S.RIDE Inc. (hereinafter referred to as "we") hereby establish this Privacy Policy (hereinafter referred to as this "Policy"), recognizing that it is our important social responsibility to protect and properly manage personal information.

1.（General provision）

1. To ensure the protection of personal information, we will comply with the Act on the Protection of Personal Information of Japan (Act No. 57 of May 30, 2003 of Japan; hereinafter referred to as the "Personal Information Protection Act") and other related applicable laws and regulations and endeavor to appropriately handle and protect personal information (meaning "Personal Information" as defined in paragraph 1 of Article 2 of the Personal Information Protection Act).
2. We may establish individual privacy policies for each of our individual services that are applicable to those services, in which case the privacy policy applicable to the relevant service shall prevail over this Policy if there is any inconsistency or conflict between them.

2.（Purpose of use of personal information）

1. We will appropriately handle personal information obtained within the scope of the following purposes:

   1. Personal information obtained in connection with our provision of services;

      • Provision, maintenance, development and improvement of various services provided by us (hereinafter referred to as "Our Services");
      • For the advertisement, publicity and marketing of Our Services;
      • For the development and improvement of Our Services;
      • For the purpose of providing customer support service and resolving disputes in connection with Our Services;
      • Notification and response, etc. regarding Our Services;
      • Amendment of the Terms of Use of Our Services or this Policy, or suspension or discontinuation of, or cancellation of the agreement of, Our Services;
      • For the purpose of giving important notices, etc. relating to Our Services;
      • For the purpose of transferring such personal information to third parties; and
      • For any other purposes incidental or related to the purposes of use described above.

   2. Personal information relating to our clients (excluding (1))

      • For the purpose of achieving the purposes of transactions with such clients; and
      • For the purpose of providing business information, etc. for such clients.

   3. Personal information of our officers and employees

      • For employment management and internal procedures.

   4. Personal information about our shareholders

      • For the purpose of managing our shareholders and following procedures under the Companies Act and other relevant laws and regulations as well as exercising our rights and performing our obligations.
2. We may change the purpose of use set forth in the preceding paragraph to the extent reasonably considered relevant to the purpose set forth in the preceding paragraph, and in the event of such change, we shall publish such change in a manner that is easily understandable, such as by posting it on Our Services or on the website operated by us.
3. In addition to paragraph 1 of this Article, we may process personal information into anonymously processed information that is unable to identify a specific individual (meaning "Anonymously Processed Information" as defined in paragraph 6 of Article 2 of the Personal Information Protection Act; the same shall apply hereinafter) or statistical information and use it in compliance with the matters stipulated by the Rules of the Personal Information Protection Commission.

3.（Transfer to third parties）

1. We will not transfer personal data (meaning "Personal Data" as defined in paragraph 3 of Article 16 of Act on the Protection of Personal Information of Japan; the same shall apply hereinafter) to any third party (excluding the consignee referred to in Article 5 and certain parties referred to in Article 6; the same shall apply hereinafter) without the consent of the user; provided, however, that if it falls under any of the following, personal information may be transferred without the consent of the user to the extent that it does not violate the applicable laws and regulations:

   1. It is in accordance with laws and regulations;
   2. It is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the User;
   3. It is necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the User;
   4. It is necessary to cooperate with a national or local government, or a person who is delegated by government in executing laws or regulations and obtaining the consent of the User is likely to impede the execution of such matters;
   5. The succession of business, including personal information of the User, due to merger, company split, transfer of business, or for any other reason.

2. Where personal data is transferred to a third party based on the consent of the user, we shall prepare and retain records relating to the following matters:

   1. The prior consent of the User has been obtained;
   2. Name or information of the third party sufficient to identify the said third party;
   3. Information sufficient to identify the person, such as the name of the person identified by the personal data;
   4. Items of such personal data.

4.（Delegation of the handling of personal information）

We may delegate the handling of all or part of personal data obtained from Users to a third party within the scope necessary for the achievement of the purpose of use. In this case, we shall execute a confidentiality agreement with the consignee in accordance with this Policy and conduct necessary and appropriate supervision to ensure that the consignee appropriately manages the information securely.

5.（Sharing）

We may share personal data information collected from the user with certain parties to the extent necessary for the provision of the affiliated services, etc. In such case, we shall notify the user in advance of the items of information to be shared, the scope of the third party sharing the information, the purpose of use of such third party and the name of the person who is responsible for the management of such personal data.

6.（Information collection module）

We may incorporate the following information collection modules selected by us into the Services to analyze information such as the usage of the Services and advertising effects related to services including the Services. Accordingly, we may provide personal data to the providers of the following information collection modules. These information collection modules collect user’s information without including personally identifiable information, and the collected information is managed in accordance with the privacy policy and other regulations of each information collection module provider.

Name

Google Analytics, Firebase

Supplier

Google Inc.

Privacy Policy

https://policies.google.com/technologies/partner-sites?hl=ja
https://firebase.google.com/terms/analytics/

Name

AppsFlyer

Supplier

AppsFlyer Ltd.

Privacy Policy

https://www.appsflyer.com/privacy-policy/

Name:

KARTE for App, KARTE Datahub

Supplier:

PLAID, Inc.

Privacy Policy:

https://karte.io/karte-policy-en.html

7.（Security management system）

1. In order to prevent the leakage, loss or damage of personal data and to protect personal data, we have implemented necessary and appropriate measures for the security management of personal data, such as restricting access to personal information files and anonymously processed information, limiting the authorized users to the minimum extent necessary and introducing security software to prevent unauthorized access from outside.
2. We will appoint the person responsible for the management of personal information, etc. and appropriately manage personal information and make continuous improvements.

8.（Users’ rights regarding disclosure and correction, etc. of retained personal data）

For the disclosure, correction, deletion or suspension of use ("Disclosure, Etc.") of retained personal data (meaning "Retained Personal Data" as defined in paragraph 4 of Article 16 of the Act on the Protection of Personal Information of Japan; the same shall apply hereinafter) on the Services or other similar actions, please refer to the "Guidance on Application for Disclosure, Etc. of Personal Information" available at [https://sride.jp/en/drform/drform.pdf]; provided, however, that if we do not assume these obligations under Act on the Protection of Personal Information of Japan or other applicable laws or regulations, we may not follow these procedures.

9.（Changes to this Policy）

1. We will review the operation of the handling of personal information from time to time in order to make continuous improvements, and this Policy may be revised from time to time as necessary.
2. The revised Policy shall be posted on the Service or on the website or in other ways which is easy to understand. Provided, however, if any revision that requires the consent of the User in accordance with applicable laws or regulations, we shall obtain the consent of the User in a manner we set forth.

10.（Inquiry）

For comments, questions, complaints and other inquiries regarding our handling of personal information, please contact the following contact point:

Contact for inquiries：S.RIDE Inc.
Address：1-5-2, Higashi-Shimbashi, Minato-ku, Tokyo 105-7105, Japan
Email: info@sride.co.jp

Established on March 25, 2019
Revised on January 5, 2021
(Changes due to change of trade name)
Revised on June 17, 2021
(The suppliers of the information collection modules were added.)
Revised on April 1, 2022
Revised on August 1, 2022