Within the scope of the purposes of use set forth in Items 1, 9 and 10 of Section 1(1) above, the Company provides the personal information of individual customers (name, contact information, and other personal information) to its business partners (attorneys, judicial scriveners, real estate business operators, small-amount short-term insurance companies, insurance agencies, and the like). In addition to the foregoing, the Company may also provide personal information to third parties after obtaining the consent of the data subject.

The Company provides personal information relating to the Placement Services to third parties in the cases set forth below. In addition to the cases set forth below, the Company may also provide personal information to third parties after obtaining the consent of the Registrant, etc.

1. Provision to the Company's Clients
   • After Registration for the Services: The Company may provide information relating to a Registrant, etc. to a hiring company in a form that does not identify the individual Registrant, etc. (such as information on the Registrant's current job duties or position; provided, that this shall not include the Registrant's name, contact information, name of affiliated company, or the like).
   • At the Time of Application for, or Selection for, a Job Opening or Internship Offered by the Company's Client: The Company's placement personnel provide to the relevant client, on behalf of the job seeker, internship applicant or other User, the personal information of the User that is necessary for the application to the client's job opening or internship.
   • After a Hiring Decision (Including for an Internship) by the Company's Client: The Company provides to the client the personal information necessary for the on-boarding procedures of the person who has received the job offer.
2. Provision to Affiliated Agents (Including Specified Job-Information Providing Business Operators) and Other Business Partners
   The Company may form partnerships with third parties in order to provide the Placement Services and improve the Services. In such cases, the Company may, within the scope of these purposes of use, provide the personal information of a Registrant, etc. to the third party with whom it has partnered.

Where necessary for the optimization of advertising distribution and the measurement of advertising effectiveness, the Company links information held by the Company with user lists held by domestic and overseas advertising distribution operators (such as Google, Meta and LINE Yahoo) in order to distribute and analyze advertisements suited to the User, and to display advertisements appropriate for the User. The items of information provided in such cases consist of hashed email addresses and telephone numbers, cookies, advertising identifiers (AAID and IDFA), usage history, and the like (and, in the case of the Placement Services, additionally include the occupation and annual income band (desired annual income band)).

Notwithstanding (1) through (3) above, the Company may provide personal information without the consent of the Registrant, etc. in the following cases:

1. Where based on laws and regulations
2. Where necessary for the protection of a person's life, body or property, and it is difficult to obtain the consent of the data subject
3. Where particularly necessary for the promotion of public health or the sound development of children, and it is difficult to obtain the consent of the data subject
4. Where it is necessary to cooperate with a national government organ, a local government, or a person entrusted by either of the foregoing, in the performance of affairs prescribed by laws and regulations, and obtaining the data subject's consent is likely to impede the performance of such affairs

1. Scope of Joint Users: ASIRO Inc. and its subsidiaries and affiliated companies.* The specific company names are posted on the Company's website (the list of Group companies page on the corporate site).
2. Items of Personal Data Jointly Used: Name, contact information (address, telephone number, email address), service usage history, content of inquiries, transaction details, and other information necessary for the provision of services.
3. Purpose of Use by Joint Users:
   • Provision and improvement of services across the Group as a whole
   • Responding to inquiries from users, and customer support
   • Improving operational efficiency through the sharing of information within the Group
   • Performing personnel-related operations, accounting operations, and operations relating to the operation and maintenance of in-house systems, among others, entrusted by Group companies
   • Introducing and proposing services provided by each Group company
4. Party Responsible for the Management of Personal Data:
   ASIRO Inc.
   Address: Shinjuku I-Land Wing 4F, 6-3-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023,
   Japan
   Representative: Hiroto Nakayama, Representative Director and President

In connection with the operation of the Services, the Company may outsource the handling of personal information to an outsourcing contractor. In such cases, the Company selects the outsourcing contractor on the condition that the contractor has established and operates an appropriate personal information management system, and stipulates in the relevant contract the matters necessary to prevent the leakage of the personal information of Registrants, etc., such as the proper management and maintenance of confidentiality of personal information, and causes the contractor to implement appropriate management accordingly.

