Privacy Policy
RevComm Inc. (the “Company”) and the Company’s subsidiaries and affiliates (the “Group Companies” andcollectively with the Company, the “Group”) handle and carefully monitor the services and systems provided by theGroup, including, without limitation, the Site, MiiTel products and Sales Hacker (the “Services”) and manage the
Personal Information (as defined below) of the users who use the Services (“Users”) or that is registered by Users
with the Services and other Personal Information as follows.
This Privacy Policy applies to the Company and the Group Companies; provided, however, that, if any Group
Company stipulates separate provisions on the handling of Personal Information other than this Privacy Policy, suchseparate provisions shall prevail.
1. Definition of Personal Information
Personal Information is information that can identify a specific individual by name, address, phone number, email
address, employment information, or other such information, including that stipulated in Article 2, Paragraph 1 of
the Act on the Protection of Personal Information in Japan (the “Personal Information Protection Act”) andindividual identification codes as defined by Article 2, Paragraph 2 of the Personal Information Protection Act.
Personal Information also includes information that cannot by itself identify a specific individual but can be easilycollated with other information and thereby identify a specific individual.
2. Acquisition/Utilization of Personal Information
When acquiring Personal Information, the Group will publish or notify Users of the purpose of use (including
publication in this Privacy Policy). When acquiring Personal Information directly in the contract or other documents(including electromagnetic records) from Users, clients/suppliers, and the like (including officers and employees ofcorporations) (collectively, “Users Et Al.”), the Group will clearly specify the purpose of use in advance and shallacquire such Personal Information by lawful and fair means. The Group properly uses Personal Information within
the scope necessary to achieve its purposes of use.
3. Purposes of Use of Personal Information
The purposes of use of Personal information are as outlined below. The Group will not use Personal Information
for any purpose other than these purposes of use without obtaining the consent of the relevant individual, except
where permitted by the Personal Information Protection Act or other laws and regulations.
(1) Information Acquired from Users of the Services
1. Member authentication, management, communication of clerical work, and providing functions of theServices;
2. Verification of User identities;
3. Operating and managing seminars and various events, etc. provided by the Group;
4. Distributing information in relation to the Services;
5. Requests, communication regarding questionnaires and campaigns, etc., or granting of prizes, etc.;
6. Replying to inquiries and comments;
7. Advertising, solicitation, and sale of merchandise, etc. of the Group and third parties;
8. Announcements regarding the Services and seminars operated by the Group;
9. Conducting maintenance work on the Services;
10. Improvement of the Services;
11. Safely providing the Services to Users (including discovery of and notifications to Users breaching theTerms of Use, etc. and investigation, detection, and prevention of misconduct, including fraud,
unauthorized access, misuse of services, etc., and responding thereto); and12. Entrustment of the handling of Personal Information to a subcontractor, partner company, or contractor
with whom the Group has concluded a confidentiality agreement concerning Personal Information within
the scope necessary to achieve the purposes of use.

(2) Information Registered by Users of the Services
1.
2.
3.
4.

Replying to inquiries and comments of Users regarding the Services;
Conducting maintenance on the Services;
Improvement of the Services;
Safely providing the Services to Users (including discovery of and notifications to Users breaching theTerms of Use, etc. and investigation, detection, and prevention of misconduct, including fraud,
unauthorized access, misuse of services, etc., and responding thereto); and5. Entrustment of the handling of Personal Information to a subcontractor, partner company, or contractor
with whom the Group has concluded a confidentiality agreement concerning Personal Information within
the scope necessary to achieve the purposes of use.

