Kyuzan Inc. (hereinafter “Company” or “we”) recognizes the importance of personal information protection, complies with the Act on the Protection of Personal Information (hereinafter “Personal Information Protection Act”), and seeks to handle and protect personal information in an appropriate manner in accordance with the following privacy policy (hereinafter “Privacy Policy”). Unless otherwise set forth herein, the definitions of the terms used in the Privacy Policy shall be as prescribed in the Personal Information Protection Act.

1. Definition of Personal Information

For the purpose of the Privacy Policy, “personal information” shall mean the personal information defined in Section 1, Article 2 of the Personal Information Protection Act.

2. Purpose of Use of Personal Information

We will use personal information for the following purposes.

(1) Provision of a blockchain game, operation of a marketplace, and provision of other services of the Company (hereinafter collectively “our services”).

(2) Provision of guidance and handling related to inquiries about our services

(3) Provision of information on our products and services

(4) Handling of violations of our terms and policies related to our services (hereinafter “terms, etc.”)

(5) Notification of changes to the terms, etc. related to our services

(6) Utilization for improvement of our services and development of new services

(7) Development and operation of our services in collaboration with GameWith, Inc.

(8) Employment management (regarding the personal information of officers and employees) and selection and contact in recruiting (regarding personal information of candidates)

(9) Shareholder management and procedures based on the Companies Act and other applicable laws and regulations (regarding personal information of shareholders, holders of stock options, etc.)

(10) Creation of statistical data in relation to our services, which is processed in such a form that specific individuals cannot be identified

(11) Any other purposes associated with the above purposes

3. Change of Purpose of Use of Personal Information

We may change the purpose of use of personal information to the extent that it is reasonably considered relevant, and we will notify the subject of the personal information (hereinafter “principal”) or make an announcement when so doing.

4. Restriction on Use of Personal Information

We will not handle personal information without obtaining in advance the principal’s consent beyond the necessary scope to achieve the purpose of use, unless it is permitted by the Personal Information Protection Act or other laws and regulations. However, this may not always apply in any of the following cases.

(1) Cases based on laws and regulations

(2) Cases in which there is a need to protect human life, well-being, or fortune, and when it is difficult to obtain the principal’s consent

(3) Cases in which there is a special need to enhance public health or promote healthy childrearing, and when it is difficult to obtain the principal’s consent

(4) Cases in which there is a need to cooperate in regard to a central government organization or a local government, or with a person entrusted thereby in matters prescribed by laws and regulations, and when there is the possibility that obtaining the principal’s consent would interfere with the performance of said affairs

5. Proper Acquisition of Personal Information

5.1 We will acquire personal information properly and not by deceitful or otherwise improper means.

5.2 We will not acquire special care-required personal information (as defined in Section 3, Article 2 of the Personal Information Protection Act) without obtaining the principal’s consent in advance, except in those cases set forth below.

(1) Cases falling under any of the items in the above Section 4.

(2) Cases in which said special care-required personal information has been made open to the public by a principal, government organization, local government, person set forth in any of the items of Section 1, Article 76 of the Personal Information Protection Act, or other persons prescribed by the rules of the Personal Information Protection Commission

(3) Cases in which special care-required personal information seems to have been acquired by seeing the principal visually or taking pictures of a principal.

(4) Cases in which special care-required personal information is provided by a third party, and such provision by a third party falls under any of the items in Section 7.1.

5.3 When we receive personal information from a third party, we confirm the matters set forth below pursuant to the rules of the Personal Information Protection Commission. However, this does not apply in cases where said personal information provision falls under any of the items of Section 4 or of Section 7.1.

(1) The name or appellation and address of the third party and, for a corporate body, the name of its representative (for a non-corporate body having appointed a representative or administrator, said representative or administrator)

(2) Circumstances under which said personal information was acquired by said third party

6. Security Control of Personal Information

We will exercise necessary and appropriate supervision over our employees so that security control of personal information is provided against risks such as loss, destruction, falsification, and leakage of personal information. Moreover, when we entrust the handling of personal information in part or in full, we will exercise necessary and appropriate supervision over the subcontractor so that security control of personal information is provided by the subcontractor.

7. Third Party Provision

7.1 We will not provide personal information to a third party without the principal’s prior consent, except in the cases in any of the items in Section 4. However, the following cases do not fall under the third party provision specified above.

(1) Cases in which personal information is provided in association with the entrustment of the handling of personal information in part or in full within the necessary scope to achieve the purpose of use

(2) Cases in which personal information is provided in association with business succession caused by a merger or other reason

(3) Cases in which personal information is jointly used in accordance with the provisions of Section 8

7.2 Notwithstanding the provisions of Section 7.1, except in those cases set forth in each item of Section 4, we will, in the case of providing personal information to a third party (excluding a person establishing a system conforming to the standards prescribed by the rules of the Personal Information Protection Commission based on Article 24 of the Personal Information Protection Act) in a foreign country (excluding those specified by the rules of the Personal Information Protection Commission based on Article 24 of the Personal Information Protection Act), obtain the principal’s consent in advance to the effect that he or she approves its provision to a third party in a foreign country.

