PRIVACY POLICY

Address: 14-10 Mita 3-chome, Minato-ku, Tokyo, Japan

Company: Wimo Co., Ltd.

Representative Director: Jiasha Hong

wimo Co., Ltd. (hereinafter referred to as "the Company") has established this privacy policy in accordance with laws, guidelines on personal information protection in the telecommunications business, and relevant ministry guidelines, and complies with internal regulations in order to handle customers' personal information appropriately. In this privacy policy, "personal information" and "personal data" are defined in accordance with the Personal Information Protection Act. Both terms are collectively referred to as "personal information, etc."

1.Collection of Customers' Personal Information, etc.

The Company handles the following personal information, etc. obtained through lawful and fair means. Please note that if a minor provides personal information, we will request prior confirmation and consent from the guardian.

• Information obtained from customers through application forms, websites, or oral communications for the purpose of providing Company services (including services provided as an agency).
• Information obtained through various events such as seminars sponsored or co-sponsored by the Company or attended by Company employees.
• Information obtained through inquiry to public authorities such as residential certificates.
• Information obtained from various publicly available sources such as telephone directories and official gazettes.
• Information obtained from credit information agencies, etc.
• Other information obtained lawfully from third parties.
• Information automatically collected by our systems, such as cookies, web beacons, and advertising identifiers, when customers use our services, etc.
  *Please note that you can disable cookies by yourself, but doing so may limit some functionalities of our website.

2.Purpose of Use of Personal Information

The Company will use the personal information obtained from customers within the necessary scope to achieve the purposes of use for each service and business, as well as for the following purposes. In addition, we may use the information when providing services related to our affiliated companies and the Company's services.

2.1 Scope of Use

• To achieve the purposes for which customers have given their consent.
• To enhance products and services.
• To provide accurate information on special services and new services to customers.
• To conduct statistical surveys related to customers' general contracts and make various reports.
• To use as reference materials for selection and evaluation of Company employees and to determine suitability (such as assignment, etc.) for Company business.

2.2 Use Without Consent

• When based on laws.
• When necessary for the protection of a person's life, body, or property, and obtaining consent from the customer is difficult.
• When particularly necessary for promoting public health or fostering healthy development of children, and obtaining consent from the customer is difficult.
• When cooperation is necessary for an institution of the country or local public body or a person entrusted by it to perform duties prescribed by laws, and obtaining consent from the customer may hinder the execution of such duties.

3.Joint Use Purpose

For the achievement of the purposes stated in 2.1 above, the Company may jointly use customers' personal information, etc. within the following scope.

①Items of Personal Information, etc. Jointly Used

All personal information, etc., of customers, except for cases where specific requests are made by the customers themselves.

②Range of Joint Users

Wimo Co., Ltd. (the Company) and the following domestic affiliated companies:

• Clara Online Co., Ltd.
• Sports IT Solution Co., Ltd.
• Tokyo United Basketball Club Co., Ltd.
• Clara Mobility Joint Company
• Chari Company Co., Ltd.
• Neuet Co., Ltd.

③Purpose of Joint Use

Same as stated in 2.1 above.

④Person Responsible for Managing Personal Data in Joint Use

14-10 Mita 3-chome, Minato-ku, Tokyo, Japan

Wimo Co., Ltd.

Representative Director: Kasha Hong

4.Changes in Purpose of Use

The Company may change the purpose of use if it is reasonably recognized to be relevant to the previous purpose of use. In such cases, the Company will notify the individuals concerned or announce the changed purpose of use on its website or other means.

5.Provision to Third Parties

Depending on the type of services applied for by customers through the Company's website, the Company may provide personal information, etc. to third parties within the necessary scope.

5.1 Provision of Personal Information to Third Parties

The Company may disclose personal information, etc. in the following cases:

• When obtaining explicit consent from the customer to disclose or provide personal information, etc. to third parties.
• When formally requested by judicial institutions, police, or other public authorities based on laws.
• When there is an urgent need to protect human life, body, or property, and obtaining consent from the customer is difficult.
• When necessary to promote public health or foster healthy development of children, and obtaining consent from the customer is difficult.
• When it is necessary to cooperate with an institution of the country or local public body or a person entrusted by it to perform duties prescribed by laws, and obtaining consent from the customer may hinder the execution of such duties.

