[Important] Release of 4Login App Ver. 5.5.0 (iOS / Android) and Notice of Revisions to the Terms of Service and Privacy Policy

4Login Terms of Service

Article 1 (Definitions)

For the purposes of these Terms of Service, the following terms shall have the meanings set forth below:

(1) “Company” means Passlogy Co., Ltd., the provider of the Service.

(2) “User” means any individual or legal entity that has agreed to these Terms of Service and has applied to use the Service in accordance with the procedures prescribed by the Company.

(3) “Website” means the website operated by the Company at https://www.4login.jp/en/.

(4) “Application” means the mobile application named “4Login” for smartphones and other mobile devices, operated by the Company.

(5) “Family Products” means all derivative products, software, browser extensions, and other products provided by the Company that operate in conjunction with the Application, including, but not limited to, the Cryptan series, Windows Login Enhancement Software, trial versions provided to Development Supporters, and any similar products.

(6) “Service” means the collective term for all services related to 4Login provided by the Company, including the 4Login authentication platform, the Application, the Website, the Family Products, and any related services.

(7) “Pattern” means the sequence and positions of four (4) selected cells out of the twenty-five (25) cells displayed within the Application, which is registered by the User during the registration process or subsequently modified by the User for the purpose of identifying the User.

(8) “User Information” means the User’s email address, Pattern, and any other information registered by the User for the purpose of using the Service.

(9) “Personal Information” means any information relating to an identified or identifiable User, including information that can readily be matched with other information to identify a specific User.

(10) “User Attribute Information” means information relating to the User’s use of the Service, including services used, products purchased, web pages viewed, times of use, methods of use, and usage environment, excluding Personal Information.

(11) “Partner Site” means any website, system, application, or other platform that has partnered with the Company and has implemented functions provided by the Service.

Article 2 (Application of these Terms)

These Terms of Service apply to all Users and govern the application for, access to, and use of the Service from the time of application through the entire period during which the User uses the Service.

Article 3 (Application for the Service, Commencement of the Service, and Service Availability)

(1) The Company shall accept applications for the Service in accordance with the procedures separately prescribed by the Company. Upon completion of any necessary review or screening, if the Company approves an application, it shall notify the applicant, by the method designated by the Company, that the applicant may use the Service. Upon receipt of such notification, the Company’s acceptance of the application shall become effective, the applicant shall become a User of the Service, and a service agreement incorporating these Terms of Service (the “Agreement”) shall be formed between the User and the Company. In order to use the Service, the User must register the User’s own email address. The Service shall commence when the User’s first registered email address has been successfully verified and the User’s registration has been completed.

(2) The Service is intended to be available twenty-four (24) hours a day, three hundred sixty-five (365) days a year. However, the Company may temporarily suspend or interrupt the Service without prior notice to the User for reasons including, but not limited to, updates or modifications to the Service or its content, system maintenance, failures or outages of equipment or communication lines, power outages, natural disasters, security measures, or any other unavoidable circumstances. The User acknowledges and agrees that the Service is provided subject to such limitations.

(3) If the User is a minor, the User must obtain the consent of a parent or other legal guardian before using the Service.

Article 4 (Disclaimer of Liability)

(1) The Company shall not be liable to the User or any third party for any delay in or failure to perform all or any part of these Terms of Service caused by force majeure, including, but not limited to, natural disasters, war, riots, civil disturbances, significant and unforeseen changes in economic conditions, enactment, amendment or repeal of laws and regulations, governmental orders, labor disputes such as strikes, transportation accidents, suspension of services by telecommunications providers, failures or malfunctions of external cloud services used by the Company, or any other events beyond the reasonable control of the Company.

(2) If the User causes any loss, damage, or dispute involving another User or any third party through the use of the Service, the User shall resolve such matter at the User’s own responsibility and expense. The Company shall bear no liability in connection therewith.

(3) The Company shall not be liable for any loss, corruption, or destruction of data stored on servers managed by the Company pursuant to Article 15, Paragraph (1), and makes no warranty with respect thereto.