(3) Personal Information of the Group’s Clients/Suppliers (Including Officers and Employees of Client/Supplier
Corporations)
1. Business-related responses, including negotiation, communication, consultation, ordering and settlementof transactions, or performance of an agreement;
2. Management of client/supplier information; and3. Any other cases in which the Group must handle the Personal Information of clients/suppliers forappropriate and smooth provision of the Services.
(4) Information of the Group’s Shareholders (Including Officers and Employees of Corporate Shareholders)
1. Exercising rights and performing obligations under the Companies Act of Japan and other applicable laws
and regulations;
2. Shareholder management, including preparation of records pursuant to prescribed standards under various
laws and regulations; and3. Any other cases in which the Group must handle the Personal Information of shareholders for appropriate
and smooth provision of the Services.
(5) Information of Applicants for Employment/Recruiting by the Group
1. Provision of employment/recruitment information, employment selection, and confirmation of application
history by the Group;
2. Communication with applicants and responding to inquiries, etc. of applicants;
3. Announcements of events/seminars relating to employment operated by the Group; and4. Any other cases in which the Group must handle the Personal Information of applicants for appropriate andsmooth provision of the Services.
(6) Information of the Group’s Officers, Employees, Retirees, and their Families (collectively, “Employees”)
1. Business communication/information exchange with the Group’s employees;
2. Employment management (payment of compensation, human resources/labor management matters, andprovision of benefits, etc.) of the Group’s employees;
3. Ensuring the health of and appropriate work environment for the Group’s employees;
4. Providing benefits services and handling various insurance procedures, etc.;
5. Notifying and reporting to authorities, etc.; and6. Any other cases in which the Group must handle the Personal Information of Employees for labor
management purposes and for appropriate and smooth provision of the Services.
4. Handling of Private Communication Information
The Group may occasionally browse, confirm, analyze, use, or disclose information pertaining to private
communications using the Services (“Confidential Communication Information”) to third parties in accordance withthe following rules.
(1) Nature of Information Acquired
Data generated while using the Services, including spoken statements, automatic transcriptions of such statements,
video images, etc., of the Services.
(2) Primary Acquirer and User
The Group shall acquire and use Confidential Communication Information primarily; provided, however, that theGroup may provide its contractors with Confidential Communication Information to the extent necessary forachieving the purposes of use outlined below.

(3) Purposes and Manner of Use
The purposes and manner of use of Confidential Communication Information are as follows:
1. Cases in which the use of Confidential Communication Information is necessary to protect the life, health,or property, etc. of a User or another person;
2. Cases in which disclosure is requested under laws and regulations or any other cases in which disclosure ispermitted under laws and regulations;
3. Cases in which a User breaches the Terms of Service or in which it is necessary to confirm whether a User
has breached the Terms of Service;
4. Cases in which it confirms whether the communication technology environment that is used by Users
conform to the applicable utilization conditions;
5. Cases in which there is a need to operate the Services or to conduct an investigation or analysis, etc. for
improvement of the Services (including, but not limited to, automatic transcription of call content,
conversation analysis by AI and operational efficiency evaluation); and6. Cases in which use is within the scope of the Master T&Cs, Individual T&Cs, Explanatory Materials, or aconfidentiality agreement, an agreement on the protection of Personal Information, or any other agreements
separately executed between the Group and a User in relation to the Services.
(4) Term of Use
The term of use shall be the period necessary to achieve the foregoing purposes of use.
(5) Point of Contact
The point of contact is set forth at the end of this Privacy Policy.
(6) Method for Revoking Consent etc.
In order to revoke your consent to the use of Confidential Communication Information, please contact the point ofcontact set forth at the end of this Privacy Policy. Please note that the Group sometimes cannot allow consent to be
revoked if the use of Confidential Communication Information is indispensable for providing the Services. Please
note that the Group may no longer be able to provide the Services to a User that has revoked consent.
5. Provision of Personal Information to Third Parties
In principle, the Group will not provide Personal Information to third parties unless the consent of Users Et Al. is
obtained; provided, however, that the Group may provide Personal Information without the consent of Users Et Al.
in the following cases:(1) Cases in accordance with laws and regulations;(2) Cases in which the provision of Personal Information is necessary to protect human life, health, or property andobtaining the relevant individual’s consent is not possible;(3) Cases in which there is a special need to enhance public health or promote the fostering of healthy children andobtaining the relevant individual’s consent is not possible;(4) Cases in which it is necessary to cooperate with a governmental organization, a local government, or a person
entrusted thereby to handle matters prescribed by laws and regulations and obtaining the relevant individual’s
consent would interfere with the handling of such matters; and(5) Cases in which the third party is an academic institution, etc. and the third party will handle the relevant Personal
Information for academic study purposes (including cases in which a purpose of handling such Personal
Information is an academic study but excluding cases in which such handling may unjustifiably infringe upon
the rights and interests of an individual).
The following cases do not constitute third-party provision as described above:(i) Cases in which all or part of the handling of Personal Information is entrusted within the scopenecessary to achieve a purpose of use;(ii) Cases in which Personal Information is provided pursuant to business succession following a merger orother reasons; and(iii) Cases in which Personal Information is jointly used under the provisions of the Personal Information
Protection Act.
6. Information Sharing within the GroupDue to the Group Companies’ entrustment of part of their businesses to the Company, there may be cases in whicha Group Company shares information acquired from Users with the Company within the scope necessary to operate
and provide the Services and within the scope of the purpose of use.

