「ActSecureχ Information Collection Policy」
Comparative Table of the Old and New Clauses
The words related to the revision are underlined.
OldNewThe ActSecure χ Information Collection Policy (“Policy”) explains how information

The ActSecure χ Information Collection Policy ("Policy") explains how informationcollected by FFRI Security, Inc. (“FFRI”) via “ActSecure χ” (“Product”) from user

collected by FFRI Security, Inc. ("FFRI") via "ActSecure χ" ("Product") from a userof this Product is handled.

of this Product ("user") is handled.

The contents of this policy are subject to change without agreement from an

The contents of this policy are subject to revision without an agreement from anindividualindividualuser.

Pleaserefertothewebpage,

user.

Pleaserefertothewebpage,

http://www.ffri.jp/information/privacy/yarai_eng_privacy_policy.htm, for the latest

https://www.ffri.jp/information/privacy/actsecure_eng_privacy_policy.htm, for thepolicy contents.

latest policy contents.

It is considered that a user of this Product agrees to the latest version of this

It is deemed that a user agrees to the latest version of this Policy.

Policy.
Ⅰ. Collection of information by ProductI. Collection of information by Product1.Information to be Collected

1. Information to be Collected

FFRI shall collect the following information from a user of this Product in a form

FFRI shall collect the following information from a user using this Product in athat does not identify a specific individual. The information shall be collected via

form that does not identify a specific individual.

this Product and transmitted to FFRI server (“Server”).

collected via this Product and transmitted to FFRI server ("Server").

1-1User Attribute Information Registered Upon Initial Usage of Product1-1 User Attribute Information Registered Upon Initial Usage of ProductAttribute Information that cannot specify an individual shall be transmitted to theAttribute Information that cannot specify an individual shall be transmitted to theServer.

Server.

1-2Use Environment of This Product1-2 Use Environment of This Product

Information related to the hardware environment in which this Product is installed

Information related to the hardware environment in which this Product is installed,

on, Operating System, and applications concurrently running shall be transmitted

Operating System, and applications concurrently running shall be transmitted toto the Server.

the Server.
1The information shall be1-3 Information Pertaining to Detected Files

1-3 Information Pertaining to Detected Files(Omitted)(No Change)

1-4 Application Operation Logs

1-4 Application Operation Logs

(Omitted)(No Change)

2.Purposes of Usage of Information Collected By This Product2. Purposes of Usage of Information Collected By This Product2-1 Improvement of usability of this Product operated on users’ machines

2-1 Improvement of usability of this Product operated on users' machines

2-2 Addressing problems occurred from the system operation

2-2 Addressing problems occurred from the system operation

2-3 Improvement of products and FFRI’s business development

2-3 Improvement of products and FFRI's business development
Other purposes of usage shall be as described in Article VI.

3.Provision of Information Collected Via This Product to A Third Party

3. Provision of Information Collected Via This Product to A Third Party(Omitted)(No change)

3-1 In case there is a legal inquiry from a judicial or administrative organization,

3-1 In case there is a legal inquiry from a judicial or administrative organization,such as courts or police departments, or other entities equivalent thereto;such as courts or police departments, or other entities equivalent thereto;

3-2 In case FFRI deals with breach of laws, regulations, the terms and conditions

3-2 In case FFRI deals with breach of laws, regulations, the terms and conditions

provided by FFRI or issues of normal social conventions;provided by FFRI or issues of normal social conventions;

3-3 In case it is necessary for protection of safety, rights and interests of users of

3-3 In case it is necessary for protection of safety, rights and interests of users

this Product and other third parties; andand other third parties; and3-4 In addition to the above, in case provision or disclosure to a third party is

3-4 In addition to the above, in case provision or disclosure to a third party isadmitted by the laws and regulations.

admitted by the laws and regulations.

4.Provision of Information Collected Via Product To Business Alliance

4.Provision of Information Collected Via Product To Business AllianceParty/Business Outsourcing Party

Party/Business Outsourcing Party(Omitted)(No change)2

Ⅱ. Detection Review Setting

II. Detection Review Setting(Omitted)(No change)

1. Information Transmitted When Using This Setting

1. Information Transmitted When Using This Setting

Following information (“Transmitted Information”) shall be transmitted to FFRI

Following information ("Transmitted Information") shall be transmitted to FFRI

server from a user (“Target User”) who submits the inquiry based on theserver from a user ("Target User") who submits the inquiry based on thepreceding paragraph. FFRI shall perform the review set forth in the preceding

preceding paragraph. FFRI shall perform the review set forth in the preceding

paragraph using Transmitted Information and transmit the review result to Target

paragraph using Transmitted Information and transmit the review result to Target

User when it becomes available. Other purposes of usage of the Transmitted

User when it becomes available. Other purposes of usage of the Transmitted

Information shall be as described in Article Ⅳ.

Information shall be as described in Article VI. FFRI will not provide Transmitted
Information to third parties in any format that could be identified by other thirdparties, unless otherwise specified by laws and regulations.

1-1. Target File

1-1. Target File

(Omitted)(No change)

1-2. Information To Identify Target User

1-2. Information To Identify Target User

This includes user attributable information registered upon initial usage of thisThis includes user attributable information registered upon initial usage of this

Product and Setting which shall be used for the aforesaid review process andProduct, FFRI AMC and this Setting which shall be used for the aforesaid review

sending back the review result.

process and sending back the review result.

