Original effective date: March 27, 2025

Last updated: March 27, 2025

LogicLinks, Inc. (the “Company”) treats the importance of protection of your personal information seriously. The following privacy policy (this “Privacy Policy”) provides you with information regarding the personal information that the Company collects and the methods of processing and using such information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BECAUSE BY USING THE SERVICE, YOU WILL BE DEEMED TO HAVE CONSENTED TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO THE PROCESSING OF PERSONAL INFORMATION BY THE COMPANY FOR THE PURPOSES STATED BELOW. IF YOU DO NOT CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICE.

In order to ensure the secure processing of your personal information, the Company implements all safety measures required by law.

1. Scope of this Privacy Policy

This Privacy Policy applies only to the service related to “TABIeSIM” provided by the Company (the “Service”).

2. Personal information to be collected (categories and sources of personal information)

The Company may collect the following personal information.

• ・Your name, email address, postal address, telephone number, date of birth or other similar identification information
• ・Your bank account number, credit card number, debit card number, or other payment or financial information
• ・If you are currently using the Service or are considering using the Service,the details of the contract regarding the Service that you are using
• ・Your Internet Protocol (IP) address, cookies, and other online identifiers
• ・Your behavioral data on the Internet including browsing history and information related to interactions between you and websites
• ・Terminal information
• ・Log information
• ・If you make inquiries of the Company, the contents of your inquiries (including issues experienced by you)
• ・Inferred information obtained from personal information to create a profile that reflects personal preference or behavior, etc.
• ・Other personal information required to provide the Service (the category of information will be separately notified to you if it is required to do so under the applicable data protection regulations)

Personal information is directly collected from you, indirectly collected from service providers, platforms, and other third parties, or inferred from collected data.

3. Cookies

The Company uses cookies in the Service.

Cookies are small text files that websites transmit to your terminal for the purpose of keeping records. Cookies identify your terminal, and generally your web browser. Some cookies are necessary to operate the Company’s website (e.g. establishing a session), while other cookies provide enhancement of functionality, collect analytics data to improve operation, make it possible for the Company or the Company's AdTech partners to distribute personalized advertising by tracking you throughout the Internet, or make it possible to share information on social media.

You can choose whether to allow the Company or a third party (e.g. the Company’s analytics, AdTech, or social media partners) to set cookies not strictly necessary for the function of the Company’s website from the cookies banner or from the settings provided on the Company’s website.

Please note that when the Company refers to “cookies,” this term also includes other technology (such as pixel tags or web beacons) which has same purpose as “cookies” as stated in this Privacy Policy.

First-party cookies are directly sent to your terminal by the website where you visit.

Third-party cookies are set on your terminal, not by the website where you visit, but a third party such as an advertiser or an analytics software provider.

You can set up multiple browsers to notify you to that effect when you receive cookies, or choose to set up your browser to reject cookies. In this case, it may not be possible for you to use specifications for individuals enjoyed by other users of the Service.

4. Use of tracking tools, etc. provided by third parties

The Company provides targeted advertising and uses advertisers or technology of a third party such as an analytics software provider to display advertising whether within or outside the Service. These third parties use cookies and similar technologies to collect or receive information from the Service or other place on the Internet, and provide you with targeted advertising by using such information. You can hide targeted advertising of a company that is a member of Network Advertising Initiative by opting out from here (https://optout.networkadvertising.org/?c=1). In addition, you can hide advertising of a company that participates in the Digital Advertising Alliance (DAA) program by opting out from here (https://optout.aboutads.info/?c=2&lang=EN). You can also manage interest-based advertising displayed on apps on your mobile terminal by using DAA mobile app available on AppStore, Google Play, or Amazon’s Appstore. Please see the website (https://digitaladvertisingalliance.org/app) for mobile app guidance.

In addition, the Company uses Google Analytics. Google Analytics is a web analytics service provided by Google LLC (“Google”) that collects anonymous statistical and analytical information regarding how the Company’s users use the Service. For example, Google Analytics collects and aggregates data regarding page views and click counts on the Service. The analytics are not used to track your shift to other websites or to identify you. Information regarding your use of the Service, generated by Google Analytics cookies, (including your IP address) will be send to and retained in a server in the United States by Google.

You can read Google’s privacy policy (https://policies.google.com/privacy?hl=en) and “How Google uses information from sites or apps that use our services” (https://policies.google.com/technologies/partner-sites?hl=en) for more detailed explanation on how Google Analytics collects and uses information when you use the Service.

