Privacy Policy

Established: March 4, 2026

This English version is a reference translation. In the event of any discrepancy between the Japanese original and this English translation, the Japanese version shall prevail.

Japan Financial Elan Technologies, Inc. (hereinafter "the Company") establishes the following Privacy Policy (hereinafter "this Policy") regarding the handling of personal information that the Company acquires (referring to "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter the "Personal Information Protection Act"), meaning information about a living individual that can identify a specific individual through name, date of birth, or other description contained in such information, or that contains an individual identification code).

1. Basic Policy on the Handling of Personal Information

• We will comply with internal rules that prescribe the appropriate acquisition, use, and provision of personal information in consideration of the nature and scale of our business.
• We will take measures to prevent the leakage, loss, or damage of personal information, and in the unlikely event of an incident, we will promptly implement corrective measures.
• We will comply with laws, regulations, national guidelines, and other norms regarding the handling of personal information.
• We will respond sincerely and promptly to complaints and consultations regarding personal information from customers.
• We will continuously improve our personal information management framework.

2. Acquisition of Personal Information

The Company acquires personal information from customers through lawful and fair means, in compliance with the Personal Information Protection Act and other applicable norms. When acquiring a customer's personal information, we will, after clearly indicating necessary matters such as the purpose of use, acquire personal information by appropriate methods within the scope of our business and to the extent necessary to achieve such purpose. The Company does not acquire sensitive information.

3. Purpose of Use of Personal Information

When personal information is provided by a customer, the Company will use such information within the scope of the following business purposes, except where consent has been obtained from the customer or where exceptions are otherwise permitted under applicable laws and regulations.

• To provide services for which you have registered or applied
• To provide information about exhibitions, seminars, and other events
• To survey usage status and satisfaction of the Company's services, or to improve our services
• To report results to those who have cooperated in or participated in surveys, events, etc.
• To respond to inquiries from customers
• To deliver or propose information regarding the Company's services (including by email)
• For the development and improvement of systems used by the Company
• To fulfill obligations under laws and regulations
• For other operations the Company deems necessary to appropriately and smoothly carry out transactions with customers
• To provide personal information to third parties to the extent necessary to achieve purposes incidental or related to the foregoing items (provided that, upon request from the individual, we will discontinue such provision to third parties)

4. Appropriate Use

The Company will not handle personal information by methods that may encourage or induce illegal or wrongful acts. Furthermore, except where the prior consent of the individual has been obtained or where based on laws and regulations, the Company will not handle personal information beyond the scope necessary to achieve the specified purpose of use.

5. Security Management of Personal Information

The Company takes measures to ensure the security management of personal information against the risks of loss, destruction, alteration, and leakage of personal information, including the development of internal rules, the establishment of organizational structures, appropriate supervision of employees, and prevention of unauthorized access.

6. Outsourcing of Personal Information Handling

The Company may outsource part of its operations to external parties. When outsourcing the handling of customer personal information, in whole or in part, to a third party in connection with such outsourcing, we will confirm that appropriate protective measures are in place at the outsourcee and conduct necessary and appropriate supervision of the outsourcee.

7. Disclosure and Provision to Third Parties

Except as set forth in "3. Purpose of Use of Personal Information," "6. Outsourcing of Personal Information Handling," or in any of the following cases, the Company will not disclose or provide customer personal information to third parties.

• When the customer has given consent
• When required by laws and regulations
• When necessary for the protection of human life, body, or property, and it is difficult to obtain the customer's consent
• When particularly necessary for improving public health or promoting the sound development of children, and it is difficult to obtain the customer's consent
• When it is necessary to cooperate with a national or local government agency, or with a person entrusted by such agency, in carrying out duties prescribed by law, and obtaining the customer's consent would interfere with the performance of such duties
• When personal information is transferred as part of business succession of the Company due to merger, company split, business transfer, or other reason

8. Disclosure, Correction, and Suspension of Use of Registered Information

• The Company will disclose personal information to the individual upon request from the individual. In such cases, we will verify the identity of the individual using methods prescribed by the Company. However, in the following cases, we may not disclose all or part of the information, and if we decide not to disclose, we will notify the individual of such decision without delay.
• When there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party
• When there is a risk of significant interference with the proper conduct of the Company's business
• When disclosure would otherwise violate laws or regulations
• If the personal information disclosed to the individual contains content that differs from the facts, the Company will promptly correct it upon request from the individual.
• If the Company is requested by an individual to suspend or delete the use of personal information (hereinafter "Suspension of Use, etc.") on the grounds that the personal information is being handled beyond the scope of its purpose of use or has been acquired by improper means, the Company will conduct necessary investigations without delay, and based on the results, will carry out the Suspension of Use, etc. of the personal information and notify the individual to that effect. However, in cases where the Suspension of Use, etc. of personal information requires substantial expense or is otherwise difficult to carry out, and where alternative measures necessary for protecting the rights and interests of the individual can be taken, we will implement such alternative measures.

9. Employee Training

To ensure thorough security management of personal information, the Company will regularly conduct education and training for officers and employees regarding the appropriate handling of personal information.

10. Inspection and Audit

The Company will conduct regular and ad hoc inspections and audits regarding the handling status of personal information, and will strive to maintain the security of information.

11. Notification, Public Announcement, and Changes to this Policy

The Company posts and publicly announces this Policy on the Company's website. The Company will appropriately review the operational status of the handling of user information and strive for continuous improvement, and may change this Policy as necessary. In the event of changes, the changes will be posted on the Company's website. The revised Policy will apply from the time of posting. If the change involves matters that require user consent under laws and regulations, we will obtain user consent through methods prescribed by the Company.

12. Inquiry Contact

For opinions, questions, and other inquiries regarding the handling of user information, please contact the following.

• Name: Japan Financial Elan Technologies, Inc.
• Personal Information Manager: Haruchika Inoue
• Representative and Address: Please refer to the "Company Profile" for the Company's representative and address.
• Email: security@jfet.co.jp

13. Security

While the Company exercises reasonable care in managing personal information, due to the nature of the internet and email, the confidentiality of personal information cannot be fully guaranteed. Please use the website and email with this in mind.

14. Use of Cookies

The Company's website uses "cookies" in some content to provide better services when users revisit our website. A cookie is a mechanism that stores server information on the computer of the customer accessing the website. By recording the date and time of visits, the number of visits, and information once entered, customers can easily use functions they previously selected. Cookies can identify a customer's computer but do not acquire personal information (name, address, telephone number, email address, etc.) of the customer.

Customers may refuse the receipt of cookies through their browser settings.

15. Use of Access Analysis Tools

• For the purpose of website maintenance and service improvement, the Company's website records customer access history (access logs). Access history includes information such as domain name, IP address, browser and OS type, access date and time, and pages viewed, but does not include information that can identify individuals.
• For the acquisition and analysis of the above access history, the Company's website uses "Google Analytics," an access analysis service provided by Google LLC. Google Analytics uses cookies to collect information regarding customers' use of the website, but this data is collected anonymously and does not include information that identifies specific individuals.
• The information collected is managed in accordance with Google LLC's Privacy Policy (https://policies.google.com/privacy?hl=en).
• You can disable data collection by Google Analytics by installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout?hl=en).
• For the Google Analytics Terms of Service, please see the following: https://marketingplatform.google.com/about/analytics/terms/us/