SumMatch Privacy Policy

This is a reference translation of the Japanese original (“SumMatch プライバシーポリシー”). In the event of any discrepancy between this English translation and the Japanese original, the Japanese original shall prevail.

In providing SumMatch (hereinafter referred to as the “Service”), Ohte, Inc. (hereinafter referred to as the “Company”) may obtain personal information from users. Recognizing the importance of the personal information obtained from users and its social responsibility to protect such information, the Company will handle it appropriately in accordance with the following basic policy.

Article 1 Basic Policy

1. In this Privacy Policy, “personal information” means information about a living individual that falls under either of the following items.
   • ① Information that can identify a specific individual by the name, date of birth, or other description, etc. contained in the information (meaning all matters stated or recorded in, or expressed by voice, movement, or any other method in, a document, drawing, or electromagnetic record (meaning a record made in an electromagnetic form (an electronic form, magnetic form, or any other form that cannot be perceived by human senses)), excluding individual identification codes; the same shall apply hereinafter), including information that can be readily collated with other information and thereby identify a specific individual
   • ② Information containing an individual identification code (as defined in Article 2, Paragraph 2 of the Act on the Protection of Personal Information (個人情報の保護に関する法律))
2. The Company shall take appropriate measures to ensure that personal information is not handled beyond the scope necessary to achieve the specified purposes of use.
3. The Company shall comply with laws and regulations, national guidelines, and other norms concerning the handling of personal information.
4. By taking necessary and appropriate security measures, the Company shall endeavor to prevent and rectify the leakage, loss, or damage of the personal information it handles.
5. The Company shall accept and appropriately respond to complaints and consultations from individuals regarding the handling of personal information and the Company’s personal information protection management system.
6. The Company shall endeavor to continuously improve its personal information protection management system, including this Privacy Policy.

Article 2 Acquisition of Personal Information, etc.

1. In providing the Service, the Company acquires the following information. The Company will appropriately manage information about application users obtained through the Service in accordance with this Privacy Policy.
   • ① The application user’s unique ID (a unique ID of the smartphone device or a unique ID assigned to the installed application), for delivering advertisements optimized for the application user
   • ② Information related to the application user’s use of the Service (location information, application operation information, launch time, hang rate, energy usage, etc.), for considering improvements to the Service and delivering advertisements optimized for the application user
   • ③ The email address required for account registration, for responding to inquiries and restoring game data
   • ④ Information required for processing purchases of paid items and the like and for handling payments
2. The Company shall not acquire personal information by deception or other wrongful means. In addition, except in the following cases, the Company shall not, without obtaining the prior consent of the individual, acquire personal information containing a description, etc. specified by cabinet order as requiring special care in its handling so as to prevent unjust discrimination, prejudice, or other disadvantage to the individual, such as the individual’s race, creed, social status, medical history, criminal record, or the fact of having suffered harm from a crime (hereinafter referred to as “special care-required personal information”).
   • ① Where based on laws and regulations
   • ② Where necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of the individual
   • ③ Where particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the individual
   • ④ Where it is necessary to cooperate with a national government body, a local government, or a party entrusted by either of them in performing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the performance of those affairs
   • ⑤ Where the special care-required personal information in question has been made public by the individual, a national government body, a local government, a party listed in the items of Article 76, Paragraph 1 of the Act on the Protection of Personal Information (個人情報の保護に関する法律), or another party specified by rules of the Personal Information Protection Commission
   • ⑥ Any other case specified by cabinet order as equivalent to the cases listed in the preceding items

Article 3 Indication of the Purposes of Use of Personal Information

The Company acquires personal information within the scope necessary to achieve the purposes of use, after notifying the individual of those purposes in writing or by a method equivalent thereto, or after publicly announcing them. However, this shall not apply in the following cases.