Moreover, the Company’s website enables the functions for advertising of Google Analytics. If the functions for advertising are enabled, the Company’s website can collect traffic data using Google Ads cookies (https://policies.google.com/technologies/cookies?hl=en#types-of-cookies) and identifiers in addition to data collected in accordance with the standard setting on Google Analytics. Therefore, the Company’s website may create a remarketing user list based on data regarding behavior, age, gender, and interest categories of a specific customer and share such list with Google Ads, use data regarding age, gender, and interest categories in analytics reports, or create segments based on data about age, gender, and interest categories.

You can manage the Google Ads to be displayed or disable customized advertising by using the My Ad Center (https://myadcenter.google.com/personalizationoff?ref=privacy-policy). Please read the following website (https://policies.google.com/technologies/ads?hl=en) for further information including other methods.

You can read the explanation of how to opt-out of Google Analytics by using a specific plug-in at the following link (https://tools.google.com/dlpage/gaoptout?hl=en). Please note that this opt-out applies only to Google activities.

The Company also uses Pt engine. Pt engine is a web analytics service provided by Ptmind[ (“Ptmind”) that collects anonymous statistical and analytical information regarding how the Company’s users use the Service. For example, Pt engine collects and aggregates data regarding page views and click counts on the Service.

The analytics are not used to track your movement to other website or to individually identify you. Information regarding your use of the Service generated by Pt engine (including your IP address) will be sent to and retained in a server in Japan by Ptmind.

You can read more detailed explanations in Pt engine’s privacy policy stated below.

https://www.ptengine.jp/privacy-policy/

You can read the explanation of how to opt-out of Pt engine at the following link (https://www.ptengine.jp/privacy-policy/opt-out/).

Please note that this opt-out applies only to Ptmind activities.

5. Purpose of use of personal information

The Company processes your personal information for the purpose stated below.

• ・To provide the Service or relevant services
• ・To develop services, accumulate statistics, analysis, and questionnaires, and manage other marketing activities intended to improve services
• ・To contact you in order to respond to your inquiries and complaints
• ・To provide you with special offers, campaign information, updated information and other new services, newsletters, and any other information from the Company or a third party
• ・To implement a transaction procedure or provision of a service requested by you
• ・To achieve marketing or sales promotion purposes
• ・To allow you to share the link to the Company’s content on social media
• ・To improve the Service
• ・To create content most relevant to you and publish such content
• ・To provide you with customized advertising
• ・To notify you with any changes to this Privacy Policy and Terms of Use for TABIeSIM Service, if necessary.
• ・To resolve disputes with you
• ・To perform obligations under laws and regulations
• ・To exercise the Company’s rights or to defend against a legal claim by a third party
• ・In the case where permitted by the data protection regulations applicable to the Company, to respond to or cooperate with the relevant authorities
• ・To protect right and interests of you or a third party within the scope permitted by the data protection regulations applicable to the Company
• ・To otherwise conduct the business operations of the Company
• ・For other purposes separately disclosed

6. Legal basis, etc. for processing of personal information

The Company processes personal information in accordance with the legal basis under the applicable laws such as data protection laws and regulations (such as your consent, performance of contracts, legitimate interests, or compliance with legal obligations).

In some cases, you must provide personal information due to reasons such as a statutory or contractual requirement, or a requirement necessary for entering into a contract. If you do not provide the necessary information, it may not be possible for the Company to provide the Service to you. For example, you are required to provide information (such as strictly necessary cookies, your activities recorded by cookies, IP addresses, and categories of web browser) to use the Company’s website. If you do not provide such information, it may not be possible for you to use the Company’s website. In addition, if you do not provide the Company with your personal information despite the fact that the provision of your personal information is necessary, it may not be possible for the Company to provide the Service, etc. to you.

7. Sharing with a third party

The Company may share or disclose your personal information specified in Article 2 “Personal information to be collected (categories and sources of personal information)” to the extent necessary with or to a third party for the following purposes.

