Privacy Policy
Lazuli Inc., (hereinafter "Lazuli") shall handle personal information of customers (hereinafter"Customer Information") in the services provided by Lazuli (hereinafter "Services") as follows.
Article 1 (General Provisions)
1.

Lazuli shall comply with the Personal Information Protection Law and other related laws
and regulations in order to protect Customer Information.

2.

This policy applies to Services (including services provided by Lazuli in conjunction withServices).

3.

In the event that Lazuli stipulates the handling of Customer Information in its privacy
policy, other personal information protection policies, or terms of use posted on thewebsite operated by Lazuli, such stipulations shall also apply, and if such stipulations
conflict with this policy, this policy shall prevail.

4.

The provisions of this policy shall not apply to services provided by parties other thanLazuli related to Services (hereinafter "External Services"). Please refer to the privacy
policy, etc. separately stipulated by the service providers for the handling of Customer
Information in such services.

Article 2 (Information to be Obtained)1.

Lazuli may acquire Customer Information, including personal information ("personalinformation" as defined in Article 2, Paragraph 1 of the Personal Information Protection
Law, hereinafter the same shall apply) as follows.
(1) Information provided by customers.
(2) E-mail address.
(3) Name, affiliation, and other information specified by Lazuli.
(4) Information collected by Lazuli when customers use Services.
(5) Terminal information of customers.

2.

Lazuli may collect information specific to the terminal used by customers (individualidentification information such as a unique terminal ID) for the operation of the system
necessary for the implementation of Services, maintenance and improvement of Services,or to prevent fraudulent activities.

3.

Lazuli may collect information on customer usage of Services, access log information,and action history information in order to maintain and improve Services or to prevent
fraud.

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4.

Lazuli shall not use deception or other wrongful means to acquire Customer Information,
but shall acquire such information in an appropriate manner. In addition, when obtaining
Customer Information by any means other than through the use of Services, Lazuli will
notify or publicly announce the purpose of use in advance.

Article 3 (Purpose of Use)1.

Lazuli shall properly handle Customer Information acquired under Services within thescope of the following purposes. Lazuli shall not use Customer Information beyond thescope of the purposes of use without the consent of customers.

Purpose of Use Purpose of Use (Details)
Provision,⚫

Information to be used

To verify customers’ identity and prevent

maintenance andunauthorized use of Services.

improvement of ⚫

To provide, maintain, and improve Services

Servicessmoothly.
⚫

⚫

E-mail address.

⚫

Name, affiliation, andotherinformation

requiredtoprovideServices.

To provide information on Services and torespond to inquiries, etc.

Notification
andtoresponse

from customers,

⚫
⚫

etc.

To notify or provide new services related to ⚫

E-mail address

Services.

Name, affiliation, and⚫

To notify customers of changes to the Terms

otherofnecessary to provide

Serviceor

thisPolicy,suspension,discontinuation, or termination of Services,

information

Servicesand other important notices related toServices⚫

ProvisionofCustomer
Information

tolisted to the right may use such information ⚫

Name, affiliation, andfor the following purposes

other

✓

To provide affiliated services.

necessary to provide✓

To display advertising information, etc. thatServices.

matches the needs, interests, and concerns of ⚫

Terminal Information.

customers.

Log and action history

third parties

2.

Third parties who receive the information⚫

✓

To analyze advertising effectiveness.

✓For market analysis and marketing

information

information

Lazuli may change the purpose of use described in the preceding paragraph to the extent
2that it is reasonably deemed to be related to the purpose of use before the change, and in
the event of a change, Lazuli shall notify customers or make a public announcement in amanner separately determined by Lazuli.
Article 4 (Protection of Personal Information)
Lazuli shall appoint a person responsible for the management of Customer Information inorder to handle Customer Information, make its reasonable effort to establish a system toprevent unauthorized access to, loss, falsification, or leakage of personal information, andstrive to properly manage Customer Information.
Article 5 (Provision to Third Parties)
1.

Lazuli shall not provide personal information among Customer Information to thirdparties, except in the following cases;(1) when the customer's consent has been obtained.
(2) When required by law.
(3) When a customer commits or attempts to commit an act that harms the interests ofothers or offends public order and morals or otherwise violates the Terms of Use ofServices, and when taking necessary action against such an act.
(4) When it is necessary for the protection of the life, body, or property of an individual
and it is difficult to obtain the consent of the individual.
(5) When the provision of personal information is particularly necessary for improvingpublic health or promoting the sound growth of children and it is difficult to obtainthe consent of the person concerned.
(6) Cases in which the provision of personal information is necessary for cooperatingwith a state organ, a local government, or an individual or entity entrusted by eithera state organ or local government to execute affairs prescribed by law, and in whichobtaining the consent of the individual is likely to impede the execution of the affairs
concerned.
(7) When a merger, corporate separation, business transfer, or other such event resultsin the succession of a business that contains customers' personal information.

2.

In order to provide affiliated services, Lazuli may provide Customer Information tobusiness operators who provide services affiliated with Services with the prior consent ofthe customer.

3Article 6 (Entrustment of Handling of Personal Information)
Lazuli may entrust a third party with the handling of all or part of the personal information
Lazuli has obtained from customers (this refers to the case where Lazuli entrusts a third party
with the management of Customer Information, including personal information). In suchcases, Lazuli shall enter into a confidentiality agreement with the third party in advance thatconforms to this policy, and provide necessary and appropriate supervision to ensure that thethird party appropriately manages the information in a secure manner.
Article 7 (Security Management System)
1.

In order to prevent leakage, loss, or damage of Customer Information and to protect other
Customer Information, Lazuli shall take necessary and appropriate measures for the safe
management of Customer Information, such as restricting access to personal information
files, recording access logs, and installing security software to prevent unauthorizedaccess from outside.

2.

The representative director of Lazuli is responsible for the management of Customer
Information, and Lazuli implements appropriate management and continuous
improvement of Customer Information.

Article 8 (Disclosure, Correction, etc. of Customer Information)1.

For disclosure, correction, addition, deletion, or discontinuance of use of personal
information provided by customers, please refer to our separate guide to requesting
disclosure, etc. of personal information. However, depending on the nature of theinformation, there may be cases where these procedures cannot be performed.

2.

In the case of a request based on the preceding paragraph, upon verification of theidentity of the applicant, Lazuli shall disclose personal information to a reasonable extent.
However, this does not apply to cases in which Lazuli is not obligated to disclose, etc.
under the Personal Information Protection Law or other laws and regulations.

Article 9 (Changes to this Policy)
1.

Lazuli shall review the operation of the handling of Customer Information from time totime and strive for continuous improvement, and may change this Policy from time totime as necessary.

2.

Lazuli shall notify customers of any changes to this Policy by posting the revised Policy
on Services or on the website operated by Lazuli, or by other easily understandable means.
However, when making changes to the contents of this Policy that require the consent ofcustomers under laws and regulations, Lazuli shall obtain the consent of the customer in4

a manner separately determined by Lazuli.
Article 10 (Inquiries)
If customers have any opinions, questions, complaints, or other inquiries regarding ourhandling of Customer Information, please contact us at the following address.
Lazuli Personal Information Handling Inquiry Desk
E-mail : yuji_ikeuchi@lazuli.ninja
Date of enactment: January 1, 2021

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