7. Handling of Personal Information in Foreign Countries
In some cases, the Company will entrust the handling of Personal Information to a contractor located in a foreigncountry for its business operations. In addition to the provision of this paragraph, the Company may provide Personal
Information to any third parties located in foreign countries in accordance with the provisions of the Personal
Information Protection Act.
The outline of such handling procedures of Personal Information of the Company in foreign countries is as follows.
[Personal Information Handled by the Company (RevComm Inc.)]
Notwithstanding the following, the data stored automatically during the use of MiiTel by Users who entered into
contracts with the Company regarding such use in Japan is maintained in a server in Japan.
(1) Countries in which Foreign Contractors are locatedPlease refer to “Handling of Personal Information in Countries Outside Japan”(2) Details of the Personal Information Protection Legislation of the Countries Covered by (1)Please refer to “Handling of Personal Information in Countries Outside Japan”(3) Personal Information Protection Systems of Contractors
The Company has executed agreements with Contractors obliging them to take action for the protection of
Personal Information. These actions include those corresponding to the OECD’s Eight Principles.
8. Entrustment of Personal Information
The Group may occasionally entrust the handling of Personal Information to its contractors for business operations.
In such event, the Group will stringently select contractors that have established a control system that properly
protects Personal Information and ensure that they control Personal Information properly by executing an agreementthat establishes a system to prevent the leakage of Personal Information of Users Et Al. through proper management
and confidentiality of Personal Information.
9. Disclaimer of Provision to Third Parties
The Group will not take any responsibility for the acquisition of Personal Information by third parties in thefollowing cases:(1) Cases in which a User reveals Personal Information to a third party using the Services or otherwise;(2) Cases in which a User is identified by a third party due to information posted by Users Et Al. in relation to theuse of the Services;(3) Cases in which Personal Information is provided by Users Et Al. via an external site linked from the Services,which then is utilized;(4) Cases in which a third party has obtained information that can identify an individual User (ID and password,etc.) without provision by the Group; and(5) Cases in which there are no reasons attributable to the Group.
10. Use of Statistically Processed Data
The Group will sometimes create statistical data that is processed so as to be unable to identify an individual basedon the Personal Information provided. The Group may unrestrictedly use statistical data that cannot identify anindividual.
11. Acquisition and Use of Browsing History and Characteristics Information
Browsing histories and characteristics information are history actions taken or attribute information that will not
identify an individual of Users Et Al., such as services used, browsed pages, IP address, or cookie information, notincluding information that identifies an individual (Personal Information).
The Group uses browsing history and characteristics information for the purposes of protecting the privacy ofUsers Et Al., improving convenience, distributing advertising, and acquiring statistical data.

