Last updated: June 19, 2026

PRIVACY POLICY

Introduction

This Fujiya store and associated website is operated by FUJIYA CO., LTD., a Japanese corporation, together with its affiliate Fujiya USA Corporation (collectively, “we,” “us,” or “the Company”), operating, including but not limited to, all pertinent information, content, features, tools, products and services, in order to provide you, the customer, with a curated shopping experience (the “Services”). Our online store is hosted on Shopify’s e-commerce platform, which enables us to provide the Services to you. This Privacy Policy describes how we collect, use, and disclose your personal information when you visit, use, or make a purchase or other transaction using the Services or otherwise communicate with us. If there is a conflict between our Terms of Service and this Privacy Policy, this Privacy Policy controls with respect to the collection, processing, and disclosure of your personal information. Please read this Privacy Policy carefully. By using and accessing any of the Services, you acknowledge that you have read this Privacy Policy and understand the collection, use, and disclosure of your information as described in this Privacy Policy.

1. Personal Information We Collect or Process

When we use the term “personal information,” we are referring to information that identifies or can reasonably be linked to you or another person. Personal information does not include information that is collected anonymously or that has been de-identified, so that it cannot identify or be reasonably linked to you. Depending on how you interact with the Services, where you live, and as permitted or required by applicable law, we may collect or process the following categories of personal information, including inferences drawn from this information:

•       Contact details, including your name, billing address, shipping address, phone number, and email address.

•       Financial information, including payment card type, the last four digits of your card number, payment card token or other payment identifier, transaction details, form of payment, payment confirmation, and other payment details. We do not store your full credit card number on our systems. Payment information is processed by Shopify Payments and other payment processors such as PayPal on our behalf, in accordance with applicable security standards.

•       Account information, including your username, password, security questions, preferences, and settings.

•       Transaction information, including the items you view, put in your cart, add to your wishlist, or purchase, return, exchange or cancel, and information about your past transactions with us.

•       Communications with us, including the information you include in communications with us, for example, when sending a customer support inquiry, responding to surveys, or participating in promotions.

•       Device information, including information about your device, browser, or network connection, your IP address, operating system, language settings, and other unique identifiers.

•       Usage information, including information regarding your interaction with the Services, such as the pages or content you view, search queries, the referring and exit pages, the dates and times of your visits, the links you click, and how and when you interact with or navigate the Services.

•       Geolocation data, including precise location data from your device when you use our mobile applications or website, if you have enabled location services.

•       Audio, visual, and biometric information, including photographs, video recordings, voice recordings, and voiceprints or other biometric identifiers, where you participate in our content production activities. Our collection and handling of such information from minors is governed by Section 16.

•       Government-issued identifiers, where lawfully required (for example, for age verification, tax, or compliance purposes), including identifiers such as a state identification or passport number.

•       Inference data, including information derived from other personal information we collect, such as preferences, characteristics, predispositions, or purchase tendencies.

2. Personal Information Sources

We may collect personal information from the following sources:

•       Directly from you, including when you create an account, visit or use the Services, place an order, subscribe to our emails, complete a form, participate in a promotion, or otherwise provide us with your personal information.

•       Automatically through the Services, including from your device when you use our products or services or visit our websites, and through the use of cookies, pixels, web beacons, and similar technologies.

•       From our service providers, including when we engage them to enable certain technology or perform services (such as payment processing, hosting, analytics, marketing, customer support, or fulfillment) and when they collect or process your personal information on our behalf.

•       From our business and marketing partners or other third parties, including advertising networks, analytics providers, and social media platforms, where permitted by law.

•       From parents or legal guardians, in connection with a minor’s participation in our content production activities, as further described in Section 16.

•       From publicly available sources, including public records, social media platforms, and other publicly available sources, to the extent permitted by applicable law.

3. How We Use Your Personal Information

3.1 Provide, Tailor, and Improve the Services

We use your personal information to provide you with the Services, including to perform our contract with you, to process your payments, to fulfill and deliver your orders and subscription boxes, to remember your preferences and items you are interested in, to send notifications to you related to your account or orders, to process purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, to facilitate any returns and exchanges, to enable you to post reviews, and to create a customized shopping experience for you, such as recommending products related to your purchases. We may also use your information to monitor and improve the Services.