7.3 When we provide personal information to a third party, we prepare and keep a record pursuant to Article 25 of the Personal Information Protection Act.

7.4 When we receive personal information from a third party, we will confirm the matters required by Article 26 of the Personal Information Protection Act, and prepare and keep a record of the confirmation.

8. Joint Use

We will provide personal information to a user specified below for the purpose of joint use as follows.

(1) Items of personal information to be jointly used

- Name

- Email address

(2) Scope of joint users

GameWith, Inc.

(3) Purpose of use

Collaborative development of our services

(4) Name or appellation of the person responsible for the management of the above personal information

- Kyuzan Inc.

9. Disclosure of Personal Information

When a principal requests that we disclose personal information based on the provisions of the Personal Information Protection Act, we will disclose such to the principal without delay, after confirming that the request was made by the principal. (If the personal information does not exist, we will inform the principal.) However, this may not apply when we are not obligated to disclose personal information based on the Personal Information Protection Act or other laws and regulations.

10. Correction, etc. of Personal Information

When a principal requests that we make corrections, additions, or deletions (hereinafter “correction, etc.”) of personal information based on the provisions of the Personal Information Protection Act on the grounds that the personal information is untrue, we will conduct the necessary investigation without delay to the extent necessary to achieve the purpose of use, after confirming that the request was made by the principal and, based on the results thereof, make the correction, etc. of personal information and inform the principal to that effect. (If we decide not to make a correction, etc., we will inform the principal.) However, this may not apply when we are not obligated to make a correction, etc. of personal information based on the Personal Information Protection Act or other laws and regulations.

11. Suspension of Use, etc. of Personal Information

When a principal requests that we suspend the use of or delete (hereinafter “suspension of use, etc.”) personal information based on the provisions of the Personal Information Protection Acton on the grounds that the personal information is handled beyond the scope of the purpose of use announced in advance, or the grounds that the personal information was acquired by deceitful or otherwise improper means, or requests that we cease the provision of personal information (hereinafter “ceasing of provision”) based on the provisions of the Personal Information Protection Act on the grounds that the personal information is provided to a third party without the consent of the principal, and when it has become clear that there is a reason for the request, we will conduct suspension of use, etc. or ceasing of provision of personal information without delay, after confirming that the request was made by the principal, and inform the principal to that effect. However, this may not apply when we are not obligated to conduct suspension of use, etc. or ceasing of provision of personal information based on the Personal Information Protection Act or other laws and regulations.

12. Handling of Anonymously Processed Information

12.1 When we produce anonymously processed information (as specified in Section 9, Article 2 of the Personal Information Protection Act, limited to those constituting anonymously processed information databases, etc. specified in Section 10, Article 2 of the same Act; the same shall apply hereafter), we will process personal information in accordance with the standards prescribed by the rules of the Personal Information Protection Commission.

12.2 When we produce anonymously processed information, we will take measures for the security control of such information in accordance with the standards prescribed by the rules of the Personal Information Protection Commission.

12.3 When we produce anonymously processed information, we will disclose to the public the categories of information related to individuals contained in the anonymously processed information in accordance with the rules of the Personal Information Protection Commission.

12.4 When we provide anonymously processed information (including information that we have produced or that was provided by a third party; the same shall apply unless otherwise specified) to a third party, we will disclose to the public the categories of information concerning an individual contained in anonymously processed information to be provided to a third party and its provision method in advance, and state to the third party explicitly to the effect that the information being provided is anonymously processed information, in accordance with the rules of the Personal Information Protection Commission.

12.5 When we handle the anonymously processed information, we will not (1) collate the anonymously processed information with other information nor (2) acquire any descriptions, etc. or individual identification codes that were deleted from the personal information, or information on the processing made based on the provisions of Section 1, Article 36 of the Personal Information Protection Act [(2) is applicable only in the case of anonymously processed information provided by a third party] to identify a principal concerned with personal information used to produce said anonymously processed information.

12.6 We will strive to take necessary and appropriate action for the security control of the anonymously processed information and necessary action for ensuring the proper handling of the anonymously processed information, such as handling complaints about the handling, including producing, of said anonymously processed information, and strive to disclose to the public the contents of such action taken.

13. Use of Technologies such as Cookies

Our services may use Cookies or similar technologies. These technologies help us to understand the usage situation of our services, which contributes to better services. If you want to disable Cookies, you can do so by changing your browser settings. However, when Cookies are disabled, some of the functions of our services may become unavailable.

14. Contact

If you have any requests for disclosure, or opinions, questions, complaints or any other inquiries on the handling of personal information, please contact us as follows.

Kyuzan Inc.

〒150-6139
WeWork, 2-24-12, Shibuya, Shibuya-ku, Tokyo, Japan

E-mail: contact@kyuzan.com

(Hours are from 10 a.m. to 6 p.m. on weekdays.)

15. Continuous Improvement

We will review the operation status related to the handling of personal information from time to time for continuous improvement, and may change the Privacy Policy if necessary.

[Established on November 1, 2019]