PRIVACY POLICY

Last Modified: Dec 20, 2024

PRIVACY POLICY

Leifras Co., Ltd. ("Company," "we," "us," or "our") respects your privacy and understands that you care about your personal data and how it is used.
We value your trust in sharing your personal data with us and are dedicated to protecting your privacy, as further described in this Privacy Policy.

1. SCOPE

This Privacy Policy ("Policy") applies to personal data about users of our websites (the "Services") collected by the Company or by third parties on our behalf. This Privacy Policy describes in detail the types of data we collect about you; how we use your data and with whom we share it; the choices and rights you have with regard to your data; how we protect your data; and how you can contact us about our privacy practices.

The Services are intended for a general audience and are not targeted to children under 16 years of age. In addition, please review our Terms of Use which governs your use of the Services.

2. DATA WE COLLECT AND OBTAIN

We obtain personal data about you from the following sources:

Data you provide to us through the Services. When you submit inquiries or correspond with us, we may collect:
- Contact information (such as name, postal address, email address and telephone numbers, including business contact details where applicable);
- Other information you may provide to us through our contact features, including our "Contact Us" form.

Data Collected by Automated Means Through Our Services. We also gather by automated means (such as cookies, web beacons, web server logs, JavaScript and other similar technologies) certain information through our Services, including:

- Your Internet Protocol (IP) address
- Device information, including unique identifiers and connection information, including mobile device advertising IDs (e.g., Apple's IDFA or Google's AAID) and the means of internet connection (e.g., WiFi connection, ISP) that can identify the physical location of such devices, in accordance with applicable law
- Your device type and settings, software used, browser type and operating system
- Language preferences
- Websites or other services you visited before and after visiting the Services (referring URL)
- Web pages you view and links you click on within the Services
- Viewing behavior, including the content you view and how long you view it
- Dates and times you access or use the Services
- Location information, including the city, state and zip code associated with your IP Address, information derived through WiFi triangulation

For more information on the various types of automated means we use to gather personal data, please see our Cookie Policy.

3. HOW WE USE THE INFORMATION WE OBTAIN

We, or service providers acting on our behalf, may use the personal data collected from and about you to:

- Respond to your inquiries
- Provide technical support
- Protect against and prevent fraud, unauthorized transactions, and other liabilities
- Comply with applicable legal requirements and our policies
- Operate, evaluate and improve our business (including developing, analyzing and improving our Services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions)
- Anonymize or de-identify personal data to conduct data analysis and prepare aggregated data reports
- Respond to inquiries from law enforcement authorities or other government officials if required by law
- Process and evaluate business-related applications, including employment applications
- Manage our information technology systems and ensure the security of our networks
- Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies
- Send business-related communications, including:
• Service updates and technical notifications
• Information about our business services and solutions
• Relevant industry updates and white papers
• Event invitations and webinar announcements
- In other ways for which we provide specific notice at the time of collection

The data retention period and specific use of your information will vary depending on the business purpose for which it was collected. We retain personal data only for as long as necessary to fulfill the stated purposes for which it was collected or as required by applicable laws or regulations.

4. INFORMATION WE SHARE

We may share your information with the following third parties:

Our Subsidiaries and Affiliated Businesses
We may share information within our family of companies to deliver and improve our services, consistent with this Privacy Policy. Such sharing will be governed by appropriate confidentiality requirements.

Third Parties for Legal Requirements and Proceedings
We may disclose information to law enforcement authorities or other government officials when:
- Required by law, subpoena, or court order
- Necessary to comply with legal obligations
- Relevant to an investigation of suspected or actual fraudulent or illegal activity

Third Parties for the Protection of our Services and Users
We may disclose information to:
- Protect and defend our rights, interests, and safety
- Protect our users, employees, and contractors
- Prevent physical harm or financial loss
- Maintain the security of our services

Third Parties in Business Transfers
We may disclose information in connection with corporate transactions, including:
- Mergers and acquisitions
- Sale of assets
- Reorganization
- Bankruptcy or liquidation

Service Providers
We may share information with:
- Internet service providers for service delivery
- Data analytics providers to improve our operations
- Technology service providers who support our systems

Non-personal Data
We may share non-personal, de-identified, or aggregated information with third parties for business purposes, provided such information does not identify any individual.

All sharing of information is conducted in accordance with applicable data protection laws and appropriate security measures.

5. YOUR CHOICES AND RIGHTS

We offer you certain choices and rights in connection with the personal data we collect about you.

A. YOUR CHOICES

You can choose to use our Services without providing any information about yourself to us directly, but please note, as described above, some personal data may be collected automatically or be requested by us so that you can take advantage of certain features of the Services.

To request removal of your personal data from our business communications lists, please contact us as outlined in the How to Contact Us Section below.

You can also unsubscribe from our communications by following the "Unsubscribe" link in our emails.

