Privacy Policy

English Reference Translation

This English translation is provided for reference purposes only and is not legally binding. The Japanese version is the authoritative text. In the event of any discrepancy or inconsistency between the Japanese version and this English translation, the Japanese version shall prevail in all respects.

Autify Kabushiki Kaisha (English name under its Articles of Incorporation: Autify, Inc.), a company incorporated under the laws of Japan (the "Company"), establishes this Privacy Policy (this "Policy") to ensure appropriate handling of personal information in the course of its business activities in accordance with Japan's Act on the Protection of Personal Information (Act No. 57 of 2003; the "APPI"). Unless otherwise provided in this Policy, "personal information," "personal data," and "retained personal data" have the meanings used in the APPI.

In this Policy, "Individual" means an individual who uses the services provided by the Company (the "Services"), visits the Company's website, makes inquiries to the Company, or is otherwise a person whose personal information or other information is handled by the Company in connection with its business activities.

1. Name, Address, and Representative of the Company

Autify Kabushiki Kaisha (English name under its Articles of Incorporation: Autify, Inc.)

2-22-1 Higashi-Nihonbashi, Chuo-ku, Tokyo, Japan

Representative Director Ryo Chikazawa

2. Information Collected by the Company

In the course of its business activities, the Company collects personal information, including the information described below.

(1) Categories of Information Collected

1. Contact information, including an Individual's name, organization, department, job title, email address, telephone number, and address.

2. An Individual's account information, including User ID and password.

3. An Individual's payment information, including billing information, transaction history, and payment-related identifiers.

4. Information provided through an Individual's inquiries or support requests, including the content of inquiries and attachments.

5. Information automatically collected through use of the Services, including IP addresses, cookie identifiers, browser types, device information, browsing and operation histories, and log information. This may include stack traces, file paths, scenario or step content, and other technical information used to identify failures, defects, or errors. This information may also include content entered by an Individual or other information and, depending on its content, may contain information including personal information or other highly confidential information.

6. Information acquired through cookies and other technologies, including behavioral information obtained through access analytics, heatmaps, and clear GIFs.

7. Other information provided by Individuals to the extent necessary to provide the Services.

8. Information that the Company may acquire or retain in connection with the use of AI features, including prompts, instructions, conversation history, input information, output information, test results, operation history, thread IDs, AI models used, token counts, and other usage information.

(2) Purposes of Use

The Company uses information acquired from Individuals for the following purposes.

1. Provision and Operational Management of the Services

The Company may use information, including personal information, to perform the basic functions and operations of the Services, including provision and maintenance, feature improvements, account creation and management, user authentication, maintenance of usage environments, contract performance, performance optimization, and system operation. This includes processing information through tools such as cloud infrastructure providers and device testing environments.

2. Customer Support and Contract-Related Matters

The Company may use information, including personal information, to respond to Individuals' inquiries and support requests, conduct contract procedures, invoice, and manage payments. This enables smooth provision of the Services and appropriate customer service.

3. Research and Analysis for Service Improvement and Product Development

The Company may use collected information, including personal information, for research, testing, analysis, and product development. For these purposes, it may also create and use statistical information, analysis results, and other information based on collected information. This enables the Company to understand how Individuals use the Services and improve products and features. Use for machine learning is limited to cases where consent has been obtained under Section 2(2)8 (Use for Machine Learning).

4. Website and User Experience Optimization

The Company may use information, including personal information, to improve the display, navigation, and operation of websites and applications using browsing histories, operation logs, and other information, and provide a more convenient experience for Individuals.

5. Marketing, Advertising Delivery, and Performance Measurement

The Company may use information, including personal information, to deliver advertisements and promotions based on Individuals' interests, distribute campaigns, conduct public relations activities, operate webinars and service introduction websites, and analyze their effectiveness. This enables the Company to provide Individuals with relevant information.

6. Security Measures and Prevention of Misuse

The Company may use information, including personal information, to maintain security and stable operation, including detecting unauthorized access, preventing spam and malicious use, and monitoring vulnerabilities.

7. Legal Compliance and Responses to Public Authorities

The Company may use information, including personal information, to the extent legally necessary, including to fulfill statutory obligations and respond to disclosure requests from administrative authorities or courts.

