Ace System Inc. (hereinafter referred to as the “Company”) has established the following privacy policy (hereinafter referred to as the “Policy”) regarding the handling of personal information of users of the Company's services (hereinafter referred to as “Users”). The Company has established the following privacy policy (hereinafter referred to as the “Policy”) regarding the handling of personal information of users of the Company's services (hereinafter referred to as “Users”). (hereinafter referred to as “the Company”) has established the following privacy policy (hereinafter referred to as “the Policy”) regarding the handling of personal information of users of the Company's services (hereinafter referred to as “Users”).

1.personal information

Personal information” means ‘personal information’ as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the ‘Personal Information Protection Act’). Personal information” means information about a living individual that can identify a specific individual by name, date of birth, or other description, etc., or that contains a personal identification code, as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the ‘Act’).

2.Purpose of use of personal information​

We will acquire personal information of users and use the acquired information to the extent necessary for the following purposes. If we intend to use personal information beyond the scope of the following purposes, we will obtain prior consent from the user in an appropriate manner.

1. (hereinafter referred to as the “Company”) to provide the Company's services (hereinafter referred to as the “Services”) To provide our services (hereinafter referred to as the “Services”)
2. To improve the contents of this service or develop new services
3. To provide information on new features, updates, campaigns, etc. of the Service and other services provided by the Company (including sending e-mails, flyers, and other direct mailings) For the following purposes
4. To contact you as necessary for maintenance, important notices, etc.
5. To respond to comments, inquiries, etc. from users regarding the Service (including to confirm the identity of the user).
6. To report to users on the use of this service
7. To request cooperation for questionnaires, interviews, etc. related to this service, to request participation in various events, or to report the results of such events, etc.
8. To research and analyze the usage history of this service and use the results to improve and develop this service and to deliver advertisements.
9. Provision of personal information to companies, etc. participating in events sponsored by the Company based on the user's consent or application
10. To identify users who have violated the Terms of Use or who are attempting to use the Service for fraudulent or unjustified purposes, and to refuse their use of the Service.

3.Management and Protection of Personal Information

Personal information shall be strictly managed and shall not be disclosed or provided to third parties without the consent of the user, except in the following cases. In addition, in consideration of safety, we will take measures to prevent and correct risks such as unauthorized access to personal information, loss, destruction, falsification, and leakage of personal information.

1. When it is necessary for the protection of a person's life, body, or property and it is difficult to obtain the user's consent
2. When it is especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the user's consent
3. When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the user's consent is likely to impede the execution of such affairs.
4. Other cases permitted by laws and regulations

4.Outsourcing of Personal Information Handling

We may outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use. In such cases, the Company will thoroughly examine the eligibility of the consignee, stipulate confidentiality obligations in the contract, and exercise necessary and appropriate supervision over the consignee.

5.Joint Use of Personal Information

We may share the personal information of users within the following scope and purposes to the extent necessary to achieve the purpose of use.

[Purpose of joint use]

• To provide and improve services
• To respond to various inquiries
• To provide information on marketing activities and campaigns
• To fulfill legal obligations

[Purpose of joint use]

• Name, phone number, e-mail address, place of employment, transaction details, etc.

[Scope of joint use]

• Group companies (Ace System Solutions Corporation, ASA Corporation, ASTEC Corporation)
• Contract agency
• Businesses with whom we have concluded an agency agreement as deemed necessary for our business

※For more information on our contracted agents, please contact us.

[Persons responsible for the management of personal information]

• Ace System Corporation (Representative: Yoshihiro Sako)

6.Provision of Personal Information to Third Parties

We will not provide your personal information to third parties except in the following cases.

1. When we have obtained prior consent from the customer
2. When outsourcing within the scope necessary to achieve the purpose of use
3. When we are required to provide the information by law
4. When it is necessary for the protection of a person's life, body, or property and it is difficult to obtain the customer's consent
5. When it is especially necessary to improve public health or to promote the sound growth of children and it is difficult to obtain the customer's consent
6. When it is necessary to cooperate with national or local governments in the execution of their legally prescribed duties, and obtaining customer consent may impede the execution of such duties.
7. When providing information to those listed in the scope of co-users
8. Other cases permitted by laws and regulations

7.Procedures for Disclosure of Personal Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at the contact information below.

Ace System Corporation Personal Information Inquiry Desk
Address: 3-1-3 Ayumino, Izumi-shi, Osaka, 594-1157, Japan
TEL:0725-54-3958
Mail:p-policy@acesystem.co.jp

8.Changes to this Policy

We will review the contents of this policy from time to time and strive to improve it. The contents of this policy may be changed except as otherwise provided in laws and regulations or in this policy. The revised Privacy Policy shall become effective when it is notified to users or posted on the Company's website in a manner prescribed by the Company.

9.Security Control Measures

We will manage users' personal data appropriately and carefully, and implement necessary and appropriate levels of security measures to protect personal data from risks such as leakage, misuse, alteration, and unauthorized access, as described below.

1. technical safeguard
   Measures to protect personal information from unauthorized access from outside (e.g., use of SSL security, introduction of anti-virus software, etc.).
2. organizational safeguard
   We regularly provide training to our employees on the management of personal information.

10.Our address, name of representative, and personal information protection manager

Our address, representative and the name of the personal information protection manager are as follows.
Address: 3-1-3 Ayumino, Izumi-shi, Osaka, 594-1157, Japan
Representative: Yoshihiro Sako
Personal Information Protection Manager: Kazunori Sako

Enacted and effective December 27, 2024.