3.2 Marketing and Advertising

We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you online advertisements for products or services on the Services or other websites, including based on items you previously have purchased or added to your cart and other activity on the Services. You may opt out of certain marketing communications as described in Section 9 of this Privacy Policy. We do not use the personal information of consumers we know to be under sixteen (16) years of age for cross-context behavioral advertising without the affirmative opt-in consent required by applicable law.

3.3 Security and Fraud Prevention

We use your personal information to authenticate your account, provide a secure payment and shopping experience, detect, investigate or take action regarding possible fraudulent, illegal, unsafe, or malicious activity, protect public safety, protect our rights and the rights of others, and to secure our Services. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We recommend that you do not share your username, password or other access details with anyone else.

3.4 Communicating with You

We use your personal information to provide you with customer support, respond to your inquiries and requests, handle complaints, send service-related communications, and otherwise maintain our business relationship with you.

3.5 Legal and Compliance Purposes

We use your personal information to comply with applicable law or respond to valid legal process, including requests from law enforcement or government agencies; to investigate or participate in civil discovery, potential or actual litigation, or other adversarial legal proceedings; and to enforce or investigate potential violations of our terms, policies, or other applicable rules.

3.6 Analytics and Research

We use your personal information to conduct analytics, research, and development activities to improve our Services, develop new products and features, and conduct audits and troubleshooting activities. This includes analyzing how users interact with our Services, identifying trends and patterns in usage and shopping behavior, and evaluating the effectiveness of our marketing campaigns.

3.7 Business Operations

We use your personal information to operate our business, such as managing inventory, processing payments, maintaining financial records, and conducting internal audits and investigations.

4. How We Disclose Personal Information

4.1 With Service Providers

We share personal information with Shopify and other vendors and service providers who perform services on our behalf, such as website hosting, information technology, payment processing, order fulfillment, warehousing and logistics, customer support, email delivery, marketing, analytics, and cloud storage. These service providers are contractually bound to process personal information only on our instructions and to protect it.

4.2 With Business and Marketing Partners

We may share personal information with business and marketing partners to provide marketing services and advertise to you. For example, we may use advertising networks and analytics providers to show you personalized ads or measure the effectiveness of our marketing. These partners will use your information in accordance with their own privacy notices.

4.3 With Third Parties at Your Direction or With Your Consent

We may disclose personal information when you direct us to do so, when it is necessary to provide the Services, or when you otherwise consent to such sharing, for example, when you use social media widgets or login integrations, participate in co-branded promotions, or choose to share content from the Services on social media.

4.4 With Our Affiliates

We may share personal information with our affiliates or otherwise within our corporate group as needed to provide and improve the Services.

4.5 In Connection with a Business Transaction

We may disclose personal information in connection with a proposed or actual merger, acquisition, reorganization, sale of assets, financing, or bankruptcy or similar event, including during due diligence.

4.6 For Legal, Safety, and Protection Purposes

We may disclose personal information to comply with any applicable legal obligations (including to respond to subpoenas, search warrants, court orders, or similar requests); to enforce any applicable terms of service or policies; and to protect or defend the Services, our rights, and the rights of our users or others.

4.7 No Sale of Personal Information

We do not sell your personal information and we do not share your personal information for cross-context behavioral advertising in a way that would be considered a “sale” or “sharing” under applicable California law without offering you an opportunity to opt out. We do not sell or share the personal information of any individual we know to be under sixteen (16) years of age without the affirmative opt-in consent required by California Civil Code Section 1798.120(c) (parental consent for consumers under thirteen (13); the minor’s own opt-in consent for consumers thirteen (13) to fifteen (15)).