8. Use for Machine Learning

Only where an Individual has expressly consented in the manner prescribed by the Company may the Company use data acquired after that consent relating to the Individual's use of the Services, including personal information, to train machine learning models or other AI models (meaning reflecting such data in the parameters of AI models; the same applies below).

An Individual may withdraw that consent at any time in the manner prescribed by the Company. Data acquired by the Company after the withdrawal becomes effective shall not be used for new training.

The withdrawal does not, however, affect any use, training, or processing performed before the withdrawal, or any statistical information, analysis results, trained models, or other results generated thereby.

Whether such consent is given does not affect the use of information necessary for the provision, operation, maintenance, support, security, detection of failures, defects, or errors, investigation or correction of their causes, understanding and analysis of usage, quality evaluation and improvement of the Services, legal compliance, or other activities necessary for the provision of the Services.

3. Provision of Personal Information to Third Parties

Except as permitted by laws and regulations, the Company shall not provide personal data to third parties without obtaining the Individual's prior consent.

4. Handling of Personal Information in Connection with Outsourcing

(1) In providing the Services, the Company may entrust the handling of personal data in accordance with Article 27, paragraph 5, item (i) of the APPI.

(2) Service providers handle personal data under the Company's instructions and process it only within the purposes of use established by the Company. When outsourcing, the Company enters into appropriate agreements, exercises necessary and appropriate supervision over service providers, and implements security control measures.

(3) Provision of personal data to service providers located outside Japan is governed by Section 5 (Provision to Third Parties in Foreign Countries).

5. Provision to Third Parties in Foreign Countries

(1) The Company may provide personal data to third parties located outside Japan to the extent necessary to achieve the purposes of use.

(2) The Company may provide personal data to its parent company, Autify, Inc., a Delaware corporation (the "U.S. Parent"), for group-wide management, formulation of business strategies, support and oversight of business operations, risk management, establishment of internal controls and compliance systems, and other purposes specified in this Policy. Such provision is based on the U.S. Parent having established a system that conforms to the standards prescribed by the Rules of the Personal Information Protection Commission as necessary for continuously implementing measures equivalent to those required of personal information handling business operators under the APPI. The Company takes measures necessary to ensure the continuous implementation of those measures by the U.S. Parent and provides information concerning those measures upon an Individual's request. To request such information, please contact the point of contact specified in Section 13 (Inquiries).

(3) In addition to the provision described in the preceding paragraph, the Company may provide personal data to third parties located outside Japan in accordance with the APPI and other applicable laws and regulations. Such provision is based on the Individual's consent, the recipient having established a system conforming to the prescribed standards, a case falling within any item of Article 27, paragraph 1 of the APPI, or another case in which the APPI does not require the Individual's consent. When providing personal data to third parties located outside Japan, the Company discloses the recipients, the names of the countries in which they are located, information on the personal information protection systems in those countries, information on measures taken by the recipients to protect personal information, and other information required to be provided to Individuals under the APPI on the Company's designated webpage: https://autify.jp/privacy/privacy-tools .

(4) The Company uses cloud services and other services to provide the Services. As a result, personal data may be stored or processed outside Japan, including in the United States. Where providers of those cloud services or other services handle personal data, provision of personal data to third parties located outside Japan is governed by Sections 5(1) through (3). The Company implements security control measures after understanding the personal information protection systems in the foreign countries where personal data is stored or processed. The names of those countries and the measures taken are disclosed on the webpage referred to in Section 5(3). Where Individuals or others are located outside Japan, or where otherwise applicable, the personal information protection laws of the relevant country or region, including the EU General Data Protection Regulation (GDPR), may apply.

6. Use of Cookies and Other Technologies

(1) The Company may use cookies and other tracking or analytics technologies on its website and in the Services to improve convenience, provide and improve the Services, analyze usage, and deliver advertisements and measure their effectiveness.

(2) The principal types of cookies used by the Company are as follows.

1. Essential Cookies

These cookies are necessary to provide the basic functions of the website and Services, including maintaining login status and managing sessions.

2. Analytics and Performance Cookies

These cookies are used to analyze access status, browsing and operation histories, traffic trends, and other information to improve the website and Services. Example: Google Analytics.

3. Functional Cookies

These cookies remember an Individual's choices, including language and display settings, to improve convenience.

