to other legal requirements (such as disclosure of sender information under Japan’s Information Distribution Platform Countermeasures Act).

9. Your rights

Under Articles 33 to 35 of the APPI you may request the disclosure, correction, addition, deletion, suspension of use, or suspension of provision to third parties of your retained personal data. Requests are accepted at support@naminol.com or through the Support page. We will verify your identity and respond without delay in accordance with the law.

10. Account deletion

You may request deletion of your account from within the app or through our support channel. On deletion, the personal information linked to your account is deleted or anonymised, other than information we are legally required to retain (accounting records, payment records, logs needed to handle rights-infringement matters, and the like). We will tell you what is deleted and what is retained when you make the request.

11. If we introduce face matching (FaceMatch)

If we introduce face matching in future to improve how accurately we match people to clips, we will collect and use the biometric-related information involved — such as facial feature data — only with your voluntary, explicit consent, and you will be able to withdraw that consent at any time. On withdrawal, we will promptly delete the biometric-related information concerned. (This section is advance notice about a possible future feature; it does not apply while that feature is not offered.)

12. Cookies and similar (web)

Our website may use cookies and similar technologies to provide the Service, improve convenience, and analyse usage. You can disable cookies in your browser settings, though some features may then be unavailable.

13. Changes to this policy

We may revise this policy in response to changes in the law or to the Service. We will announce significant changes on the Service.

14. Contact

For enquiries about this policy, please contact support@naminol.com or use the Support page.