Privacy Policy

neew, Inc. (the "Company") establishes this Privacy Policy (the "Policy") regarding the handling of personal information of users of our services (the "Users"), builds systems to protect personal information, and promotes protection of personal information by making all employees recognize its importance.

## Article 1 (Personal Information)

"Personal information" means "personal information" as defined in the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003, the "APPI"), and refers to information about a living individual that can identify a specific person by name, date of birth, or other descriptions contained in the information, or that includes a personal identification code.

## Article 2 (Purpose of Use of Personal Information)

The Company acquires and uses Users' personal information to the extent necessary for the following purposes. If we use personal information beyond these purposes, we will obtain the User's consent in advance by an appropriate method.

(1) To provide services necessary for use of the matching app "GALAXIA" (the "App")

(2) To improve and enhance the content of the App

(3) To provide information on new features, updates, campaigns, and other services offered by the Company (including sending email, flyers, and other direct mail)

(4) To contact Users as necessary for maintenance and important notices

(5) To respond to opinions and inquiries from Users regarding the App (including identity verification)

(6) To report to Users on usage of the App

(7) To request cooperation with surveys and interviews regarding the App and to report results

(8) To investigate and analyze usage history and use the results for improvement, development, and advertising of the App

(9) To provide personal information to participating companies of Company-hosted events based on the User's consent or application

(10) To identify Users who violate the Terms of Use or who attempt to use the App for improper purposes and to refuse their use

## Article 3 (Management and Protection of Personal Information)

We manage personal information strictly and will not disclose or provide data to third parties without the User's consent except in the cases listed below. We also implement measures to prevent and correct risks such as unauthorized access, loss, destruction, alteration, and leakage of personal information.

(1) When necessary to protect a person's life, body, or property and obtaining consent is difficult

(2) When particularly necessary for improving public health or promoting the sound growth of children and obtaining consent is difficult

(3) When necessary to cooperate with a national or local government body in performing duties prescribed by law and obtaining consent may impede performance of those duties

(4) Other cases permitted by law

## Article 4 (Outsourcing of Handling of Personal Information)

The Company may outsource all or part of the handling of personal data to the extent necessary to achieve the purpose of use. In such cases, we will carefully evaluate the suitability of the contractor, stipulate confidentiality obligations in contracts, and provide necessary and appropriate supervision.

## Article 5 (Disclosure of Personal Information)

When a User (limited to the person concerned) requests disclosure of personal information held by the Company, we will disclose it without delay. However, we may not disclose all or part of the information if disclosure would fall under any of the following, and if we decide not to disclose, we will notify the User without delay.

(1) When there is a risk of harm to the life, body, property, or other rights or interests of the User or a third party

(2) When there is a risk of significant hindrance to the proper conduct of our business

(3) When it would violate other laws and regulations

## Article 6 (Correction of Retained Personal Data)

1. If personal information held by the Company is incorrect, the User may request correction, addition, or deletion ("Correction") of such personal information.

2. Upon receiving such a request, we will conduct necessary investigation without delay and, if we determine there are grounds for the request, perform Correction without delay.

3. We will notify the User without delay of whether Correction was performed or not based on the above.

## Article 7 (Suspension of Use, etc.)

1. The User may request suspension of use, erasure, or suspension of provision to third parties ("Suspension of Use") of personal data held by the Company.

2. Upon receiving such a request, we will conduct necessary investigation without delay and, if we determine there are grounds for the request, perform Suspension of Use. However, if Suspension of Use requires excessive cost or is otherwise difficult, we may take alternative measures necessary to protect the User's rights and interests.

3. We will notify the User without delay of whether Suspension of Use was performed or not based on the above.

## Article 8 (Procedure for Changing This Policy)

We will review the content of this Policy from time to time and strive to improve it. Unless otherwise provided by law or this Policy, we may change the content of this Policy. The revised Privacy Policy shall take effect when we notify Users by a method designated by the Company or when it is posted on our website.

## Article 9 (Compliance with Laws and Standards)

The Company complies with Japanese laws and other norms applicable to personal information we hold.

## Article 10 (Response to Complaints and Consultations)

We accept and respond appropriately and promptly to complaints and consultations from Users regarding the handling of personal information. We also respond promptly and appropriately to requests for disclosure, correction, addition, deletion, or refusal of use or provision of such personal information.

## Article 11 (Security Control Measures)

Personal information entrusted to us by Users is protected against unauthorized access, loss, destruction, alteration, and leakage through organizational, physical, human, and technical measures, including access restrictions to personal information files, recording of access logs, and security measures against unauthorized external access. If an incident such as leakage of Users' personal information occurs, we will promptly report to supervisory authorities in accordance with the APPI and related guidelines and take necessary measures such as prevention of similar cases and recurrence prevention in accordance with instructions from such authorities.

## Article 12 (Contact)

For inquiries regarding our handling of personal information, please contact:

Company: neew Inc. / neew LLC (合同会社 neew)

Business: Application services, events

Offices:

- New York: 580 Fifth Avenue, Suite 820, New York, NY 10036
- Tokyo: 3F Roppongi Mikawadai Building Square, 4-2-14 Roppongi, Minato-ku, Tokyo 106-0032, Japan

E-mail: info.galaxia.app@gmail.com

Established and enforced: July 15, 2024