PRIVACY POLICY

Davebreak Co., Ltd. (hereinafter referred to as “the Company”) establishes this Privacy Policy (hereinafter referred to as “the Policy”) regarding the handling of user information, including personal information, of purchasers and users (hereinafter collectively referred to as “Users”) of the products and services provided by the Company (hereinafter collectively referred to as the “Services”).

Article 1: Compliance with Laws and Regulations

The Company shall comply with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”), other relevant laws and regulations, guidelines of relevant ministries and agencies, and this Policy in order to achieve the protection of personal information. The Company will promote the protection of personal information by ensuring that all employees are aware of the importance of personal information protection and take appropriate measures.

Article 2: Collected User Information and Collection Methods

1. In this Policy, “User Information” refers to information about Users obtained at the time of purchasing or applying for the Services (such as name, postal code, address, phone number, email address, credit card information, and other payment-related information), behavioral history on the communication service, information of emails sent and received by Users, information generated or accumulated on Users’ smartphones, computers, or other devices, information provided by other services through collaboration permitted by Users when using the Services, information collected by the Company when Users use the Services based on Users’ individual consent, and information collected appropriately by the Company based on this Policy.

2. In this Policy, among the User Information, “Personal Information” refers to information defined by Article 2, Paragraph 1 of the Personal Information Protection Act, which includes information about a living individual that can identify a specific individual by name, date of birth, or other descriptions, etc. (including information that can easily be collated with other information and thereby identify a specific individual).

Article 3: Information Management

The Company shall take necessary measures such as establishing a security system, implementing a management structure for maintaining and managing the security system, and thoroughly educating employees to prevent unauthorized access, loss, destruction, alteration, leakage, and other risks to User Information, thereby ensuring the accurate and up-to-date status and strict management of User Information.

Article 4: Purpose of Use

1. Provision, maintenance, protection, and improvement of the Services
2. Correspondence to inquiries and notifications regarding the Services
3. Response to acts violating agreements, rules, policies, etc. related to the Services
4. Notification of changes to agreements, rules, policies, etc. related to the Services
5. Mailing, telephone, email, etc., for sales activities and marketing activities to provide information that Users may find useful, such as improvement of the functionality of the Services
6. Requesting cooperation in surveys and participation in various events, and reporting the results, etc.
7. Use purposes publicly disclosed by the Company in the provision of the Services and use purposes based on Users’ individual consent obtained by the Company
8. Delivery of targeted advertisements using Users’ behaviors, gender, access history, etc.
9. Exercise of rights and fulfillment of obligations based on contracts, laws, etc.
10. After-sales service and response to various inquiries
11. Other purposes related to the above purposes

Article 5: Restrictions on the Use of Personal Information

Except in certain cases specified in the Policy, the Company will not handle personal information beyond the scope necessary to achieve the purposes of use without obtaining the User’s consent.

Article 6: Third Party Provision of Personal Information

Except in certain cases specified in the Policy, the Company will not provide personal information to third parties without obtaining the User’s prior consent.

Article 7: Disclosure of Personal Information

When the Company is requested to disclose personal information by a User, the Company will promptly disclose the personal information to the User (or notify them if the personal information does not exist) after confirming the request is from the User.

Article 8: Correction, Suspension of Use, etc., of Personal Information

When the Company receives a request from a User to correct or suspend the use of their personal information, the Company will promptly investigate the request and, based on the results, correct or suspend the use of the personal information and notify the User accordingly.

Article 9: Treatment after Termination of Service Handling

Even in the event of the termination of the Services, etc., the Company may continue to store and use the various information obtained by the Company until that point.

Article 10: Use of Cookies and Other Technologies

The Company may use cookies and similar technologies in the Services to understand Users’ purchases or usage status and improve the Services. Users can disable cookies by changing their web browser settings, although this may limit certain features of the Services.

Article 11: Contact Information

For inquiries regarding personal information, opinions, questions, complaints, or other inquiries related to the Services, please contact:

5th Floor, Newke Building, 2-2-33 Higashi-Shinagawa, Shinagawa-ku, Tokyo 140-0002, Japan

Article 12: Procedures for Changes to the Privacy Policy

The Company may change the collected usage information, purposes of use, and other contents of this Policy as necessary. Changes to the Policy will be communicated to Users through appropriate methods.