PRIVACY POLICY

• 1User Information to Be Collected and Method of Collection

  For the purposes of this Policy, “User Information” means information related to the identification of users, behavioral history on communication services, and any other information generated or accumulated in connection with the user or the user’s device, which the Firm collects in accordance with this Policy.
  User Information collected by the Firm in the Services includes the following, depending on the method of collection:

  1. Information provided by the user
     Information provided by the user when using the Services or through the use of the Services includes:
     ・Profile information such as name, date of birth, gender, occupation
     ・Contact information such as email address, phone number, and address
     ・Payment information such as credit card details, bank account information, and electronic money information
     ・Still images including the user’s likeness
     ・Information entered or transmitted by the user through input forms or other methods specified by the Firm
  2. Information provided by external services when linked by the user
     If the user permits linkage with external services, such as social networking services, the Firm may collect the following information from such external services based on the user's consent at the time of linkage:
     ・IDs used by the user on the external service
     ・Other information disclosed by the user to the linked service according to the external service’s privacy settings
  3. Information collected by the Firm during service use
     The Firm may collect information regarding access status and usage of the Services, including:
     ・Referrer information
     ・IP address
     ・Server access logs
     ・Cookies, ADID, IDFA, and other identifiers
  4. Information collected based on the user’s individual consent
     If the user individually consents in the manner specified in Article 3.1, the Firm may collect the following information from the user’s device:
     ・Location information

• 2Purpose of Use

  The Firm uses User Information for the following purposes in connection with the provision of the Services:

  1. Provision, maintenance, protection, and improvement of the Services, including registration, identity verification, user authentication, saving user settings, and calculation of service fees
  2. Measurement of user traffic and behavioral analysis
  3. Distribution, display, and measurement of advertising effectiveness
  4. Responses to inquiries and guidance related to the Services
  5. Actions necessary to respond to violations of the Firm’s terms, policies, and other rules (“Terms, etc.”)
  6. Notifications regarding changes to the Terms, etc.

• 3Method of Notification, Publication, Consent, and Request for Suspension of Use

  The Firm uses User Information for the following purposes in connection with the provision of the Services:

  1. The Firm will obtain the user’s consent in advance before collecting the following information:
     ・Location information
  2. Users may request the suspension of collection or use of all or part of their User Information by configuring the settings of the Services as prescribed by the Firm. In such cases, the Firm will suspend use within a reasonable period.
     Certain User Information is essential for the provision of the Services; therefore, suspension of collection or use may only be possible if the user withdraws from the Services in the manner prescribed by the Firm.

• 4Provision to Third Parties

  The Firm will not provide personal information included in User Information to any third party (including parties located outside Japan) without obtaining prior consent from the user, except in the following cases:

  1. When outsourcing all or part of the handling of personal information within the necessary scope to achieve the purpose of use
  2. When personal information is provided due to business succession such as mergers
  3. When cooperation with a national or local government agency is necessary to execute duties prescribed by law, and obtaining user consent may hinder such execution
  4. Other cases permitted by the Act on the Protection of Personal Information (“APPI”) and other applicable laws

• 5Disclosure of Personal Information

  Upon receiving a request from a user for disclosure of personal information based on the APPI, the Firm will confirm that the request is from the user and will disclose the information without delay (or notify the user if such information does not exist). However, the Firm will not disclose information where the Firm has no legal obligation to do so. A handling fee (amount determined by the Firm) will be charged for disclosure requests.

• 6Correction, Suspension of Use, etc. of Personal Information

  Among user information, our office will not provide personal information to third parties (including those located outside of Japan) without the user's prior consent. However, this does not apply if any of the following items apply.

  1. If the Firm receives a request for correction of personal information due to inaccuracy, or a request for suspension of use due to use beyond the publicly announced purpose or collection by fraudulent means, the Firm will conduct an investigation without delay after confirming the request is from the user. Based on the results, the Firm will correct or suspend use and notify the user. If the Firm decides not to correct or suspend use, the user will be notified accordingly.
  2. If the user requests deletion of their personal information and the Firm determines that such request should be accommodated, the Firm will delete the information after confirming the requester’s identity and notify the user.
  3. If the Firm is not legally obligated to correct, suspend, or delete personal information under the APPI or other laws, the above provisions will not apply.

• 7Contact Information

  For opinions, questions, complaints, or other inquiries regarding the handling of User Information, please contact:
  
  Meikyo Law Office, Legal Professional Corporation
  Personal Information Protection Manager: Takahito Igami
  Nishiki Park Building 16F, 2-4-3 Nishiki, Naka-ku, Nagoya-shi, Aichi 460-0003, Japan
  Tel: 050-3113-5050

• 8Procedure for Amendments to This Policy

  The Firm may amend this Policy as necessary. However, if amendments require user consent under applicable laws, the amended Policy will apply only to users who have consented in the manner prescribed by the Firm.
  When amending this Policy, the Firm will notify users of the effective date and content of the revised Policy through the Firm’s website or other appropriate means.
  
  Enacted: April 8, 2024