PRIVACY POLICY

GENERAL POLICY

Personal Information Protection Policy

Acquisition and use of personal information

We will clearly define the purpose of use of the personal information we acquire, and use it appropriately and fairly within the scope necessary to achieve the purpose for which we have obtained the consent of the person concerned.

Prohibition of Use of Personal Information for Other Purposes and Preventive Measures

We will not use the personal information we have acquired beyond the scope necessary to achieve the purpose for which we have obtained the consent of the individual (use for purposes other than the intended use). To this end, we will take specific measures to prevent the use of personal information for purposes other than the intended use, such as clearly defining the purpose of use of personal information handled by the Company and the manager of the Company.

Management and Protection of Personal Information

Personal information obtained will not be disclosed or provided to any third party, except when required by law or by a public agency, when we have the consent of the person concerned, when we outsource our business to an outside contractor, or when permitted by other laws or regulations. When outsourcing part or all of the personal information to an outside contractor for business reasons, we will select a contractor that meets our strict personal information protection outsourcing standards, conclude a contract with the contractor on matters such as handling of personal information within the scope of the purpose of use specified by us and agreed upon by the person concerned, and appropriately manage and guide the contractor. We will also appropriately manage and provide guidance to the contractor.

Compliance with Laws and Regulations, National Guidelines, and Other Standards

In handling personal information obtained and used in the course of our business activities, we will comply with laws and ordinances, government guidelines, and other norms regarding the protection of personal information.

Appropriate Management of Personal Information and Risk Management

We will strictly manage all personal information from acquisition to disposal, keep personal information accurate and up-to-date, and take appropriate preventive measures against risks such as leakage, loss, or damage (including unauthorized access, loss, destruction, and alteration) of personal information. In the event that a risk should occur, we will strive to quickly assess the situation, and promptly take and implement corrective measures.

Response to complaints, consultations, etc.

We will appropriately respond to inquiries regarding the handling of personal information, requests for disclosure, correction, deletion, suspension of use, etc. of personal information subject to disclosure from the person in question, complaints, and consultations.

Maintenance and Continuous Improvement of Personal Information Management System

We will ensure that all of our directors and employees comply with laws, regulations, national guidelines, and other standards regarding personal information, recognize the importance of protecting personal information, and maintain and continuously improve our personal information protection management system in an appropriate manner.

Handling of Personal Information

Definition of Personal Information, etc.

The term "personal information" shall mean information as defined in Article 2.1 of the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"). (i) "personal information" means information that satisfies the following three requirements: (1) it is information about an individual, (2) it is a living individual, (3) it is possible to identify a specific individual by any item contained in that information, or (3) it contains a personal identification code. In addition, "personal data" means information (personal information that constitutes a "personal information database, etc.") as defined in Article 16, Paragraph 3 of the Act. In addition to the above, definitions of terms used herein shall be in accordance with the Personal Information Protection Law and related laws and regulations.

Personal Information to be collected

We collect the following personal information for this service.

• Service registration data (name, address, telephone number, e-mail address, account information, SNS account, identification (passport, etc.), emergency contact information, items listed on identification documents, etc.)
• Service usage data (IP address, cookies, access log, device ID, usage environment, etc.)

Acquisition of Personal Information

When we acquire personal information, we will clarify the purpose of handling personal information in advance, and will do so appropriately within the scope necessary to achieve that purpose.
We will strive to ensure the security of the personal information provided by our customers by using encryption technology (SSL) and other means to ensure the accuracy and safety of the personal information.
We collect personal information from customers in the following cases

• When we receive personal information directly from customers or through written documents or other media in connection with the use of this service.
• When we collect information about you in connection with the use of this service
• When we obtain personal information legally, such as when we receive it from a third party with the customer's consent.

Purpose of use of personal information

Personal information about the customer (name, address, telephone number, etc.)

