[The governing language of this policy shall be Japanese.]

Cloud Data Policy
Cybozu, Inc. (“Cybozu”) appropriately handles the data (excluding the Customer Information)
generated by using our cloud services as follows.

1. Classification of DataClassification of the data generated by using our cloud services is as follows.
Data TypeDefinition and Examples

Stored Data

“Stored Data” means data and information uploaded, produced orotherwise stored by Customer or the Users at your or their initiatives on
our cloud services other than Customer Information. For example,
Stored Data includes without limitation: (a) file names and contents offiles uploaded by the Users, (b) contents of what was stored into amessage or other fields by the Users and (c) names of the Users. For theavoidance of doubt, data and information generated by extracting andtransforming Stored Data so that the original contents cannot be
identified constitute Analytical Data, not Stored Data.

Analytical Data

“Analytical Data” means data and information collected or generated
during the course of your use of our cloud services in form that cannot
identify original contents of Stored Data other than Customer
Information and Stored Data. For example, Analytical Data includes
without limitation: (a) numbers of Users and department settings, (b)types and versions of operating systems of computer terminals, (c)device types of computer terminals and (d) trends of how applications
are used (e.g., (i) how many times applications are accessed, (ii)numbers of used functions and created records, (iii) how configurationand value settings are set and (iv) whether or not and how many times
customization functions are used).

2. Handling of Stored Data
Cybozu will handle Stored Data based on “Article 15, Handling of Stored Data, cybozu.com
Terms of Use.”3. Handling of Analytical Data
(1) Purpose of use
Cybozu will use the Analytical Data only for the following purposes:① To support the services

For example, when the cloud services fail due to the User’s operation, by analyzing andidentifying the triggered operation will help to resolve the problem.
② To provide, maintain, protect, improve and develop our cloud services

For example, by comparing and analyzing the usage frequency of the User for each function
will help to determine the priority of which features to improve.
③ To analyze, consider and implement appropriate marketing strategies for the Users

For example, by comparing and analyzing the behavior of Users who do and don’t haveagreements for our cloud services, the results will be used to help the best guide the Users.
④ To optimize the method, content and timing of communication to the User

For example, by comparing and analyzing the behavior of persons who are undertaking trial
use and using of our cloud services will help to optimize the method (telephone, e-mail, mail,etc.), content and timing of communication.
⑤ To optimize listening to the Users’ feedback

For example, by comparing and analyzing the Analytical Data of our cloud services will help
to listen to the usage methods, etc. from the targeted persons.

(2) Sharing of Analytical Data
Cybozu will not share the Analytical Data to any third parties, except in the following cases:① When the User agrees to disclose or share its Analytical Data with others.
② When Cybozu shares the Analytical Data to our affiliated companies only for purposes
outlined in this policy.
③ When Cybozu shares the Analytical Data with third parties to which Cybozu outsources partor all of the handling of the Analytical Data only for purposes outlined in this policy.*④ When Cybozu organizes the Analytical Data in such a way that specific customer’s usage
cannot be easily assumed by aggregating or analyzing the Analytical Data across several
customer accounts.

⑤ When the User goes against our Terms of Use, etc., and disclosing the User Data is
considered necessary to protect the rights, property, and/or the services of other Users and/orCybozu.
⑥ When there is an imminent danger to a person’s life, body or property, and disclosing yourAnalytical Data is deemed to be needed urgently.
⑦ When Cybozu is required to disclose the Analytical Data under applicable laws andregulations* Cybozu shall enter into an agreement of outsourcing business including confidentiality
obligations and security requirements, and shall disclose only the necessary data within the scopeof such necessary purposes. In addition, Cybozu prohibits the use of the data for any business thatis not for the purpose of providing the services.

4. Amendment of this policy
Please note that this policy may be amended without notice in response to revisions in laws andregulations, changes in business activities, etc.

July 28, 2017

Amended

September 18, 2020

AmendedJuly 8, 2021

AmendedNovember 14, 2021

Amended