(4) If the agreement between the Company and the User under these Terms of Service constitutes a consumer contract as defined in Article 2, Paragraph (3) of the Consumer Contract Act of Japan (Act No. 61 of 2000), any provision that completely exempts the Company from liability shall not apply. Where the Company is liable for damages arising from breach of contract or tort under such consumer contract, except in cases of the Company’s willful misconduct or gross negligence, the Company’s liability shall be limited to the direct and actual damages suffered by the User, up to the total amount of fees paid by the User for the Service during the preceding twelve (12) months. The Company shall not be liable for any indirect, incidental, consequential, special, or similar damages, including damages arising from special circumstances, regardless of whether such damages were foreseen or foreseeable.

(5) The Company does not warrant that emails, content, or other data transmitted from the Company’s websites, servers, domains, or other systems are free from computer viruses or other harmful components.

(6) The Company may, from time to time, provide the User with information, guidance, or advice regarding the Service; however, the Company shall not be liable for any consequences arising from such information, guidance, or advice.

(7) The Company does not warrant that any cryptographic technology, authentication technology, or cryptographic algorithms implemented in the Application or any Family Product, including, without limitation, post-quantum cryptography, will remain secure against decryption, compromise, or other successful attacks indefinitely in the future.

Article 5 (Equipment and Environment Required for Use of the Service)

The User shall, at the User’s own expense and responsibility, procure, maintain, and manage all communication devices (including smartphones, personal computers, and other necessary equipment) and the environment required to use the Service. The Company shall not be liable for any inability to use, interruption of, or delay in the use of the Service resulting from any malfunction, failure, or inadequacy of such communication devices or environment.

Article 6 (Grant of License to Use the Application)

The Company grants the User a non-exclusive license to download and use the Application on the User’s smartphone or other compatible mobile device, subject to the terms and conditions set forth in these Terms of Service. The Company does not warrant that the Application will be compatible with or operate on all mobile devices.

Article 7 (Scope of License to Use the Application)

(1) The Application may be used solely by the User for the User’s own internal purposes. If the User is a legal entity, the Application may be used only by its officers or employees. The User shall not use the Application for any other purpose, including, without limitation, sale, distribution, or software development.

(2) The User shall use the Application only in the form provided by the Company and shall not copy, reproduce, modify, alter, adapt, or create derivative works of the Application (including any and all programs related thereto), nor disclose any part thereof to any third party.

(3) If the User’s registration is cancelled pursuant to Article 13 or Article 14, or if the User withdraws from the Service, the User shall uninstall the Application from all of the User’s devices at the User’s own responsibility.

(4) In addition to these Terms of Service, the use of each Family Product shall be subject to any separate terms of service, license agreement, or other rules established by the Company for the applicable Family Product. In the event of any inconsistency or conflict between these Terms of Service and such separate terms or rules, the separate terms or rules applicable to the relevant Family Product shall prevail unless otherwise expressly provided.

Article 8 (Management of User Login Credentials)

The User shall be solely responsible for the management and security of the User’s login credentials, including the User’s login information, Pattern, and password. If the User becomes aware of any unauthorized use of the User’s login credentials, Pattern, or password, the User shall promptly notify the Company.
The Company shall not be liable for any loss or damage arising from the User’s failure to properly manage such credentials, any misuse by the User, or any unauthorized use by a third party.

Article 9 (Prohibited Conduct)

In using the Service, the User shall not engage in any of the following acts:

(1) Violating any applicable laws, regulations, or these Terms of Service.

(2) Infringing upon or otherwise harming the rights, interests, reputation, or other legitimate interests of the Company or any third party.

(3) Transmitting, posting, or distributing any harmful computer programs, malicious code, emails, or other harmful content.

(4) Gaining unauthorized access to the Company’s servers or other computer systems, using methods or operating procedures that have not been officially disclosed, or using the Website, the Application, or any other part of the Service by any means other than those expressly permitted under these Terms of Service, including, without limitation, the use of another person’s login credentials or password.