1-3. Target User’s User Environment For This Product1-3. Target User's User Environment For This ProductThis includes information pertaining to this Product managed by the ProductThis includes information pertaining to this Product managed by FFRI AMC(software version information, the hardware environment in which this Product is(software version information, the hardware environment in which this Product isinstalled on, Operating System, applications concurrently running, etc.) that is

installed, Operating System, applications concurrently running, etc.) that isrequired for the review of Target File.

required for the review of Target File.

31-4. Target User’s Product Operation Logs Managed By This Product1-4. Target User's Product Operation Logs Managed By FFRI AMC

This information is used for Target File review.

This information is used for Target File review.

Ⅲ. Cloud Collaboration Feature

III. Cloud Collaboration Feature

In addition to Setting, a user may submit a Target File using “Cloud Collaboration

In addition to this Setting, a user may submit a Target File using "CloudFeature” (“Feature”) through the Product based on this Policy to determine if it isCollaboration Feature" ("Feature") through FFRI AMC or not through FFRI AMC

a legitimate software (over-detection) or malware and receive the result on thebased on this Policy to determine if it is a legitimate software (over-detection) orProduct.

malware and receive the result on the Product.

1. Information Transmitted When Using This Feature

1. Information Transmitted When Using This Feature

Hash values relating to a Target File (“Hash Values”) shall be transmitted from a

Hash values relating to a Target File ("Hash Values") shall be transmitted from auser who submit a Target File based on the preceding paragraph (“Target User”)

User who submits a Target File based on the preceding paragraph ("Target Userto FFRI server.

FFRI shall perform the review set forth in the precedingof this Feature") to the FFRI server. FFRI shall perform the review set forth in theparagraph using the Hash values and transmit the result to a Target User when it

preceding paragraph using the Hash Values and transmit the result to a Target

becomes available. Other purposes of usage of Hash values shall be as

User of this Feature when it becomes available. Other purposes of usage of Hashdescribed in Article Ⅳ.

Values shall be as described in Article VI.

Ⅳ. Improvement of This Setting and This Feature, etc.

(Deleted)

FFRI may utilize information and Hash values transmitted by each Target User toreflect them in the improvement and development of this Product including thisSetting and this Feature and other FFRI software; provided that, in no case shall
FFRI provide the transmitted information to a third party in the form that may be
identifiable by a general third party, unless otherwise specified by laws andregulations.
IV. Log Collection Feature(Established)

FFRI uses the "Log Collection Feature", which is used to manually distribute log4

collection commands via FFRI AMC to collect user information, in order to collectthe information required to provide the Support Service, etc.
1. Information collected when using the Log Collection Feature
FFRI may collect information regarding the user's system information (information
about the system, services, tasks, network, drivers, installed software, etc.),
Product log information and setting information managed by the system and FFRI
AMC, Microsoft Defender information, special folder information, information
stored in the browser, registry information, and other information. Other purposesof usage of this information shall be as described in Article VI.
V. Support Service(Established)

FFRI shall provide a Support Service to a user who has purchased the Product,
for the objectives of ensuring the proper and suitable use of the Product andassisting in the resolution of any issues that occur and are confirmed in use ofthe Product.
1. Information collected in the Support Service
In conducting the Support Service, FFRI may collect user system information for
the environment where FFRI AMC is installed (information about the system,services, tasks, network, drivers, installed software, etc.), log information
regarding the system and FFRI AMC, information on FFRI AMC settings, andother information in addition to the information described in I-IV above. Other
purposes of usage of this information shall be as described in Article VI.
VI. Purpose of Usage of the Information Collected(Established)

FFRI shall be able to view and use the information collected through I-V above at5

any time for the following purposes:(1) For user support such as updates and maintenance of FFRI products(2) For improvement, development, etc. of FFRI product functions and quality(3) For improvement in quality of FFRI services(4) For external disclosure including research pertaining to detected malware orvulnerability attacks and commercial usage such as statistical data and malware
analysis information
However, FFRI shall never provide user attributable information to third parties inany format that could be identified by other third parties.
Moreover, FFRI shall take the necessary and appropriate safety control
measures to manage the information that is collected in I-V above.
Ⅴ. Disclaimer

VII. Disclaimer

Malware and vulnerability attacks continuously become more sophisticated and

Malware and vulnerability attacks continuously become more sophisticated andcomplicated on a daily basis and in no case shall FFRI guarantee to Target User

complicated on a daily basis and in no case shall FFRI guarantee to Target User,

that this Setting and this Feature work perfectly despite the effort described in theetc., that this Setting and this Feature work perfectly. Target User, etc., hereby

preceding paragraph. Target User hereby agrees that FFRI shall not be liableagrees that FFRI shall not be liable for any damages incurred by Target User,for any damages with respect to usage of the Setting and the Feature.

etc., with respect to usage of the Setting and the Feature.

Ⅵ. Reference On Information Collected via Product

VIII. Reference On Information Collected via Product(Omitted)(No change)

Revised on June 25, 2020

Revised on March 30, 2023

6