The Group uses cookies for such purposes. In addition, the Group sometimes acquires attribute information(limited to one that cannot identify an individual even by combining) that cannot identify an individual, such as age,sex, occupation, or residential area, provided upon member registration, etc., or user action history on the site (URLs
accessed, content, and reference order, etc.) by using technology such as cookies or JavaScript; provided, however,that no Personal Information is gathered by cookies or attribute information and action history. You may choose not
to allow cookies via your browser settings. If you choose not to allow cookies, some functions of the Services may
be restricted.
[Acquisition of Information by Using Third-Party Services]
For details of the information which the Group acquires by using third-party services, please refer to the“Acquisition of Information by Using Third-Party Services” section.
12. Requests for Disclosure, Correction, or Suspension of Use, etc. of Personal Information
The Group properly responds to requests of Users Et Al. for disclosure (including disclosure of third-party
provision records; the same shall apply hereinafter), notice of purposes of use, correction, addition to, deletion,suspension of use, erasure, and suspension of provision to a third party of Personal Information in the possession of
the Group (“User Request”) in accordance with the Personal Information Protection Act (or if laws regarding thehandling of personal information outside of Japan is applicable, such laws and regulations).
There may be cases where the Group will not accept the following User Requests:(1) Disclosure of Personal Information
1 Cases in which disclosure is likely to harm the life, health, property, or other rights and interests of Data
Subjects or a third party;
2 Cases in which disclosure is likely to significantly interfere with the proper operation of the Services;
3 Cases in which disclosure would violate other laws and regulations; or4 Any other cases which fall under a reason for exception of laws and regulations.
(2) Suspension of Use, Erasure, or Provision of Personal Information to Third Parties
1 Cases in which great expense would be incurred thereby or in which taking such actions is difficult andsubstitute actions to protect the rights and interests of Users Et Al. have been taken; or2 Any other cases which fall under a reason for exception of laws and regulations.
(3) Correction of, Addition to, or Deletion of Personal Information
1 Cases in which laws and regulations other than the Personal Information Protection Act specify special
procedures; or2 Any other cases which fall under a reason for exception of laws and regulations.
Please refer to the point of contact below to submit a User Request.
[If the Personal Information Protection Act is applicable:]Upon receiving a User Request under the Personal Information Protection Act, the Group will verify the identity of
the User with specified materials (driver’s license, Individual Number card, etc.).
In addition, upon receiving a User Request by a representative, the Group will verify the authority with the following
materials.
• For legal representative:
Documents confirming that he/she has the legal authority to represent the individual in question (family register, acopy of a health insurance card in which dependents are indicated), documents verifying the identity of the legal
representative (a copy of a document indicating the name and current address of the representative, such as a driver’s
license, passport, or health insurance card)• For a privately appointed agent:
Power of attorney (Personal Information disclosure request form attachment), certificate of the principal’s seal(issued within three (3) months of the User Request), documents verifying the identity of the privately appointed
agent a copy of a document indicating the name and current address of the agent, such as a driver’s license, passport,
or health insurance card)13. Restriction on the Acquisition of Special-Care-Required Personal Information
Except where permitted by laws and regulations or as provided directly by Users Et Al., the Group will not acquire
the following Personal Information, which is specified as special-care-required personal information (Article 2,
Paragraph 3 of the Personal Information Protection Act), without the prior consent of the relevant Users; provided,
however, that this provision shall not apply where such information is provided by Users Et Al:(1) Race;(2) Creed;(3) Social status;(4) Medical history;(5) Criminal record;(6) The fact that the User has suffered damage from a crime; and/or(7) Personal Information prescribed by the Order for the Enforcement of the Personal Information Protection Act
as requiring special care in handling so as not to cause unfair discrimination, prejudice, or other disadvantages
to the relevant individual.
14. Management of Personal Information (Security Control Actions)
The Group strives to implement security measures to prevent the leakage, loss, misuse, and alteration, etc. of
Personal Information placed under its control and takes the necessary and appropriate security actions. The Groupretains Personal Information in a safe environment inaccessible by general Users Et Al.
In order to ensure that security actions are properly taken, the Group has acquired an information security
management system authentication and a privacy mark certificate in Japan and regularly reviews the management
system.
An outline of the security actions taken by the Group is as follows:(1) Formulation of the Basic Policy and Policies for the Handling of Personal Information
To ensure the proper handling of Personal Information, the Group has created a Personal Information
Protection Policy and this Privacy Policy in order to comply with laws and regulations pertaining to theprotection of Personal Information, contact point for inquires and complaint handling and the like.
In addition, the Group has created internal rules for the handling of Personal Information, including handling
methods and responsible persons/persons in charge and their duties, etc., at each stage of acquisition, utilization,
retention, provision, and deletion/disposal, etc.
(2) Organizational Security Controls
The Group has appointed a manager to handle Personal Information and identified the Group’s employees
engaged in the handling of Personal Information and the scope of Personal Information handled by such
employees. The Group has also developed a reporting system in the event that a violation of the Personal
Information Protection Act or a breach of the Group’s internal rules is discovered.
The Group regularly conducts audits of its handling of Personal Information and periodically requests audits
by other departments and outside auditors.
(3) Human Security Controls
The Group provides employees with regular training with respect to the handling of Personal Information. It
also sets forth the confidentiality of Personal Information in the Rules of Employment, etc.
(4) Physical Security Controls
The Group monitors the entry and exit of employees, restricts equipment, etc. brought into areas where
Personal Information is handled, and prevents unauthorized persons from browsing Personal Information. The
Group takes actions to prevent the theft or loss, etc. of equipment holding Personal Information, electronic
media, and documents, etc. and implements measures to avoid Personal Information from being easily foundwhen carrying such equipment or electronic media, etc., including move within an office.
(5) Technical Security Controls
The Group limits access to Personal Information to specific employees and has introduced a mechanism toprotect its information system from external unauthorized access or illicit software.