(5) Copying, reproducing, transmitting, republishing, distributing, sublicensing, or otherwise providing to any third party all or any part of the information provided through the Service without the prior authorization of the Company.

(6) Reverse engineering, decompiling, or disassembling the Application.

(7) Renting, leasing, lending, assigning, transferring, or otherwise making the Application available to any third party.

Article 10 (Handling of User Information)

(1) The Company shall handle the User’s Personal Information in accordance with the Company’s Privacy Policy, available at: URL : https://www.4login.jp/en/privacy-policy/

(2) The Company may use User Information for the following purposes:

(i) To provide information regarding feature additions, updates, specification changes, maintenance, important notices, and other communications relating to the Service.

(ii) To respond to inquiries, requests, and other communications from the User, including the use of inquiry details and User Attribute Information where necessary.

(iii) To prepare statistical data by aggregating and analyzing Personal Information provided in connection with the Service in a manner that does not identify any individual.

(iv) To improve the Service and to develop new products, services, and features.

(v) To customize the content and presentation of the Service based on the User’s registered Personal Information, User Attribute Information, and other information relating to the User’s use of the Service.

(vi) To facilitate the User’s input of information when registering Partner Sites within the Application or when using Family Products. For this purpose, the Application or Family Products may display the User’s registered email address or other Personal Information in input fields. In addition, upon the User’s instruction, the Company may transfer the User’s email address or other necessary information to a Partner Site.

(3) The Company shall not disclose or provide the User’s Personal Information to any third party without the User’s prior consent, except as otherwise permitted by applicable law. The Company shall not use User Information beyond the scope necessary for providing the Service, user authentication, or the decryption of encrypted data. If the Company intends to use User Information for sending advertisements or for any other unrelated purpose, the Company shall obtain the User’s separate consent in advance.

(4) Notwithstanding the foregoing, if the Company is required by a court order or other lawful request to disclose User data, the Company may provide User Information to the relevant authority or third party to the minimum extent necessary without obtaining the User’s prior consent.

Article 11 (Paid Services)

The Service includes both free services and paid services. Users of the free services may access and use certain features of the paid services.

Article 12 (Fees for Use of the Service)

(1) The fees for the Paid Services shall be as specified within the Service, including on the Website, or by any other means designated by the Company.

(2) The Company may revise the fees for the Paid Services without obtaining the prior consent of Users of the Paid Services by providing notice in a manner designated by the Company at least one (1) month prior to the effective date of such revision. Any such revision shall apply prospectively only.

(3) If a User does not agree to the revised fees, the Company shall have no obligation to continue providing the Service to such User. If the User does not complete the cancellation procedures by the applicable deadline and continues to use the Paid Services after the revised fees become effective, the User shall be deemed to have accepted the revised fees.

(4) Fees for the Paid Services shall be paid using the payment methods designated by the Company.

(5) Except where a refund is required due to the Company’s willful misconduct or negligence, the Company shall not refund any fees or other amounts already received. If the User cancels the Paid Services before the end of the applicable subscription period, any fees already paid shall not be refunded, and no pro rata adjustment or partial refund shall be made.

(6) If the User does not complete the cancellation procedures by the prescribed date and time, the subscription period may be automatically renewed in accordance with the conditions specified by the Company.

Article 13 (Termination)

(1) A User may terminate the User’s use of the Service by completing the termination procedures prescribed by the Company.

(2) If a User loses eligibility to use the 4Login Application, the User will no longer be able to use not only the 4Login Application itself, but also any functions provided through the Service by all Family Products and Partner Sites that are associated with or integrated with the 4Login Application.

(3) IMPORTANT: Before completing the termination procedures, the User shall, at the User’s own responsibility, decrypt any data encrypted using the Family Products and back up any data the User wishes to retain. The Company shall not be liable for the inability to decrypt encrypted data, the loss of any data resulting from termination, or any restoration of such data, nor shall the Company be liable for any damages arising therefrom.