Cookies and Analytics
- You have choices about cookies and similar technologies on your devices
- We use analytics services (such as Google Analytics) to improve our Services
- To opt out of Google Analytics, visit: https://tools.google.com/dlpage/gaoptout
- For more information about cookies, visit our Cookie Policy

B. YOUR RIGHTS

Subject to applicable law, you have the following rights regarding your personal data:

1. Access and Rectification Rights
- Access your personal data
- Correct and update your information
- If you have an account, access and update through that account

2. Deletion Rights
- Request deletion of your personal data
- We will respond in accordance with legal requirements
- Some data may be exempt if needed for service provision
- Deleting certain data may affect your ability to use our Services
3. Data Portability Rights
- Receive your data in a structured, machine-readable format
- Transmit data to another entity
- Request direct transmission where technically feasible

4. Identity Verification
- We may request verification of identity for security
- Authorized agents may act on your behalf with proper documentation

Response Process
We will respond to your requests as follows:
- Verify your identity (and your agent, if applicable)
- Process your request according to applicable laws
- Notify you of any limitations or exemptions that apply
- Provide our response within legally required timeframes

Note: Some rights may be limited by:
- Legal requirements
- Technical capabilities
- Service operational needs
- Data retention obligations

For detailed information about exercising these rights or understanding any limitations, please contact us using the information provided in the How to Contact Us section.

C.CALIFORNIA PRIVACY RIGHTS

For additional information for residents of the State of California click here.

6. HOW WE PROTECT PERSONAL DATA

We maintain administrative, technical and physical safeguards designed to protect the personal data we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no data transmission or storage, or use of the Internet, can be guaranteed to be 100% secure.

7. TRANSFERS OF PERSONAL DATA

The Services are hosted in and managed from Japan or the country in which we engage service providers. We may transfer the personal data we collect about you to another country, which may not have the same data protection laws as the country in which you initially provided the data. Applicable laws in Japan and/or other countries may allow the courts, law enforcement and national security authorities to access your personal data when in such country.

If you are a user located outside Japan or the country to which your information may be transferred, you understand (and, as permitted under applicable law, consent to) having any personal data processed in Japan and/or such country. When we transfer your data, we will protect that data as described in this Privacy Policy

8. LINKS TO THIRD-PARTY SITES, APPS AND SERVICES

For your convenience and information, our Services may provide links to third-party sites, apps and services that may be operated by companies not affiliated with us. These companies may have their own Privacy Notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any third-party sites, apps or services.

9. CHANGES TO OUR PRIVACY POLICY

From time to time, we may change our Privacy Policy to reflect changes to our privacy practices and Services. If we modify the Privacy Policy, we will update the "Last Modified Date" and the changes will be effective as of the date we post such Policy. For material changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Privacy Policy when it was most recently updated.

10. HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or the manner in which we or our service providers treat your personal data, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us at:

Email: privacy@leifras.co.jp

Last Modified: December 20, 2024

CCPA

FOR CALIFORNIA RESIDENTS
CALIFORNIA PRIVACY RIGHTS

A. CALIFORNIA SHINE THE LIGHT LAW

Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us at privacy@leifras.co.jp.

For all such requests, please indicate "CA Shine the Light" in the subject field of your request and include the name of the Service with respect to which you are requesting the information. You must also include your full name, street address, city, state, zip code and email address.

B. CALIFORNIA CONSUMER PRIVACY ACT RIGHTS

The California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA") provide certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California ("California Resident") and uses our Services in a business context. This notice supplements the information in the Privacy Policy. Certain terms used below have the meanings given to them in the CCPA and CPRA. The CCPA and CPRA shall be collectively referred to herein as the "CPRA."

The following sets forth the categories of information we collect and purposes for which we may use California Residents' personal information:

1. Categories of Personal Information We Collect and Process

In the past 12 months, we have collected:

A. Identifiers and Contact Information

- Name, email address, postal address, telephone numbers
- Company information and professional title
- Unique identifiers (device ID, cookies, IP address, username, password)

B. Commercial and Transaction Information

- Service inquiries and correspondence
- Transaction data and history
- Service delivery information

C. Technical and Internet Activity Data

- IP address and device information
- Browser type and settings
- Operating system and software used
- Website interaction and service utilization patterns
- Cookies and similar technologies

D. Geolocation Information

- City, state, and zip code associated with IP address
- Information derived through WiFi triangulation
- Precise location data (when authorized through device settings)

E. Professional and Profile Information

- Employment-related information
- Professional relationship details
- Preferences and characteristics
- Behavioral patterns and tendencies

F. Inference Data

- Preferences and interests
- Professional characteristics and behaviors
- Service usage patterns and preferences

2. How We Use Business Personal Information

We use this information for:
- Providing our business services
- Managing business relationships
- Security and fraud prevention
- Legal compliance
- Internal business operations
- Service improvement and development

3. Your California Privacy Rights

As a California resident, you have the right to:
- Know what business information we collect and how we use it
- Access your business personal information
- Request deletion of your business information (subject to exceptions)
- Opt-out of personal information sales (although we do not sell business information)
- Non-discrimination for exercising your rights

4. How to Exercise Your Rights

You may exercise these rights by:
- Emailing: privacy@leifras.co.jp

For all requests, we will:
- Verify your identity
- Confirm your California residency
- Respond within required timeframes
- Document our response process

5. Business Data Retention

We retain business information for:
- Active business relationships: Duration of the relationship
- Completed transactions: As required by law or business needs
- Technical data: 13 months
- Internal business records: Up to 6 years

6. Verification Process

To protect your information, we will:
- Verify your identity before processing requests
- Require additional documentation for authorized agents
- Confirm business relationship status

Important Notice Regarding Exemptions:

Under California law, certain exemptions may apply to personal information processed in the context of business-to-business transactions and communications. Some information may be exempt from certain CCPA requests when:

- It is necessary to maintain our business relationship
- It is required to comply with legal or regulatory obligations

These exemptions help ensure the continuity of business operations while protecting privacy rights in accordance with applicable laws.