This Privacy Policy is made to : (i) protect Personal Information as defined below, (ii) establish certain rules and procedures to protect Personal Information, (iii) ensure that our employees observe and understand the importance of protecting Personal Information and taking the necessary measures to protect such Personal Information carefully, including by promoting such protection.

1 (Personal Information)
“Personal Information” in this Privacy Policy means “personal information” as stipulated in the Act on the Protection of Personal Information of Japan (Act No. 57 of May 30, 2003; “Personal Information Protection Act”); and therefore means information which can identify a specific living individual by name, date of birth or other description contained in such information; or which includes a code that can identify a specific individual.
(1) information provided by the User,including:name,screen name,nick name ,other information entered by the User into such from as specified by us.
(2) information provided from services outside our services(the “Services”) to the extent that the User permits for use with the Services;We may collect the following information from services outside the Services,including but not limited to social network services,to the extent the User permits for use with the Services at that time:ID used by the User for such outside service;and other information that the User has authorized the other service provider to disclose through its privacy settings in such outside service.
(3) information collected by us for the User by the User of the Services.We may collect information upon access to or use of the Services,including:terminal information,log information,cookies and anonymousID,and location information.

2 (Acquisition and Use of Personal Information)
We may acquire from and use Personal Information of users of the Services (individually “User” or collectively “Users”) within the scope necessary for the following purposes. If we seek to use such Personal Information beyond the following purposes, we will obtain prior written consent of the User whose Personal Information is concerned:
(1) To perform the Services;
(2) To improve and refine the Services, or to develop new services;
(3) To notify Users of new functions or updated information of the Services, campaigns, and our other services (including via e-mails, flyers, and other direct mails);
(4) To inform Users of any maintenance of the Services or important news regarding the Services;
(5) To answer questions from Users regarding the Services (including to confirm Users identification);
(6) To report to Users the situation regarding the use of the Services;
(7) To request Users to answer any questionnaires and questions regarding the Services or to attend events, or to report the answers of such questionnaires and questions or results of such events to such Users;
(8) To conduct research on and provide analysis of the history of the Services and to utilize the results of such research and analysis for the improvement and development of the Services and to deliver any promotional materials; and
(9) To identify Users who have violated the Terms of Use or who intend to use the Services for unlawful or illegitimate purposes, and to block their use of Services.

3 (Management and Protection of Personal Information)
We will carefully and closely manage Personal Information and will not disclose or provide such Personal Information to any third parties without the prior written consent of Users whose Personal Information is concerned, except in the following circumstances:
(1) if such disclosure of Personal Information is necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of such person;
(2) if such disclosure of Personal Information is necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person whose Personal Information is concerned;
(3) if such disclosure of Personal Information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by such state organ or local government in executing the affairs required by laws and regulations, and if obtaining the consent of the person whose Personal Information is concerned is likely to hinder the execution of such affairs;
(4) if we entrust the handling of Personal Information in whole or in part within the scope necessary to achieve our purposes as stipulated in Article 2, in order to implement our operations smoothly;
(5) if such Personal Information is obtained as a result of the succession of business in a merger or otherwise;
(6) if such Personal Information is used jointly between specific individuals or entities, and in such case if the scope, and purposes of such joint use, and the name of the individual or business operator responsible for the management of such Personal Information have been notified to the User(s) whose Personal Information is concerned in advance; and
(7) if it is permitted by laws and regulations to disclose or provide Personal Information.

We will, take preventive and corrective measures against risks resulting from any unlawful access to Personal Information, or any loss, destruction, falsification, or leakage of Personal Information.

4 (Entrustment of Personal Information Handling)
We may entrust an individual or a business operator to handle Users’ personal data in whole or in part. In such case, we will examine their eligibility sufficiently, obligate such individual or business operator to maintain confidentiality obligations by contract, and will perform the necessary and appropriate supervision over such individual or business operator.

5(Analytics)
We may use third-party Service Providers to monitor and analyze the use of our Service.
The following affiliated parties may save cookies in the user’s devices and thereby accumulate and use the user information.
(1) Affiliated Party ;Firebase
(2) URL of Privacy Policy of Affiliated Party above; https://policies.google.com/privacy
(3)URL of Opt-out(invalidation) of Affiliated Party above;
https://firebase.google.com/docs/analytics/configure-data-collection?hl=ja&platform=ios

6 (Disclosure of Personal Information)
Upon a request of a User, we will promptly disclose the Personal Information of such User. However, we may keep all or part of such Personal Information undisclosed, if such disclosure falls under any of the following categories; and in this case, we will promptly notify such User:
(1) if such disclosure is likely to harm the life, body, property, or other rights or interests of such User or any other third parties;
(2) if such disclosure is likely to hinder the proper execution of our business; and
(3) if such disclosure may result to violation of any laws and regulations.

7 (Correction and Deletion of Personal Information)
7.1 If any Personal Information retained by us includes false information, we will, upon the request of the User whose Personal Information is concerned, correct or delete such false information in accordance with our internal procedures.
7.2 Based on the request of such User whose Personal Information is concerned, as referred in paragraph 1 of this Article 7, we will promptly notify such User once such correction or deletion of the Personal Information has been completed.

8 (Discontinuation of Personal Information Use)
If we receive any request from a User to discontinue using or to erase his or her Personal Information (“Discontinuation”) on the ground that such Personal Information is used beyond the purposes as stipulated in Article 2 of this Privacy Policy or has been acquired by unlawful means, we will promptly conduct the necessary research and, based on the result of such research, implement the Discontinuation and notify such User to that effect. However, if such Discontinuation is unduly expensive or is otherwise difficult to implement, we will, if possible, take the necessary alternative measures to protect the rights and interests of such User.

9 (Procedures for Amending Privacy Policy)
We will review the content of this Privacy Policy appropriately and endeavor to improve this Privacy Policy. The content of this Privacy Policy can be amended unless otherwise stipulated in laws, regulations, and this Privacy Policy. The amended Privacy Policy will be valid when notified to all Users or uploaded on our website in accordance with our procedures.

10 (Compliance with Laws, Regulations and Norms)
We will comply with the laws and regulations in Japan and other rules that are applicable to the use of Personal Information we retain.

11 (Response to Complaints and Consultations)
We will respond to any complaints from Users and will provide consultation to any User whose Personal Information is concerned as to the handling of his or her Personal Information. We will respond properly and promptly to any request for disclosure, correction, addition, deletion, refusal of use or provision regarding Personal Information.

12 (Customer Desk)
For inquiries concerning our policy of handling of Personal Information, please contact us as below at:
SQOOL Co.,Ltd.
Raionesu Hamamatutyou 402, 1-20-10 Hamamatutyou, Minato-ku, Tokyo 105-0013, Japan
TEL: +81-3-6821-1261
E-mail: info@sqool.co.jp

Established on and valid from 16 Sep 2021.