(4) Upon termination, the User shall lose all rights to use the Service and shall have no right to make any claim against the Company, including, without limitation, any claim for a refund of fees already paid for the Paid Services.

Article 14 (Suspension or Termination of User Eligibility)

The Company may, without prior notice, suspend a User’s access to the Service or terminate the User’s eligibility to use the Service if the Company determines that the User falls under any of the following circumstances. The Company shall not be liable for any loss or damage incurred by the User as a result of any action taken by the Company under this Article.

(1) The User violates any applicable laws or regulations, these Terms of Service, or any separate terms of service, license agreements, guidelines, or other rules applicable to any Family Product, trial version, or other related service.

(2) The User engages in any fraudulent, unlawful, or otherwise improper conduct in connection with the use of the Service.

(3) The User delays, fails, or refuses to pay any fees for the Paid Services or any support contributions under the Development Supporter Program.

(4) The User has not used the Service for a period of six (6) consecutive months or more from the date of the User’s last use of the Service. However, this shall not apply to Users who have subscribed to the Paid Services and continue to make the required payments.

(5) The User engages in any conduct that the Company reasonably determines to materially impair the purpose of the Service, including, without limitation, development support activities or community management.

(6) The User is determined to be:

(i) a member of, or affiliated with, any organized crime group, organized crime group member, former organized crime group member, organized crime group affiliate, corporate extortionist (sokaiya), organization advocating violence, special intelligence violent group, or any other anti-social force as defined under the laws of Japan;

(ii) a person or entity that provides funding or other support to any such anti-social force;

or

(iii) a person or entity designated under any economic sanctions or terrorist sanctions list established by Japan, the United States, the United Kingdom, the European Union, or any other relevant country or international organization.

(7) The Company otherwise reasonably determines that the User’s continued use of the Service is inappropriate.

Article 15 (Use and Deletion of Data)

(1) The User acknowledges and agrees that User Information, User Attribute Information, and all other information generated or stored through the User’s use of the Service (including any external services integrated with the Service) (collectively, the “Data”) may be stored on the User’s communication devices or on servers managed by the Company.

(2) The Company may anonymize or aggregate Data generated through the User’s use of the Service, including information registered by the User and User Attribute Information, in such a manner that no individual can be identified, and may provide such anonymized or aggregated information to third parties.

(3) If the User terminates the Service pursuant to Article 13 or the User’s registration is terminated pursuant to Article 14, the Company shall promptly delete all Data stored on servers managed by the Company within a reasonable period. Notwithstanding the foregoing, the Company may retain such Data where retention is required by applicable law or where temporary retention is necessary for system administration purposes, including backup data. The User acknowledges and agrees to such retention.

Article 16 (Modification or Discontinuation of the Service)

(1) The Company may, at its sole discretion, modify or discontinue all or any part of the Service at any time. If such modification or discontinuation is not in the general interest of Users, the Company shall provide notice to the Users by a method designated by the Company at least one (1) month prior to the effective date of such modification or discontinuation.

(2) If a User does not agree to the modified Service, the Company shall have no obligation to continue providing the Service to such User. If the User continues to use the Service after the modification becomes effective, the User shall be deemed to have accepted the modified Service.

Article 17 (Amendments to these Terms of Service)

(1) The Company may amend all or any part of these Terms of Service from time to time. If any such amendment is not in the general interest of Users, the Company shall provide notice to the Users by a method designated by the Company at least one (1) month prior to the effective date of the amendment.

(2) If a User does not agree to the amended Terms of Service, the Company shall have no obligation to continue providing the Service to such User. If the User continues to use the Service after the amended Terms of Service become effective, the User shall be deemed to have accepted and agreed to be bound by the amended Terms of Service.

Article 18 (Notices)

(1) Unless otherwise specified, communications between the Company and the User, including notices, invoices, requests, and other communications from the Company, shall be made by email. Notices shall be sent to the User’s email address registered at the time of the User’s application for the Service. The User may update the registered email address at any time in accordance with the procedures prescribed by the Company.

