Privacy Policy

*This English text is a reference translation. The Japanese version is the authoritative text; if there is any discrepancy in meaning between the Japanese and English versions, the Japanese version prevails.*

X Inc. (the "Company") recognizes that it bears a very significant role and social responsibility with respect to the protection of personal information. Accordingly, in order to comply with the laws, government guidelines and other norms concerning the protection of personal information, the Company establishes the following personal information protection policy, builds a framework for protecting personal information, and handles personal information appropriately and properly.

Article 1 (Personal Information)

"Personal information" means personal information as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003; the "Personal Information Protection Act"): information about a living individual that can identify the specific individual by the name, date of birth or other description contained in the information, or that contains an individual identification code.

Article 2 (Acquisition and Use of Personal Information)

1. The Company acquires the following personal information.
(1) The name, address, email address and telephone number of a user of the Company's services
(2) Login history and communication logs when using the Company's services (date and time of communication, IP address, cookies, etc.)
(3) The content of communications and the email address when contacting the Company
(4) Credit card information (name, card number, expiry date) required for payment for the Company's services, and account information used at the time of bank transfer
(5) Information provided by the user to the Company in connection with the usage agreement for the Company's services
(6) The IP address, host name, access date and time and other access logs of persons who access this site or other websites operated by the Company
(7) Matters stated in a résumé or other documents submitted when applying to the Company's job openings
(8) The name, address, email address, telephone number and date of birth of employees
(9) Employees' account information and other information necessary for salary payment
(10) Employees' health information and other information necessary for employment
(11) Information about business partners (including their officers and employees in the case of a corporation) disclosed by the business partner when commencing a transaction other than the use of the Company's services (a "Transaction")

2. The Company uses the personal information acquired by the methods in the preceding paragraph to the extent necessary for the following purposes. If the Company uses personal information beyond the scope of the following purposes, it will obtain the consent of the user of the Company's services in advance by an appropriate method.
(1) To conclude and renew agreements for the Company's services, provide services, and manage and confirm contract information or usage status
(2) To identify individual users of the Company's services
(3) To bill usage fees for the Company's services
(4) To aggregate as statistical information and improve or enhance the Company's service content, or develop new products and services
(5) To provide information such as updates and campaigns for the Company's services and information about services other than the Company's services provided by the Company (including sending by email, LINE, flyers and other direct mail)
(6) To notify, as necessary, information required for maintenance of the Company's service websites and for provision of the Company's services
(7) To respond to inquiries from users of the Company's services or persons considering use (including performing identity verification)
(8) To report usage status to users of the Company's services
(9) To request cooperation with questionnaires, interviews and the like regarding the Company's services, or to report their results
(10) To investigate and analyze the usage history and the like of the Company's services and use the results for the improvement and development of the Company's services and for the delivery of advertisements
(11) To investigate facts, such as identifying users of the Company's services who have violated the terms or laws or who attempt to use the Company's services for improper or unjust purposes (including provision of information to public agencies)
(12) To respond to disputes or litigation with users of the Company's services
(13) To hold negotiations and reach agreements on Transactions with business partners, to perform the contents of contracts, and to make communications necessary for Transactions
(14) To manage business-partner information
(15) To conduct the screening of job applicants and to communicate regarding hiring
(16) To make business communications to employees, pay remuneration, perform personnel and labor management, provide welfare benefits, and manage health
(17) To otherwise carry out operations incidental or related to the Company's services

3. On the Company's sites, in order to understand the visit status of the Company's sites, the Company uses Google Analytics, a service of Google, and Google collects, records and analyzes the visit history of the Company's sites based on cookies issued by the Company. The Company receives the analysis results from Google and understands the visit status of the Company's sites. However, the information collected, recorded and analyzed by Google Analytics does not contain any information that identifies a specific individual.

Such information is managed by Google in accordance with Google's privacy policy.

You can also stop the collection of your information through the Company's use of Google Analytics by disabling Google Analytics in your browser's add-on settings. To disable Google Analytics, download and install the "Google Analytics Opt-out Add-on" from Google's opt-out add-on download page and change your browser's add-on settings. Note that if you disable Google Analytics, it will also be disabled on websites other than this site that you visit; you can re-enable Google Analytics by re-configuring your browser's add-on. For an explanation of the Google Analytics terms of service, see the Google Analytics site, and for an explanation of Google's privacy policy, see Google's site.

Google Analytics Terms of Service
https://marketingplatform.google.com/about/analytics/terms/jp/

Google Privacy Policy
https://policies.google.com/privacy?hl=ja

Google Analytics Opt-out Add-on
https://tools.google.com/dlpage/gaoptout?hl=ja

Article 3 (Provision of Personal Information to Third Parties)

The Company manages personal information strictly and does not disclose or provide personal information to third parties except in the following cases.
(1) Where consent is given
(2) Where it is necessary for the protection of the life, body or property of a person and it is difficult to obtain consent
(3) Where it is especially necessary for improving public health or promoting the sound development of children and it is difficult to obtain consent
(4) Where it is necessary to cooperate with a national agency, a local government, or a party entrusted by either, in performing affairs prescribed by law, and obtaining consent is likely to impede the performance of those affairs
(5) Where the Company entrusts all or part of its operations to a third party within the scope necessary to carry out the Company's services smoothly or to achieve the purpose of use
(6) Where personal information is provided in connection with the succession of business due to a merger or other cause
(7) Where personal information is jointly used with a specific party, and the Company has notified in advance, or placed in a readily accessible state, the fact thereof, the items of personal information jointly used, the scope of joint users, the purpose of use, and the name of the party responsible for the management of the personal information
(8) Where the disclosure or provision of personal information is otherwise permitted by law

Article 4 (Entrustment of Handling of Personal Information)

The Company may entrust all or part of the handling of personal information to a third party to the extent necessary to achieve the purpose of use. In this case, the Company stipulates matters concerning confidentiality obligations in the contract and exercises necessary and appropriate supervision over the entrustee. The Company may also jointly use all or part of the acquired personal information in accordance with the provisions of the Personal Information Protection Act.

