— Legal
Privacy Policy
Last updated: 20 May 2026
HARRO Netherlands B.V. (hereinafter referred to as the “Company”) establishes this Privacy Policy (hereinafter referred to as the “Policy”) regarding the handling of users’ personal information in the HARRO Snack services provided on this website (hereinafter referred to as the “Services”).
Article 1 (Personal Information)
“Personal Information” means information about a living individual as defined in the Personal Information Protection Act, and refers to information that can identify a specific individual by name, date of birth, address, telephone number, contact details, or other descriptions contained therein; as well as data relating to appearance, fingerprints, voiceprints, and the insurer number on health insurance cards, or any other information that can identify a specific individual on its own (collectively referred to as “Personally Identifiable Information”).
Article 2 (Method of Collecting Personal Information)
The Company may ask users to provide personal information such as name, date of birth, address, telephone number, email address, bank account number, and credit card number when registering for use of the Services.
During the pre-launch period of HARRO Snack, the Company collects only the email address through the waitlist form. The form is processed by Google Forms (Google Ireland Ltd., Dublin), which may also log technical data (IP address, browser, timestamp).
The Company may also collect transaction records or payment information involving transactions between the user and our business partners (hereinafter collectively referred to as “Partners”)—such as information providers, advertisers, and advertising distributors—that include personal information.
Article 3 (Purpose of Collecting and Using Personal Information)
The Company collects and uses personal information for the following purposes:
1. To provide and operate the Services, including the pre-launch waitlist and the subsequent subscription and one-off box service;
2. To respond to user inquiries (including verifying the identity of the user);
3. To send emails regarding launch announcements, new features, updates, campaigns, and other information about the Services;
4. To contact users as necessary for maintenance, shipping, or important notices;
5. To identify and refuse use by users who violate the Terms of Use or attempt to use the Services for fraudulent or improper purposes;
6. To allow users to view, change, delete, or check their own registration information and usage status;
7. To charge users for paid services and process payments;
8. For purposes incidental to the above purposes.
Article 4 (Change of Purpose of Use)
The Company may change the purpose of use of personal information only when it is reasonably deemed to be related to the purpose before the change.
If the purpose of use is changed, the Company shall notify users of or publicly announce the new purpose in a manner prescribed by the Company.
Article 5 (Provision of Personal Information to Third Parties)
The Company shall not provide personal information to third parties without the prior consent of the user, except in the following cases or as permitted by the Personal Information Protection Act and other applicable laws and regulations:
1. When it is necessary for the protection of a person’s life, body, or property and it is difficult to obtain the consent of the individual;
2. When it is particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the individual;
3. When it is necessary to cooperate with a national or local government agency, or a person entrusted thereby, in executing affairs prescribed by laws and regulations, and obtaining consent would interfere with the execution of such affairs;
4. When the following matters have been notified or publicly announced in advance and the Company has filed a report with the Personal Information Protection Commission:
・Inclusion of provision to third parties in the purpose of use;
・Items of data to be provided to third parties;
・Means or methods of provision to third parties;
・Provision to third parties will be suspended upon the individual’s request; and
・Method for receiving such requests.
Notwithstanding the foregoing, the following cases shall not be regarded as provision to third parties:
1. When the Company entrusts the handling of personal information, in whole or in part, within the scope necessary to achieve the purpose of use;
2. When personal information is provided due to business succession by merger or other reasons;
3. When personal information is jointly used with specific persons, and the items of personal information jointly used, the scope of joint users, the purpose of use, and the name or title of the person responsible for managing such personal information are notified to the individual in advance or made easily accessible.
Article 6 (Disclosure of Personal Information)
When requested by the individual, the Company shall promptly disclose the personal information held about that individual.
However, disclosure may be withheld in whole or in part if any of the following apply, and in such cases the Company shall promptly notify the individual of the decision not to disclose:
1. If disclosure may harm the life, body, property, or other rights or interests of the individual or a third party;
2. If disclosure may seriously impede the proper execution of the Company’s business;
3. If disclosure would violate any law or regulation.
A handling fee of 10 EUR per request will be charged for disclosure of personal information.
Notwithstanding the foregoing, the Company generally does not disclose non-personal information such as historical or characteristic data.
Article 7 (Correction and Deletion of Personal Information)
If a user finds that the personal information held by the Company is incorrect, the user may request correction, addition, or deletion (collectively, “Correction, etc.”) according to procedures specified by the Company.
If the Company deems it necessary to respond to such a request, it shall promptly make the Correction, etc.
The Company shall promptly notify the user when such Correction, etc. has been made or when a decision has been made not to make such Correction, etc.
Article 8 (Suspension of Use, etc. of Personal Information)
If the Company receives a request from the individual to suspend or delete the use of personal information (“Suspension, etc.”) on the grounds that it has been handled beyond the scope of the stated purpose or was obtained by improper means, the Company shall promptly conduct a necessary investigation.
If, based on the results of the investigation, it is determined that the request is valid, the Company shall promptly carry out the Suspension, etc.
The Company shall notify the user without delay when the Suspension, etc. has been carried out or when a decision has been made not to do so.
Notwithstanding the foregoing, if the Suspension, etc. requires excessive costs or is otherwise difficult to carry out, and alternative measures necessary to protect the user’s rights and interests can be taken, the Company shall implement such alternative measures.
Article 9 (Changes to This Policy)
Except as otherwise provided by laws or this Policy, the Company may change the contents of this Policy without notifying users.
Unless otherwise specified by the Company, the revised Policy shall take effect when posted on this website.
Article 10 (Contact Information)
For inquiries regarding this Policy, please contact the following:
Company: HARRO Netherlands B.V.
Email: info@harrojp.com