(2) The Company may send information relating to the Service, including the information described in Article 10, Paragraph (2), Item (i), to the User’s registered email address. The User consents to receiving such communications to the extent permitted under applicable laws and regulations, including the data protection laws of the relevant country or region.

(3) If the User fails to update the registered email address referred to in Paragraph (1), any notice sent by the Company to the registered email address shall be deemed to have been duly delivered upon transmission. Except in cases of the Company’s willful misconduct or gross negligence, the Company shall not be liable for any loss or damage arising from the User’s failure to update the registered email address.

Article 19 (Non-Assignment and Confidentiality)

The User shall not assign, transfer, delegate, pledge, or otherwise dispose of the User’s status under this Agreement or any of the User’s rights or obligations hereunder to any third party without the prior written consent of the Company.
The User shall keep confidential all confidential or proprietary business information of the Company obtained through this Agreement and shall not disclose or use such information for any purpose other than as permitted under this Agreement without the prior written consent of the Company.

Article 20 (Intellectual Property Rights)

(1) All patents, copyrights, and other intellectual property rights relating to the functions of the Service, the software implementing such functions, the content of the Website, content, user manuals, these Terms of Service, and any other materials associated with the Service shall belong to the Company or the legitimate rights holders who have granted the Company the right to use such intellectual property. Except as expressly provided in these Terms of Service, nothing in this Agreement shall be construed as granting the User, whether expressly, by implication, estoppel, or otherwise, any right, title, license, or interest in or to the Company’s or such rights holders’ intellectual property.

(2) All intellectual property rights in any data created by the User through the use of the Application or any Family Product shall remain vested in the User.

(3) By commencing use of the Service, the User shall be deemed to have acknowledged and agreed to the provisions of this Article.

Article 21 (No Waiver and Severability)

(1) No failure or delay by the Company in exercising any right or remedy under these Terms of Service shall constitute or be deemed a waiver of such right or remedy.

(2) If any provision of these Terms of Service is held to be invalid, illegal, or unenforceable in any jurisdiction, such provision shall be ineffective only to the extent of such invalidity, illegality, or unenforceability in that jurisdiction, and the remaining provisions of these Terms of Service shall remain in full force and effect.

Article 22 (Entire Agreement)

This Agreement constitutes the entire agreement between the Company and the User with respect to the subject matter hereof and supersedes all prior negotiations, discussions, understandings, representations, promises, and agreements, whether written or communicated by email.

Article 23 (Language)

Translations of these Terms of Service, the Privacy Policy, and all other documents relating to or associated with the Service are provided solely for convenience. The Terms of Service, the Privacy Policy, all other agreements and documents between the Company and the User, and any additional terms applicable to the Paid Services shall be governed by and construed in accordance with the Japanese-language versions.

Article 24 (Governing Law and Jurisdiction)

These Terms of Service (including any separate terms of service, guidelines, or other rules relating to the Service provided by the Company; hereinafter collectively referred to as the “Terms” for the purposes of this Article) shall be governed by and construed in accordance with the laws of Japan.
The User and the Company agree that the Tokyo District Court of Japan shall have exclusive jurisdiction as the court of first instance over any dispute arising out of or in connection with these Terms.
Notwithstanding the foregoing, if the mandatory laws of the country or region in which the User resides (including applicable consumer protection laws) provide otherwise, nothing in this Article shall restrict the User’s right to bring legal proceedings before the competent court of the User’s place of residence to the extent required by such mandatory laws.

Article 25 (Export Control)

(1) The User shall comply with the Foreign Exchange and Foreign Trade Act of Japan and all applicable export control laws and regulations of other relevant jurisdictions when using the Service, including any software and technology provided as part of the Service.

(2) The User shall not, directly or indirectly, export, re-export, transfer, or otherwise provide the Service to any non-resident or any other person without obtaining any licenses, approvals, or authorizations required by the Government of Japan or any other applicable governmental authority.

(3) The Company does not warrant that the use of the Service outside Japan complies with the laws and regulations of the applicable jurisdiction, including, without limitation, cryptographic regulations, data protection laws, or import and export control laws. The User shall be solely responsible for confirming and complying with all applicable local laws and regulations.