1. Where notifying the individual of, or publicly announcing, the purposes of use is likely to harm the life, body, property, or other rights or interests of the individual or a third party
2. Where notifying the individual of, or publicly announcing, the purposes of use is likely to harm the rights or legitimate interests of the Company
3. Where it is necessary to cooperate with a national government body or a local government in performing affairs prescribed by laws and regulations, and notifying the individual of, or publicly announcing, the purposes of use is likely to impede the performance of those affairs
4. Where the purposes of use are found to be clear in light of the circumstances of acquisition

Article 4 Use of Personal Information

1. The personal information acquired by the Company shall be used solely for the following purposes.
   • ① Understanding usage conditions relating to the Service, responding to inquiries, and providing and conducting surveys and interviews for the improvement of the Service
   • ② Processing purchases of paid items and the like, handling payments, and managing usage history
   • ③ Delivering advertisements matching users’ interests
   • ④ Account registration for data restoration in the event of a device change or data loss
2. In addition to the cases in the preceding paragraph, the Company shall not use personal information beyond the scope of the purposes of use without obtaining the consent of the individual. Even where the Company has acquired personal information as a result of a merger or other reason, the Company shall not use the personal information beyond the purposes of use prior to the succession without obtaining the consent of the individual. However, this shall not apply in the following cases.
   • ① Where based on laws and regulations
   • ② Where necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of the individual
   • ③ Where particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the individual
   • ④ Where it is necessary to cooperate with a national government body, a local government, or a party entrusted by either of them in performing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the performance of those affairs

Article 5 Disclosure of Personal Information to Third Parties

The Company shall not disclose or provide personal information to any third party other than the Company, except where any of the following applies or where otherwise specifically provided in this Privacy Policy.

1. Where the user has given consent
2. Where based on laws and regulations
3. Where necessary for the protection of the life, body, or property of a person and it is difficult to obtain the customer’s consent
4. Where necessary for the operation of the Service (including provision to businesses to which payment processing for paid items and the like is entrusted)
5. Where the information is provided in a state in which an individual user cannot be specified or identified (including provision to internet advertising businesses for the purpose of delivering advertisements to application users)

Article 6 Analysis of Traffic Data

For the operation and analysis of services and systems that improve the convenience of the Service, the Company uses technology that identifies the usage conditions of the same user by means of a unique ID. This technology acquires traffic data between the application and the server and uses data that has been statistically processed so that individuals cannot be identified for the purpose of analysis.

Article 7 Changes to the Purposes of Use of Personal Information

Where the Company changes the purposes of use of personal information, it shall not do so beyond the scope reasonably deemed to have a substantial relevance to the purposes of use prior to the change, and shall notify the individual of, or publicly announce, the changed purposes of use in writing or by a method equivalent thereto.

Article 8 Security Control Measures

Deeply recognizing that personal information is subject to risks of unauthorized access, loss, destruction, falsification, leakage, and the like, the Company shall take reasonable security measures.

Article 9 Supervision of Contractors

Where the Company entrusts all or part of the handling of personal information, it shall select a party with a sufficient level of personal information protection, conclude a contract including confidentiality obligations with the contractor in order to ensure the protection of personal information, and exercise necessary and appropriate supervision so that security control of personal information is achieved at the contractor.

Article 10 Joint Use of Personal Information

In order to efficiently provide comprehensive services in an integrated manner in internet advertising and various businesses, and in order to strengthen the security of its services, the Company jointly uses personal information with the companies listed in (2) below, limited to the scope necessary to achieve the purposes of use in (3) below. The details of the joint use are as follows.

1. The items of personal information jointly used shall be information relating to individuals, such as name, gender, date of birth, address, telephone number, fax number, and email address, as well as information relating to contracts.
2. The jointly using companies shall be i-mobile Co., Ltd. and Cyber Consultant Inc., which are group companies of the Company.
3. The purposes of use by the joint users shall be: ① development, improvement, research, and security enhancement of the various services operated by the jointly using companies; ② introduction and proposal of the various services operated by the jointly using companies; and ③ provision of the personal information in question to third parties in connection with the provision of a service where the various services operated by the jointly using companies themselves contain personal information.
4. The company responsible for the joint use shall be the Company.

Article 11 Publication of Matters Relating to Personal Information

1. The Company shall keep the purposes of use of personal information in a state accessible to the individual.
2. Where an individual requests notification of the purposes of use of personal information, the Company shall notify the individual thereof without delay. However, this shall not apply where any of the following applies.
   • ① Where the purposes of use of personal information are clear under the provisions of (1) above
   • ② Where notifying the individual of, or publicly announcing, the purposes of use is likely to harm the life, body, property, or other rights or interests of the individual or a third party
   • ③ Where notifying the individual of, or publicly announcing, the purposes of use is likely to harm the rights or legitimate interests of the Company
   • ④ Where it is necessary to cooperate with a national government body or a local government in performing affairs prescribed by laws and regulations, and notifying the individual of, or publicly announcing, the purposes of use is likely to impede the performance of those affairs
3. Where the Company decides not to notify the purposes of use of personal information requested under the provisions of 2 above, it shall notify the individual to that effect without delay.

