Privacy policy

This English translation is provided for reference purposes only. If there is any discrepancy between this translation and the original Japanese text, the Japanese text shall prevail.

Clabo Inc. (hereinafter referred to as the "Company") recognizes the protection of customers' personal information as an important management responsibility in connection with the website and various services operated by the Company (hereinafter referred to as the "Services"), and hereby establishes this Privacy Policy (hereinafter referred to as this "Policy") in compliance with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act") and other related laws, regulations, and guidelines.

Article 1. Definition of Personal Information

The terms used in this Policy are defined as follows.

1. "Personal Information" means information relating to a living individual as defined in Article 2, Paragraph 1 of the Personal Information Protection Act, that can identify a specific individual by name, email address, address, telephone number, or other description, etc. (including information that can be readily collated with other information, thereby enabling the identification of a specific individual), or information that contains an individual identification code.
2. "Special Care-Required Personal Information" means personal information as defined in Article 2, Paragraph 3 of the Personal Information Protection Act, which includes descriptions concerning a person's race, creed, social status, medical history, criminal record, facts of having suffered damage by a crime, or other descriptions designated by cabinet order as requiring special care in handling so as not to cause unfair discrimination, prejudice, or other disadvantages to the person concerned.
3. "Personal Related Information" means information relating to a living individual as defined in Article 2, Paragraph 7 of the Personal Information Protection Act, that does not fall under personal information, pseudonymized personal information, or anonymized personal information (e.g., Cookie IDs, browsing history, purchase history, etc.).

Article 2. Method of Collecting Personal Information

The Company may collect personal information by the following lawful and fair means.

• Entries via inquiry forms, document request forms, etc.
• Contact by email or chat
• Account registration information when using the Services
• Automatic collection of usage data through cookies or access analysis tools
• Collection through the exchange of business cards, etc.

The Company will not collect Special Care-Required Personal Information without obtaining the prior consent of the person concerned.

Article 3. Purpose of Use of Personal Information

The Company will use the collected personal information within the scope of the following purposes.

1. To provide, operate, and improve the Services
2. To respond to inquiries, contact, and other correspondence
3. To distribute email newsletters, notices, guidance, etc. (limited to customers who have requested them)
4. To conduct and contact customers regarding surveys, campaigns, etc.
5. To analyze usage of the Services and improve the user experience
6. To create statistical data for the planning and development of new services
7. To prevent unauthorized use and to investigate and respond to troubles
8. To respond to violations of the Terms of Use
9. To respond in accordance with laws and regulations

When changing the purpose of use, the Company will do so only within a scope reasonably deemed to be related to the purpose before the change, and will notify customers of, or publicly announce, the purpose of use after the change.

Article 4. Provision of Personal Information to Third Parties

Except in the following cases, the Company will not provide personal information to third parties without obtaining the prior consent of the person concerned.

1. Where required by law
2. Where necessary to protect the life, body, or property of a person, and it is difficult to obtain the consent of the person concerned
3. Where particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the person concerned
4. Where it is necessary to cooperate with a national government agency, a local government, or a person entrusted by either of them in executing affairs prescribed by laws and regulations, and obtaining the consent of the person concerned is likely to impede the execution of the affairs concerned

Provision to Outsourcing Contractors

The Company may outsource all or part of the handling of personal information to external parties to the extent necessary to achieve the purpose of use (e.g., email delivery services, server maintenance providers, cloud service providers, etc.). In such cases, the Company will exercise necessary and appropriate supervision over the outsourcing contractor regarding the security management of personal information.

Provision of Personal Related Information to Third Parties

When the Company provides Personal Related Information (such as cookie information) to a third party in cases where it is anticipated that the recipient will acquire such information as personal data, the Company will confirm in advance that the consent of the person concerned has been obtained.

Article 5. Security Control Measures

To prevent the leakage, loss, or damage of personal information it handles and to otherwise ensure security control, the Company implements the following measures.