5. Relationship with Shopify

Our store is hosted on Shopify Inc. Shopify provides us with the online e-commerce platform that allows us to sell our products and services to you. Your data may be stored through Shopify’s data storage, databases and the general Shopify applications. Shopify stores your data on secure servers behind a firewall and processes certain personal information about your use of our store, including for fraud detection, security, analytics, and to improve Shopify’s services. In some cases, Shopify acts as an independent controller of your personal information. To learn more about how Shopify uses your personal information, the legal bases it relies on, and how you can exercise your rights with respect to data processed by Shopify, you can visit the Shopify Consumer Privacy Policy at https://www.shopify.com/legal/privacy and the Shopify Privacy Portal at https://privacy.shopify.com.

6. Cookies and Similar Technologies

We use cookies, pixels, web beacons, and similar technologies to operate and improve the Services, remember your preferences, keep you signed in, understand how you use the Services, and personalize content and advertising. Cookies are small data files that are placed on your device when you visit a website. You can control cookies through your browser settings, including by blocking or deleting cookies, or by setting your browser to alert you when cookies are being sent. If you disable cookies, some features of the Services may not function properly. Where required by applicable law, we will request your consent before placing non-essential cookies or similar technologies on your device, and you can withdraw your consent at any time through your browser settings or, where available, through a cookie preferences tool on our website. We honor recognized opt-out preference signals, including the Global Privacy Control (GPC), as a valid request to opt out of the sale or sharing of personal information transmitted through the browser or device from which the signal is sent, as required by California law.

6.1 Types of Cookies We Use

•       Essential cookies: These cookies are necessary for the website to function properly and cannot be switched off in our systems.

•       Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.

•       Functional cookies: These cookies enable the website to provide enhanced functionality and personalization.

•       Targeting cookies: These cookies may be set through our site by our advertising partners to build a profile of your interests and show you relevant advertisements on other sites.

6.2 Managing Your Cookie Preferences

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or not function properly.

7. Children’s and Minors’ Data

The general Services (our e-commerce platform) are not directed to children and are not intended to be used by children, and we do not knowingly collect personal information from children through our general Services. If you are the parent or guardian of a child who has provided personal information through our general Services, please contact us at support@fujiyausa.com to request deletion, and we will delete such information in accordance with applicable law. As of the effective date of this Privacy Policy, we do not have actual knowledge that we sell or share the personal information of individuals under sixteen (16) years of age through our general Services, as those terms are defined in applicable California law. Our collection and handling of personal information from minors under eighteen (18) years of age in connection with our content production activities is governed separately by Section 16 of this Privacy Policy, which controls in the event of any conflict with respect to such information.

8. Security and Retention of Your Information

We use reasonable technical and organizational measures designed to protect your personal information from unauthorized access, use, alteration, or destruction. However, no security measures are perfect or impenetrable, and we cannot guarantee absolute security. Any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide you with the Services, to comply with legal obligations, to resolve disputes, or to enforce other applicable contracts and policies. In general, we apply the following guidelines:

•       Transaction and billing records are typically retained for at least seven years to comply with tax, accounting, and legal requirements.

•       Marketing-related information (such as email subscription data) is retained until you unsubscribe or otherwise opt out, or until we decide to delete the data in accordance with our internal policies.

•       Account information is retained for as long as your account is active. After account closure, we may retain certain information for an additional period where necessary for legal, accounting, or compliance purposes.

•       Personal information collected from minors in connection with content production is retained in accordance with the data-retention provisions of Section 16, including the prohibition on indefinite retention of the personal information of children under thirteen (13).

•       De-identified or aggregated information that does not identify you may be retained indefinitely.

8.1 Data Security Measures

We implement and maintain reasonable security measures to protect your personal information, including encryption of sensitive personal information both in transit and at rest, regular security assessments and vulnerability testing, access controls and authentication procedures, employee training on data security and privacy practices, incident response planning and procedures, and regular monitoring and auditing of our systems and processes. We maintain a written information security program governing the personal information of children, as described in Section 16.8.

8.2 Data Breach Notification

In the event of a data breach that compromises your personal information, we will notify you and relevant authorities as required by applicable law.

9. Your Rights and Choices Under California Law

9.1 Right to Know and Access

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale or sharing of your personal information.