Article 12 Disclosure of Personal Information

Where an individual requests disclosure of personal information, the Company shall disclose it to the individual without delay. However, where disclosure would fall under any of the following, the Company may withhold all or part of the disclosure, and where it decides not to disclose, it shall notify the individual to that effect without delay.

1. Where disclosure is likely to harm the life, body, property, or other rights or interests of the individual or a third party
2. Where disclosure is likely to seriously impede the proper execution of the Company’s business
3. Where disclosure would violate laws or regulations other than the Act on the Protection of Personal Information

Article 13 Correction of Personal Information

Where an individual requests correction, addition, or deletion of the content of personal information (hereinafter referred to as “correction, etc.”) on the grounds that the personal information is not factual, the Company shall, except where special procedures for such correction, etc. are prescribed by laws or regulations other than the Act on the Protection of Personal Information, conduct the necessary investigation without delay within the scope necessary to achieve the purposes of use, and, based on the results thereof, carry out correction, etc. of the content of the personal information. In addition, where the Company has carried out correction, etc. of all or part of the content of personal information, or has decided not to carry out correction, etc., it shall notify the individual to that effect (including the content thereof where correction, etc. has been carried out) without delay.

Article 14 Suspension of Use of Personal Information

1. Where an individual requests the suspension of use or the erasure of personal information (hereinafter referred to as “suspension of use, etc.”) on the grounds that the individual’s personal information is being handled in violation of Article 2 or Article 4 of this Privacy Policy, and it is found that the request has grounds, the Company shall carry out the suspension of use, etc. of the personal information without delay. However, this shall not apply where the suspension of use, etc. of the personal information in question would require a large expense or would otherwise be difficult, and the Company takes alternative measures necessary to protect the rights and interests of the individual.
2. Where an individual requests the suspension of provision of personal information to a third party on the grounds that the individual’s personal information is being provided to a third party in violation of Article 10 of this Privacy Policy, and it is found that the request has grounds, the Company shall suspend the provision of the personal information in question to third parties without delay. However, this shall not apply where the suspension of provision of the personal information in question to third parties would require a large expense or would otherwise be difficult, and the Company takes alternative measures necessary to protect the rights and interests of the individual.
3. Where the Company, under the provisions of 1 above, has carried out suspension of use, etc. of all or part of personal information or has decided not to carry out suspension of use, etc., or where the Company, under the provisions of 2 above, has suspended provision of all or part of personal information to third parties or has decided not to suspend such provision, it shall notify the individual to that effect without delay.

Article 15 Explanation of Reasons

Where, under the provisions of Article 11, Paragraph 2, Article 12, Article 13, and Article 14, Paragraph 3 of this Privacy Policy, the Company notifies an individual that it will not take all or part of the measures requested by the individual, or that it will take measures different from those requested, the Company shall endeavor to explain the reasons therefor to the individual.

Article 16 Cookie Information

1. In operating the various services it provides, the Company may acquire and utilize cookie information. To disable the Company’s acquisition of cookie information, please opt out in accordance with the instructions on the web pages of the respective services.
2. The Company may use advertisements delivered by third parties, including LY Corporation, and in connection therewith, such third parties may acquire and use cookie information and the like of users who have visited the Company’s sites. Cookie information and the like acquired by such third parties is handled in accordance with the privacy policy of that third party. Users may access the opt-out page provided on the website of the third party in question to stop the use of cookie information and the like by that third party for advertising delivery.

• The privacy policy and opt-out page of LY Corporation are as follows.

• LY Corporation Privacy Policy: https://www.lycorp.co.jp/ja/company/privacypolicy/

• LY Corporation Behavioral Targeting Advertising Opt-Out Page: https://btoptout.yahoo.co.jp/optout/index.html

Article 17 Inquiries Regarding Personal Information

For inquiries and the like regarding the handling of personal information, please contact us at the address below.

Ohte, Inc. info@ohte.co.jp

(Supplementary Provisions)

This Privacy Policy shall take effect as of June 1, 2026.