Brass Design Ltd. (hereinafter referred to as the "Company") is committed to the following privacy policy (hereinafter referred to as the "Policy") regarding the handling of personal information of users in the services provided on this website (hereinafter referred to as the "Services"). The following privacy policy (hereinafter referred to as the "Policy") applies to the handling of users' personal information in the services provided on this website (hereinafter referred to as the "Services"). The following privacy policy (hereinafter referred to as the "Policy") is set out below.

Article 1 (Personal information).

The term 'personal information' refers to 'personal information' as defined in the Personal Data Protection Act, and refers to information relating to a living individual that can identify a specific individual by name, date of birth, address, telephone number, contact details and other descriptions contained in the information, as well as data relating to appearance, fingerprints, voiceprints, and the insurer number on health insurance cards. Information that can identify a specific individual from such information alone, such as name, date of birth, address, telephone number, contact details and other descriptions contained in such information (personal identification information).

Article 2 (Methods of collecting personal data).

The Company may ask for personal information such as name, date of birth, address, telephone number, email address, bank account number, credit card number and driving licence number when the user registers for use.

In addition, transaction records including the user's personal information and information relating to payments made between the user and the partners and other parties (including information providers, advertisers, advertisers and other parties to which the user distributes advertisements) are provided by our partners (including information providers, advertisers and other parties to which the user distributes advertisements. Hereinafter referred to as "partners"). The information may be collected from our partners (including information providers, advertisers, advertisers, etc.) and other parties.

Article 3 (Purpose of collecting and using personal information).

The purposes for which we collect and use personal data are as follows

• To provide and operate our services.
• To respond to user enquiries (including to verify identity).
• To send emails about new features, updates, campaigns, etc. of the services the user is using and information about other services provided by the Company To contact the user as necessary, such as maintenance, important notices, etc.
• To identify users who have breached the Terms of Use or who are attempting to use the services for fraudulent or unjustified purposes, and to refuse their use.
• To allow users to view, change or delete their own registration information and view the status of their usage.
• To charge users for paid services.

Purposes incidental to the above purposes of use.

Article 4 (Provision of personal data to third parties)

1.The Company will not provide personal information to third parties without the prior consent of the user, except in the following cases. However, this excludes cases permitted under the Personal Data Protection Act and other laws and regulations.

Where it is necessary for the protection of a person's life, body or property and it is difficult to obtain the consent of the person.

Where it is particularly necessary for the improvement of public health or the promotion of the sound development of children and it is difficult to obtain the consent of the person concerned.

When it is necessary to cooperate with a state body, a local authority or a person entrusted by such a body to carry out affairs prescribed by law, and obtaining the consent of the person may impede the carrying out of such affairs.

When the following matters have been notified or published in advance and the Company has notified the Personal Data Protection Commission

The purpose of use must include provision to third parties.
Data items provided to third parties.
Means or method of provision to third parties.
To stop the provision of personal data to third parties at the request of the individual.
How to accept the request of the person.

2.Notwithstanding the provisions of the preceding paragraph, the following cases shall not constitute third parties to whom such information is provided

Where the handling of personal information is outsourced in whole or in part to the extent necessary to achieve the purpose for which it is used by the Company.
Where personal data is provided as a result of the succession of a business due to a merger or otherwise.

Where personal information is to be used jointly with a specific person, and this fact and the items of personal information to be used jointly, the scope of the joint users, the purpose of the use of the personal information and the name of the person responsible for the management of the personal information are notified to the person in advance or are readily available to the person in question. (iii) where the person concerned is notified in advance or is made readily accessible to the person concerned.

Article 5 (Correction and deletion of personal data)

If the User's personal information held by the Company is incorrect, the User may request the Company to correct, add to or delete the personal information (hereinafter referred to as "correction") in accordance with the procedures set out by the Company. The User may request the correction, addition or deletion of his/her personal information (hereinafter referred to as "Correction, etc.") in accordance with the procedures set by the Company.

If the Company receives a request from a User under the preceding paragraph and deems it necessary to respond to that request, the Company shall correct the relevant personal data without delay.

If the Company makes corrections in accordance with the preceding paragraph or decides not to make corrections, it will notify the User of this without delay.

Article 6 (Contact person for enquiries).

For any enquiries regarding this policy, please contact

Address: 2-17-23 Ebisu, Shibuya-ku, Tokyo
Name of company: Brass Design Ltd.
Representative director: Takeo Kato
Telephone number: 03-6770-7440