ICONIC DATA Co., Ltd. (hereinafter referred to as "our company") complies with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act") and is committed to the proper handling and protection of personal information. Therefore, we have established a privacy policy (hereinafter referred to as "this policy") as follows.

1. Definition of Personal Information

In this policy, personal information is information about a living individual that can identify a specific individual by name, date of birth, and other descriptions contained in the information (such as information that can be easily (Including those that can be collated and thereby identify a specific individual.).

2. Purpose of Use of Personal Information

While registering as a user, we may ask for personal information such as name, date of birth, address, telephone number, bank account number, credit card number, driver's license number, etc. In addition, transaction records including the user's personal information and information related to payments made between the user and our business partners, as well as other parties, (including information providers, advertisers, and advertisement distributors, etc.) may be used by our business partners.

(1) We will use personal information for the following purposes

A) Customers' personal information

• ① Provision of our services
• ② Distribution and sending of communications, various notifications, etc. associated with the provision of our services
• ③ Response to customer requests, inquiries, complaints, etc.
• ④ Creation and update of transaction records with customers
• ⑤ Reference for improving our services and developing new services
• ⑥ Creation of statistical data processed into a format that cannot identify individuals
• ⑦ Distribution and display of advertisements by the Company or third parties
• ⑧ Use for marketing and sales promotion activities
• ⑨ Other uses related to or incidental to the use of ① to ⑧ above

B) Personal information of those who apply for our company's job postings (hereinafter referred to as "applicants")

• ① Providing information, contacting, and notifying applicants
• ② Pass/fail judgment of recruitment selection
• ③ Creation and update of internal records
• ④ Internal processing of recruited personal information as an employee
• ⑤ Reference for business improvement, improvement of our services, development of new services, etc.
• ⑥ Creation of statistical data processed into a format that cannot identify individuals
• ⑦ Other uses related to or incidental to the use of ① to ⑥ above

(2) The Company may change the purpose of use of personal information in (1) above to the extent that it is reasonably recognized that there is considerable relevance to the purpose of use of personal information in (1) above. In this case, we will promptly notify the person of the purpose of use of personal information after the change or make it public.

(3) The Company will not handle personal information beyond the scope necessary to achieve the purposes of use in (1) and (2) above. However, this shall not apply in cases where the Company has obtained the prior consent of the person in question or in cases falling under any of the following items.

• ① When required by law
• ② Cases in which the handling of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the individual
• ③ Cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person
• ④ Cases in which the handling of personal information is necessary for cooperating with a state organ, a local government, or an individual or entity entrusted by either a state organ or local government to execute affairs prescribed by law, and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned.

3. Proper acquisition of personal information

The Company will acquire personal information by appropriate means and will not acquire personal information through deception or other wrongful means.

4. Security management of personal information, etc.

The Company shall not provide personal information to a third party (hereinafter referred to as “third party provision”) without obtaining the prior consent of the person, except when disclosure is permitted under the Personal Information Protection Law and other laws and regulations. ) will not be accepted. However, the following cases shall not constitute provision to a third party.

• ① When the Company entrusts all or part of the handling of personal information within the scope necessary to achieve the purpose of use of our company
• ② Cases in which personal information is provided along with the succession of business due to merger or other reasons
• ③ Cases in which personal information is shared in accordance with the provisions of the Personal Information Protection Law

5. provision of personal information to third parties

We will not provide personal information to third parties (hereinafter referred to as "provision to third parties") without the prior consent of the individual, except in cases where disclosure is permitted under the Personal Information Protection Law or other laws and regulations. We will not do so. However, the following cases do not constitute the provision of Personal Information to a third party.

• ① When the Company entrusts all or part of the handling of personal information to a third party within the scope necessary to achieve the purpose of use.
• ② Cases in which personal information is provided as a result of the succession of business due to merger or other reasons
• ③ When personal information is jointly used in accordance with the provisions of the Personal Information Protection Law.

6. Provision of personal information to third parties

We will jointly use personal information as follows.

(1) Items of personal information to be jointly used
Company name, name, address, telephone number, fax number, e-mail address, etc., and all personal information that the Company obtains from customers. However, sensitive personal information is excluded.

(2) Scope of joint users
The following companies that are our group companies
Eyesaac Inc., Opportunity Lab Inc., Propulse Inc., Ecosphere Inc., CyberFortress Inc., Cognitive Data Inc., FILOXENIA Inc., AiGlow Inc.

(3) Purpose of use by joint users
For reference in improving the business of the Company and each of the companies mentioned in the preceding paragraph, improving services and developing new services, creating statistical data processed into a format that does not identify individuals, distributing or displaying advertisements, and using for marketing or sales promotion activities.

(4) Name of the person responsible for the management of personal information
Tokyo Square Garden 14F, 3-1-1 Kyobashi, Chuo-ku, Tokyo 104-0031, Japan
ICONIC DATA Corporation Representative Director: Yuko Arai, (Personal Information Management Officer)
E-mail address: info@iconic.inc
Personal Information Manager: Yuko Arai

7. Disclosure of personal information

When we are requested by an individual to disclose his/her personal information in accordance with the provisions of the Personal Information Protection Law, we will disclose such information to the individual without delay (If such personal information does not exist, we will notify the individual to that effect).
However, this does not apply if the Company is not obligated to disclose it under the Personal Information Protection Law or other laws and regulations.

8. Correction of personal information, etc.

If the Company is requested by an individual to correct, add, or delete his/her personal information (hereinafter referred to as "correction, etc.") based on the provisions of the Personal Information Protection Act on the grounds that the personal information is not true, the Company will conduct the necessary investigation without delay within the scope necessary to achieve the purpose of use, and based on the results, will correct the content of the personal information and notify the person to that effect. (If the Company decides not to make such correction, we will notify you to that effect without delay.)
However, this does not apply if the Company is not obligated to make corrections, etc. under the Personal Information Protection Act or other laws and regulations.

9. Suspension of Use of Personal Information

If we receive a request from a person to cease use or erase his/her personal information (hereinafter in this article referred to as "cease of use, etc.") in accordance with the provisions of the Personal Information Protection Law on the grounds that the personal information has been handled beyond the scope of the purpose of use publicly announced in advance or that the information was obtained through deception or other wrongful means, we will cease use or erase the personal information. (hereinafter in this article referred to as "Suspension of Use, etc."). (If the Company decides not to suspend the use of personal information, we will notify the person to that effect without delay.)
However, this does not apply to cases in which we are not obligated to suspend the use of personal information under the Personal Information Protection Law or other laws and regulations.

10. Use of Cookies, etc.

For the purpose of improving our services, we may acquire and use information that cannot identify specific individuals, such as cookies, URLs accessed, and action history such as reference order. How Google uses cookies

11. Contact for Inquiries

For requests for disclosure, etc., opinions, questions, complaints, and other inquiries regarding the handling of personal information, please contact the contact described in 6.(4) above.

12. Changes to this policy

The Company will review its handling of personal information from time to time and strive for continuous improvement, and may change this policy as necessary.
If we change this policy, we will notify you by posting the changes on our website. However, in the case of changes to the content of this policy that require the consent of the person concerned under laws and regulations, the Company shall obtain the consent of the person concerned in a manner prescribed by the Company.