LUNACO JAPAN

LUNACO JAPAN Co., Ltd. (hereinafter referred to as “the Company”) recognizes the importance of protecting personal information, complies with the Act on the Protection of Personal Information (hereinafter referred to as “APPI”), and handles and safeguards personal information appropriately in accordance with this Privacy Policy (hereinafter referred to as “this Policy”). Unless otherwise specified, terms used in this Policy shall have the same meanings as defined in the APPI.

1. Definition of Personal Information
In this Policy, “personal information” refers to personal information as defined in Article 2, Paragraph 1 of the APPI.

2. Purpose of Use of Personal Information
The Company shall use personal information for the following purposes:

• To provide the Company’s services and products (hereinafter “Services”)

• To respond to inquiries and provide guidance related to the Services

• To communicate information about the Services

• To address violations of the Company’s agreements, policies, etc. (hereinafter “Terms”) related to the Services

• To notify of changes to the Terms related to the Services

• To improve Services, develop new services and products

• To understand and analyze browsing history, behavior history, and purchase history to improve and add features to the Services, and to develop and advertise new products and services tailored to interests and preferences

• For employment management and internal procedures (regarding personal information of officers and employees)

• For shareholder management and procedures under the Companies Act and other laws (regarding personal information of shareholders, etc.)

• To create statistical data in a form that does not identify individuals, related to the Services

• To provide information (including advertisements) from the Company

• For other purposes incidental to the above

3. Change in Purpose of Use
The Company may change the purpose of use of personal information within a scope reasonably related to the original purpose. In such cases, the Company will notify or publicly announce the change to the individual.

4. Restriction on Use
Except as permitted by the APPI or other laws, the Company will not use personal information beyond the scope necessary to achieve the purpose of use without obtaining the individual’s consent. However, this does not apply in the following cases:

1. Where required by law

2. When necessary to protect human life, body or property and it is difficult to obtain consent

3. When particularly necessary for improving public health or promoting the healthy development of children and consent is difficult to obtain

4. When cooperation with national or local government agencies or their agents is necessary for carrying out duties prescribed by law and consent would impede such duties

5. When providing personal data to academic research institutions for academic research purposes, provided there is no undue infringement on individual rights and interests

5. Proper Acquisition of Personal Information
5.1 The Company acquires personal information properly and does not use false or fraudulent means.
5.2 Except in cases specified in Item 4 or when obtaining sensitive personal information (as defined in Article 2, Paragraph 3 of the APPI) from academic research institutions for academic research purposes or when such information is publicly disclosed by the individual, government, delegated bodies, or authorized entities, the Company does not acquire sensitive personal information without prior consent.

6. Security Control of Personal Information
The Company supervises employees appropriately to ensure protection against loss, destruction, alteration, or leakage of personal information. When outsourcing handling of personal information, the Company supervises the contractors to ensure secure management. Main security measures include:

• Compliance with the APPI and related laws and guidelines

• Establishment of responsible personnel and procedures for each stage (acquisition, use, storage, provision, deletion/destruction)

• Appointment of a person responsible for personal data handling and regular checks

• Establishment of reporting systems for violations or suspicions by employees

• Regular employee training and confidentiality measures in employment regulations

• Restriction of personal data access to authorized personnel and devices

• Storage of electronic media and documents containing personal data in lockable cabinets

• Securing devices against unauthorized access or theft (e.g., with security cables)

• Identity confirmation upon deletion/destruction of personal data by the responsible person

7. Provision to Third Parties
7.1 Except as allowed under Item 4, the Company will not provide personal information to third parties without consent. However, this does not apply when:

• Personal information is provided to contractors within the scope necessary for achieving the purpose of use

• Personal information is provided due to business succession (e.g., mergers)

• Joint use is permitted under the APPI
  7.2 Notwithstanding the above, when providing personal information to third parties located outside Japan (excluding countries specified under Article 28 of the APPI or parties with compliant systems), the Company will obtain prior consent and take measures in accordance with the APPI.
  7.3 When personal information is provided to third parties, records will be created and retained in accordance with Article 29 of the APPI.
  7.4 When the Company receives personal information from a third party, necessary checks and record-keeping will be conducted as required by Article 30 of the APPI.
  7.5 Notwithstanding 7.1, the Company may provide user information to partner companies under the Terms or special agreements for the use of Services.

8. Acquisition and Use of Pseudonymously Anonymized Information
When acquiring personal-related information from third parties and using it as personal data, the Company will first obtain consent and use it within the scope of the purposes in Item 2. When providing personal-related information to third parties who may use it as personal data, the Company will confirm prior consent has been obtained.

9. Disclosure of Personal Information
At the individual’s request for disclosure of retained personal data or records of third-party provision under the APPI, the Company will confirm identity and promptly disclose the information (or notify if none exists), unless exempted under the APPI or other laws.

10. Correction and Deletion of Personal Information
If an individual requests correction, addition, or deletion as inaccurate personal information under the APPI, the Company will verify identity and promptly investigate and apply corrections or notify the individual. If a request is denied, the Company will notify the individual, unless obligations are exempted under the APPI or other laws.

11. Suspension of Use, etc.
If an individual requests suspension of use or erasure of personal information for reasons such as use beyond publicized purposes or acquisition by improper means, or suspension of provision to third parties without consent, and if justified, the Company will verify identity, promptly take action, and notify accordingly. This also applies when data is no longer necessary, or a serious safety incident or risk to rights/interests occurs. Exceptions apply under the APPI or other laws.

12. Handling Of Anonymously Processed Information
12.1 When creating anonymously processed information (as defined in Article 2, Paragraph 6 and Article 16, Paragraph 6 of the APPI), the Company will process it in accordance with standards set by the Personal Information Protection Commission.
12.2 The Company will implement necessary safety control measures as prescribed when creating anonymously processed information.
12.3 When created, the Company will publish the items of personal information included.
12.4 When providing such information to third parties, the Company will publish the included items and specify that it is anonymously processed.
12.5 The Company will not re-identify individuals or acquire deleted identifying features or processing methods.
12.6 The Company will implement and publicly strive for necessary measures to handle complaints and ensure appropriate handling of anonymously processed information.

13. Use of Cookies and Similar Technologies
The Company’s Services may use cookies and similar technologies to understand usage and improve Services. Users may disable cookies via browser settings, though some features may become unavailable.

14. Use of External Services
The Services may use the external services listed below. Please refer to each provider’s privacy policy.

1. For visitor analytics: the Company may use Google Analytics and Google Analytics advertising functions, including:

• Google Analytics Remarketing

• Google Display Network Impression Reporting

• Google Analytics Demographics and Interests Reporting
  Opt‑out procedures and cookie disabling may be done through browser settings or each service’s opt‑out tools (e.g., Google Analytics Opt‑out Add‑on).

15. Company Name, Address, and Representative
LUNACO JAPAN Co., Ltd.
2F, Nishi‑Shinjuku Mizuho Building, 3‑3‑13 Nishi‑Shinjuku, Shinjuku‑ku, Tokyo, Japan
Representative Director: Yukiharu Akase

16. Contact Information
For requests for disclosure, opinions, questions, complaints, or any inquiries regarding the handling of personal information, please contact us by phone or email:
LUNACO JAPAN Co., Ltd.
2F, Nishi‑Shinjuku Mizuho Building, 3‑3‑13 Nishi‑Shinjuku, Shinjuku‑ku, Tokyo, Japan
Privacy Contact Office
Email: yukiharu.akase@gmail.com

17. Continuous Improvement
The Company will review and improve the handling of personal information as necessary and may revise this Policy accordingly.

Established: January 9, 2025