1. Organizational Security Control Measures: Appointment of a personal information protection manager, establishment of handling regulations, and recording and inspection of the handling status
2. Human Security Control Measures: Regular education and training for employees, and clear statement of confidentiality obligations in employment regulations, etc.
3. Physical Security Control Measures: Management of areas where personal information is handled, measures to prevent theft of equipment and electronic media, and appropriate measures upon disposal
4. Technical Security Control Measures: Access control, identification and authentication of persons accessing information, measures to prevent unauthorized external access, and measures to prevent leakage arising from the use of information systems

Article 6. Cookies and External Transmission

6.1 Use of Cookies

The Company's website may use cookies to improve convenience and to analyze access status. A cookie is a small data file sent from a web server to your browser.

6.2 External Transmission (Disclosure Pursuant to Article 27-12 of the Telecommunications Business Act)

The Company's website uses the following external services, through which information is transmitted from your device to external parties.

6.3 Management of Cookies

You may use your browser settings to refuse to accept cookies or to display a warning when cookies are to be accepted. However, if cookies are disabled, some functions of the Services may not operate correctly.

Article 7. Disclosure of Matters Concerning Retained Personal Data

Pursuant to Article 32 of the Personal Information Protection Act, the Company discloses the following matters concerning the retained personal data it holds.

1. Name of the personal information handling business operator: Clabo Inc.
2. Personal information protection manager: Ikuma Ueno, Representative Director [ACTION REQUIRED (TO BE CONFIRMED)]: Please update if a different person is responsible.
3. Purpose of use of all retained personal data: As stated in Article 3 of this Policy
4. Measures taken for the security control of retained personal data: As stated in Article 5 of this Policy
5. Procedures for requesting disclosure, etc.: As stated in Article 8 of this Policy
6. Contact for complaints: As stated in Article 11 of this Policy
7. Accredited personal information protection organization: [ACTION REQUIRED (TO BE CONFIRMED)]: If the Company is a member, state the name of the organization and the complaint handling contact. If not a member, state "Not applicable."

Article 8. Disclosure, Correction, Deletion, etc. of Personal Information

Customers themselves may make the following requests to the Company pursuant to the provisions of the Personal Information Protection Act.

1. Notification of the purpose of use of retained personal data
2. Disclosure of retained personal data
3. Correction, addition, or deletion of retained personal data
4. Suspension of use or erasure of retained personal data
5. Suspension of provision of retained personal data to third parties

Request Procedures

• Contact for requests: Clabo Inc. Personal Information Inquiry Desk (info@clabo-inc.co.jp)
• Method of request: [ACTION REQUIRED (TO BE CONFIRMED)]: State the prescribed method of submitting the request form.
• Identity verification: When making a request, you may be required to present documentation (driver's license, passport, etc.) to verify your identity.
• Fee: A fee of [ACTION REQUIRED (TO BE CONFIRMED): AMOUNT] per request will be charged for requests for notification of the purpose of use and for disclosure.
• Method of response: In principle, the Company will respond by mail or email. You may also request that the response be provided in electromagnetic record form.

Article 9. Personal Information of Minors

When the Company collects personal information from a minor (a person under 18 years of age), it will endeavor to do so only after obtaining the consent of the minor's parent or guardian. If a parent or guardian wishes to confirm or delete the personal information of their minor child, please contact the inquiry desk set forth in Article 11.

Article 10. External Links

The Company's website may contain links to external sites operated by third parties. The Company is not responsible for the handling of personal information on such external sites. When using an external site, please review that site's own privacy policy.

Article 11. Inquiry Desk

Inquiries, complaints, and requests for disclosure of personal information, etc. regarding this Policy should be directed to the following.

• Business operator name: Clabo Inc.
• Address: Ark Hills South Tower 16F, 1-4-5 Roppongi, Minato-ku, Tokyo 106-0032, Japan
• Representative: Ikuma Ueno, Representative Director
• Personal information protection manager: Ikuma Ueno, Representative Director
• Email address: info@clabo-inc.co.jp
• Inquiry form: https://www.clabo-inc.co.jp/company/contact

Article 12. Changes to this Privacy Policy

The Company may change the content of this Policy as necessary due to changes in laws and regulations, changes in business content, or other reasons. When making an important change, the Company will notify customers by announcement on this website or by other appropriate means. The revised Policy will take effect from the time it is posted on this website.

Established: February 19, 2026

Last revised: February 19, 2026 Clabo Inc.