PRIVACY POLICY

[Scope of Application]

This privacy policy (hereinafter referred to as "Privacy Policy") is provided by UMITO Partners Co., Ltd. (hereinafter referred to as "UMITO Partners") in the service operated by UMITO Partners (hereinafter referred to as "our service"), or the handling of personal information of customers (including users of our services, business partners and other third parties; the same shall apply hereinafter) obtained in connection with our business operations.

In addition, if there is an individual privacy policy or other regulations for each of our services, or if there is individual consent (individual regulations and individual consent are collectively referred to as “individual consent”), we shall comply with the content of the individual consent.

[Definition of Terms]

1. Personal Information

The term "personal information" as used in this Privacy Policy means information about a living individual that identifies the specific individual by name, address, telephone number, e-mail address, place of employment, date of birth, or any other description that constitutes the information. Personal information also includes information that cannot be used to identify an individual by itself, but can be easily cross-checked with other information to identify a specific individual, as well as information that is considered personal information under laws regarding protection of personal information.

2. Other Personal Data

The term "Other Personal Data" as used in this Privacy Policy shall mean information that includes the services clients use, software, history of advertisements viewed, products purchased, search keywords, date of use, user environment, site operation history, IP address, location information, unique device identifier information, and communication status of in case site is visited by a mobile device. The term "Other Personal Data" means information that can be used to analyze the interests and preferences of users by accumulating such information, but that does not lead to the identification of specific individuals, such as advertising history, products purchased, search keywords, date of use, user environment, operation history within the site, IP address, location information, unique device identifier, communication status when used via mobile devices, and various setting information when used.

[Handling of Personal Information]

1. With respect to personal information obtained from customers, UMITO Partners shall comply with the regulations relating to personal information and shall establish an internal system for the protection of personal information and strive for its continuous improvement. In addition, UMITO Partners will establish an internal system for the protection of other personal data, which is equivalent to the protection of personal information.
2. When a customer registers for our service we may ask for personal information such as name, date of birth, gender, address, telephone number, e-mail address, bank account information, and credit card number. We may also obtain information such as transaction and purchase history of customers from business partners, advertisers and advertising distributors (hereinafter referred to as “business partners”). In addition, we may obtain personal information of customers when they use our company’s or business partners’ services or website.
3. Unless specifically permitted from UMITO Partners services, please refrain from entering or sending personal information regarding race, creed, social status, medical history, criminal record, or whether you were a victim of a crime (hereinafter referred to as “special care-required personal information”).
4. UMITO Partners will use personal information obtained from customers within the scope of the following purposes (hereinafter referred to as "Purposes of Use").

(1) Personal information of customers who use UMITO Partners’ services

1. Contacting customers regarding registration to UMITO Partners’ services.
2. For log-in autocomplete purposes in case customer is registered to UMITO Partners’ services as a member.
3. To forward or mediate information based on customer application to advertising companies or organizations.
4. To distribute information and surveys by email (including email newsletters), by post or by telephone.
5. To analyze and extract information for the purpose of improving the quality of our services and advertisements.
6. To personalize advertisement content based on customer personal information, gender, age, location, interests, UMITO Partners website view history, UMITO Partners service use history, other personal data.
7. To provide information, including by way of advertisement, that is deemed beneficial to UMITO Partners’ customers.
8. To respond to customer inquiries and complaints.
9. To research and analyze marketing data, develop new services, and advertisement.
10. For the purpose of system maintenance, respond to system malfunctions, and to take other necessary measures for technical or operational reasons.
11. For the purpose of analyzing website traffic, engagement analytics and usage of UMITO Partners’ services.
12. To be used as statistical data in a form that does not identify individuals.
13. To monitor, prevent, and respond to fraudulent activities.
14. To provide services to our customers.
15. To perform services entrusted by a third party.
16. For other purposes specified in individual agreements.

(2) Personal information of business partners

1. For communication regarding business, fulfillment of contracts, and other discussions regarding business.
2. To manage information regarding business partners.
3. For other purposes as specified in the individual agreement.

