PKSHA Technology Inc. (hereinafter referred to as “we” or “our company”) considers the appropriate handling and protection of personal information and other related data (as defined in Article 2, hereinafter the same) of our customers and other stakeholders (hereinafter referred to as “you”) to be an important responsibility. To protect personal information, we have established the following privacy policy (hereinafter referred to as “this policy”) and will appropriately handle and protect your personal information in accordance with this policy.

Article 1 (Scope of Application of this Policy)

• This policy applies to all personal information and related data handled by our company in all of our business operations, products, and services. If we establish a specific policy regarding personal information for certain businesses, products, or services, such specific policy shall take precedence.
• You are required to understand and agree to this policy in advance when using our company’s products and services.

Article 2 (Definitions)

The terms used in this policy shall have the following meanings:

• 1. “Personal Information”
• Refers to personal information as defined by the Act on the Protection of Personal Information.
• 2. “Personal Information and Related Data”
• Refers to personal information and other data collected or stored in relation to the identification of you, such as behavioral history on communication services, and information generated or accumulated regarding the devices you use. Specifically, this includes, but is not limited to, names, gender, date of birth, occupation, address, contact details (email address, phone number, etc.), payment information (credit card, bank account information, credit information, etc.), referrer, IP address, server access information, cookies, and other identifiers, location information, etc.
• 3. “Affiliated Companies”
• Refers to affiliated companies as defined in Article 8 of the Rules on Terminology, Forms, and Preparation Methods of Financial Statements.

Article 3 (Compliance with Laws and Regulations)

We will comply with applicable laws, regulations, and guidelines when handling personal information and related data.

Article 4 (Purposes of Using Personal Information and Related Data)

The purposes for which we use your personal information and related data are as follows:

Article 5 (Acquisition and Management of Personal Information and Related Data)

• We will lawfully and fairly acquire personal information and related data to the extent necessary to achieve the purposes of use.
• We will take organizational, human, physical, and technical safety management measures that we deem appropriate to prevent leakage, loss, or damage of personal information and to manage personal information appropriately. For inquiries regarding our safety management measures, please contact the contact point provided in Article 9.

Article 6 (Provision of Personal Information and Related Data to Third Parties)

Except for cases of joint use as specified in the next article, cases where we entrust the handling of personal information and related data to achieve the purposes of use (including entrustment to entities outside Japan), and other cases permitted by law, we will not provide your personal information and related data to third parties without your consent.

Article 7 (Joint Use of Personal Information and Related Data)

We may jointly use personal information and related data as follows:

Article 8 (Disclosure, Correction, Suspension of Use, etc. of Personal Information and Related Data)

• You may request the disclosure (including disclosure of records of provision to third parties), correction, addition, deletion, suspension of use, or erasure (hereinafter referred to as “disclosure, etc.”) of your personal information and related data held by us by making a request to the contact point specified in the next article. However, this does not apply if we are permitted by law to refuse such disclosure, etc.
• You shall follow the procedures separately specified by us for disclosure, etc., and shall pay the fees separately specified by us.

Article 9 (Contact Information)

The contact information for inquiries regarding personal information and related data is as follows:

Article 10 (Changes to this Policy)

We may change this policy by notifying you in a manner we deem appropriate. Such notice shall be made in advance, except in cases of emergency or unavoidable circumstances.

End

Enacted on October 1, 2016 Revised on June 1, 2020 Revised on April 1, 2022