1. Compliance with Laws and Regulations

The Company shall comply with all applicable laws and regulations related to the handling of information.

2. Acquisition of Information

The Company shall obtain information through legal and fair means.

3. Information Management

The Company shall manage information based on the principles of confidentiality, integrity, and availability.

4. Security Measures

To prevent loss, destruction, alteration, or leakage of information, the Company shall implement appropriate security measures, including access control, entry and exit management of departments handling information, protection against unauthorized access, and measures against computer viruses.

Details of the Company’s safety control measures for personal information can be obtained through the “Personal Information and Specific Personal Information Inquiry Desk.”

When entrusting the handling of information to third parties, the Company shall take appropriate steps to ensure the confidentiality of information.

5. Organizational Structure

The Company shall appoint a Chief Information Management Officer to oversee the proper management of information.

The Company shall provide training to all employees (including executives, full-time employees, contract employees, temporary staff, and part-time workers) on the protection and appropriate handling of information, and ensure thorough implementation in their daily work.

6. Development, Implementation, Maintenance, and Improvement of Information Management Program

To implement this policy, the Company shall establish an information management program (including this policy, the “Information Management Regulations,” and other relevant rules and procedures), ensure that it is well understood and practiced by all employees and related parties, and work toward its continuous maintenance and improvement.

1. Types of Information Collected

The Company collects personal information including the individual’s full name, address, gender, date of birth, company or organization name and title, telephone number, email address, communication history, and any other information
necessary for the proper and smooth execution of the Company’s business.

2. Purpose of Use

Entrustment of Personal Information Handling

The Company may entrust the handling of personal information to third parties within the scope necessary to achieve the purposes of use described above.

In such cases, the Company shall enter into confidentiality agreements and ensure appropriate management.

Provision of Personal Information to Third Parties

The Company shall not provide personal information to third parties without the prior consent of the individual, except as required by law.

Joint Use of Retained Personal Data

When jointly using personal information registered in databases with third parties, the Company shall clarify the scope of the joint users, the types of jointly used data, and the purpose of use.

A manager responsible for the joint use will be appointed.

This information will be clearly disclosed in advance on the Company’s website or through other appropriate means.

The Company and the Sega Sammy Group (Sega Sammy Holdings Inc. and its subsidiaries and affiliates, hereinafter referred to as “Sega Sammy Group”) may jointly use the personal information provided by customers, business partners
(including potential business contacts), and employees (collectively referred to as “Users”) as follows:

Measures for the Safe Management of Personal Information

The Company maintains the accuracy of personal information and manages it securely.

Requests for Disclosure of Retained Personal Data

If a customer or other individual wishes to request disclosure, correction, suspension of use, or deletion of their personal information, we will respond promptly in accordance with applicable laws and regulations upon presentation of the
required information to the contact point for inquiries regarding personal information and specific personal information, as listed below.
Please note that in the event of correction, addition, or deletion of retained personal data, or suspension of its use, erasure, or cessation of provision to third parties, it may no longer be possible for the customer to receive certain
products or services provided by us or our affiliates, including membership services.
While we do not charge any fees for handling requests for disclosure of retained personal data, the customer shall bear all associated costs, such as communication expenses and media or data transmission costs, when disclosure is made via
electromagnetic records.

1. Customers may request the following regarding their retained personal data:
   • Notification of the purpose of use
   • Disclosure of retained personal data
   • Correction, addition, or deletion of data contents
   • Suspension of use or erasure of data
   • Cessation of provision to third parties
2. Specification of Personal Information Subject to Request
   When submitting a request, the customer must clearly specify the service, event, or survey in which the personal information was registered, as well as the specific data items involved (e.g., name, address, date of birth).
3. Verification of Identity or Authority of the Requesting Party
   To prevent unauthorized access or impersonation, we may request the submission of documentation (as separately designated by us) to verify that the requester is either the individual in question or a legally authorized representative.
4. Cases Where Requests Cannot Be Fulfilled
   We may not be able to comply with a request for disclosure or other actions in the following cases:
   1. If the requester cannot be confirmed as the individual or an authorized agent due to insufficient or improper documentation.
   2. If the requested information cannot be identified as belonging to the customer, based on the submitted details and our investigation.
   3. If the requested information is not part of our retained personal data.
   4. If disclosure may violate applicable laws or regulations.
   5. If revealing the existence or nonexistence of the information may endanger the life, body, or property of the customer or a third party.
   6. If revealing the existence or nonexistence of the information may facilitate or induce illegal or unjust acts.
   7. If revealing the existence or nonexistence of the information may interfere with public safety, crime prevention, suppression, investigation, or other public interests.
   8. If revealing the existence or nonexistence of the information may significantly hinder our business operations or those of our affiliated companies.
   9. If we determine, at our reasonable discretion, that the request is not appropriate or lacks sufficient grounds.
5. Our Response and Method of Communication
   Once we confirm that the request is made by the individual or an authorized representative, we will respond or take necessary actions within a reasonable time frame by postal mail or email.

Use of Cookies and Third-Party SDKs

The Company may display advertisements distributed by third parties such as Yahoo Japan Corporation.

In connection with such advertisements, these third parties may obtain and use cookies and other data of visitors to the Company’s website.Please note that if you choose to reject all cookies, you may be unable to use services that
require authentication, which may limit your access to various online services.

Compliance with Relevant Laws and Guidelines

The Company complies with the “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures,” the “Act on the Protection of Personal Information,” and the “Guidelines for Proper Handling of Specific Personal Information (for Business Operators).”

Security Measures

Security measures for specific personal information are set forth in the Company’s Information Security and Privacy Policy and the “Information Management Program,” which includes related regulations and rules.

Purposes of Use

The Company uses specific personal information for the following purposes:

1. Matters related to employees (including dependents and retirees):
   1. Withholding tax-related procedures
   2. Salary and compensation payments
   3. Municipal tax-related procedures
   4. Health insurance-related procedures
   5. Welfare pension-related procedures
   6. National pension-related procedures
   7. Corporate pension-related procedures
   8. Employment insurance-related procedures
   9. Workers’ compensation insurance-related procedures
2. Matters related to non-employees:
   1. Preparation of payment records for fees and compensations
   2. Preparation of payment records for real estate usage fees
   3. Preparation of payment records for compensation related to real estate purchases
3. Other matters related to (1) and (2)