Impact Circle Leasing Co., Ltd. (hereinafter referred to as "the Company") and its group companies (hereinafter collectively referred to as "the Company Group") have established this Privacy Policy to govern the handling of personal information acquired by the Company Group. We will comply with laws concerning the protection of personal information (hereinafter referred to as "Personal Information Protection Law"), guidelines, and other applicable laws and regulations. In cases where a group company of ours has established a separate Privacy Policy that conflicts with this Privacy Policy, this Privacy Policy shall take precedence. Article 1 (General Provisions) The Company Group shall handle personal information based on this Privacy Policy, the Personal Information Protection Law, and other applicable laws, regulations, and guidelines (hereinafter referred to as "Personal Information Protection Laws, etc."). The Company Group will identify as specifically as possible the purpose for acquiring personal information and will use the information only within the scope necessary to achieve that purpose. The Company Group shall acquire personal information in a proper and lawful manner and shall not obtain it through deception or other fraudulent means. The Company Group shall endeavor to manage personal information in a manner that is accurate and up-to-date within the scope necessary to achieve the purpose of use. In addition, to prevent unauthorized access to servers storing personal information, loss, destruction, alteration, and leaks of personal information, the Company Group will implement organizational, physical, human, and technical measures in accordance with Personal Information Protection Laws, etc., such as restricting access to personal information files, recording access logs, and implementing security measures against unauthorized access from external sources. The Company Group will promptly respond to opinions, questions, complaints, and consultations concerning the handling of personal information. If you contact the inquiry window specified in this Privacy Policy (as provided in Article 14), we will respond as quickly as possible. The Company Group shall establish an appropriate management system for the protection of personal information within the organization. Article 2 (Definitions) The definitions of terms used in this Privacy Policy are as follows: "Personal Information" refers to information as defined in Article 2, Paragraph 1 of the Personal Information Protection Law, relating to users of the services provided by the Company Group (hereinafter simply referred to as "users") and other existing individuals, which can identify the individual through information such as name, date of birth, photographs, videos, and other descriptions, as well as personal identification codes. This also includes information that may not identify the individual solely based on its content but can be easily matched with other information to identify the individual. "Retained Personal Data" refers to the term as defined in Article 16, Paragraph 4 of the Personal Information Protection Law. "Applicant" refers to an individual among the users who wishes to enter into a lease contract with the Company and has applied using the method specified by the Company. Article 3 (Purpose of Use) The personal information collected by the Company Group will be used within the scope of the purposes outlined below. Should the information be used for purposes beyond this scope, the applicant's consent will be obtained in advance through appropriate methods. [Purpose of Use from Lease Application to Lease Contract Conclusion] To assess the applicant’s suitability as a contracting party in the lease business provided by the Company (hereinafter referred to as "the Service"). To provide the applicant’s information to third parties for the purpose of jointly conducting the assessment specified in the previous section. To determine, within the Company, the applicant's suitability as a contracting party for auto insurance related to the leased vehicle, or to provide this information to the insurance company making this assessment. For identity verification, authentication, and verification of the accuracy of personal information related to the applicant. For ancillary business operations, communications, and other related proceedings. [Purpose of Use After Concluding a Lease Contract with the Company] To bill and confirm payment of lease fees based on the lease contract concluded with the Company. To statistically analyze the repayment status of the lease fees specified in the previous section. In the event that the applicant receives a delivery business consignment from a third party, to statistically analyze the information related to the remuneration for the relevant delivery business provided by the third party to the Company, after matching it with the personal information of the applicant. To publicly disclose statistical results obtained from the analyses mentioned above in a manner that does not allow for the identification of the individual applicant. To publicly disclose photographs and videos taken during interviews with the applicant, as well as articles based on the content of such interviews, to third parties (only with the prior consent of the individual applicant). For ancillary business operations, communications, and other related proceedings. [Other Purposes of Use] For the maintenance of, and response to issues related to, the Service. For the improvement and development of the Service. For the distribution of emails related to the Service. For administrative communication and provision of information related to the Service. To handle inquiries from users and improve customer service quality. To provide information on campaigns, new services, or other services conducted by the Company Group (this includes sending emails, flyers, and other direct mail). To conduct campaigns, giveaways, customer service operations, development, and other various marketing activities. To conduct surveys related to the Service. To deliver or display advertisements related to products and services of the Company Group or third parties on the web, tailored to the attributes (age, gender, etc.) and preferences of the users. To address and resolve issues related to applicants suspected of violating lease contracts or where violation of a lease contract has been confirmed. For ancillary business operations, communications, and other related proceedings. Article 4 (Disclosure of Personal Information) The Company Group will disclose personal information related to the user without delay when requested by the user. However, we may not disclose all or part