(4) The Company shall not be liable for any disputes with governmental authorities, penalties, losses, damages, or other liabilities arising from the User’s use of the Service outside Japan. The User shall resolve any such matters at the User’s own expense and responsibility.

Supplementary provisions:

These Terms of Service shall come into effect on October 24, 2014.

Established: October 10, 2014.

Revised: April 10, 2015.

Revised: April 1, 2020.

Revised: March 30, 2022.

Revised: October 26, 2026

4Login Privacy Policy

Passlogy Co., Ltd. (hereinafter referred to as the “Company”) establishes this Privacy Policy (hereinafter referred to as this “Policy”) as follows in order to appropriately handle information relating to users that the Company obtains in connection with 4Login, the 4Login app, 4Login My Page, Development Supporter, Cryptan, and other 4Login-related services provided by the Company, as well as websites, applications, and other services related thereto (collectively, the “Services”).

Article 1 (Scope and Definitions)

1. This Policy applies to the handling of information relating to users in connection with the Services.

2. In this Policy, the terms “Personal Information,” “Personal Data,” and “Retained Personal Data” shall have the meanings set forth in the Act on the Protection of Personal Information of Japan.

3. In this Policy, “User Information, etc.” means Personal Information as well as service usage information, log information, device information, IP addresses, cookies, and other information relating to users that the Company obtains or manages in connection with the provision of the Services.

Article 2 (User Information, etc. We Collect)

1. In providing the Services, the Company may collect the following User Information, etc.

(1) Information provided by users

– Email addresses and other account registration information

– Information registered or entered by users in the Services

– Registration status for Development Supporter and other services

– Information concerning contracts, applications, purchases, payments, and payment status

– Details of inquiries, consultations, reports, and other communications with the Company

– Other information provided by users to the Company in connection with their use of the Services

(2) Information collected through the use of the Services

– Information concerning authentication, including whether authentication was successful and the date and time of authentication

– Dates and times of use of the Services, functions used, login history, operation history, and other usage information

– Source IP addresses

– Browser type and version

– Device type, operating system, application version, and other device-related information

– Cookies, device identifiers, and other similar identifying information

– Error information, failure information, and security-related logs

– Other information necessary for the provision, operation, and security of the Services

(3) Information obtained from external services

If a user chooses to link the Services with an external service, the Company may obtain from such external service information necessary for the linkage with the Services, based on the user’s consent or the user’s settings in such external service.

Article 3 (Purposes of Use)

1. The Company uses the User Information, etc. it collects for the following purposes:

(1) To provide, operate, and maintain the Services

(2) To verify users’ identities, authenticate users, and manage user accounts

(3) To confirm users’ registration status, contract status, and eligibility to use the Services

(4) To bill users for the Services and manage payments and payment status

(5) To notify users, by email or other means, of additional functions, updates, maintenance, important notices, and other information relating to the Services

(6) To respond to inquiries, consultations, reports, and other communications from users

(7) To maintain the Services and respond to failures and maintenance requirements

(8) To investigate, prevent, and address unauthorized access, unauthorized use, impersonation, phishing, malware distribution, spam, and other illegal or improper activities

(9) To ensure the security of the Services and protect the rights and interests of users and third parties

(10) To aggregate and analyze the usage of the Services

(11) To improve the Services and to plan, research, and develop new functions, products, and services

(12) With the user’s consent, to provide information regarding the Company’s products and services, campaigns, events, advertisements, and other information by email or other means

(13) To respond to conduct that violates this Policy or the terms of use applicable to the Services

(14) To comply with applicable laws and regulations, contracts, or lawful requests from public authorities

(15) Based on the user’s instructions, consent, or settings in an external service, to link the Services with such external service and to send and receive information necessary for such linkage

(16) For other purposes disclosed at the time the User Information, etc. is collected

2. When providing information under Paragraph 1, Item (12) above, the Company will obtain the user’s consent in advance. Users may request at any time that such communications be discontinued in accordance with the procedures prescribed by the Company. However, this shall not apply to notices necessary for the operation of the Services as provided in Paragraph 1, Item (5) above.