Where the Company's business is succeeded to as a result of a merger, company split, business transfer or other cause, and personal information is transferred in connection with such succession, the Company shall handle such personal information within the scope necessary to achieve the purpose of use of that personal information as it existed prior to the succession. In such cases, the recipient of the personal data does not constitute a "third party" under Article 27, Paragraph 5, Item 2 of the APPI, and the procedures relating to provision to third parties shall not apply.

The Company (ASIRO Inc.), in its business of measuring advertising effectiveness using cameras mounted on AdTrucks (mobile outdoor digital signage) and similar devices, handles personal information as set forth below, as the entity responsible for managing the handling of such personal information. The Company outsources the collection of video footage to truck operators, and the processing and statistical compilation of data to annotation contractors. These outsourcing contractors operate under the Company's supervision and are selected on the condition that they have established and operate an appropriate personal information management system.

The Company acquires video footage and facial images of persons passing on public roads, extracts attribute information such as gender and age group from such footage and images, and uses that information for statistical analysis of the attribute composition of advertising viewers (measurement of advertising effectiveness). Raw data such as acquired facial images is, in principle, deleted immediately upon completion of the process of extracting attribute information. Only statistical data (numerical information that cannot identify a specific individual) is retained.

Personal data such as the video footage and facial images acquired is provided, as an outsourcing arrangement, to the truck operators and annotation contractors selected by the Company as outsourcing contractors. Use or further provision of such data beyond the scope of the outsourcing purpose is prohibited. The Company does not provide such data to third parties other than these outsourcing contractors, except where based on laws and regulations or where the consent of the data subject has been obtained. Statistical information (that has been processed so as not to identify a specific individual) is not subject to regulation under the APPI, and the Company may accordingly use such information within the scope of its business purposes.

In light of the nature of camera images and facial image data (including that such data is highly immutable and may enable the tracking of an individual's movements), the Company implements organizational, personnel-related, physical and technical security control measures (Article 23 of the APPI). Specifically, the Company: (i) restricts and logs access authority to video data; (ii) exercises appropriate supervision over its outsourcing contractors; (iii) appropriately manages and disposes of data storage media; (iv) implements technical security measures (such as encryption) for transfers over networks; and (v) establishes technical access controls for systems that process personal data.

For inquiries regarding this Section, please contact the personal information inquiry desk set forth in Section 12(4) below.

In LegalBase (a legal-tech service), in addition to the personal information of the subscriber and its users, data such as contracts uploaded by the subscriber (hereinafter, "Document Data") may contain the personal information of third parties (such as personnel of business counterparties). The Company uses such Document Data only within the scope of the purpose of providing the AI legal check function, and disposes of it without delay after that purpose has been achieved. Further details regarding the handling of Document Data are as set forth in the terms of use for that service.

The anti-social forces screening service is jointly provided by the Company and its business partner, RISK EYES Co., Ltd. The Company provides search queries entered by the subscriber (company names, personal names, and the like) to the business partner, and provides the subscriber with the results of matching those queries against the database held by the business partner. This provision of information is carried out pursuant to an outsourcing agreement between the Company and the business partner. The business partner maintains its own privacy policy (https://www.riskeyes.jp/privacy).

Payment of usage fees for LegalBase is made through the payment processing service provided by Stripe, Inc. (United States). In connection with such payment processing, Stripe, Inc. may collect and process a User's IP address, browser information, device information, and the like, for the purpose of detecting fraudulent use. Confidential payment information such as credit card numbers does not pass through the Company's servers and is processed solely within Stripe, Inc.'s secure environment. Please refer to Stripe, Inc.'s privacy policy at https://stripe.com/jp/privacy.

In the legal chat service (THEMIL), questions and consultation content entered by a User are disclosed to the registered attorneys who participate in that chat (hereinafter, "Registered Attorneys"). Registered Attorneys are independent legal professionals and are not employees of the Company. The Company is involved only as the provider of the means of communication (the platform) and does not itself perform legal services. Where consultation content entered by a User contains personal information, the User acknowledges in advance that such personal information will be shared with the Registered Attorneys. Where the relationship between a Registered Attorney and a User transitions into an individual attorney-client engagement, the handling of personal information in that relationship shall be governed by the privacy policy established by the relevant Registered Attorney.