of the information if any of the following conditions apply. If we decide not to disclose the information, we will notify the user without delay. Please note that a nominal fee may be charged for the disclosure of personal information. If disclosing the information may harm the life, body, property, or other rights and interests of the user or a third party. If disclosure would significantly hinder the proper execution of the Company Group’s business. If disclosure would violate other laws. Article 5 (Correction of Retained Personal Data) If the user finds any incorrect information in their personal data retained by the Company Group, they can request the Company Group to correct, add, or delete the information (hereinafter referred to as "corrections, etc."). Upon receiving such a request, the Company Group will promptly conduct the necessary investigations. If we determine that there is a valid reason for the request, we will make the corrections, etc., without delay and notify the user. Article 6 (Suspension of Use of Retained Personal Data) Users can request the Company Group to suspend the use of, delete, or stop providing their retained personal data to third parties (hereinafter referred to as "suspension of use, etc."). Upon receiving such a request, the Company Group will conduct the necessary investigations promptly. If it is determined that the request is valid, the use of the personal data will be suspended, etc. However, if the suspension of use, etc., is difficult due to high costs or other reasons, and alternative measures can be taken to protect the rights and interests of the user, such alternative measures will be taken. We will notify the user of the decision to implement or not implement the suspension of use, etc., without delay. Article 7 (Provision of Personal Information to Third Parties) The Company Group will not provide personal information to third parties except with the prior consent of the user, as permitted by law, or in the following cases: To respond to inquiries from or to users, for the operation of investment platforms, or for the operation and provision of the Company Group's services, when such information needs to be provided to investors, business contractors, and other third parties. If the user violates any terms of service, this Privacy Policy, or any other contracts with the Company Group, and it is deemed necessary to provide personal information to courts, lawyers contracted with the Company Group, or other third parties in order to protect our rights and properties. When it is deemed necessary to protect the rights, benefits, etc., of other users or third parties, or to resolve disputes with third parties. In the case of organizational restructuring activities such as issuance of shares, transfer of shares, mergers, or other similar transactions, as well as in investigations or negotiations preceding such actions. Article 8 (Outsourcing the Handling of Personal Information) Within the scope necessary for achieving the purposes of use, the Company Group may outsource all or part of the handling of personal information to external subcontractors (hereinafter referred to as "Subcontractors"). The Company Group will select Subcontractors after evaluating their suitability from the perspectives of personal information protection and information security. The Company Group will also conclude appropriate contracts with Subcontractors, which include safety management measures, and will implement necessary and appropriate supervision to ensure the secure management of personal information. Article 9 (Joint Use of Personal Information) Our company group may jointly use personal information provided by the user within the scope and for the purposes detailed below: <Purpose of Joint Use> - To determine the user's suitability as a party to a lease agreement - To use as training data for credit models - To verify lease payments, receipts, and payment statuses based on lease agreements - To assess the user's suitability as a party to an automobile insurance contract related to leased vehicles <Types of Personal Data for Joint Use> - The user's name, age, address, phone number, and lease payment status <Scope of Personal Information for Joint Use> - All personal information provided by the user <Entities Participating in Joint Use> - FIRST LIFE Co., Ltd. - Impact Circle Co., Ltd. - Mitsui Sumitomo Marine Fire Insurance Co., Ltd. <Party Responsible for Managing Personal Information> Impact Circle Co., Ltd. (Representative: Takashi Takahashi) Article 10 (Changes in the Purpose of Using Personal Information) Unless we have obtained prior consent from the individual, we will not change the purposes of use specified in Article 3. However, changes may be made after publicizing the new purposes of use if they are reasonably related to the original purposes. Article 11 (Use of Cookies, etc.) For purposes such as fraud prevention, enhancing website convenience, collecting statistical data, and measuring advertising effectiveness, we collect log files, send cookies, and use web beacons to gather information like the user’s cookies, IP address, access frequency, and usage environment. Users can disable cookies, but this might prevent the proper functioning of our services. Article 12 (Use of Information Provided by Third Parties) We may acquire and use personal information by linking cookie data provided by third parties who do not have identifiable information with the personal information we manage. If consent is required by law for such use, we will only proceed upon obtaining consent in compliance with privacy laws. Article 13 (Handling of Personal Information on Linked Websites) Our privacy policy applies only to our own website and not to any external websites linked from it. For information handling on linked sites, please consult their privacy policies. Article 14 (Inquiries Concerning Personal Information) For questions, comments, complaints, or any other inquiries regarding personal information, please contact the following: Address: Customer Service, Impact Circle Co., Ltd., 16th Floor, Sumitomo Realty & Development Shiba Park Tower, 2-11-1 Shibakoen, Minato-ku, Tokyo Representative: CEO Takashi Takahashi Data Protection Manager: Ryutaro Omura Contact: E-mail: info@impact-circle.co.jp Office hours: 9:00–17:00, excluding weekends and holidays. Article 15 (Amendments to This Privacy Policy) We may revise and update this privacy policy as needed. If an amendment requires user consent by law, it will only apply to users who have consented to the change. Any changes to this privacy policy will be announced on our website or by other appropriate means. September 10, 2023 Enacted and effective
