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Privacy Policy

Kuukan Inc. (hereinafter referred to as "the Company") establishes this privacy policy (hereinafter referred to as "this Policy") regarding the handling of user information, including personal information of users, in the services (hereinafter referred to as "the Services") provided by the Company.

Information Collected and Collection Methods

In this Policy, "User Information" means information related to users' identification, behavioral history on the Services, and other information generated or accumulated in relation to users or their devices, which the Company collects based on this Policy. The User Information collected by the Company in the Services is as follows, depending on the collection method:

(1) Information Provided by Users

The information provided by users for the use of the Services or through the use of the Services is as follows:
* Information related to the user's profile, such as name, date of birth, gender, etc.
* Contact information such as email address, phone number, address, etc.
* Information related to payment methods such as credit card information, bank account information, electronic money information, etc.
* Information related to credit assessment such as income and debt amounts, repayment status of other loans, occupation and place of employment, family structure, living conditions, transaction purposes, etc.
* Information that the user inputs or submits through input forms or other methods established by the Company.

⑵ Information provided by the user through integration with other services

When a user allows integration with other services such as social networking services to use this service, we will collect the following information from the external service based on the content agreed upon at the time of permission.
* Profile information such as name, date of birth, gender, etc.
* Contact information such as email address, phone number, address, etc.
* Payment method information such as credit card information, bank account information, electronic money information, etc.
* Credit assessment information such as the amount of income and debt, repayment status of other borrowings, occupation and employer, family composition, living situation, transaction purpose, etc.
* Information related to the user's ID used in the external service and their usage status in the external service.
* Other information that the user allows to disclose to the integration partner based on the privacy settings of the external service.

⑶When using this service, the information that our company may collect includes access status and usage information. This may include the following information:

* Referrer
* IP address
* Server access log information
* Cookies, ADID, IDFA, and other identifiers.

Purposes of Use:

1. To provide, maintain, protect, and improve this Service, including accepting registration, confirming identity, authenticating users, recording and managing user settings, and determining usage fees.

2. To develop new products, functions, and services related to our business and to conduct market research.

3. To provide customized services to users by analyzing their transaction history, behavior history, and information obtained from external services.

4. To deliver information related to this Service tailored to the user's needs, or to display advertisements from other businesses who become advertisers, by analyzing the user's transaction history, behavior history, and information obtained from external services.

5. To respond to inquiries and provide information related to this Service.

6. To take measures against acts that violate our terms and conditions related to this Service.

7. To notify users of changes to our terms and conditions related to this Service.

8. To perform other related tasks.

We do not acquire or use sensitive information or personal information that requires careful consideration except in cases permitted by law or other exceptions.

How to Request Discontinuation of Use

To request the cessation of the collection or use of their user information, the user can perform the designated settings within the service. In this case, the company will promptly comply with its established procedures and stop the use of the user's information. However, please note that depending on the item of user information, the collection or use of such information may be necessary for the service, in which case the company will only stop the collection or use of such information if the user withdraws from the service according to the company's prescribed method.

Third-Party Disclosure

Our company will not disclose personal information (referring to personal information as defined by the Personal Information Protection Law, hereinafter simply referred to as "personal information") of users to third parties (including those located outside Japan) without the prior consent of the user. However, this does not apply in cases where it is necessary to disclose personal information to third parties (including those located outside Japan) as listed below:
* When entrusting all or part of the handling of personal information to a third party within the scope necessary to achieve the purpose of use
* When personal information is provided due to business succession or other reasons such as a merger
* When it is necessary to cooperate with a national government agency or local public body, or a person
entrusted by them, in performing tasks defined by law, and obtaining user consent would interfere with the execution of the task
* In cases where disclosure is permitted by the Personal Information Protection Law or other laws and regulations.

Disclosure of Personal Information

If a user requests disclosure of personal information in accordance with the provisions of the Personal Information Protection Law, our company will confirm that the request is from the user himself/herself and promptly disclose the information to the user (if the personal information does not exist, we will inform the user accordingly). However, this does not apply if our company is not obligated to disclose the information under the Personal Information Protection Law or other laws and regulations. Please note that a fee may be charged for the disclosure of personal information in accordance with the separate procedures established by our company.

Correction and Suspension of Personal Information Usage, etc.

