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PRIVACY POLICY

Fusic Co., Ltd. (the "Company") contributes to the advancement of society by leveraging high-level IT skills and creativity.
Recognizing that the appropriate protection of personal information is a social responsibility necessary to achieve this goal, the Company promotes the following initiatives.

Basic Policy

  1. The Company acquires, uses, and provides personal information appropriately, taking into account the nature and scale of its business.
  2. The Company clearly specifies the purposes of using personal information and takes appropriate measures to ensure that personal information is not handled beyond those purposes.
  3. The Company complies with laws, government guidelines, and other norms relating to the handling of personal information.
  4. The Company establishes a security management framework to prevent unauthorized access to personal information and to prevent the leakage, loss, destruction, or damage of personal information. The Company also implements appropriate preventive and corrective measures in the event of incidents involving personal information.
  5. The Company establishes a contact point and responds promptly to requests for disclosure, etc., and to inquiries, complaints, and consultations regarding the handling of personal information.
  6. The Company continuously reviews and appropriately improves its personal information protection management system.

Purposes of Use of Personal Information

The Company uses personal information for the following purposes.

  • To provide, maintain, protect, and improve the services provided by the Company
  • To register accounts, verify identity, and record user authentication
  • To analyse skills and other relevant attributes and prepare analytical materials on the services provided by the Company
  • To conclude contracts
  • To perform and manage contractual obligations
  • To process and manage data received under service engagements
  • To deliver products, and for maintenance and support
  • For billing and payment
  • To receive and respond to inquiries and requests
  • To provide materials and information that may be useful to customers
  • To send greeting communications
  • To address violations of terms and other misconduct
  • To provide information about the Company
  • To introduce and promote the Company's services
  • For research and development and advertising/promotion
  • To analyse collected browsing history information and conduct advertising activities for new products and services tailored to users' preferences
  • To perform obligations and exercise rights related to transactions
  • To collect necessary information for business purposes, and to contact, notify and provide information to users, including for marketing purposes in relation to the services provided by the Company
  • For the preparation of statutory documents relating to the payment of remuneration and the processing of other administrative matters permitted under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures
  • To consider and decide hiring, and to respond to inquiries
  • To analyze recruitment and internship activities for future planning
  • To conduct internship programs
  • For business communications and facility management
  • For labor management
  • For education and training
  • For occupational safety and health management
  • To fulfill obligations under labor laws
  • For the preparation of statutory documents relating to the payment of remuneration and the processing of other administrative matters permitted under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures
  • For other related operations
  • For business communications and facility management
  • For human resources and labor management
  • For payroll and benefits
  • For education and training
  • For occupational safety and health management
  • For legal procedures related to employment, insurance, and taxation
  • For the preparation of statutory documents relating to the payment of remuneration and the processing of other administrative matters permitted under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures
  • For other related operations
  • To exercise rights and fulfill obligations under applicable laws
  • To operate and record shareholders' meetings
  • To implement shareholder-related measures
  • For shareholder data management in accordance with laws

"Personal information of business partners, alliance partners and other similar parties", "personal information of job applicants, interns and former employees", "personal information of officers and employees" includes Individual Numbers (My Number) and specific personal information, where applicable. Such information shall be collected only to the extent necessary for the preparation of statutory documents relating to the payment of remuneration and the processing of other matters permitted under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.

Provision of Personal Information to Third Parties

The Company will not provide personal information to any third party except in the following cases:

  • Where the individual has given consent
  • Where such provision is required by applicable laws and regulations

Notwithstanding the foregoing, the Company may, based on the customer's consent to this Privacy Policy, provide customer information to the third parties specified below.

The Company may provide personal information, including information relating to the customer's use of the services, to research and analytics companies, affiliates, social media service providers, advertising-related companies, advertising delivery service providers, data management platform providers and other business partners with whom the Company collaborates in its business operations (collectively, "Business Partners, etc."), to the extent necessary for the purpose of enabling such Business Partners, etc. to combine personal information already held by them with personal information obtained from the Company, and to use such combined information for analysis, advertising delivery and other related purposes.