5.2 Provision of Personal Information to Third Parties Abroad

The Company may provide personal data to third parties in the People's Republic of China for operational reasons. In this case, the provisions of the Personal Information Protection Act will be followed. Please refer to the following for information regarding personal information protection law in the People's Republic of China:

https://www.ppc.go.jp/files/pdf/china_report.pdf

6.Thorough Management of Personal Information

The Company will take organizational security measures (clarifying the responsibilities and authorities of employees handling personal information, establishing and implementing provisions, confirmation of implementation, etc.), human security measures (thorough communication to employees, necessary education, etc.), physical security measures (measures to prevent physical leakage, such as theft, loss, and unauthorized access to personal information, etc.), and technical security measures (access control, anti-malware measures, encryption, etc.) in accordance with relevant laws, guidelines established by government agencies, and ISMS (Information Security Management System) to prevent leakage, loss, destruction, or alteration of personal information, etc., and to ensure appropriate management of personal information, etc.

However, please note that security during information transmission and access via the Internet cannot be guaranteed due to the nature of the Internet. When transmitting personal information, please do so at your own responsibility.

7.Suspension of Direct Mail and Other Notifications

If you do not wish to receive advertising materials by direct mail, etc. (including notifications via email or SMS), you can request to stop receiving them through the URL in the email. However, this does not apply to emails related to confirmation of various service applications or orders and important notifications related to the services you are using, which are necessary for our business operations. For inquiries about suspension, please contact the designated contact or the contact at the end of this privacy policy.

8.Request for Disclosure of Personal Information

If the customer or a representative makes a request for the disclosure of personal information, the Company will respond promptly in accordance with the following:

8.1 Cases Where Response Is Not Possible

The Company cannot comply with a request for the disclosure of personal information in the following cases:

• When there is a risk of harming the life, body, property, or other rights and interests of the customer or a third party.
• When there is a significant risk of significantly hindering the proper implementation of the Company's business.
• When it would result in a violation of the law.

8.2 Method for Accepting Disclosure Requests

For requests made by the customer themselves, please provide the necessary information and send it to the contact provided at the end of this privacy policy. Be sure to attach personal identification documents, such as a copy of your driver's license, for verification purposes.

In the case of requests made by a representative on behalf of the customer, please make sure to attach a letter of attorney that clearly indicates the customer's authorization for the request (e.g., stamped with the customer's seal). Additionally, please attach the representative's personal identification document for verification.

Regarding requests for disclosure of personal information, a fee of 1,000 yen (including consumption tax) will be charged for each request. The requestor is responsible for covering the remittance fee for the payment, and the payment should be made through a bank transfer.

9.Other Requests Related to Personal Information

9.1 Correction and Other Requests

If a customer or their representative requests the correction or deletion (hereinafter referred to as "correction and other requests") of their personal information, we will promptly conduct an investigation. Based on the results of the investigation, if the content of the personal information is found to be inaccurate, if the retention period has elapsed, or if we are obligated to correct the personal information under the law, we will promptly make the necessary corrections. Please refer to section 8.2 for the procedures regarding such correction and other requests.

9.2 Notification of Purpose of Use

When a customer or their representative requests notification of the purpose of use, we will promptly provide the information, except in the following cases. Please note that the procedures for requesting notification of the purpose of use are the same as those described in section 8.2.

• Cases where the purpose of use of the identifiable personal information is clear
• Cases where there is a risk of harming the life, body, property, or other rights and interests of the individual or a third party
• Cases where there is a risk of interfering with the legitimate rights or interests of our company
• Cases where it is necessary to cooperate with a national agency or local public entity in executing affairs prescribed by law, and there is a risk of hindering the execution of such affairs.

9.3 Handling of Complaints Regarding Personal Information

We will promptly and appropriately handle complaints related to the use, provision, disclosure, or correction of personal information, and other matters concerning the handling of personal data. Please direct any complaints to the contact provided at the end of this privacy policy.

[Contact Information]

wimo Co., Ltd.

https://www.wimo.co.jp/contact/ (Please use the inquiry form on this page)

(Title your inquiry "Regarding Privacy Policy" when contacting us)

This is automaticly translated by the translation engineer which may not be correct as the original copy.

Please do check the original copy in Japanese as well.