PRIVACY POLICY

(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.

Article 1 (Purpose)

1. Terms of Use of Asilla SDK (hereinafter referred to as “this Terms of Use”) sets forth the conditions under which Asilla, inc. (hereinafter referred to as “our company”) grants Users the license to use Asilla SDK (hereinafter referred to as “this SDK”).
2. Users shall use this SDK only for the purpose of developing apps (hereinafter referred to as “this purpose of use”) in accordance with the conditions set forth in this Terms of Use.

Article 2 (Definitions)

1. “This SDK” means the software development kit including, but not limited to, programs for developing application software for behavior recognition AI which our company provides to Users.
2. “Apps” means the application software for behavior recognition AI.
3. “Users” means persons who develop application software for behavior recognition AI using this SDK.
4. “Developed apps” means the apps developed by Users.
5. “This agreement” means the license agreement for this SDK concluded between our company and Users in accordance with the conditions set forth in this Terms of Use by the user downloading this SDK.
6. “This site” means the Asilla SDK site on the Internet managed by our company.

Article 3 (Scope of Application)

1. This Terms of Use shall apply to the use of this SDK. The detailed regulations, etc. regarding this SDK which will be announced by our company to Users through this site shall constitute parts of this Terms of Use. The detail regulations, etc. shall become effective from the time they are displayed on this site, unless otherwise provided by our company.
2. Our company may change this Terms of Use at it's sole discretion if necessary.

Article 4 (Contents of License)

Our company grants a non-exclusive license to use this SDK to Users within the scope of this Terms of Use.

Article 5 (Ownership of Rights)

1. Any copyrights, patent rights, trademark rights, and other intellectual property rights related to this SDK shall belong to our company or the third party with legitimate authority.
2. The license of this SDK set forth in this Terms of Use shall not permit any transfer or license of our company's intellectual property rights related to this SDK.

Article 6 (Distribution of the product)

Users shall download this SDK any time at their discretion as this SDK is distributed via the Internet. We shall not limit the countries from which users shall use this SDK.

Article 7 (Conclusion of This Agreement)

1. This agreement shall be concluded when Users agree to this terms of use and download this SDK. Our company shall restrict or suspend the use of this SDK in case of the followings:
(1) Users who have been disposed of cancellation or suspension in the case of violation of this Terms of Use in the past
(2) Notification at the time of downloading is false, error or incompletion
(3) Effectively for the purpose of secret by competitive company合
(4) Users are Anti Social Forces
(5) Other things that our company deems inappropriate

Article 8 (Change or correction of notified information)

1. Users shall change or correct the information notified to our company immediately by the prescribed manner of our company if the information has an update or error.
2. Our company shall not be liable for any damages incurred by Users due to the non-performance of the preceding provision of this Article

Article 9 (Non-warranty)

1. Users shall use this SDK under understanding and accepting that our company makes no warranties for the completeness, accuracy, usefulness, fitness for a particular purpose, security, or non-infringement, etc. of this SDK.
2. This SDK shall be provided as is and to the extent possible in our company. Our company shall make no explicit, implicit, or statutory warranties with respect to this SDK. Our company shall not be liable for whatsoever (including, but not limited to, implied warranties of suitability as product, suitability for specific purposes, rightness, and non-infringement) with respect to this SDK. Users shall use this SDK at its own risk, and shall be solely liable for any liability caused by the use of this SDK (including, but not limited to, damage to the user's system, hardware, or software, etc., and loss of data).

Article 10 (Compliance)

1. Users shall warrant that the user's developed apps do not infringe the rights and interests of any third party and do not constitute breach of contract with any third party.
2. Users shall represent and warrant that the user's developed apps does not contain anything which violates laws or public order and morals, slanders third parties, interferes with the proper management of our company's business, or has the potential to do so.
3. In the event that a third party makes a claim in relation to the user's developed apps or due to the user's violation for this Terms of Use, the User shall promptly give the notice to our company and settle this at the user's own responsibility and expense. In the event that our company suffers damages due to these the user's actions, the User shall immediately compensate for such damage and shall not cause any inconvenience to our company.

Article 11 (Rights Ownership of Developed apps)

1. Copyrights of the developed apps developed by User using this SDK belong to the User.
2. When Users sell or provide the developed apps to a third party other than the User, the User shall conclude a license agreement, etc. for the developed apps with the relevant party at it's own responsibility.

Article 12 (Public Disclosure)

After Users downloaded this SDK, our company may publish the user's company name and logo on our website or sales materials for indicating that this SDK was used. Our company may publish the user's developed apps as used example of this SDK on our website or sales materials.

Article 13 (Prohibited Matters)

Users shall not:
(1) use this SDK for any purpose other than this purpose of use,
(2) perform modification, reverse engineering, reverse compilation, reverse assembling, or any other similar acts on this SDK,
(3) sublicense, sublease or transfer this license to any third party other than the User,
(4) transfer, lend, or dispose the rights and obligations under this Terms of Use and this Agreement to any third party whether with or without consideration, the dispose including, but not limited to, offer the rights as collateral or have any third party take over the obligations,
(5) use this SDK to develop apps which violate laws and regulations or guidelines of governmental authorities, etc., or apps which is intended to infringe on the life, body, or property etc. of any person,
(6) use this SDK in a manner or form which infringes on the legal interests of others or is contrary to public order and morals,
(7) misrepresent the user's developed apps as if it were an apps issued by our company itself or an apps authorized by our company,
(8) use, in the user's developed apps, expressions which may cause discomfort to others by including excessively violent expressions, explicit sexual expressions, and other contents which are contrary to public order and morals,
(9) produce, sell, or distribute an apps which obtains personal information from a person who has not explicitly consented to the collection of personal information,
(10) have this SDK used by those who are or have been antisocial forces (organized crime groups, general merchants, other antisocial groups or individuals), or whose business activities are deemed to be substantially controlled by antisocial forces,
(11) perform any other activities which our company deems inappropriate.