Outsourcing the Handling of Personal Information

Within the scope necessary to achieve the above purposes, the Company may entrust the handling of personal information to third parties.
In such cases, the Company selects contractors in accordance with applicable laws and Company standards, enters into confidentiality agreements, and supervises such contractors to ensure appropriate handling of personal information.

Provision of Personal Information to Third Parties Located Outside Japan

The Company will not provide personal data to any third party located outside Japan except in any of the following cases:

  1. where the personal data is provided to a third party located in a country specified by the rules of the Personal Information Protection Commission as a foreign country having a personal information protection system that is recognised as providing a level of protection equivalent to that of Japan in terms of protecting the rights and interests of individuals;
  2. where, between the Company and the recipient of the personal information, measures consistent with the intent of Chapter IV, Section 2 of the Act on the Protection of Personal Information are ensured to be implemented by appropriate and reasonable means with respect to the handling of such personal information by the recipient;
  3. where the recipient of the personal information has obtained certification under an international framework relating to the handling of personal information; or
  4. where the provision or disclosure of personal data to a third party located outside Japan is otherwise permitted under the Act on the Protection of Personal Information or other applicable laws and regulations.

In the cases referred to in items 2 and 3 above, the Company takes necessary measures to ensure continuous implementation by the third party of equivalent measures. For details of such measures, please contact the contact point set out in "Contact for Inquiries Regarding Personal Information".

Notwithstanding the foregoing, based on the customer's consent to this Privacy Policy, the Company may provide customer information to third parties located outside Japan. Information regarding the foreign country in which such third parties are located, the personal information protection system of such foreign country, and the measures taken by such third parties for the protection of personal information is as follows:

Name of Foreign Country
• United States of America

Reference Information
• Information regarding the personal information protection system in the country where the recipient is located, namely the United States of America: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/

Measures Taken by Third Parties Located Outside Japan for the Protection of Personal Information
• The third-party recipients have taken all measures corresponding to the eight principles set out in the OECD Privacy Guidelines.

Voluntary Nature of Providing Personal Information

Providing personal information to the Company is voluntary.
However, failure to provide such information may hinder the Company's ability to perform the services described above and may result in disadvantages to the individual.

Security Management Measures

To prevent leakage, loss, or damage of personal information, the Company implements the following measures:

  • Organizational measures
    • Appointment of a person responsible for personal information management
    • Establishment of reporting systems for incidents
  • Human measures
    • Internal rules regarding confidentiality and handling of personal information
    • Regular training
  • Physical measures
    • Restricted access to areas handling personal information
    • Entry/exit controls
  • Technical measures
    • Access control to limit authorized personnel
    • Protection against unauthorized access and malicious software
  • Understanding of external environments

    Implementation of measures based on the legal systems of countries where data is stored

Contact for Personal Information Matters

Personal Information Inquiry Desk
Email: privacy@fusic.co.jp
Personal Information Protection Manager: Head of Corporate Planning Division

Procedures for Requests for Disclosure, etc.

With respect to requests concerning retained personal information for notification of the purpose of use, disclosure, correction, addition or deletion, or suspension of use, erasure or suspension of provision to third parties (collectively, "Disclosure, etc."), the Company will determine whether such requests are appropriate in accordance with applicable laws and regulations and respond without delay.

If you wish to make such a request, please contact the Personal Information Inquiry Desk by email.

  • Identity verification documents (one required):
      • Driver's license
      • Passport
      • Certificate of residence
      • Health insurance card
      • Pension book
    • If the request is made by an agent, a power of attorney is required.
    • A fee of JPY 1,040 (in postage stamps) is required per request for disclosure or notification of purpose of use.
    • All related costs shall be borne by the requester.
  • Procedures will commence after identity verification is completed.
  • Responses will be provided by mail or email.
  • If the Company cannot comply with a request, the reason will be provided.