4. Advertising and Targeting Cookies

These cookies are used to deliver advertisements based on an Individual's interests and measure advertising effectiveness.

(3) Individuals may disable cookies or delete stored cookies through their browser settings. Disabling cookies may make some features of the website or Services unavailable.

(4) The Company may use third-party services for access analytics, advertising delivery, performance measurement, and other purposes. This may involve transmission of information about Individuals, including cookies or other identifiers, browsing histories, and device information, from their devices to those third parties.

For details of the third-party services used by the Company, please see the External Transmission Policy (Use of Cookies and Other Technologies).

7. Information Retention Periods

The Company retains personal data acquired from Individuals for the period necessary to achieve the purposes of use. Retention periods are determined taking into account the type of information, purposes of use, contractual terms, legal requirements, backups and other technical needs, and the specifications of external services used by the Company. The Company endeavors to erase personal data without delay once retention is no longer necessary, including where the purposes of use have been achieved. Information that must be retained by law shall be retained for the legally prescribed period.

8. Deletion of Information by Individuals

If an Individual deletes their own account on the Services, the Company endeavors to erase without delay personal data it holds relating to that account. This does not apply to information that must be retained by law or that is difficult to erase immediately for technical reasons, including backups. Retention periods for such information are governed by Section 7 (Information Retention Periods).

9. Links to Websites of Other Parties

The Company's website may contain links to websites of other corporations, organizations, or entities. The Company is not responsible for the handling of personal information on those websites.

10. Disclosure and Other Requests Regarding Retained Personal Data

(1) If an Individual requests notification of the purposes of use of retained personal data; disclosure of retained personal data or records of provision to third parties; correction, addition, or deletion of the content of retained personal data; suspension of use, erasure, or suspension of provision to third parties (collectively, "Disclosure and Other Actions"), the Company will verify that the request is made by the Individual concerned and respond in accordance with the APPI. This does not apply where the Company is not obliged to take Disclosure and Other Actions under the APPI or other laws and regulations. In response to a request for disclosure of retained personal data or records of provision to third parties, the Company may withhold all or part of the information if disclosure may harm the life, body, property, or other rights or interests of the Individual concerned or a third party; may significantly impede the proper conduct of the Company's business; or would violate other laws or regulations.

1. Disclosure of Retained Personal Data and Records of Provision to Third Parties

When an Individual requests disclosure of retained personal data or records of provision to third parties, the Company will disclose them to the Individual without delay by providing electronic records or delivering written documents, using the method requested by the Individual.

2. Correction and Related Actions Regarding Retained Personal Data

If an Individual states that the content of retained personal data is inaccurate and requests its correction, addition, or deletion (collectively, "Correction and Related Actions"), the Company will conduct necessary investigations without delay, take Correction and Related Actions based on the results, and notify the Individual accordingly.

3. Suspension of Use or Erasure of Retained Personal Data and Suspension of Provision to Third Parties

If an Individual requests suspension of use or erasure of retained personal data (collectively, "Suspension of Use and Related Actions") or suspension of provision to third parties under Article 35 of the APPI, the Company will conduct necessary investigations without delay and, based on the results and in accordance with that Article, take Suspension of Use and Related Actions or suspend provision to third parties and notify the Individual accordingly.

(2) To request Disclosure and Other Actions, please contact the point of contact specified in Section 13 (Inquiries).

11. Security Control Measures

The Company has established an "Information Security Policy" as its policy for information security initiatives.

The Company implements organizational, personnel, physical, and technical security control measures for personal data it acquires. Individuals wishing to obtain details of these measures should contact the point of contact specified in Section 13 (Inquiries).

For security control measures concerning the handling of personal data in foreign countries (understanding the external environment), please see Section 5(4).

12. Updates to This Policy

The Company may amend this Policy from time to time and will post the amended content on its website. Where the Company makes material changes to this Policy, it will endeavor, in addition to posting the changes, to inform Individuals in advance through notices within the Services or other appropriate means.

13. Inquiries

If you have any questions about this Policy, or any questions, complaints, or concerns about the handling of personal information in the Services, please contact the following point of contact.

Inquiries

https://autify.jp/contact

Established August 24, 2019

Revised November 4, 2026

Effective date December 14, 2026