(3) Personal information about third parties provided by business partners

1. To provide such personal information to the business partner who has provided it to us (hereinafter referred to as the "Provider") and to provide our services to such business partner (hereinafter referred to as the "Provider") and the provision of our services.
2. To provide information and surveys about UMITO Partners Services by email (including email newsletters), by post and telephone to customers that provide personal information.
3. To analyze and extract information to improve the quality of our services and advertisements.
4. To send rewards and prizes related to services and campaigns provided by UMITO Partners to customers that provide their personal information.
5. To provide personalized advertisements and information by UMITO Partners and third party based on personal information provided by customers, including: gender, age, location, interests, website viewing history, service use history and other personal data.
6. To provide advertising and other information that is deemed beneficial to the person whose personal information has been provided.
7. To analyze the usage of services provided by business partners.
8. To respond to inquiries or complaints from the individual whose personal information has been provided.
9. For the purpose of researching and analyzing marketing data, develop new services, and advertisement.
10. For the purpose of system maintenance, respond to system malfunctions, and to take other necessary measures for technical or operational reasons.
11. For the purpose of analyzing website traffic, engagement analytics and usage of UMITO Partners’ services.
12. To be used as statistical data in a form that does not identify individuals.
13. To monitor, prevent, and respond to fraudulent activities.
14. To provide services to our customers.
15. To perform services entrusted by a third party.
16. For other purposes specified in individual agreements.

(4) Personal Information of Inquirers

1. To respond to inquiries.
2. For other purposes specified in the individual agreement.

(5) Personal information of employment applicants

1. To provide information to, contact, and notify applicants for employment.
2. For the purpose of determining employment selection.
3. For other purposes specified in the individual consent.

[Providing to third parties]

1. We will not provide personal information to third parties unless we have the prior consent of the customer, such as that specified in the terms of use for the service used by the customer, or unless permitted by law, such as when required by law or when entrusting the handling of personal information within the scope necessary for the achievement of the purpose of use.
2. Notwithstanding the preceding paragraph, we may provide acquired personal information to third parties outside of UMITO Partners for the purpose of providing data containing personal information in a way that does not disclose individuals.
3. In the event that we provide your personal information to a third party in accordance with the preceding two paragraphs, such personal information will be placed under the control of such third party at the time such information is provided. Both UMITO Partners and the third party shall handle the customer's personal information in compliance with their own personal information protection policies and shall not be mutually liable for the other party's handling of the personal information.

[Outsourcing the Handling of Personal Information]

We may outsource all or part of the operations handling personal information to a third party. In such cases, we will require the entrusted party to handle personal information appropriately and supervise the entrusted party as necessary and appropriate, such as by periodically confirming the status of the entrusted party's handling of personal information.

[Contact for handling of personal information]

For inquiries regarding the handling and management of personal information, or for consultation or contact regarding notification of the purpose of use, disclosure, correction, addition, or deletion of content, suspension of use, or suspension of provision to a third party (hereinafter referred to as "disclosure, etc.") of your personal information, please contact UMITO Partners at the contact point below. Please note that we do not accept inquiries in person or by telephone.

UMITO Partners Inc.
co-lab Shibuya Cast 1-2F, 1-23-21 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan
E-mail address: info@umitopartners.com

[Procedure for Disclosure of Personal Information]

Procedures for disclosure of personal information are as follows.

1. Contact for requests for disclosure

Please contact the above contact for requests for disclosure. After receiving your request for disclosure we will send you the prescribed form by mail.

2. How to Request Disclosure

Please fill in all necessary items on the prescribed form and return it to the provided contact information. When returning the form, please write "Request for Disclosure of Personal Information enclosed". Please note that we will not be able to respond to requests for incomplete documents or miscommunication.

(1) In the case of a request for disclosure from the person themselves
Please enclose a copy of one of the following documents as proof of identity. Please make sure that none of the documents contain your personal number or that your personal number is deleted.

1. Driver's license.
2. Health insurance card.
3. Pension book.
4. Certificate of residence.
5. Passport.
6. Certificate of alien registration.

(2) In the case of a request for disclosure from a proxy
In addition to the identification documents for the principal, please enclose the identification documents for the agent (each of the documents in (1) above) and a letter of attorney.

3. Response to Requests for Disclosure

UMITO Partners will confirm the contents of your request for disclosure and respond within one month of receipt of the request form, although this may be delayed due to circumstances. If UMITO Partners are unable to respond to a request for disclosure in any of the following cases, a notification will be sent to that effect. However, the reason for such a request may not be disclosed depending on the circumstances.

1. When the identity of the person making the request cannot be confirmed.
2. If the request is made by a representative and the right of representation cannot be verified.
3. When the submitted documents are incomplete.
4. When the subject of the request for disclosure is not "personal information subject to disclosure.
5. If there is a risk of harm to the life, body, property, or other rights or interests of the individual or a third party.
6. If there is a risk of causing hindrance to our business.
7. when there is a risk of violating other laws and regulations.

4. Commission fee

Customer will be required to pay the disclosure fee as specified by UMITO Partners.

[Change in Privacy Policy]

In adition to complying with Japanese laws and regulations applicable to handling of personal information, UMITO Partners may change the content of the Privacy Policy at any time in the process of continuously reviewing, improving and enhancing the company’s effort to protect personal information. Any changes will be posted on the UMITO Partners website.