A440 inc. (hereinafter referred to as the “Company”) hereby sets out its privacy policy (hereinafter referred to as the “Policy”) as follows in connection with the handling of personal information of users that is acquired through services (hereinafter referred to as the “Services”; even if the names and contents of such services are changed, the services after the change shall be included in the Services) related to “MEWVER”, which is provided on an application (hereinafter referred to as the “App”) that is provided by the Company for smartphones.

Article 1 (Personal Information)

“Personal information” shall refer to “personal information” defined in the Personal Information Protection Act.

Article 2 (Personal Information Collection Method)

When users make registration for the use of the Services, the Company may ask them to provide their email addresses, credit card numbers and other personal information. In addition, the Company may collect information (including personal information of users) relating to transaction records and settlements between users and the Company’s partner companies from such partner companies (including information providers, advertisers, parties to which ads are delivered, etc., and hereinafter referred to as “Partner Companies”) and other parties.

Article 3 (Purposes of Collecting and Using Personal Information)

  1. Purposes for which the Company collects and uses personal information are as follows:

    (a)To provide and operate the Company’s services;

    (b)To respond to inquiries made by users (including confirming their identity);

    (c)To send emails about new functions, updates, campaigns, etc. for services that are being used by users and about other services provided by the Company;

    (d)To make a notification, as necessary, regarding maintenance, important information, etc.;

    (e)To identify a user who violates the Terms of Use and a user who tries to use services for illegal or unjust purposes, and refuse the use by such users;

    (f)To allow users to check, change or delete their registered information and check the status of usage;

    (g)To charge users a fee for paid services; and

    (h)Purposes associated with the above purposes of use.

Article 4 (Changes to the Purposes of Use)

  1. The Company shall change any of the purposes of use of personal information to the extent that a purpose of use after the change is reasonably considered to show association with that before the change.
  2. If any of the purposes of use is changed, the Company shall notify users of the purpose after the change or publicize such purpose on the App in a manner specified by the Company.

Article 5 (Provision of Personal Information to Third Parties)

  1. The Company will not provide personal information of a user to a third party without obtaining prior consent of such user, except in the following cases. However, this shall not apply where such provision is permitted under the Personal Information Protection Act or other laws and regulations:

    (a)Where such provision is necessary to protect the life, body or assets of a person and it is difficult to obtain the consent of such user;

    (b)Where such provision is particularly necessary for improving public health or promoting healthy development of children and it is difficult to obtain the consent of such user;

    (c)Where the Company needs to cooperate with a state body or a local government or their agent in the execution of their duties set forth in laws and regulations and obtaining the consent of such user may obstruct the execution of such duties; and

    (d)Where the following matters are notified or publicized in advance and the Company has made a notification to the :

    (ⅰ) Items of data provided to a third party;

    (ⅱ) Means or method of providing to a third party;

    (ⅲ) Provision of personal information of a person to a third party is discontinued at the request of such person; and

    (ⅳ) Method of receiving a request from such person.

  2. Notwithstanding the provisions of the preceding paragraph, in the cases set forth in the following items, a party to which such information is provided shall not be deemed as a third party:

    (a)Where all or part of the handling of personal information is entrusted to the extent that such entrustment is necessary for the Company to achieve the purposes of use;

    (b)Where personal information is provided as a result of transfer of business due to a merger or other reasons; and

    (c)Where personal information of a person is used jointly with a specific party(s) and the following matters are notified in advance to, or made readily accessible by, such person: the fact of such joint use; items of personal information that are subject to the joint use; the scope of joint users; the purposes of use by users; and the name of a person or entity in charge of management of such personal information.

Article 6 (Disclosure of Personal Information)

  1. The Company shall disclose personal information of a person to such person without delay if he/she requests the Company to disclose such personal information; provided that, if any of the following situations occurs as a result of the disclosure, the Company may refrain from disclosing all or part of the personal information and if the Company decides not to disclose it, the Company shall notify such fact to the person without delay. In addition, in the case of disclosing personal information, the Company shall charge 1,000 yen per case as a fee:

    (a)When the life, body, assets or other rights and interests of such person or a third party may be damaged;

    (b)When the proper implementation of operations of the Company may be significantly obstructed; and

    (c)Other than the above, cases of violating laws and regulations.