• To provide and implement this service (including responses to inquiries regarding this service)
• For identification and authentication services
• For guidance, surveys, and other information related to the Service (e.g., customization of the contents of the pages of the Company's Service and the distribution of advertising and promotional materials in a manner consistent with your age, occupation, gender, hobbies and preferences, etc.)
• To analyze and study the improvement, expansion of functions, and other changes to our services
• To examine and develop new services
• Personal information (name, address, telephone number, e-mail address, etc.) regarding our business partners (including the person in charge of the business partner) Personal information (name, affiliation, contact information, etc.) regarding our business partners
• To select business partners, etc., to perform contract procedures, to manage business partners, etc., and to perform related tasks.
• To provide guidance regarding our services or other information that we believe will be useful to you.
• Personal information (name, contact information, career history, etc.) of applicants for employment with the Company
• To provide reference materials for selection evaluation
• To provide information on each step of the selection process
• To statistically process information on the status of employment applications

Voluntary nature of providing personal information and failure to respond

However, we may not be able to respond to your request if you do not provide us with the personal information necessary for the services we provide, or if you provide us with incorrect or false information. In such cases, the Company may not be able to respond to the customer's request.

Measures taken for security control

We take strict technical and organizational security measures to prevent unauthorized access to personal data or leakage, loss, or damage of personal data, and to otherwise manage personal data safely. In order to continuously and permanently protect personal data, we will review and improve our internal rules and regulations in accordance with changes in laws, regulations, and social norms.
When having employees handle personal data, we will ensure that they are familiar with the proper handling of personal data, provide them with appropriate training, and supervise them as necessary and appropriate.
When entrusting the handling of personal data to a subcontractor, we will select a subcontractor that has appropriate security control measures in place and provide necessary and appropriate supervision to the subcontractor.
Personal data will be retained for the period necessary to achieve the purpose of use or for the period stipulated by applicable laws and regulations. Personal data will be promptly deleted after the period necessary to achieve the purpose of use or after the period stipulated by applicable laws and regulations. However, personal data may be retained and used to comply with our legal obligations and to protect our rights and interests.

Sharing of Personal Data

We may share personal data in accordance with the following :

(Scope of joint users)
Our group companies located in Japan as follows. In the event that any of our group companies is newly established in Japan, the same shall apply to the newly established company.

• BORDERLESS JAPAN Corporation
• BORDERLESS SOCIAL FUND Corporation
• Joggo Corporation
• Sunday Morning Factory Corporation
• Post & Post Corporation
• Business Leather Factory Corporation
• BORDERLESS CAREER Corporation
• Miraihata Corporation
• People Port Corporation
• Tabemonogatari Corporation
• Kirahoshi Corporation
• Tomoshi bito Corporation
• Relight Corporation
• Enter the E Corporation
• Local Food Cycling Corporation
• Houbokusha Corporation
• Smile Button Corporation
• WAOful Corporation
• Mama Life Balance, Corporation
• Nonprofit Organization Mama Life Balance,Corporation
• BOREDERLESS FARM Corporation
• Island Honey Works Corporation
• Musubiba Corporation
• Small Forest School Children Corporation
• Annotation Support Corporation
• Futarino Corporation

(Items of personal information to be shared)

• All of your personal data, including your registration data for the Service.
• All of your personal data, including your service usage data.
• Names, affiliations, and contact information of our business partners and persons in charge of our business partners

(Purpose of joint use)
Same as "Purpose of Use of Personal Data" above.

(Person responsible for the management of personal data to be shared)
Yaesu Ichigaya Bldg. 10F, 2-17 Ichigaya-Tamachi, Shinjuku-ku, Tokyo 162-0843, Japan
BORDERLESS JAPAN Co.
President and Representative Director Kazunari Taguchi

Provision of Personal Data to Third Parties

Personal information acquired by BORDERLESS JAPAN will not be entrusted to a third party, except in the case of entrusting the handling of personal information to a subcontractor with whom we have concluded a confidentiality agreement regarding personal information, to the extent necessary to achieve the purpose of use that has been clearly indicated or announced in advance.
In addition to the above, personal information obtained by the Company will not be provided or disclosed to any third party, except in the following cases

• When we have obtained prior consent from the person in question.
• When we are obliged to provide the information in accordance with laws and regulations, etc.
• When 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 individual.
• Cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children, and in which it is difficult to obtain the consent of the individual concerned
• Cases in which the provision of personal information is necessary for cooperating with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the consent of the individual is likely to impede the execution of the affairs concerned.