(6) Understanding of External Systems
The Group entrusts cloud service providers and the like with the management of information, including some
Personal Information, which is stored and managed by such service providers in the countries indicated in “6.
Handling of Personal Information in Foreign Countries.” The Group puts security controls in place based on
the information provided by the Personal Information Protection Commission in Japan after researching the
Personal Information protection systems of each country.
Please see the point of contact indicated below for the details of the security controls put in place by the Group.
15. Optional Provision of Personal Information
The provision of Personal Information to the Group is at the relevant individual’s discretion. However, please notethat you may not be able to register as a member or User or use the Services or systems if you do not provide thenecessary information,
16. Amendment to the Personal Information Protection Policy and the Privacy Policy
The Company may amend the Personal Information Protection Policy and Privacy Policy at its discretion to theextent that such amendment does not violate any laws or regulations.
17. Handling of Links Posted on the Group’s Websites
This Privacy Policy does not apply to any third-party websites (websites which are not managed by the Group)
linked from the Group’s websites.
For details of the handling of Personal Information within such third-party websites, please refer to the privacy
policies, etc. on such websites.
18. Point of Contact
The Group’s point of contact for complaints, requests, and disclosures, etc. relating to Personal Information is asfollows.
[RevComm, Inc./Personal Information Complaints and Consultation Counter]
To: RevComm, Inc.
Personal Information Protection Supervisor
Compliance Manager
Address: HULIC Shibuya 1-chome Building 7F, 1-3-9 Shibuya, Shibuya-ku Tokyo, 150-0002 Japan
Email address:privacy@revcomm.co.jp[Name of authorized personal information protection organization and point of contact for complaint resolution]
Name of authorized personal information protection organization: Japan Information Processing and Development
CenterPoint of contact for complaint resolution: Personal Information Protection Complaints and Consultation Office
Address: Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo, 106-0032 Japan
TEL:+81-(0)3-5860-7565 / 0120-700-779 (Only available from Japan)

Enacted: October 1, 2018
Revised: October 3, 2019
Revised: January 5, 2022
Revised: April 1, 2022
Revised: February 1, 2023
Revised: February 1, 2024
Revised: April 1, 2024

[Exhibit 1]

