In order to provide our customers with safe, secure, and reliable services, Subspire Inc. (hereinafter referred to as "we" or "us") is committed to properly handling and protecting personal information in accordance with the following policy. This Privacy Policy describes the personal information we collect, the purposes for which we use it, the safeguards we have in place, and your rights.

Article 1 (Definition of Personal Information)

1. Personal information means "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act"). (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act"), and refers to information that contains personal identification codes related to identifiable specific individuals. Specifically, it includes name, e-mail address, IP address, online identifier, cookie information, purchase history, etc.

Article 2 (Method of Obtaining Personal Information)

1. We obtain your personal information in the following ways
   • •　Contact form or account registration: name, email address, phone number, etc.
   • •　When using the service: access date and time, usage history, IP address, browser information, etc.
   • •　Linkage with partner sites: information related to purchase history and review submissions.
   • •　Cookies and Tags: Behavioral data during website visits.

Article 3 (Purpose of Use of Personal Information)

1. We use personal information obtained from our customers for the following purposes
   • 1.Service provision and operation.
   • 2.Inquiry response.
   • 3.Improvement of services and development of new features.
   • 4.Notification of promotions and important announcements.
   • 5.Violation prevention and abuse detection.
   • 6.Fulfillment of legal obligations.
   • 7.To identify users who have violated the Terms of Use or who are attempting to use the Service for fraudulent or unjustified purposes, and to refuse their use of the Service.

Article 4 (Provision of Personal Information to Third Parties)

We will not provide personal information to third parties except in the following cases

1. 1.If the customer consents.
2. 2.When required by law.
3. 3.When necessary for the operation of services with our partners (e.g., disclosure of review content).

When providing such information, we will take necessary measures, such as processing it into a form that does not identify individuals.

Article 5 (Safety Measures)

We will take the following measures to ensure the security of personal information:

• •　Data protection using encryption technology.
• •　Regular security audits.
• •　Prevention of internal fraud by restricting access.

Article 6 (Data Retention Period)

We will retain personal information only for the period of time required by law or necessary to achieve the purpose of use. Anonymized information may be used indefinitely.

Article 7 (Customer Rights)

You have the right to

1. 1.Right of access: Request for disclosure of retained personal data.
2. 2.Right of correction: Correction of inaccurate information.
3. 3.Deletion rights: Delete information that is no longer needed.
4. 4.Right of Objection: Rejection of a specific processing.
5. 5.Data portability rights: receive data in a structured format.

If you wish to exercise your rights, please contact the following contact person.

Article 8 (Use of Cookies)

We use cookies to improve the usability of our website. You can disable cookies by setting your browser , but this may limit some of the functionality.

Article 9 (Continuous Improvement)

We will continually review and improve our privacy policy. Any changes will be notified on our website.

Article 10 (Compliance with Laws, Regulations and Norms)

We will comply with Japanese laws and regulations and other norms applicable to personal information in our possession.

Article 11. (Our address, name of representative, and personal information protection manager)

Our address, representative and the name of the personal information protection manager are as follows
Address: 368-8, Kuzuno, Kumihama-cho, Kyotango City, Kyoto, Japan
Representative and Privacy Officer: Churchill Riley

Article 12 (Contact for Inquiries)

If you have any questions regarding this policy, please contact us at the following address
Address: 368-8, Kuzuno, Kumihama-cho, Kyotango City, Kyoto, Japan
Company name: SUBSPIRE Co.
Department in charge: U-KOMI Division
E-mail address: info@u-komi.com

Enacted and effective January 6, 2025