Article 4 (Use of Cookies and Similar Technologies)

1. The Company may use cookies and similar technologies for the purposes of providing the Services, maintaining login status, ensuring security, understanding usage, and improving the Services.

2. If the Company uses third-party access analytics services or other external services, details concerning the information transmitted externally, the recipients of such information, the purposes of use, and other relevant matters will be separately disclosed through the Services or on the Company’s website.

Article 5 (Management of User Information, etc. and Security Measures)

1. The Company implements organizational, personnel, physical, and technical security measures to prevent the leakage, loss, or damage of User Information, etc. and otherwise ensure its secure management.

2. Details of such security measures will be provided upon request by a user, except for information whose disclosure may interfere with the secure management of information.

Article 6 (Provision to Third Parties)

1. The Company will not provide Personal Data to any third party unless the user has given consent or such provision is otherwise permitted under the Act on the Protection of Personal Information or other applicable laws and regulations.

2. If the Company provides Personal Data to a third party located outside Japan, the Company will take necessary measures, including providing information to the user and obtaining the user’s consent, in accordance with applicable laws and regulations.

Article 7 (Outsourcing the Handling of User Information, etc.)

1. The Company may outsource all or part of the handling of User Information, etc. to external service providers to the extent necessary to achieve the purposes of use set forth in Article 3. In such cases, the Company will appropriately select such service providers and exercise necessary and appropriate supervision over them.

Article 8 (Handling of User Information, etc. Outside Japan)

1. User Information, etc. may be stored, processed, or accessed outside Japan by providers of cloud services or other external services used by the Company, or by their subcontractors.

2. When handling Personal Data outside Japan, the Company will ascertain the personal information protection systems and other external circumstances in the relevant country or region and implement necessary and appropriate security measures in accordance with applicable laws and regulations.

3. The names of the relevant countries and details of the measures implemented will be provided upon request by a user, except for information whose disclosure may interfere with the secure management of information.

Article 9 (Retention Period)

1. The Company retains User Information, etc. for the period necessary to achieve the purposes of use set forth in Article 3. When such information is no longer required to be retained, the Company will delete or dispose of it securely in accordance with applicable laws and regulations or the Company’s internal rules.

Article 10 (Requests Concerning Retained Personal Data)

1. In accordance with applicable laws and regulations, an individual may make the following requests to the Company concerning Retained Personal Data by which the individual can be identified:

(1) Notification of the purpose of use

(2) Disclosure of Retained Personal Data

(3) Correction, addition, or deletion

(4) Suspension of use or erasure

(5) Suspension of provision to third parties

(6) Disclosure of records of provision to third parties

2. To make any of the above requests, please contact the inquiry desk specified in Article 12. After confirming the identity of the individual making the request or the individual’s authorized representative, the Company will respond without delay in accordance with applicable laws and regulations.

3. If the Company does not comply with a request pursuant to applicable laws and regulations, the Company will notify the individual accordingly.

Article 11 (Amendments to this Policy)

1. The Company may amend this Policy as necessary due to amendments to laws and regulations, changes to the Services, or other circumstances. The amended Policy and its effective date will be announced by posting them on the Company’s website or by other appropriate means.

Article 12 (Company Information and Contact Information)

1. For inquiries or complaints regarding the Company’s handling of User Information, etc., or for requests under Article 10, please contact the following:

Passlogy Co., Ltd.

Takii Tokyo Building 7F

1-6-1 Kandajimbocho, Chiyoda

Tokyo 101-0051, Japan

For the name of the Company’s representative and other corporate information, please refer to the following page:

https://www.passlogy.com/corporate/profile

Contact Us:

https://www.4login.jp/contacts/

The Japanese version of this Policy is the authoritative version. In the event of any discrepancy or inconsistency between the Japanese and English versions, the Japanese version shall prevail.

Revised: October 26, 2026