Article 5 (Matters Concerning Security Control Measures)

The Company takes the following necessary and appropriate security control measures for the management of personal information, including the prevention of leakage, loss or damage. The Company also exercises necessary and appropriate supervision over employees who handle personal data and over entrustees (including sub-entrustees; employees and entrustees are collectively referred to as "Employees, etc.").

(1) Organizational security control measures
The Company appoints a person in charge of handling personal information, clarifies the Employees, etc. who handle personal information and the scope of personal information they handle, and establishes a system for reporting to and contacting the person in charge when a fact or sign of a violation of the Personal Information Protection Act or the personal information handling rules is identified.
In addition, when the Company entrusts operations to an entrustee, it discloses and provides personal information only after concluding a confidentiality agreement with the entrustee.

(2) Human security control measures
The Company provides education or training to Employees, etc. regarding points to note in handling personal information.

(3) Physical security control measures
The Company restricts the devices used by Employees, etc. and implements measures to prevent the viewing of personal information by unauthorized persons.

(4) Technical security control measures
The Company limits the scope of Employees, etc. who handle personal information.
The Company introduces mechanisms to protect information systems that handle personal information from unauthorized external access or malicious software.
The Company continuously reviews the safety of its information systems, including measures against attacks that exploit system vulnerabilities.

Article 6 (Disclosure of Personal Information)

1. When a user of the Company's services requests disclosure of personal information, the Company discloses it to the user without delay. However, if any of the following applies, the Company may not disclose all or part of it, and after deciding not to disclose, notifies the user to that effect without delay.
(1) Where it cannot be confirmed that the requester is the user themselves or the user's agent
(2) Where there is a risk of harming the life, body, property or other rights and interests of the user or a third party
(3) Where there is a risk of significantly impeding the proper conduct of the Company's business
(4) Where it would otherwise violate laws

2. When a user requests the Company to disclose personal information under the preceding paragraph, the user shall mail to the Company the prescribed request form set out below together with the required documents. The cost of sending the documents shall be borne by the requester.

< Documents to send >
(1) Personal information disclosure request form
(2) Materials for identity verification (e.g., a driver's license, passport or other item that carries a facial photograph and can identify the individual)
(3) In the case of an agent, materials evidencing the authority of representation (e.g., a family register, power of attorney and seal registration certificate)

< Address >
108-0073
Furointo Mita 603, 2-14-5 Mita, Minato-ku, Tokyo
X Inc.

Note: After submission of the required documents, the Company will perform identity verification (including confirmation of an agent) based on the personal information it holds, and upon confirming identity, will provide the information. Note that if identity cannot be confirmed, the Company may be unable to disclose personal information about the user.

3. For the procedure for disclosure of personal information under Paragraph 1, the user requesting disclosure shall bear a fee of 5,500 yen (tax included) per request, so please note this in advance. The fee shall be paid by bank transfer or the like.

Article 7 (Correction and Deletion of Personal Information)

1. If the personal information held by the Company is incorrect, the Company will, at the request of the user and in accordance with the procedures determined by the Company, correct or delete the personal information. The Company's prescribed procedures are as stated in Paragraph 2 of the preceding Article.

2. If the Company receives a request under the preceding paragraph from a user and determines that it is necessary to comply, it will correct or delete the relevant personal information without delay and notify the user thereof.

Article 8 (Suspension of Use of Personal Information)

If a user of the Company's services requests suspension of use or erasure ("Suspension of Use, etc.") of personal information on the ground that it is being handled beyond the scope of the purpose of use, or that it was acquired by improper means, the Company will conduct the necessary investigation without delay and, based on the results, carry out the Suspension of Use, etc. and notify the user thereof. However, where the Suspension of Use, etc. requires a large expense or is otherwise difficult, and where alternative measures necessary to protect the user's rights and interests can be taken, the Company may take such alternative measures.

Article 9 (Procedure for Changing this Privacy Policy)

The Company reviews the contents of this policy as appropriate and endeavors to improve it. Except for matters otherwise provided by law or in this policy, the contents of this policy may be changed. The changed privacy policy takes effect from the time the Company notifies users by the method determined by the Company, or posts it on the Company's website.

Article 10 (Compliance with Laws and Norms)

The Company complies with the laws of Japan and other norms applicable to the personal information it holds.

Article 11 (Handling of Complaints and Consultations)

The Company accepts complaints and consultations from users of the Company's services regarding the handling of personal information and responds appropriately and promptly. The Company also responds promptly and appropriately to requests from users, such as disclosure, correction, addition, deletion of the relevant personal information, or refusal of its use or provision.

Article 12 (Company Information and Contact)

The Company's information is as follows. For inquiries regarding the handling of personal information, please contact us below.

Business operator: X Inc.
Representative Director: Yukari Takano
Address: Furointo Mita 603, 2-14-5 Mita, Minato-ku, Tokyo
Contact: support@mintfile.com

Established: March 25, 2026