[Note: This Privacy Policy is originally created in the Japanese language and this English version is a translation thereof prepared for convenience only. In the event of any conflict or inconsistency between the Japanese and English versions, the Japanese version shall prevail.]

AY HAPPY (the “Company”) hereby sets forth the following privacy policy (“Policy”) regarding the handling of customers’ personal information in connection with products and services provided by the Company (“Services”); the Company will endeavor to handle such information appropriately. Further, a separate privacy policy shall apply to services regarding game applications provided by the Company, and a separate privacy policy may also be prescribed for the use of other specified services; accordingly, please review the privacy policies for each of the services.

1. Definition of Personal Information

In this Policy, “personal information” refers to information pertaining to living persons that can be used to identify specific individuals from names, dates of birth, or other information contained in such information (including information that can be easily checked against other information to identify specific individuals). Cookies and IP address information do not fall under the category of personal information unless such information can be easily checked against other information to identify specific individuals.

2. Obtaining Personal Information

To the extent necessary for achieving the use purposes set forth in Paragraph 3, the Company will obtain personal information by lawful and appropriate means.

3. Use Purposes of Personal Information

The Company will use personal information to the extent necessary for achieving the purposes set forth below or the purposes permitted under laws and regulations; provided, however, that the Company may amend the use purposes at any time in accordance with procedures for the amendment of the Policy stipulated in Paragraph 9 if the Company reasonably determines that the amended use purposes will have appropriate relevance to the pre-amendment use purposes.

・ Provision, maintenance and improvement of the Services (including invoicing, identification and authentication of individuals, after-purchase service, the handling of inquiries and complaints, and implementation of surveys and campaigns);

・ Sale, sale solicitation, promotion/advertising (including mailing of direct mail and transmission of e-mails), and shipping and provision of or for products and services of the Company or third parties;

・ Marketing of products and services of the Company or third parties;

・ Development of new products, services and functions;

・ System maintenance;

・ Addressing of conduct violating the Company’s rules and policies concerning the Services; and

・ Other purposes the Company stipulates in the Services individually.

4. Use of Personal Information for Other Purposes

The Company will use personal information solely for the purposes listed in Paragraph 3, and except where otherwise stipulated by laws and regulations or where separate notice or announcement has been made of use purposes, such information will not be used for other purposes without the direct consent of the customer.

5. Provision of Personal Information to a Third Party

Except in cases stipulated by laws and regulations, the Company will not provide personal information to a third party without the direct consent of the customer.

6. Measures for Safe Management of Personal Information

To prevent leaks, loss, or damage of personal information handled by the Company, the Company will have necessary and appropriate measures in place to manage personal information properly. The Company will appropriately oversee employees with respect to the handling of personal information, and when outsourcing the handling of personal information, the Company will oversee the relevant service providers to ensure that personal information is managed appropriately.

7. Request for Disclosure, Correction and Suspension of Use of Personal Information

If, pursuant to the Act on Protection of Personal Information, a customer requests disclosure, correction, addition or deletion, discontinuance of use and erasure, discontinuance of provision to a third party, or notice of the use purpose of personal information possessed by the Company, the Company will first confirm that the person making the request is the actual individual him or herself and respond to the request appropriately in accordance with the Act on the Protection of Personal Information. Please note that a fee (of 1000 yen per case) is charged for disclosure pursuant to the Act on the Protection of Personal Information.

8. Handling of Personal Information at Linked Sites

Even when a link to a third party’s website is provided on websites operated by the Company or through the Services, personal information a customer provides on the relevant third party website will be obtained by such third party and will be controlled by its privacy policy, and the company will not be responsible in any way for the handling of such information.

9. Procedures for Amending the Policy

The Company may amend the Policy as necessary. When the Policy is amended, the Company will notify customers by posting the information on the Company’s website; provided, however, that if the amendment requires customer consent under laws and regulations, the Company will obtain customer consent in a manner prescribed by the Company.

AY HAPPY KK

Aset Planning Odori Building　6th

Nishi 2-chome 2 – 2, Chuo-ku

Sapporo, Hokkaido 060-0042

JAPAN

EFFECTIVE AS OF: July 5th, 2019