“Personal Information” means personal information as defined in Japan’s Act on the
Protection of Personal Information. It includes information relating to a living individual that
can identify a specific individual through their name, date of birth, address, telephone
number, contact details, or other descriptions contained in that information. It also includes
information that can identify a specific individual on its own, such as facial appearance data,
fingerprints, voiceprints, and health insurance card insurer numbers (“Personally Identifying
Information”).

The Company may request personal information when users register to use the Services,
including their name, date of birth, address, telephone number, email address, bank account
number, credit card number, and driver’s licence number.
The Company may also collect transaction records and payment information containing
users’ personal information from its partners, including information providers, advertisers,
and advertising distribution partners (collectively,
“Partners”), in connection with transactions
between users and such Partners.

The Company collects and uses personal information for the following purposes:

1. To provide and operate the Company’s services.
2. To respond to users’ enquiries, including verifying their identity.
3. To send emails about new features, updates, campaigns, and other information
concerning services users currently use, as well as information about other services
offered by the Company.
4. To contact users as necessary regarding maintenance, important notices, and other
relevant matters.
5. To identify users who violate the Terms of Use or attempt to use the Services for
fraudulent or improper purposes, and to refuse their use of the Services.
6. To enable users to view, update, or delete their registered information and review
their service usage.
7. To bill users for paid services.
8. For purposes incidental to those listed above.

1. The Company may change the purposes for which personal information is used only
when the new purposes can reasonably be considered related to the original
purposes.
2. If the purposes of use are changed, the Company will notify users of the revised
purposes by a method specified by the Company or publish them on this website.

1. Restrictions on Third-Party Disclosure

The Company will not provide personal information to third parties without the user’s prior
consent, except in the following circumstances or where otherwise permitted by the Act on
the Protection of Personal Information or other applicable laws and regulations:

(a) When disclosure is necessary to protect a person’s life, physical safety, or property, and
obtaining the individual’s consent is difficult.
(b) When disclosure is particularly necessary to improve public health or promote the sound
development of children, and obtaining the individual’s consent is difficult.
(c) When cooperation is necessary for a national government agency, local public authority,
or a party acting on their behalf to perform duties prescribed by law, and obtaining the
individual’s consent could interfere with the performance of those duties.
(d) When the Company has provided advance notice or publicly announced the following
matters and has submitted a notification to Japan’s Personal Information Protection
Commission:

・That the purposes of use include provision to third parties.
・The categories of data to be provided to third parties.
・The means or methods of providing the information.
・That provision of personal information to third parties will cease upon the individual’s
request.
・The method for submitting such a request.

2. Recipients Not Considered Third Parties

Notwithstanding the preceding paragraph, recipients of personal information will not be
considered third parties in the following circumstances:

(a) When the Company entrusts all or part of the handling of personal information to another
party to the extent necessary to achieve the purposes of use.
(b) When personal information is provided as part of a business succession resulting from a
merger or other circumstances.
(c) When personal information is used jointly with specified parties, provided that the
individual has been notified in advance, or can readily access information, regarding:

・The fact that the information will be used jointly.
・The categories of personal information to be used jointly.
・The scope of parties participating in the joint use.
・The purposes of use by those parties.
・The name of the person or entity responsible for managing the personal information.

1. When an individual requests disclosure of their personal information, the Company
will disclose it to that individual without delay. However, the Company may decline to
disclose all or part of the information if disclosure would fall under any of the following
circumstances. If the Company decides not to disclose the information, it will notify
the individual without delay. A fee of JPY 1,000 will be charged for each disclosure
request.

(a) Disclosure could harm the life, physical safety, property, or other rights or interests
of the individual or a third party.
(b) Disclosure could significantly interfere with the proper conduct of the Company’s
business.
(c) Disclosure would otherwise violate laws or regulations.

2. Notwithstanding the preceding paragraph, the Company will, in principle, not disclose
information that does not constitute personal information, such as historical or
attribute information.

1. If personal information held by the Company about a user is inaccurate, the user may
request its correction, addition, or deletion (collectively,
“Corrections”) in accordance
with the procedures established by the Company.

2. If the Company receives such a request and determines that it is necessary to
comply, it will make the Corrections without delay.

3. If the Company makes Corrections under the preceding paragraph or decides not to
make them, it will notify the user without delay.

1. If an individual requests the suspension of use or erasure of their personal
information (collectively,
“Suspension of Use”) on the grounds that it is being handled
beyond the stated purposes of use or was obtained through improper means, the
Company will conduct the necessary investigation without delay.

2. If, based on the results of that investigation, the Company determines that it is
necessary to comply with the request, it will implement the Suspension of Use
without delay.

3. If the Company implements the Suspension of Use under the preceding paragraph or
decides not to do so, it will notify the user without delay.

4. Notwithstanding the preceding two paragraphs, if Suspension of Use would involve
substantial costs or would otherwise be difficult, and alternative measures necessary
to protect the user’s rights and interests can be taken, the Company will take those
alternative measures.

1. The Company may change this Policy without notifying users, except where
otherwise provided by law or this Policy.

2. Unless otherwise specified by the Company, the revised Policy will take effect when
published on this website.

For enquiries regarding this Policy, please contact:

SORAHA Co., Ltd.
6F, Ichigo Higashi-Ikebukuro Building
1-34-5 Higashi-Ikebukuro, Toshima-ku
Tokyo 170-0013, Japan

Representative Director: Haruka Kimura