9.2 Right to Delete

You have the right to request that we delete any personal information about you that we have collected from you, subject to certain exceptions.

9.3 Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you.

9.4 Right to Opt-Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising purposes. While we do not currently sell your personal information or share it for cross-context behavioral advertising, you can exercise your right to opt out by clicking on the “Do Not Sell or Share My Personal Information” link in the footer of our website, by transmitting a recognized opt-out preference signal such as the Global Privacy Control (GPC), which we honor, or by contacting us using the contact details provided below.

9.5 Right to Limit Use of Sensitive Personal Information

To the extent we use or disclose sensitive personal information for purposes other than those permitted under applicable law, you have the right to direct us to limit our use of that sensitive personal information.

9.6 Right to Non-Discrimination

We will not discriminate or retaliate against you for exercising any of your privacy rights.

9.7 Exercising Your Rights

To exercise the rights described above, please contact us by emailing support@fujiyausa.com or by submitting a request through our website. We will confirm receipt within ten (10) business days and will respond to your request within forty-five (45) days of its receipt, with one additional forty-five (45)-day extension where reasonably necessary and permitted by law. We will take steps to verify your identity before fulfilling your request.

9.8 Authorized Agent

You may designate an authorized agent to submit requests on your behalf. We may require the authorized agent to provide proof of authorization and may require you to verify your identity directly with us.

9.9 Right to Appeal

In certain jurisdictions, if we decline to take action on your request, you have the right to appeal that decision. To appeal, please contact us using the contact details in Section 14. If we deny your appeal, you may contact your state attorney general or applicable regulatory authority to submit a complaint.

9.10 Notice of Financial Incentive

If we offer any financial incentives in exchange for the retention or sale of your personal information, we will provide a written description of the material terms of such program. Participation is entirely voluntary and requires your prior opt-in consent, which you may revoke at any time.

10. Your Rights Under Other Privacy Laws

10.1 European Economic Area, United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, you may have certain rights under applicable data protection laws, including the GDPR, such as the right of access, right to rectification, right to erasure, right to restrict processing, right to data portability, right to object, and right to withdraw consent. To exercise these rights, please contact us using the contact details provided in Section 14 below.

10.2 Other U.S. State Privacy Laws

Depending on your state of residence, you may have rights under a comprehensive state privacy law. As of the date of this Policy, comprehensive consumer privacy statutes are in effect in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Jersey, New Hampshire, Nebraska, Maryland, Minnesota, Tennessee, Indiana, Kentucky, and Rhode Island, among others, with additional state laws taking effect on a rolling basis. Subject to the particular statute and applicable exceptions, these laws generally afford residents the rights to confirm, access, correct, delete, and obtain a portable copy of their personal data; to opt out of targeted advertising, the sale of personal data, and certain profiling; to limit the processing of sensitive data (which in several states requires opt-in consent); and to appeal a denial of a request. Several of these statutes also prohibit processing the personal data of a known minor under eighteen (18) for targeted advertising or sale without consent. To exercise any of these rights, please contact us using the contact details in Section 14 below.

10.3 Other Jurisdictions

Depending on your jurisdiction, you may have additional rights under applicable local privacy laws. Please contact us using the contact details provided in Section 14 below to learn more.

11. Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. You may also have the right to lodge a complaint with your local data protection authority or regulatory body, such as the California Attorney General’s Office or the California Privacy Protection Agency.

12. International Transfers

We are based in Japan and the Services are intended for customers in the United States. However, we may transfer, store, and process your personal information outside of the country where you live, including in Japan, the United States, and other countries that may have different data protection laws than those in your country. When we transfer personal information from the EEA, UK, or Switzerland to countries without an adequacy determination, we use appropriate safeguards such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, and, where applicable, Binding Corporate Rules.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the revised Privacy Policy on this website and update the “Last Updated” date at the top. Where required by applicable law, we will provide additional notice of, or obtain your consent to, material changes. Your continued use of the Services after any changes become effective will signify your acceptance of the revised policy.

14. Contact

If you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please contact us at:

FUJIYA CO., LTD.