Handling of Personal Information in Countries Outside Japan
In some cases, the Company will entrust the handling of Personal Information to a contractor located in anothercountry (collectively, “Foreign Contractors”) for business operational reasons. The outline of such entrustment is
set forth below.
If the handling of Personal Information is entrusted to any country outside Japan other than those listed below, theCompany will list such entrustment on this page as necessary.
Among the data stored automatically during the use of MiiTel, the data of Users who have entered into contracts
in Japan regarding the use of such service is maintained in a server in Japan.
(1) Countries in which Foreign Contractors (Information Recipients) are LocatedUnited States of America
Australia
Singapore
Germany
IrelandUnited Kingdom
SwedenIndia
Republic of Korea
CanadaBrazilIndonesia
Switzerland
IsraelMexicoPhilippines
United Arab Emirates
South Africa
Costa Rica
(2) Details of the Personal Information Protection Legislation of the Countries Listed in (1)1United Kingdom and EEA member countries

These countries are prescribed by the rules of the Personal Information Protection Commission as establishing apersonal information protection system recognized as having equivalent standards to those in Japan in regard to theprotection of individual rights and interests.
For more details, please refer to the “Foreign Countries, Etc. Establishing a Personal Information Protection
System Recognized to Have Equivalent Standards to That in Japan in Regard to the Protection of an Individual’s
Rights and Interests (Public Notice of the Personal Information Protection Commission No. 1 of 2019)” page (inJapanese).
2Countries or Regions for which the European Commission’s Adequacy Decision Has Been Rendered・CanadaFor more details, please refer to the “Investigation on Personal Information Protection Systems
in Canada (Personal Information Protection Commission)” page (in Japanese).
・Republic of Korea
For more details, please refer to the “Investigation on Personal Information Protection Systems in the Republic ofKorea (Personal Information Protection Commission)” page (in Japanese).
・Switzerland
For more details, please refer to the “Investigation on Personal Information Protection Systems in Switzerland(Personal Information Protection Commission)” page (in Japanese).

・Israel
For more details, please refer to the “Investigation on Personal Information Protection Systems in Israel (Personal
Information Protection Commission)” page (in Japanese).
3

APEC Cross-Border Privacy Rules Participating Countries

・United States of America
For more details, please refer to the “Investigation on Personal Information Protection Systems in the United Statesof America (Personal Information Protection Commission)” page (in Japanese).
・Australia
For more details, please refer to the “Investigation on Personal Information Protection Systems in Australia(Personal Information Protection Commission)” page (in Japanese).
・CanadaFor more details, please refer to the “Investigation on Personal Information Protection Systems in Canada (Personal
Information Protection Commission)” page (in Japanese).
・Singapore
For more details, please refer to the “Investigation on Personal Information Protection Systems in Singapore(Personal Information Protection Commission)” page (in Japanese).
・Republic of Korea
For more details, please refer to the “Investigation on Personal Information Protection Systems in the Republic ofKorea (Personal Information Protection Commission)” page (in Japanese).
・MexicoFor more details, please refer to the “Investigation on Personal Information Protection Systems in Mexico(Personal Information Protection Commission)” page (in Japanese).
・Philippines
For more details, please refer to the “Investigation on Personal Information Protection Systems in Philippines(Personal Information Protection Commission)” page (in Japanese).
4

Other Countries

・IndiaFor more details, please refer to the “Investigation on Personal Information Protection Systems in India (Personal
Information Protection Commission)” page (in Japanese).
・Brazil
For more details, please refer to the “Investigation on Personal Information Protection Systems in Brazil (Personal
Information Protection Commission)” page (in Japanese).
・Indonesia
For more details, please refer to the “Investigation on Personal Information Protection Systems in Indonesia(Personal Information Protection Commission)” page (in Japanese).
・United Arab Emirates
For more details, please refer to the “Investigation on Personal Information Protection Systems in the United ArabEmirates (Personal Information Protection Commission)” page (in Japanese).
・South Africa
For more details, please refer to the “Investigation on Personal Information Protection Systems in South Africa(Personal Information Protection Commission)” page (in Japanese).
・Costa Rica
For more details, please refer to the “Investigation on Personal Information Protection Systems in Costa Rica
(Personal Information Protection Commission)” page (in Japanese).