⑴ If a user requests correction of their personal information based on the provisions of the Personal Information Protection Law, citing reasons such as the information being untrue, or if a user requests suspension of its usage based on reasons such as its collection through false or other illicit means or beyond the scope of the purpose of use previously disclosed, the company will promptly conduct necessary investigations upon confirming that the request is made by the user themselves, and correct or suspend the usage of the personal information based on the investigation results. The user will be notified accordingly. If the decision is made not to correct or suspend the usage, the user will be informed of such a decision.

⑵ If a user requests the deletion of their personal information, the company will delete the information and notify the user accordingly after confirming that the request is made by the user themselves, and determining that there is a need to comply with such a request.

⑶ The provisions of (1) and (2) above do not apply if the company is not obligated to correct or suspend the usage of personal information under the Personal Information Protection Law or other laws and regulations

Regarding the joint use of personal information

We will use personal information based on Article 27, Paragraph 5, Item 3 of the Personal Information Protection Act as follows. However, if joint use is prohibited or restricted by other laws and regulations, we will comply with those laws and regulations.

⑴ Personal information items to be jointly used:

* Name
* Address
* Date of birth
* Contact information such as email address and phone number
* Information related to income, debt amount, repayment status of other loans, credit judgment related to occupation and employer, etc.
* Information related to transactions with our company (including the user's identification number)
* Other information related to credit judgment and risk management

* ⑵ Range of persons who will jointly use the information

* ⑶ Kuukan Corporation

* Purpose of use by joint users
* Development of new products, functions, and services related to the joint user's business (including the construction of a new credit model) and market research
* Providing customized services for joint users (including the construction of a new credit score) by analyzing the user's transaction history, behavior history, and information obtained from external services
* Providing information on joint user services that meet the user's needs by analyzing the user's transaction history, behavior history, and information obtained from external services, or delivering/advertising ads from other businesses that are not joint users
* Responding to inquiries related to joint user services and providing guidance
* Other tasks related to the above-mentioned items for joint users

* ⑷ Manager responsible for managing the personal information to be jointly used:

* 2F Shalm Toyohira, 4-3-1 Toyohira 4-jo, Toyohira-ku, Sapporo-shi, Hokkaido 062-0904
* Kuukan Inc.
* Personal Information Management Officer: Kentaro Yamamoto, Representative Director

Regarding Business Outsourcing

Sometimes we may entrust handling of personal information to third-party contractors for various services such as sales, customer support, maintenance, billing, marketing, etc. We carefully examine the eligibility of these contractors and establish contracts that include security measures, confidentiality, re-entrustment conditions, and proper handling of personal information. We also monitor their performance regularly to ensure appropriate supervision. The personal information provided to us by the client will be used only within the scope necessary for achieving the purpose of the contract.

Management of Personal Information Security:

1. We ensure that our users' personal information is accurate and up-to-date by taking various security measures.

2. We limit access rights to prevent unauthorized access to our users' personal information.

3. We take appropriate information security measures to prevent leakage, alteration, loss or damage of personal information.

4. We limit the departments that handle personal information, grant only the minimum necessary authority, and supervise our entrusted companies.

5. We store user's personal information in data centers located in Japan, and take appropriate security measures when handling personal information of users outside Japan.

Disclaimer

While we take the maximum measures to protect our users' personal information from threats such as attacks and intrusion by external parties and third parties, personal information is always exposed to threats and attacks from external sources. We do not guarantee the effectiveness of our protective measures or complete prevention of unauthorized access from external parties. We are not responsible for any damages incurred by users due to leakage or other mishandling of personal information, for which we are not at fault.

Contact Information:

For inquiries regarding opinions, questions, complaints, or other inquiries related to the handling of user information, please contact us at the following address:
2F Sharm Toyohira, 4-3-1 Toyohira 4-jo, Toyohira-ku, Sapporo-shi, Hokkaido 062-0904
Kukan Inc.
Personal Information Management Officer: Kentaro Yamamoto, Representative Director
Contact: info@kukanhokkaido.co.jp

Procedure for changing the privacy policy:

We may change this policy as necessary. However, if changes to this policy require the user's consent under the law, the changed policy will only apply to users who have agreed to the changes in the manner specified by us. We will notify users of the effective date and contents of the changed policy by posting it on our website or using other appropriate methods when we change this policy.

Applicable relationship with other rules and regulations

If there is any inconsistency between the contents of this policy and the terms and conditions of our services (limited to those agreed by the user), the terms and conditions of our services related to the service shall take precedence over this policy.

[Established on November 29, 2022]

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