2-15-6 Otsuka, Bunkyo-ku, Tokyo 112-0012, Japan

Email: support@fujiyausa.com

Website: https://www.fujiyausa.com/

For matters concerning minors and content production, you may also contact our designated privacy contact: Junji Suzuki, Esq., junji.suzuki@fujiyausa.com, telephone (415) 725-8897.

We aim to respond to inquiries within 1–2 business days.

15. Additional Information for California Residents

15.1 California Shine the Light Law

California Civil Code Section 1798.83 permits California residents to request information about categories of personal information we disclosed to third parties for direct marketing purposes once per year, free of charge. To make such a request, please contact us using the information provided in Section 14.

15.2 California Privacy Rights for Minor Users (“Eraser” Right)

California Business and Professions Code Section 22581 allows California residents under the age of eighteen (18) who are registered users of online sites, services, or applications to request removal of content or information they have publicly posted. To request removal, please contact us using the information in Section 14. Please note that removal may not be complete or comprehensive, for example where content has been republished or shared by third parties, as provided by statute.

15.3 Notice at Collection

At or before the point of collection, we inform California residents of the categories of personal information to be collected, the categories of sensitive personal information to be collected, the purposes for which such information will be used, whether the information is sold or shared, and the applicable retention periods, as provided through this Privacy Policy and other notices we may provide.

15.4 California Consumer Privacy Act (CCPA) Metrics

To the extent required by the CCPA, we will annually disclose information about requests we received from California residents to exercise their CCPA rights during the previous calendar year.

16. Children’s and Minors’ Content Production Privacy Notice

This section applies solely to the collection and handling of personal information from minors in connection with Fujiya USA Corporation’s content production activities (for example, the production of photographs, video, and social media content). It supplements all other sections of this Privacy Policy and controls in the event of any conflict regarding a minor’s personal information in a content production context. This section is to be read together with the Minor Consent and Likeness Release Agreement executed by the parent or legal guardian (the “Release”); in the event of a conflict between this section and the Release as to the scope of the license to use Materials, the Release controls, and as to data-protection rights and obligations, this section controls.

16.1 Scope and Definitions

For purposes of this section: a “Minor” means any participating individual under eighteen (18) years of age; a “Child” means a Minor under thirteen (13) years of age, whose personal information is subject to the Children’s Online Privacy Protection Act (“COPPA”) and the FTC’s amended COPPA Rule; and a “Teen” means a Minor who is thirteen (13) to seventeen (17) years of age, whose personal information is subject to applicable state privacy laws and to the parental-consent framework of the Release. Where a requirement below is identified as a COPPA requirement, it applies to Children; the protections of this section otherwise apply to all Minors regardless of age.

16.2 Information We Collect from Minors

In connection with our content production projects, we collect the following categories of personal information from or about participating Minors:

•       Full legal name, age, and date of birth;

•       Photographs, video recordings, voice recordings, voiceprints, and other media capturing the Minor’s image, likeness, voice, or performance, including biometric identifiers;

•       Health and medical information disclosed by the parent or guardian to ensure safe participation;

•       Parent or guardian contact information, including name, address, telephone number, and email address;

•       Government-issued identifiers, where lawfully required for age verification or compliance; and

•       Participation and performance data generated during production activities.

We collect only the information reasonably necessary for the Minor’s safe and effective participation. We do not condition a Minor’s participation on the disclosure of more personal information than is reasonably necessary to participate in the activity.

16.3 How We Use This Information

We use a Minor’s personal information solely for the following purposes:

•       Producing, editing, distributing, and promoting project content;

•       Ensuring the Minor’s health and safety during production;

•       Communicating with the parent or guardian regarding the project; and

•       Complying with applicable legal obligations, including COPPA, the Federal Trade Commission’s advertising and endorsement guidelines, and applicable state privacy laws.

