■ Personal Information Protection Policy

Jasmy Incorporated (hereinafter referred to as the "Company") develops and provides an IoT platform that enables anyone to use physical assets easily and securely by leveraging blockchain technology. In conducting this business, the Company recognizes that all personal information it handles is closely tied to individuals’ rights and interests and must therefore be handled properly and with care, in accordance with the principle of respect for the individual and the protection of privacy. Company's business, we have established this Personal Information Protection Policy as a code of conduct for all employees, and we are committed to ensuring itsthorough implementation.

１．The Company complies with the Act on the Protection of Personal Information (the “APPI”) and all other related laws, regulations, guidelines issued by the government, and relevant norms. ２．The Company acquires, uses, and provides personal information in an appropriate manner, taking into consideration the nature and scale of its business. This includes refraining from handling personal information beyond the scope necessary to achieve the specified purposes of use and implementing necessary measures to ensure compliance. ３．When outsourcing the handling of personal information, the Company exercises necessary and appropriate supervision over the entrusted parties to ensure secure management of such personal information. ４．Except when required by laws and regulations or with the individual’s consent, the Company does not provide personal information to any third parties. ５．The Company implements appropriate safety and control measures to prevent and correct unauthorized access, leakage, destruction, loss, or alteration of personal information, and strives for continuous improvement. ６．The Company responds appropriately and promptly to complaints and inquiries regarding the handling of personal information. We also accept requests related to retained personal data, including notification of the purpose of use, disclosure, correction, addition, deletion, or suspension of use or provision. ７．The Company continuously reviews and improves its personal information protection systems and initiatives.

■ Handling of Personal Information

Article 1: Definition of Personal Information

"Personal Information" refers to information as defined by the Act on the Protection of Personal Information in Japan, meaning information about a living individual that can identify a specific person by name, date of birth, address, telephone number, or other descriptions contained therein, or that includes a "personal identifier."(A "personal identifier" includes biometric data such as facial recognition, fingerprints, vein patterns, or voiceprints, as well as public numbers such as driver's license numbers, passport numbers, and My Number assigned by national or local government agencies.)

Article 2: Acquisition of Personal Information

The Company collects personal information such as name, date of birth, address, telephone number, and email address at the time of user registration.In addition, the Company may acquire transaction records and payment information containing personal data that has been lawfully obtained by business partners or other third parties with the user’s consent.

Article 3: Purpose of Use of Personal Information

The purposes for which the Company collects and uses personal information are as follows:
(1) Customers’ Personal Information
For Contractual Fulfillment
• To provide services operated by the Company
• To deliver products sold by the Company
• To process billing and payments for products or paid services
• To contact customers as necessary for maintenance, important notices, etc.
For Advertising and Promotions
• To inform users about new features, updates, and promotions related to the services in use
• To provide advertisements and promotional content related to the Company’s or its partners’ services For Product and Service Development • To provide personalized services and content tailored to individual users
• To improve existing services and plan or develop new services operated by the Company For Maintaining Safe Use of Services
• To identify and respond to users who violate terms of service or attempt to use the service for fraudulent or improper
purposes, ensuring safe and reliable service delivery
(2) Personal Information of Business Partners
• To appropriately manage contracts and transactions with business partners
(3) Personal Information of Inquirers
• Responding to inquiries
• To accurately understand and address the content of inquiries and communications

The purposes for which the Company collects and uses the personal information of employment applicants and employees are as follows:
(1) Personal Information of Employment Applicants
• To provide and communicate information regarding recruitment and job opportunities to applicants
• To conduct recruitment and selection processes and determine suitable job placements
(2) Personal Information of Employees
• To process payroll, taxation, social insurance, and health management
• To facilitate business-related communication and carry out various legal procedures, including those required after resignation
• To appropriately manage Specific Personal Information in accordance with applicable laws, including the preparation of withholding tax slips and payment records, and the submission of health, pension, and employment insurance filing

