(1) Basic Policy on the Handling of Personal Information

Our company recognizes the importance of Personal Information and will protect Personal Information by implementing appropriate security measures to prevent the leakage, loss, or damage of Personal Information whichour company owns or uses. Our company will acquire Personal Information by appropriate means and to the extent necessary for the execution of our business, in accordance with the provisions of the law. Our company will comply with laws, national guidelines and other standards regarding the protection of Personal Information, and will strive to protect Personal Information.

（2）Definitions

“Personal Information” means “Personal Information” as defined in the article 2 of Personal Information Protection Law. “Personal Information” is information about a living individual including information that may be used to identify a specific individual such as name, date of birth, address, telephone number, contact information, or other descriptions, and is information about a living individual that may identify a specific individual from a single piece of information (personal identification information) such as appearance data, fingerprint data, voice print data, and the insurer number on health insurance cards.

（3）Method of Obtaining Personal Information

1. Our company may ask for Personal Information such as name, date ofbirth, address, telephone number, e-mail address, bank account number, credit card number, driver's license number, etc. when you register for use. Whether or not to provide Personal Information is voluntary. However, if you do not agree to provide your Personal Information, you may not be able to use all or part of our services.

2. Regardless of the provisions of the preceding paragraph, our company may correct your transaction records or payment information including Personal Information which are made between you and our business partners, etc., from our business partners (including information providers, advertisers, and advertising distributors, etc.; hereinafter referred to as "business partners").

（4）Purpose of Use of Personal Information

1. Our company collects and uses Personal Information for the following purposes:

1. ①for the provision and operation of our services
2. ②for responding to inquiries from users (including personal identification)
3. ③for sending e-mails with information on new features, updates, campaigns, etc. of our services which users are using, as well as information on other services provided by our company
4. ④for contacting users as necessary for maintenance, important notices,etc.
5. ⑤for identifying users who have violated the terms of use or are trying to use our services for illegal or improper purposes, and restricting the use of our services by the users
6. ⑥for allowing users to view, change, or delete their own registered information, and view their usage status
7. ⑦for billing users for paid services
8. ⑧for other purposes incidental to the above purposes of use

2. Our company will change the purpose of use of Personal Information only when it is reasonably recognized that the purpose of use is related to that before the change. In the event that the purpose of use is changed, our company will notify the user of the changed purpose by the method prescribed by our company, or announce it on this website.

（5）Method of Managing Personal Information

Our company will take necessary and appropriate measures to control access to Personal Information, restrict the means of taking Personal Information out of our company, prevent unauthorized access from outside, prevent leakage, loss, or damage of Personal Information, and perform other safety management of Personal Information (hereinafter referred to as "safety management measures").
In implementing safety management measures, our company will utilizerelevant laws, guidelines, and ISMS (Information Security Management System),and will appropriately take technical and organizational protection measures as follows:

(1) Technical Protection Measures

Our company will implement control of access to Personal Information (limiting of access to authorized persons, changing of passwords on a regular basis, etc.) and restriction of the means for taking out.
Our company will implement measures to prevent unauthorized access from outside (such as the installation of firewalls).

(2) Organizational protection measures

1. ①

   Supervision of Employees (including temporary employees)

   Our company will appoint an "Information Security Manager" as the person responsible for Personal Information management, and clearly define theresponsibilities and authorities of employees regarding the safety management of Personal Information.
   Our company will establish internal rules and manuals for safety management, ensure that all employees comply with these rules and manuals, and conduct appropriate audits of the status of compliance.
   Our company will provide education and training to our employees regarding the safety management of Personal Information.



2. ②

   Supervision of Outsourcees

   Our company may outsource all or part of the work of handling of Personal Information. In this case, our company will select a company that can handle Personal Information appropriately. In the outsourcing contract, our company will establish appropriate rules for safety management measures, confidentiality, conditions for re-consignment, return of Personal Information upon termination of the outsourcing contract, and other matters related to the handling of Personal Information, and implement necessary and appropriate supervision.