(3) Personal Information Protection Systems to be Provided by Information Recipients
The Company has executed agreements with information recipients obliging them to take action for the protectionof Personal Information. These actions include those corresponding to the OECD’s Eight Principles.

In addition to the above, the Company may provide personal information to third parties in other countries inaccordance with the provisions of the Act on the Protection of Personal Information.
Last updated: April 1, 2024

[Exhibit 2]

Acquisition of Information by Using Third-Party Services
Please refer to the table below for details on the acquisition of information through third-party services that areused by the Group.
If any acquisition of information is to occur through third-party services other than those listed below, the Company
will list such acquisition on this page as necessary.
The Group uses the Services stated in “Names of Information Collection Modules” section provided by the entities
stated in the “Names of Parties to Which Information is to Be Transmitted” section.
Through such services, the Group may acquire “Contents of Information to Be Transmitted” for the purposes statedin the “Purpose of Use at the Company” section.
In addition, such information will be managed by the entities stated in the “Names of Parties to Which Information
is to Be Transmitted” section during the “Information Retention Period” and will be used for the purposes stated in
the “Purpose of Use by Parties to Which Information is to Be Transmitted” section. Please refer to the “Availability
to Opt-Out” section for the availability/unavailability of disabling the settings of the Services stated in the “Names
of Information Collection Modules” section.

Upon providing the Services, the Group uses cookies, codes or programs, etc. that transmit information stored on each User’s terminal device to external servers (collectively,“Information Collection Modules”). The details of the Information Collection Modules used by the Group are as follows:
Name of
Information
Collection
ModulesContent of Information to
Be Transmitted

Names of Parties toWhich Information is
to Be Transmitted

Purpose of Use of Information to Be Transmitted
Purpose of Use at
the Company

Purpose of Use by Parties to Which
Information is to Be Transmitted

Availability
to Opt-Out

Information Retention
Period (if known)◎ Information Collection Modules Used on the Company’s Website
Google Analytics• Ad identifiers• Information on terminal
device and app• Information on network• Access history

Google LLC• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://policies.google.com/privacy

Available

Up to 26 months

Google SearchConsole• Ad identifiers• Information on terminal
device and app• Information on network• Access history

Google LLC• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://policies.google.com/privacy

Available

Up to 16 months

Google Tag
Manager• Ad identifier• Information on terminal
device and app• Information on network• Access history

Google LLC• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://policies.google.com/privacy

Available

Yahoo TagManager• Ad identifiers• Information on terminal
device and app• Information on network• Access history

LY Corporation• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://line.me/ja/terms/policy/

Available

Microsoft
Advertising• Ad identifiers• Information on terminal
device and app• Information on network• Access history

Microsoft Ireland
Operations Limited(Microsoft Ad)• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://privacy.microsoft.com/jajp/privacystatement

Available-

Up to 25 months-

Microsoft
Advertising
Universal Event
Tracking• Ad identifiers• Information on terminal
device and app• Information on network• Access history

Microsoft Ireland
Operations Limited(Microsoft Ad)• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://www.facebook.com/privacy/c
enter

Available

Facebook Pixel• Ad identifiers• Information on terminal
device and app• Information on network• Access history

Meta Platforms, Inc.
(Facebook)• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://www.taboola.com/policies/pri
vacy-policy

Available

Taboola• Ad identifiers• Information on terminal
device and app• Information on network• Access history

Taboola, Inc.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://www.ptengine.jp/privacypolicy/

Available

Up to 13 months

Ptengine• Information on terminal
device and app• Information on network

Ptmind• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://policies.google.com/privacy

Available

The retention period formeasured data varies
depending on thecontract plan, as
follows:--

Free Plan: 1 month
Growth Plan: 6 months
Premium Plan:
Customizable
Microsoft Clarity• Ad identifiers• Information on terminal
device and app• Information on network• Access history

Microsoft• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://policies.google.com/privacy

Available-

OPTEMO
optemo_visitor_id

Visitor's unique ID

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 days

optemo_visitor_
token

Key required to passthrough API (to prevent
operation by anyone otherthan the visitor)

