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Privacy Policy

User Information to be Acquired

The Company may acquire from the user(s) (the “User(s)) the following information (the “User Information”):

Purpose of Use of User Information

The Company uses User information for the following purpose:

Third Party Provision

The Company will not provide any information collected from the Users that constitutes personal data (Article 2, Paragraph (6) of Act on the Protection of Personal Information) to any third party (including anyone outside Japan) without obtaining in advance the Users’ consent. However, this shall not apply in the following cases:

Access Analysis Tools

The Company uses "Google Analytics" to analyze the User’s access. Google Analytics uses cookies to collect traffic data. Traffic data is collected anonymously and is not personally identifiable. By disabling cookies, the User can refuse collection of these information. Please check your browser settings for details. To learn more about Google Analytics, visit: https://marketingplatform.google.com/about/analytics/terms/jp/

Distribution of Advertisements

Anonymously Processed Information

The Company may produce and use anonymously processed information (this means those set forth in Article 2, paragraph (9) of Act on the Protection of Personal Information, and limited to those constituting anonymously processed information database etc. set forth in Article 2, paragraph (10) of the said Act) by using information acquired from the Users. In such case, the Company will take actions as required by Act on the Protection of Personal Information.

Amendment to Privacy Policy

The Company will amend this Privacy Policy as necessary. In such case, the Company will announce or notify, in an appropriate manner, the timing when the amended Privacy Policy will be enforced and the contents thereof.

Contact Information

If you wish to disclose, correct, suspend use of or delete your information, please contact us at the following email address.

info@gen-ltd.jp

In such a case, we will confirm that such request was made by the person himself/herself, by asking such person to present his/her driver's license or by other means designated by the Company. Requests for disclosure of information, whether such information will be disclosed or not, are subject to a processing fee of 1,000 yen per case at the time of application.

Company name

GEN Ltd.

Prescribed on

December 20, 2024


Privacy Policy (For EU residents)

Users to Whom the Privacy Policy Applies

This Privacy Policy applies to the handling of personal data (Article 4(1) of the General Data Protection Regulation 2016/679 (the “GDPR”)) of the users who use the services of the Company (defined as below) from EU, Iceland, Liechtenstein, and Norway (hereinafter collectively referred to as "EU")

User Personal Data to be Collected

The Company may collect from the user(s) (the “User(s)) the following personal data (the “User Personal Data”):

Purpose of Use of the User Personal Data

The Company uses the User Personal Data collected from the User for the following purposes, on the legal bases including legitimate interests (Article 6(1)(d) of the GDPR), performance of contractual obligations (Article 6(1)(b) of the GDPR), the User’s consent (Article 6(1)(a) of the GDPR) or compliance with legal obligations in EU and its member states (Article 6(1)(c) of the GDPR):

When processing is required for the pursuit of legitimate interests (Article 6(1)(d) of the GDPR)

When processing is required for the performance of contractual obligations to provide the Services to the User(Article 6(1)(b) of the GDPR)

When the User’s express consent is obtained in advance (Article 6(1)(a) of the GDPR)

To deal with any act which violates the laws and regulations of EU and its member states which applies to the Company(Article 6(1)(c) of the GDPR)

Transfer of the User Personal Data to Japan

The Company will transfer the User Personal Data to Japan for the purposes of fulfilling any contractual obligations with the User or any pre-contractual procedures requested by the User. Japan has been accredited by the European Commission for the protection of personal data.

Retention Period

The Company will retain the User Personal Data for as long as necessary to fulfill the purposes for obtaining and processing the User Personal Data as set out in this Privacy Policy. Specific retention periods are decided by taking into account the purposes for obtaining and processing the User Personal Data, the nature of the User Personal Data and the necessity of retaining the personal data for legal or business reasons.

User’s Rights

The User has the right under the GDPR to obtain information regarding processing of the User Personal Data, to access the User Personal Data, to request corrections to or deletion of the User Personal Data, to restrict the processing of the User Personal data, to data portability, to be free from automated decision-making (including profiling) and to object to the processing of the User Personal Data. In addition, if the User is dissatisfied with the processing of the User Personal Data, the User may lodge a complaint with the Data Protection Supervisory Authority of the User’s country of residence, place of workplace or place of the alleged infringement.

Withdrawal of Consent

The User may withdraw its consent to the Company’s use of the User Personal Data at any time by the means otherwise specified by the Company at the time the Company obtaining the User’s consent. However, the legality of any action taken based on the User’s consent prior to the withdrawal is not affected by the User’s withdrawal of consent.

Automated Decision-making

The Company does not make decisions solely based on automated data processing that produces any legal or similar material effect on the User.

Amendment to Privacy Policy

The Company will amend this Privacy Policy as necessary. In such case, the Company will announce or notify, in an appropriate manner, the timing when the amended Privacy Policy will be enforced and the contents thereof.

Contact Information

If you have any question regarding this Privacy Policy, please contact the data administrator at:

GEN Ltd.

7F, N&E BLD., 1-12-4 Ginza, Chuo-ku, Tokyo, 104-0061, Japan

info@gen-ltd.jp

Prescribed on December 20, 2024