（6）Provision of Personal Information to Third Parties

Our company will not provide Personal Information to third parties without the prior consent of the user, except in cases where disclosure is permitted under the Personal Information Protection Law or other laws, or in thefollowing cases:

1. ①When it is necessary for the protection of the life, body, or property ofan individual, and it is difficult to obtain the consent of the user
2. ②When it is particularly necessary for the improvement of public healthor the promotion of the sound growth of children, and it is difficult to obtain the consent of the user
3. ③When it is necessary to cooperate with government organizations, local public organizations, or persons or organization entrusted by either of the foregoing in executing affairs prescribed by laws, and obtaining the consent of the user may impede the execution of such affairs
   Notwithstanding the provisions of the preceding paragraph, the following cases shall not apply.

1. ①

   When our company entrusts all or part of the handling of Personal Information within the scope necessary to achieve the purpose of use

2. ②

   When Personal Information is provided as a result of the succession of business

3. ③When permitted under the Personal Information Protection Law or other laws

（7）Disclosure and Correction, etc. of Personal Information

1. When requested to disclose Personal Information by user oneself, our company will disclose it to the user without delay. However, our company may not disclose all or part of Personal Information if disclosure would cause any of the following to occur, and if our company decides not to disclose Personal Information, we will notify the user to that effect without delay:

1. ①When there is a risk of harm to the life, body, property, or other rightsor interests of the user or third parties
2. ②When there is a risk of significant hindrance to the proper execution of our company business.
3. ③When it would violate other laws

2. Notwithstanding the provisions of the preceding paragraph, our company will not, in principle, disclose any information other than Personal Information, such as history and/or characteristics information.

3. If Personal Information which our company owns is incorrect, Users may request our company to correct, add, or delete the Personal Information (hereinafter referred to as "correction, etc.") in accordance with the procedures established by our company.

4. If our company receives a request from a user as described in the preceding paragraph and deems it necessary to respond to the request, our company will make correction etc. the relevant Personal Information without delay.

5. If our company makes any correction, etc. based on the provisions of the preceding paragraph or decides not to make any correction, etc., our company will notify the user of that effect without delay.

（8）Contact Information for Handling of Personal Information

If you have any comments, questions, complaints, disclosure or correction of personal information, or any other inquiries regarding the handlingof user information, please contact us at the following address:

4-2, Nakamachi 1-chome, Machida-shi, Tokyo 194-0021, Japan
Asilla, inc.

（9）Disclaimer

Our company assume no responsibility for the following cases:

1. ①When a user oneself reveals the own Personal Information to a third party using the functions of our service or other means
2. ②When an individual is able to be identified by the information etc. which the user oneself disclosed on our service

（10）SSL/TLS

When users provides us with the own Personal Information through the services which our company operates, we will use encryption using SSL (Secure Sockets Layer)/TLS (Transport Layer Security) or equivalent security technology to prevent third parties from intercepting the user’s information during communications.
However, you may not be able to use these technologies in rare cases depending on your computer environment. In such cases, our company will indicate that the security during the communications cannot be ensured.

（11）Cookie/Web Beacon/IP Address

Cookies, Web beacons, and IP addresses may be used for the following purposes in services operated by our company:

• To find and resolve the causes of failures and problems that occur on our server
• To improve the content of our website, e-mails, etc.
• To customize the contents of our websites and e-mails for individual users
• To use the user’s browsing history, questionnaire results, etc. in membership services where the user’s Personal Information is registered in advance, for marketing activities
• To utilize as statistical data in a state where individual cannot be identified

Users may refuse our company’s use of cookies and web beacons by setting the user’s Internet browsing software (hereinafter referred to as "browser") to refuse the acceptance of cookies
However, in such cases, there may be restrictions, such as the inability to use some functions such as a customization function.

（12）Others

1. Our company may revise the contents of this policy in order toenhance the protection of customers' Personal Information, or in accordancewith changes in laws to be followed, national guidelines, or other standards.

2. Our company may change the contents of this policy without noticeto users, except as otherwise provided by law or in this policy.

3. Except as otherwise provided by our company, the revised PrivacyPolicy shall become effective when it is posted on this website.