Certified Personal Information Protection Organization

Japan Institute for Promotion of Digital Economy and Community (JIPDEC)

Telephone: +81-3-5860-7565
Toll-free: +81-120-700-779

Company Address and Representative

The Company's address and the name of its representative are as set out below:
https://fusic.co.jp/english/company

Date of establishment: October 10, 2008
Date of last amendment: July 1, 2026

Notes on Terms

"Personal information," "personal data," and "retained personal data" shall have the meanings defined under the Act on the Protection of Personal Information (APPI) of Japan.

Singapore-Specific Data Protection Addendum

For the handling of personal information subject to the Personal Data Protection Act 2012 ("PDPA"), the following data protection addendum (this "Addendum") shall apply in addition to this Privacy Policy.

For the purposes of this Addendum, in line with the provisions under the PDPA, "Personal Data" shall mean data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which the Company has or is likely to have access, including but not limited to name, NRIC, birth date and contact information.

1 Collection and Use of Personal Data

1.1 The Company generally does not collect your Personal Data unless (a) it is provided to the Company by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to the Company (your "authorised representative") after (i) you (or your authorised representative) have been notified of the purposes for which the Personal Data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your Personal Data for those purposes, or (b) collection and use of Personal Data without consent is permitted or required by the PDPA or other laws. The Company shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).

1.2 In accordance with the preceding clause, we will collect and use your Personal Data for any or all of the purposes specified above in this Privacy Policy.

2 Withdrawing Your Consent

2.1 The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

2.2 Upon receipt of your written request to withdraw your consent, the Company may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, the Company shall seek to process your request within ten (10) business days of receiving it.

2.3 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose your Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.

3 Access to and Correction of Personal Data

3.1 If you wish to make (a) an access request for access to your Personal Data which the Company holds or information about the ways in which the Company uses or discloses your Personal Data, or (b) a correction request to correct or update any of your Personal Data which the Company holds, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

3.2 Please note that a reasonable fee may be charged for an access request. If so, the Company will inform you of the fee before processing your request.

3.3 The Company will respond to your request as soon as reasonably possible. Should the Company not be able to respond to your request within thirty (30) days after receiving your request, the Company will inform you in writing within thirty (30) days of the time by which the Company will be able to respond to your request. If the Company is unable to provide you with any Personal Data or to make a correction requested by you, the Company shall generally inform you of the reasons why the Company is unable to do so (except where the Company is not required to do so under the PDPA).

4 Retention of Personal Data

4.1 The Company may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

4.2 The Company will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

5 Reporting A Personal Data Breach

5.1 If the Company encounters suspected Personal Data Breach (defined below), the Company will conduct an assessment of whether the Personal Data Breach is a notifiable Personal Data Breach (hereinafter defined). "Personal Data Breach" shall mean (a) the unauthorised access, collection, use, disclosure, copying, modification or disposal of Personal Data; or (b) the loss of any storage medium or device on which Personal Data is stored in circumstances where the unauthorised access, collection, use, disclosure, copying, modification or disposal of the personal data is likely to occur.

5.2 The Company will notify the Personal Data Protection Commission, as soon as practicable, but in any case, no later than three (3) calendar days after the day the Company makes that assessment, if the Personal Data Breach:

  • (a) results in, or is likely to result in, significant harm to an affected individual; or
  • (b) is, or is likely to be, of a significant scale ("notifiable Personal Data Breach").

5.3 The Company will also notify you if you are affected by a notifiable Personal Data Breach mentioned in clause 5.2 above in any manner that is reasonable in the circumstances.

6 Data Protection Officer

6.1 If you have any enquiries or wish to make any request relating to your Personal Data, you may contact our Data Protection Officer at:

Department: Corporate Planning Division
Email: privacy@fusic.co.jp
Weekdays: Monday–Friday (10AM–5PM)

Effective Date: July 9, 2026