Notification of Purpose of Use

When there is a request from the individual or his/her representative to be notified of the purpose of use of retained personal data (hereinafter referred to as "notification of purpose of use"), the Company shall notify the individual or his/her representative of the following cases When a person or his/her representative requests to be notified of the purpose of use of retained personal data ("Purpose of Use Notification"), the Company will notify the person without delay except in the following cases

• When the purpose of use of retained personal data that identifies the individual is clear
• When there is a risk of harm to the life, body, property, or other rights or interests of the person concerned or a third party
• When there is a risk of harm to the Company's rights or legitimate interests
• When it is necessary to cooperate with a national agency or local public body in the execution of its legally prescribed duties, and there is a risk of interfering with the execution of such duties.

A handling fee will be charged for requests for notification of the purpose of use.
To request notification of the purpose of use, please contact the Personal Information Inquiry Desk below. After contacting us, we will inform you of the procedure and the amount of the fee as described in the previous section.

Disclosure of Personal Information

When we receive a request for disclosure of retained personal data or records of provision to a third party from the person in question or his/her representative, we will disclose the information without delay, except in the following cases

• When there is a risk of harm to the life, body, property, or other rights or interests of the person in question or a third party
• If there is a risk of significant hindrance to the proper conduct of our business
• If it is in violation of laws and regulations.
• Notwithstanding the preceding paragraph, we may not disclose all or part of a record of provision to a third party in connection with a request for disclosure under the preceding paragraph if the record falls under any of the following conditions.
• (i) Cases in which the life, body, or property of the person or a third party is likely to be endangered if the existence or nonexistence of the record in question is made public.
• (ii) The existence or nonexistence of the record is likely to encourage or induce illegal or unjust acts by revealing the existence or nonexistence of the record.
• (iii) Those in which the existence or nonexistence of the record is likely to cause harm to national security, damage the relationship of trust with other countries or international organizations, or cause a disadvantage in negotiations with other countries or international organizations.
• (iiii) Cases in which the prevention, suppression, or investigation of crimes or the maintenance of other public safety and order is likely to be disturbed if the existence or nonexistence of the record in question is revealed

A fee may be charged for requests for disclosure of retained personal data or records provided to third parties.
To request disclosure of retained personal data or records provided to a third party, please contact the Personal Information Inquiry Desk below. After contacting us, we will inform you of the method of procedure and the amount of the fee mentioned in the preceding paragraph.

Correction, addition, or deletion of personal information

When a person or his/her representative requests us to correct, add, or delete (hereinafter referred to as "correct, etc.") his/her retained personal data, we will investigate the request without delay and take appropriate actions based on the results. If we receive a request for correction, addition, or deletion of retained personal data (hereinafter referred to as "Correction, etc.") from the person or his/her representative, we will investigate without delay and take appropriate measures based on the results. Please contact the "Personal Information Inquiry Desk" below to make a request for correction, etc. We will inform you of the procedures to be taken after we receive your request.

Suspension of Use or Deletion of Personal Data

If you or your representative request us to stop using or erase your personal data (hereinafter referred to as "stop using, etc."), we will stop using or erase your personal data and notify you of the reason for such a request. If the person or his/her representative requests the suspension of use or deletion of personal data (hereinafter referred to as "Suspension of Use, etc.") and the request is found to be reasonable, we will take appropriate measures. If the Suspension of Use, etc. is not carried out, the Company will promptly notify the customer to that effect. Please contact the "Personal Information Inquiry Desk" below to make a request for suspension of use, etc. We will inform you of the procedure after we receive your request.