Article 4: Provision of Personal Information to Third Parties

The Company does not provide personal information to third parties, except in any of the following cases. Additionally, in order to facilitate smooth operations, the Company may outsource certain tasks and, as necessary, provide personal information to service providers within the scope required. In such cases, the Company will enter into appropriate agreements regarding the handling of personal information and exercise necessary and appropriate supervision over the service providers. The Company may provide personal information to third parties when:
1. Consent has been obtained from the individual
2 .Information is disclosed or provided in a format that does not allow for the identification of individuals, such as statistical data
3. It is necessary for the prevention or response to fraudulent use of services operated by the Company, or to protect the rights and property of the Company or third parties
4. Disclosure or provision is required by law or regulation
5. It is necessary to protect the life, body, or property of an individual, and obtaining consent is difficult
6. There is a need to cooperate with national or local authorities in the execution of public affairs, and obtaining consent may hinder the performance of such duties
7. Personal information is provided to a successor organization due to a merger, company split, or other business succession
8. Personal information is jointly used with a specific party, and the individual has been notified in advance or such information is made readily accessible, including the purpose of joint use, the items of personal data to be jointly used, the scope of parties involved, and the name or title of the party responsible for managing the information

Article 5: Security Measures for Personal Information

The Company shall implement appropriate organizational, human, physical, and technical measures to safeguard personal information under its control from unauthorized access, leakage, loss, or damage. The Company has established security management systems and takes necessary and appropriate actions to ensure the protection of such information. Examples of security measures implemented by the Company include:
1. Formulating basic policies to ensure the proper handling of personal data, including compliance with applicable laws and guidelines, and establishing contact points for questions and complaints
2. Developing internal regulations and organizational structures for the protection of personal data
3, Providing regular training to all employees regarding best practices for handling personal data
4. Managing entry and exit to work areas and restricting the use of equipment based on the classification and sensitivity of personal data
5. Implementing access controls for personal data and preventive measures against unauthorized external access
6. When handling personal data in foreign countries, implementing security measures based on an understanding of the local personal data protection regulations

Article 6: Purpose of Use of All Retained Personal Data

The purposes of use for retained personal data related to customers are identical to those specified in Article 3. Similarly, the purposes of use for retained personal data related to employment applicants and employees are also as specified in Article 3

Article 7: Request for Disclosure of Retained Personal Data and Third-Party Disclosure Records

Customers may request disclosure of retained personal data held by the Company, including notification of the purpose of use, disclosure, correction, addition, or deletion of content, suspension or erasure of use, suspension of provision to third parties, and disclosure of third-party disclosure records (hereinafter referred to as a “Disclosure Request”). Procedures for submitting a Disclosure Request are as follows:

1. Eligible Persons for Request
• The customer themself
• The customer’s legal representative, in cases where the customer is a minor or an adult ward
• An agent authorized by the customer to act on their behalf for the Disclosure Request procedure

2. Procedure for Disclosure Request
Please complete and affix your seal to the Company’s designated “Request Form for Disclosure of Retained Personal Data,” and send it by postal mail to the Company’s “Personal Information Inquiry Desk” along with the following documents:
• A copy of a document verifying your identity
• In the case of an authorized representative, a letter of proxy and a copy of the commercial register or similar documents as required
※ For details regarding the necessary documents, please refer to the “Request Form for Disclosure of Retained Personal Data.”
※ After receiving your request, the Company may contact you or your representative by email or telephone to verify your identity against our internal records.

[Contact information for requests for disclosure, etc. (address for sending request documents)]
Jasmy Incorporated — Personal Information Inquiry Desk
11th Floor, Aoyama Building, 1-2-3 Kita Aoyama, Minato-ku, Tokyo 107-0061, Japan

3. Handling Fee for Disclosure Requests

A handling fee of JPY 1,100(tax included) will be charged per request, only when the request pertains to notification of the purpose of use, disclosure, or disclosure of third-party records. Please enclose a postal money order in the above amount with the application documentswhen submitting by mail.

4. Method of Response to Disclosure Requests

In response to a disclosure request, the Company will provide an answer within a reasonable period of time, either by issuing a written document, providing an electronic record, or using other appropriate means.