16.4 How We Share This Information

We may share a Minor’s personal information with the following categories of recipients: production service providers and contractors; platform providers and distributors on which the content will be made available (for example, TikTok, Instagram, and Facebook); marketing partners; legal and regulatory authorities as required by law; and any successors or assigns of Fujiya USA Corporation. We do not sell a Minor’s personal information, and we do not share it for cross-context behavioral advertising. For Children under thirteen (13), we obtain separate verifiable parental consent before disclosing personal information to third parties for any purpose that is not integral to the activity in which the Child participates, as required by the amended COPPA Rule. Upon request, we will provide a parent or guardian with the identities or specific categories of the third parties to which we disclose a Child’s personal information and the purposes of such disclosure.

16.5 Parental and Guardian Rights

As the parent or legal guardian of a participating Minor, you have the right to:

•       Review the personal information we have collected from your child;

•       Request deletion of your child’s personal information, subject to our legal obligations and the rights granted under the Release;

•       Refuse to permit our further collection or use of your child’s personal information; and

•       Withdraw consent to further collection or use of your child’s personal information at any time by providing written notice in accordance with Article 8 of the Release.

To exercise any of these rights, please contact our designated privacy contact, Junji Suzuki, Esq., at junji.suzuki@fujiyausa.com or telephone (415) 725-8897, or at the address listed in Section 14. We will verify that the requester is the Minor’s parent or guardian and will respond within forty-five (45) days of receipt. You may exercise these rights without the Minor’s participation being conditioned on, or penalized by, your decision.

16.6 Verifiable Parental Consent

For Children under thirteen (13), we obtain verifiable parental consent prior to collecting personal information, consistent with COPPA. The signed Release serves as a principal mechanism for obtaining such consent, supplemented by reasonable measures to confirm the consenting individual is the Child’s parent or legal guardian. For Teens aged thirteen (13) to seventeen (17), we collect personal information on the basis of the parental or guardian consent provided in the Release and the consent requirements of applicable state law. A parent, guardian, or the Minor may withdraw consent and discontinue further participation at any time in accordance with Article 8 of the Release.

16.7 Data Retention

We maintain a written data-retention policy governing the personal information of Minors. We retain a Minor’s personal information only for as long as is reasonably necessary to fulfill the purposes described in this section, and we do not retain such information indefinitely. For Children under thirteen (13), we set a maximum retention period tied to the specific purpose of collection, after which the information is deleted, consistent with the amended COPPA Rule’s prohibition on indefinite retention. The foregoing retention limits apply to underlying personal information (such as health, contact, and unused production data); finished Materials that incorporate a Minor’s likeness or performance and that have been published or licensed are retained and used pursuant to the license granted under the Release, which the parent or guardian acknowledges is perpetual and irrevocable as to Materials created prior to any withdrawal of consent.

16.8 Information Security Program

We establish, implement, and maintain a written information security program that contains safeguards appropriate to the sensitivity of the personal information collected from Minors and to our size and complexity, including administrative, technical, and physical safeguards designed to protect the confidentiality, security, and integrity of such information, consistent with the amended COPPA Rule. We periodically assess and update these safeguards.

16.9 FTC Endorsement and Disclosure Compliance

Content involving Minors may constitute advertising subject to the Federal Trade Commission’s endorsement and advertising guidelines, including requirements to clearly and conspicuously disclose material connections. We are responsible for determining and providing the required disclosure language and formatting, and parents or guardians agree to cooperate in implementing such disclosures as provided in the Release.

16.10 Additional Protections for California Minors

California residents under eighteen (18) who have publicly posted content may request its removal under California Business and Professions Code Section 22581, as described in Section 15.2. We do not sell or share the personal information of any Minor under sixteen (16) without the opt-in consent required by California Civil Code Section 1798.120(c). To the extent the California Protecting Our Kids from Social Media Addiction Act (SB 976) or its implementing regulations apply to any of our activities, we will comply with their requirements, including any applicable parental-consent and default-setting provisions.

16.11 Updates to This Section

We may update this section to reflect changes in our content production practices or in applicable law, including future amendments to COPPA or state children’s privacy statutes. Material changes affecting a Minor’s personal information will be communicated to the relevant parent or guardian where required by law or the Release.

END OF PRIVACY POLICY