Privacy Policy

Recognizing the importance of personal information and the need to protect it, we comply with Japan's Act on the Protection of Personal Information, provisions of the Telecommunications Business Act concerning the secrecy of communications, other applicable laws and regulations, the guidelines on personal information protection in the telecommunications business, and this Privacy Policy in all handling of customers' personal information.

When you use our services, including this website, you will be deemed to have agreed to this Privacy Policy.

We may ask you to register personal information when you use services provided on this website.

We use personal information we obtain for the following purposes: • Responding to your opinions and inquiries • Operating, providing, and informing you about our services and events, and conducting surveys • Improving, analyzing, and developing our services • Achieving other purposes disclosed when we obtain your personal information

We will specify and disclose in advance, to the extent possible, any purposes of use not covered above.

We handle personal information only to the extent necessary to achieve purposes of use specified and disclosed in advance. We may exceed that scope without your consent (excluding information concerning the secrecy of communications) where: required by law; necessary to protect life, body, or property and consent is difficult to obtain; particularly necessary to improve public health or promote the sound development of children and consent is difficult to obtain; or cooperation with a national or local government body or its delegate is necessary and obtaining consent could impede its duties.

We may use your personal information to inform you about services and other offerings from our affiliates and business partners.

We may change a purpose of use when reasonably considered related to the previous purpose. We will notify you or publish the changed purpose on our website.

We handle information obtained by lawful and fair means. Depending on its content, some information may not constitute personal information, but we take due care in handling all customer information. Information includes: • Information obtained through application forms, web screens, or verbally to provide services. Calls may be recorded to confirm inquiry details and improve services. • Information obtained when you use our services, including access information collected using cookies, web beacons, or advertising identifiers and information collected automatically by our systems. We may combine this access information with personal information we hold. • Information obtained by inquiry to public authorities • Information obtained from published sources such as official gazettes • Information obtained from credit information agencies • Other information lawfully obtained from third parties, including through referrals

We obtain your consent when acquiring sensitive personal information defined by law.

We set retention periods within the scope necessary for the purposes of use and promptly delete personal information after the period expires or the purpose is achieved. This does not apply when retention is required by law or the individual has consented.

We may continue to use personal information within the scope of the purposes of use after contracts with you have ended.

We endeavor to keep personal information accurate and up to date and take necessary and appropriate security measures to protect it from unauthorized access, alteration, leakage, loss, or damage.

Our technical measures include: • Restricting access rights, monitoring access and retaining logs, regularly changing passwords, and managing facility entry and exit • Restricting ways information may be taken out, including prohibiting unnecessary use of external media and monitoring internal and external email in accordance with company rules • Preventing unauthorized external access, including through firewalls

We appropriately supervise employees to ensure the security of personal information and provide necessary training to ensure its proper handling.

We may outsource all or part of personal information handling within the scope of the purposes of use, including sales and reception, billing, and marketing. We select contractors that handle information appropriately, stipulate security, confidentiality, subcontracting conditions, and other relevant matters in our contracts, and provide necessary and appropriate supervision.

We outsource personal information management to ByteIQ Analytics Pvt Ltd (India). The contractor uses data centers in India provided by Amazon Web Services (AWS) to store personal information. We require appropriate security measures by contract and conduct regular checks.

We do not provide your personal information to third parties without your consent, except where required by law; necessary to protect life, body, or property and consent is difficult to obtain; particularly necessary to improve public health or promote the sound development of children and consent is difficult to obtain; or necessary to cooperate with a national or local government body or its delegate where consent could impede its duties.

When providing personal information to a third party in a foreign country, we take necessary measures, including obtaining consent, in accordance with applicable laws.

When creating anonymously processed information, we take necessary measures to prevent identification of individuals and restoration of the personal information used to create it.

We do not compare anonymously processed information with other information for the purpose of re-identifying an individual.

When creating anonymously processed information, we disclose the personal data items it contains as required by law.

When providing anonymously processed information to a third party, we publish its data items and method of provision as required by law and inform the recipient that it is anonymously processed information.

We respond without delay to requests to disclose personal information, except where this may harm the rights or interests of the individual or a third party, significantly impede our proper business operations, or violate law.

When asked to correct, add, or delete personal information, suspend its use, or stop its provision to third parties, we investigate without delay and promptly respond if we find it inaccurate, retained beyond its retention period, or otherwise improperly handled.

We promptly notify you of purposes of use upon request, except where the purpose is already clear, notification may harm rights or interests, may harm our legitimate interests, or may impede cooperation with a public body's statutory duties.

We respond promptly and appropriately to complaints and other inquiries about our handling of personal information.

Requests and inquiries under this article may be directed to: POGLI Co., Ltd. (inquiry contact) Phone: 080-1372-9288 (weekdays, 9:00–17:45) Email: info@p-icube.com

If a personal information leak or similar incident occurs, we promptly notify you of the facts and take appropriate measures, including reporting to the Personal Information Protection Commission as required by law.

We continuously improve our handling of personal information through internal rules, employee training, and internal audits.

If we change this Privacy Policy, we publish the revised policy on our website. You will be deemed to have agreed to the revised policy when you first use this website after publication.

This Policy is governed by and construed in accordance with the laws of Japan.

The Kyoto District Court in Japan has exclusive agreed jurisdiction as the court of first instance for disputes concerning this Policy.