5. Cases Where Disclosure Requests Cannot Be Accepted

Disclosure requests may be denied in the following cases. In such instances, the Company will notify you of the reason. Please note that the handling fee will still be charged even if the request is not granted.
① When the identity of the individual or their representative cannot be verified
② When the submitted documents are incomplete or contain errors
③ When the subject of the request does not constitute personal information (e.g., history or characteristic information)
④ When disclosure may cause harm to the life, body, property, or other rights or interests of the individual or a third party
⑤ When disclosure may significantly hinder the proper execution of the Company’s business operations
⑥ When disclosure would violate applicable laws or regulations

Article 8: Contact for Inquiries Regarding Personal Information

If you have any questions, concerns, complaints, or other inquiries regarding the handling of personal information by the Company, please contact the following office

[Contact Office]

Jasmy Incorporated — Personal Information Inquiry Desk
Address: 11th Floor, Aoyama Building, 1-2-3 Kita Aoyama, Minato-ku, Tokyo 107-0061, Japan
e-mail ：jasmy-info@jasmy.co.jp
Inquiry form: https://www.jasmy.co.jp/contact_company.html

[Personal Information Protection Manager]

Director in Charge of Personal Information Protection Jasmy Incorporated
Address: 11th Floor, Aoyama Building, 1-2-3 Kita Aoyama, Minato-ku, Tokyo 107-0061, Japan

Article 9: Changes to the Privacy Policy

The content of this Privacy Policy may be revised in accordance with changes in applicable laws, regulations, or official guidelines. Any such revisions will be announced on the Company’s website.

[Personal Information Handling Business Operator]

Jasmy Incorporated President and COO: Kazumasa Sato
Address: 11th Floor, Aoyama Building, 1-2-3 Kita Aoyama, Minato-ku, Tokyo 107-0061, Japan

■Handling of Anonymized Information

In accordance with the Act on the Protection of Personal Information (hereinafter, the “Personal Information Protection Act”), the Company strives to ensure the proper handling of information regarding individuals that has been processed so as not to identify specific individuals (hereinafter, “Anonymized Information”) and information related to the methods of such processing (hereinafter, “Processing Method Information”) as set forth below.

Article 1: Name of the Business Operator

Jasmy Incorporated

Article 2: Compliance with Applicable Laws and Guidelines

The Company properly handles anonymized information and related processing method information (hereinafter referred to as “Anonymized Information, etc.”) in compliance with the Act on the Protection of Personal Information and other applicable laws, as well as the “Guidelines Concerning the Act on the Protection of Personal Information” and other related guidelines.

Article 3: Security Control Measures

The Company implements necessary and appropriate security measures to prevent leakage, loss, or damage of Anonymized Information, etc. In addition, the Company exercises necessary and appropriate supervision over employees and contractors (including subcontractors) who handle Anonymized Information, etc. Specific details of these security measures are stipulated separately in the Company’s internal regulations.

Article 4: Categories of Personal Information Contained in Anonymized Information Created by the Company

• Age (aggregated for individuals over a certain age)
• Gender
• First three digits of postal code
• Address (up to city, ward, or county level)
• Survey content (excluding any information that can identify individuals)
• Personal attribute information provided via surveys and other methods
• Household composition, housing status, educational background, industry/occupation, income range, hobbies and preferences

Article 5: Matters Related to the Provision of Anonymized Information to Third Parties

(1) Items of Personal Information Included in Anonymized Information Provided to Third Parties The categories of information are identical to those listed in Article 4, “Categories of Personal Information Contained in Anonymized Information Created by the Company.”

(2) Method of Provision of Anonymized Information Anonymized Information is provided via a securely managed server. The Company clearly indicates to the recipient third party that the data being provided is Anonymized Information.

Article 6: Contact for Inquiries and Complaints

For any questions or complaints regarding the Company’s handling of Anonymized Information, etc., please contact the following office:

Jasmy Incorporated – Personal Information Inquiry Desk
Address: 11th Floor, Aoyama Building, 1-2-3 Kita Aoyama, Minato-ku, Tokyo 107-0061, Japan
e-mail ：jasmy-info@jasmy.co.jp
Inquiry form：https://www.jasmy.co.jp/contact_company.html

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