Article 14 (Suspension)

In the event that a defect in this SDK or the possibility of infringement of a third party's rights or interests is discovered, or in any other cases where our company deems it necessary, our company may request Users suspend the use of this SDK. In this case, Users shall promptly respond to the suspension of use of this SDK. Our company shall not be liable for any damages incurred by Users due to the suspension of use of this SDK pursuant to this Article.

Article 15 (Measures to be taken in case of violation)

In the event that our company reasonably determines that User or the user's developed apps violates this Terms of Use, our company may instruct the User to take any of the following measures, and the User shall comply with them:
(1) Stop selling or distributing of the user's developed apps
(2) Modification of the user's developed apps to a content which does not violate this Terms of Use
(3) Suspension of use of this SDK and destruction of copies of this SDK

Article 16 (Limitation of liability)

1. Our company shall not be liable for any damages incurred by Users due to the use of this SDK, for whatever reason. However, this may not apply to damages caused by our company's intentional or gross negligence.
2, Our company, its board members, officers, employees, affiliated companies, agents, contractors or licensors shall not be liable for any damages or claims due to the use of this SDK.

Article 17 (Termination)

In the event that User violates this Terms of Use, or is reasonably deemed to have violated this Terms of Use, our company may terminate this Agreement without prior notice and at our sole discretion. Our company shall not be liable for any damages caused to the User by termination under this Article. In the event that our company suffers damages as a result of termination under this Article, our company may claim compensation for damages against the User.

Article 18 (Duration)

1. This agreement shall be in effect from the effective date hereof and continue for an initial term of one year.
2. Thereafter, it shall be automatically renewed under the same terms for successive one year renewal terms unless users provide notice of non-renewal to our company at least 30 days prior to the expiration of the applicable term.

Article 19 (Cancellation and refund)

Users shall not cancel this agreement after users paid for it. As per the cancellation during the one year period, our company has no obligation to refund the users for the time remaining.

Article 20 (Confidentiality)

Our company and Users shall not divulge to any third party any information designated as confidential by the other party (hereinafter collectively referred to as “Confidential Information”), unless the prior written consent of the other party is obtained. However, this shall not apply to the information listed in the following items:
(1) information which is already obtained before being obtained from the other party
(2) information which is publicly known before being obtained from the other party or has become publicly known through no fault of its own after being obtained from the other party
(3) information which is obtained from a third party having legitimate authority without obligation of confidentiality
(4) information which is independently developed without using of the disclosed confidential information

Article 21 (Protection of Personal Information)

1.Oue company shall handle Personal information of Users (defined in the Act on the Protection of Personal Information) which is expressly disclosed as personal information same as the provisions under the preceding Article.
2. Our company shall use personal information obtained from users only for the purpose of this agreement.
3. Besides the provisions under the preceding two paragraphs, our company shall strive to take necessary action so as to ensure the proper handling of the retained personal information in accordance with our privacy policy.。

Article 22 (Exclusion of Anti Social Forces)

1. "Anti Social Forces" means
(1) an organized crime group, a member of an organized crime group, a related company or association of an organized crime group, and any other equivalent person of above; or
(2) a person who themselves or through the use of third parties conducts a demand with violence, an unreasonable demand beyond its legal entitlement, use of intimidating words or actions, damages the credit or obstructs the business of the other party by spreading false rumors or by the use of fraudulent, or any other equivalent actions of above.
2. Each party represents and warrants that is not a person who falls and has fallen, and shall not fall under any of the followings:
(1) the Anti Social Forces;
(2) a person having such relationship with the Anti Social Forces that shows the Anti Social Forces' substantial involvement in the person's management;
(3) a person having such relationship with the Anti Social Forces that shows reliance on the Anti Social Forces;
(4) a person who cooperate and is involved with the maintenance or operation of any Anti social Forces by providing funding to any Anti Social Forces or any similar act; or
(5) a person who is engaged in socially condemnable relationship with the Anti Social Forces.
3. Each party shall be entitled to terminate this Agreement and request for the damages without any notice and any and all obligations of the party owed to the other party shall become due and payable and the other party shall immediately repay such obligations, if the other party breached the representations and warranties in the preceding clause

Article 23 (Governing Law)

This Terms of Use and This agreement shall be governed by, and construed in accordance with, the laws of Japan.

Article 24 (Jurisdiction)

Any dispute arising out of or in connection with this Terms of Use and This agreement shall be subject to the exclusive jurisdiction of the Tokyo District Court in the first instance.

Article 25 (Contact information)

Asilla Inc,
Mail-address： cs@asilla.jp
Telephone number: +81-42-785-5091
Or we accept the inquiries via the communication application provided for the licensed users.

Company name: Asilla Inc,
Corporate number as per registered at the National Tax Agency of Japan: 012301010123
Company location: Machida, Tokyo