Cookies

Cookies are a mechanism that identifies the computer used by the customer and records data on the hard drive of the customer's computer with the information selected by the customer in order to make the customer's visit to our website more convenient, for example, when the customer revisits the website. Cookies do not identify individual customers.
Browsers are initially set up to accept cookies. You can also set your browser to reject cookies, so please check your browser settings.
We use cookies on our site for the following purposes

• Storing the information you have registered on My Page
• Storing the contents of your postings
• To manage your login session
• To improve our services by understanding the number of times you visit our site and how you use it

In order to improve the quality of our services, we use analytical and marketing tools such as Google Analytics to measure our services, including our website. Based on the cookies we issue, Google collects, records, and analyzes the history of your visits to our sites. We may use this information to provide you with our services, including to understand how you use them. For an explanation of Google's privacy policy, please visit the following sites
Google Analytics Terms of Use
Google's Privacy Policy
Google Analytics opt-out add-on

The services of the external service providers we use and the locations of such providers are as follows If you wish to refuse to send or receive cookies or to stop receiving information from certain advertising services, please visit the sites of the following companies and follow the prescribed opt-out procedures.

• Meta Platforms, Inc.
• Google LLC (California, U.S.A.)
• Yahoo Japan Corporation (Japan)
• Twitter, Inc.

Our company, along with affiliated third-party companies, may utilize cookies and similar technologies to send information to users' browsers via our web services and websites. If your browser settings allow the acceptance of cookies and similar technologies, browsing history and related data may be associated with them.
Rest assured that our company will strictly use this collected information within the specified purposes outlined in our privacy policy. In accordance with the provisions stated in section "8. Provision of Personal Data to Third Parties," we may share cookie information and associated data with third-party companies. These third-party companies will handle the use of cookie information in accordance with their respective privacy policies. Please visit the websites of each company for detailed information on the major third-party companies and their privacy policies.

• Google
https://policies.google.com/privacy?hl=en
• Facebook
https://www.facebook.com/privacy/explanation
• Instagram
https://privacycenter.instagram.com/policy
• LINE
https://line.me/en/terms/policy/
• Twitter
https://help.twitter.com/en/rules-and-policies/twitter-cookies

Access Log

When a customer accesses our website, information on the operation is recorded in the form of an access log. This log does not contain information that can identify individuals, but is collected for the purpose of improving the convenience of our site in the future, tracking down the cause of any problems that may occur, and processing statistics and analysis regarding usage conditions, and will not be used for any other purpose.

Links to third-party websites

The Company is not responsible for the handling of personal information on third-party websites linked to the Company's website. When using such websites, please use them at your own risk after checking their privacy policies, etc.

Protection of Personal Information by Displaying SSL

The Company's website uses SSL (Secure Socket Layer) encryption technology on screens where personal information must be entered when submitting forms, to ensure that personal information is not transmitted in an unprotected state. SSL (Secure Socket Layer) is an Internet encryption technology recommended by credit card companies. With a compatible browser, you can check the encrypted message in real time, so you can transmit your personal information with peace of mind. However, we do not guarantee the security of this service, and we will not be held responsible in the event of data leakage or other accidents that occur through no fault of ours.

Compliance with Laws and Regulations and Revision of this Privacy Policy

We will comply with Japanese laws and other standards applicable to personal information in our possession, and will review our handling of personal information from time to time in an effort to continually improve our privacy policy. In the event of any changes to this Privacy Policy, the Company shall publicly announce such changes by posting a notice on the Service's website or by any other method deemed appropriate by the Company. If you use the Service after the date specified in the revised Privacy Policy, you will be deemed to have agreed to the revised Privacy Policy, except in cases where the revised Privacy Policy is denied by law or regulation.

Person Responsible for Personal Information

Yaesu Ichigaya Bldg. 10F, 2-17 Ichigaya-Tamachi, Shinjuku-ku, Tokyo
BORDERLESS JAPAN Co.
Person Responsible for Personal Information Protection

Contact for Inquiries

If you have any questions, please contact us by phone or mail for inquiries about the various services we provide and our handling of personal information.

BORDERLESS HOUSE K.K.
Representative Director: Seiichi Lee
Address: Yaesu Ichigaya Bldg. 10F, 2-17 Ichigaya-Tamachi, Shinjuku-ku, Tokyo 162-0843, Japan
TEL：03-5227-8320

(First edition) April 1, 2022
BORDERLESS HOUSE K.K.
Representative Director: Seiichi Lee