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 days

optemo_call_on_～

Call flags (i.e., flag todetermine whether a call isin progress); controlling
multiple tabs

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 daysisChatting_～

Chat flags (i.e., flag todetermine whether the chaticon is open or closed);controlling multiple tabs

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 days

optemo_session_
id_～

Session ID for website
visitor

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 days

optemo_form_
notification_id_～

Relevant automatictransmission form ID

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 days

optemo_manual_
form_id_～

Relevant manualtransmission form ID

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://privacy.microsoft.com/jajp/privacystatement

Unavailable

90 days

Notification
ConditionsId_～

Relevant notification
conditions ID

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 daysis_valid_thanks_
page_～

Flag for thank you calls

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 daysisDomainShared_～

Flag to manage whether
subdomain is shared

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 daysprimaryDomain_～

Primary domain being set
when subdomain is shared

J-Tama’s Co. Ltd.

• To collect dataon User behavior• To improve User
experience

For more details, please see here:
https://j-tamas.com/privacy-policy/

Unavailable

90 daysd-cast.tokyo• IP address• User agent• Tracking ID

GEOCODE, Co., Ltd.

• Results
measurement

For more details, please see here:
https://www.geo-code.co.jp/privacy/

Unavailable

Up to 12 months

Names ofInformation
Collection
ModulesContent of Information to
Be Transmitted

Names of Parties toWhich Information is
to Be Transmitted

Purpose of Use of Information to Be Transmitted
Purpose of Use at
the Company

Purpose of Use by Parties to Which
Information is to Be Transmitted

Availability
to Opt-Out

Information
Retention Period(if known)◎ Information Collection Modules Commonly Used Among “MiiTel,” “MiiTel Meetings” and “MiiTel RecPod”
Fullstar

Information contained in
the script (personal
information may be
included)
URL of the site browsed •Date and time of browsing
the title (to be used for
calculating the time spenton the site, etc.)
Information on response toreviews and questionnaires
response information;
identifiers recorded on thedevice, such as cookies(those created throughFullstar / those createdthrough BowNow)
Progress data regarding
guide information browsed(unique UID data / CS
selector of registration
information)
Progress data regarding
tooltip information
browsed (unique UID data)

Cloud CIRCUS, Inc.

• To collect andanalyze data on
User behavior

For more details, please see here:
https://cloudcircus.jp/privacy/

Unavailable

Unlimited period oftimeAzure OpenAI
Service

MiiTel, MiiTel Meetingsand MiiTel Speech
recognition results
generated by RecPod(transcription), speakers’
names, and analysis scores

Microsoft Corporation• To generate
minutes and advice

For more details, please see here:
https://privacy.microsoft.com/jajp/privacystatement/

Available

30 daysAnnouncekit

Login ID, company ID,
cookie information

AnnounceKit LLC• For reference for
product
development

For more details, please see here:
https://announcekit.app/privacypolicy

Available-•For the provisionof information
corresponding toclient quality andtype

Names ofInformation
Collection
ModulesContent of Information to
Be Transmitted

Names of Parties toWhich Information is
to Be Transmitted

Purpose of Use of Information to Be Transmitted
Purpose of Use at
the Company

Purpose of Use by Parties to Which
Information is to Be Transmitted• To acquire andanalyze recorded
data and meeting
information

For more details, please see here:
https://www.recall.ai/privacy/

Availability
to Opt-Out

Information
Retention Period(if known)

Available

Recorded data:
Other than one-weekrecorded data:
Unlimited period oftime◎ Information Collection Modules Used in “MiiTel Meetings”
Recall.ai

1) When using calendar
integration of Microsoft
Outlook:(i) Authentication
information to acquirecalendar information fromMicrosoft Outlook(ii) Calendar information(iii) Recorded data

Hyperdoc Inc.

2) When using calendar
integration of Google
Calendar:(i) Authentication
information to acquirecalendar information from
Google Calendar:(ii) Calendar information(iii) Recorded data
3) Recorded data in thecase of connecting through
URL integration

Last updated: April 1, 2024