1. Creation of statistical data, analysis of market trends, and market research
2. Ben-Navi: the creation, publication and distribution of legal information articles based on consultation content that has been anonymized
3. Placement Services: the creation, publication and distribution of articles on successful job-change case studies, with information that could identify individuals withheld
4. Data analysis for the improvement of services and the development of new services

1. Age group, gender, and area of residence (at the prefectural level)
2. Category of consultation (divorce, inheritance, debt restructuring, and the like), and a summary of the consultation (to the extent that it does not identify the individual)
3. Service usage history, pages viewed, time of use, and the like

* When creating or providing anonymously processed information, the Company implements appropriate processing and security control measures in accordance with the standards prescribed under the APPI. Where the Company provides anonymously processed information to a third party, it takes appropriate measures, such as public announcement, in accordance with laws and regulations.

A User may request notification of the purpose of use of personal information or disclosure of personal information. However, the Company may decline to make disclosure where any of the following applies:

1. Where disclosure is likely to harm the life, body, property or other rights or interests of the User or a third party
2. Where disclosure is likely to significantly impede the proper conduct of the Company's business
3. Where disclosure would violate laws and regulations
4. Where the Company is unable to confirm that the request for disclosure is made by the data subject

A User or other data subject may, in accordance with the procedures set forth in (6) below, request the correction, addition or deletion of their personal information. In such cases, the Company shall, without delay, conduct an investigation to the extent necessary to achieve the purpose of use, and shall, based on the results of that investigation, correct, add to, or delete such personal information to the extent permitted under the APPI.

A User or other data subject may, in accordance with the procedures set forth in (6) below, request the suspension of use of their personal information or the suspension of its provision to third parties. In such cases, the Company shall respond appropriately in accordance with the APPI.

ASIRO Inc. Personal Information Inquiry Desk
Shinjuku I-Land Wing 4F, 6-3-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023, Japan
https://asiro.co.jp/contact/info/
* Inquiries received on Saturdays, Sundays, national holidays, the year-end and New Year holiday period, or the Golden Week holiday period will be handled on or after the next business day.

The Company does not currently belong to any accredited personal information protection organization.

1. Where to Submit Requests for Disclosure, etc.
(Mailing Address)
ASIRO Inc. Personal Information Inquiry Desk
Shinjuku I-Land Wing 4F, 6-3-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023, Japan

2. Procedures Relating to Requests for Disclosure, etc.

• After receiving your request, the Company will mail you the prescribed request form to be used, entitled "Request Form for Disclosure, etc. of Disclosure-Subject Personal Information."
• Please mail the completed request form — together with, if the request is made by an agent, documentation confirming the agent's status, and, in the case of a request for notification of the purpose of use or for disclosure only, a postal money order for the applicable fee — to the Personal Information Inquiry Desk above.
• After receiving the above request form, in order to verify your identity, the Company will ask you to provide approximately two items of information registered with the Company that can be used to confirm your identity (for example, telephone number and date of birth).
• The Company will respond by whichever method you designate: provision of an electromagnetic record, or a written response.

3. Procedures for Requests for Disclosure, etc. Made by an Agent
Where the person making a Request for Disclosure, etc. is an agent, please enclose documentation proving that the person is an agent, together with documentation proving the identity of the agent. In any document containing information regarding the registered domicile (honseki), such information should be limited to the prefecture level, with any further detail redacted (for example, blacked out). In addition, please either send documents that do not contain an Individual Number (My Number), or redact (for example, black out) all digits of any Individual Number contained therein.
Documentation Proving Agent Status

• [Where the agent has been delegated authority by the data subject to make the Request for Disclosure, etc.] A power of attorney (original) from the data subject
• [Where the agent is the statutory agent of a minor] (a copy of any of the following) A copy of the family register (koseki tōhon), a copy of the certificate of residence (jūminhyō) stating the relationship, or another official document that can confirm statutory agency authority
• [Where the agent is the statutory agent (guardian) of an adult ward] (a copy of any of the following) A certificate of registered matters relating to guardianship registration, or another official document that can confirm statutory agency authority
  Documentation Proving the Agent's Own Identity
• Driver's license
• Passport
• Health insurance card
• Certificate of residence (jūminhyō)
• Basic Resident Register Card (Jūkihon Card)

4. Fee for Requests for Notification of the Purpose of Use or for Disclosure
1,000 yen per request (please enclose a postal money order together with the request form and other documents that you send).