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Privacy Policy

Last updated: July 30, 2025

Contents

Stellagent, Inc. (hereinafter referred to as "the Company") establishes this Privacy Policy (hereinafter referred to as "this Policy") regarding the handling of users' personal information in the services provided on this website (hereinafter referred to as "the Service").

Article 1 (Personal Information)

"Personal Information" refers to "personal information" as defined in the Personal Information Protection Act, meaning information about a living individual that can identify a specific individual by name, date of birth, address, telephone number, contact information, or other descriptions contained therein, as well as data relating to appearance, fingerprints, voiceprints, and health insurance card insurer numbers that can identify a specific individual from such information alone (personal identification information).

Article 2 (Method of Collecting Personal Information)

The Company may request personal information such as name, date of birth, address, telephone number, email address, bank account number, credit card number, and driver's license number when users register for use. The Company may also collect transaction records and payment information made between users and partners from the Company's partners (including information providers, advertisers, ad distribution destinations, etc.; hereinafter referred to as "Partners").

Article 3 (Purpose of Collecting and Using Personal Information)

The purposes for which the Company collects and uses personal information are as follows: • Providing and operating the Company's services • Responding to user inquiries (including identity verification) • Sending emails about new features, updates, campaigns, etc. of services currently in use, and information about other services provided by the Company • Contacting users as necessary for maintenance, important notices, etc. • Identifying users who violate the terms of use or who attempt to use the service for fraudulent or improper purposes, and refusing their use • Allowing users to view, change, or delete their own registration information and view their usage status • Charging usage fees for paid services • Purposes incidental to the above

Article 4 (Change of Purpose of Use)

The Company shall change the purpose of use of personal information only when it is reasonably recognized that the purpose of use is related to the purpose before the change. When the purpose of use is changed, the Company shall notify users of the changed purpose by the method prescribed by the Company or publish it on this website.

Article 5 (Provision of Personal Information to Third Parties)

The Company will not provide personal information to third parties without obtaining prior consent from the user, except in the following cases. However, this excludes cases permitted by the Personal Information Protection Act and other laws and regulations. • When it is necessary to protect a person's life, body, or property, and it is difficult to obtain the consent of the individual • When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual • When it is necessary to cooperate with a national government agency, local government, or a person entrusted by them in executing affairs prescribed by laws and regulations, and obtaining the consent of the individual may impede the execution of such affairs • When the following matters have been notified or published in advance, and the Company has filed a notification with the Personal Information Protection Commission: That the purpose of use includes provision to third parties The items of data provided to third parties The means or method of provision to third parties That provision of personal information to third parties will be stopped at the request of the individual The method of accepting the individual's request Notwithstanding the provisions of the preceding paragraph, the recipient of information shall not constitute a third party in the following cases: • When the Company outsources all or part of the handling of personal information to the extent necessary to achieve the purpose of use • When personal information is provided as a result of business succession due to merger or other reasons • When personal information is jointly used with a specific person, and the individual has been notified in advance or the information has been placed in a state easily accessible to the individual regarding the fact, the items of personal information jointly used, the scope of persons jointly using them, the purpose of use, and the name of the person responsible for managing such personal information

Article 6 (Disclosure of Personal Information)

When the Company is requested by an individual to disclose personal information, the Company shall disclose it to the individual without delay. However, if disclosure falls under any of the following, the Company may choose not to disclose all or part of it, and when it decides not to disclose, the Company shall notify the individual without delay. A fee of 1,000 yen per case shall be charged for the disclosure of personal information. • When there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party • When there is a risk of significantly impeding the proper conduct of the Company's business • When it would violate other laws and regulations Notwithstanding the provisions of the preceding paragraph, information other than personal information, such as history information and characteristic information, shall not be disclosed as a general rule.

Article 7 (Correction and Deletion of Personal Information)

Users may request the Company to correct, add, or delete (hereinafter referred to as "Correction, etc.") personal information held by the Company if it is incorrect, through the procedures established by the Company. When the Company receives a request from a user as described in the preceding paragraph and determines that it is necessary to comply with the request, the Company shall correct the personal information without delay. When the Company has made corrections, etc. based on the provisions of the preceding paragraph, or has decided not to make corrections, etc., the Company shall notify the user without delay.

Article 8 (Suspension of Use of Personal Information)

When the Company is requested by an individual to suspend use or delete (hereinafter referred to as "Suspension of Use, etc.") personal information on the grounds that it is being handled beyond the scope of the purpose of use or that it was obtained by fraudulent means, the Company shall conduct the necessary investigation without delay. If, based on the results of the investigation in the preceding paragraph, it is determined that it is necessary to comply with the request, the Company shall suspend use of the personal information without delay. When the Company has suspended use, etc. based on the provisions of the preceding paragraph, or has decided not to suspend use, etc., the Company shall notify the user without delay. Notwithstanding the preceding two paragraphs, in cases where suspension of use, etc. would require a large expense or is otherwise difficult, and alternative measures can be taken that are necessary to protect the rights and interests of the user, such alternative measures shall be taken.

Article 9 (Changes to Privacy Policy)

The contents of this Policy may be changed without notice to users, except for matters otherwise provided by laws and regulations or this Policy. Unless otherwise specified by the Company, the changed Privacy Policy shall take effect from the time it is posted on this website.

Article 10 (Contact for Inquiries)

For inquiries regarding this Policy, please contact the following: Stellagent, Inc.

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