• ・The Company may disclose your personal information to service providers in order to provide the Service to you. A service provider is an agent or independent contractor which provides the Service on behalf of the Company, supports the development and maintenance of the Service by the Company, or provides other administrative services to the Company.
• ・In addition, the Company may use Amazon Web Services, Inc. (“AWS”) and other cloud service providers in order to retain and manage service data on a server and process your personal information. The Company may also disclose your personal information to a service provider who provides a service to evaluate advertising effectiveness. When engaging the service provider, the Company enters into a contract regarding the protection of personal information with the delegated party, and requests to consent to the provisions and agreed matters thereof in order to safely manage personal information.
• ・Obtaining information by social media service providers and video distribution platforms: Buttons through which you can share contents on social media or video links on video distribution platforms may be embedded in the Company’s website. In this case, social media service providers and video distribution platforms may obtain your personal information.
• ・The Company may share personal information to comply with laws and regulations, to protect and defend the rights or property of the Company, or in urgent circumstances when there is a need to protect the life, body, or property of an individual and it is difficult to obtain the consent of the identified individual when necessary or when the Company determines such measure is necessary in good faith under laws or regulations, a legally-binding court order, or a governmental order duly issued by an investigative agency or competent regulatory authority.
• ・The Company may share or disclose personal information with or to a third party as part of corporate reorganization (including, but not limited to, merger, acquisition, or assignment of all or substantially all of the Company’s assets).

8. Security control measures

No data transmissions over the Internet can be guaranteed to be 100% secure. Therefore, the Company cannot ensure or guarantee the security of any information that you transmit to the Company, and you understand that any information that you transmit to the Company is transmitted at your own responsibility. The Company prescribes regulations for the personal information protection, and incorporates appropriate administrative, technical, organizational, and physical security measures that are required under applicable regulations. The Company uses firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that the Company does not make any guaranty that such information will not be accessed, disclosed, altered or destroyed due to a breach of such firewalls or secure server software.

If the Company becomes aware of any security system invasion, the Company may attempt to notify you by electronic methods so that you can take the appropriate protective measures. You shall be deemed to consent that the Company can contact you by electronic methods regarding security, privacy, and administrative issues relating to your use of the Service by using the Service or providing personal information to the Company. If a security breach occurs, the Company may publish a notice on the Service of the Company. The Company may also send an email to you at the email address you provided to the Company.

9. Your rights

The Company will respect the rights you hold under the data protection regulations applicable to you. You may demand (i) the disclosure, correction, addition or deletion, the interruption of use, or elimination, the interruption of provision to a third party of personal data you hold, or (ii) the disclosure of records of provision to a third party pertaining to personal data that identifies the principal, in accordance with the “Act on the Protection of Personal Information” of Japan. In addition to these rights, other rights may be granted to you under the applicable data protection regulations of other countries (if applicable). For example, in accordance with data protection regulations of an applicable country, you may be granted the following rights, and if the conditions prescribed by such data protection regulations are satisfied, the Company will comply with your exercise of such rights.

• ・Access to your personal information:
  The right to obtain confirmation from the Company on whether your personal information has been or is being processed, and if such information has been or is being processed, the right to access the relevant personal information and specific related information.
• ・Correction of your personal information:
  The right to modify incorrect personal information concerning you without unreasonably delay and the right to complete your incomplete personal information.
• ・Deletion of your personal information:
  The right to delete personal information concerning you without unreasonable delay.
• ・Restriction on processing of your personal information:
  The right to restrict processing of your personal information.
• ・Objection to processing of your personal information
  The right to make an objection to processing of your personal information that affects your rights.
• ・Withdrawal of your consent:
  The right to withdraw your consent on which the Company relies to process your personal information. However, your withdrawal of consent does not affect the lawfulness of processing conducted based on such consent before its withdrawal.
• ・Data portability:
  The right to receive your personal information in a structured and generally machine-readable form, and the right to transfer such information to a third party without hindrance from the Company.

If you wish to exercise any of the foregoing rights, please contact the Company by using the contact information stated in Article 15 “Contacting the Company”. It may be necessary for the Company to ask you specific information in order to confirm your identity. In addition, the Company may contact you to ask you additional information in connection with your inquiry to facilitate contact from the Company.

You may directly file a complaint against the relative supervisory authorities related to the processing of your personal information by the Company.

10. Retention period

The Company retains personal information only to the extent necessary to achieve the purpose for which the Company collected the personal information including the purpose of fulfilling any legal, accounting, or reporting requirement, making or defending a legal claim, or for the purpose of compliance and protection purposes.

In order to determine the appropriate retention period for personal information, the Company considers (i) the amount, nature, and confidentiality of the personal information, (ii) the potential risk of damage from unauthorized use or disclosure of your personal information, (iii) the purposes for which the Company processes your personal information and whether the Company can achieve such purposes by other means, and (iv) the applicable legal requirements.

11. Cross-border transfer of personal information

Personal information that you determine to provide to the Company will be retained in Japan. The Company may transfer such information (by any method including sending or permitting access) to a country or region outside of the country or region in which you live in accordance with applicable laws and regulations. At present, the Company transfers personal information to Japan. In addition, the service provider of the Company also uses a cloud server provided by AWS, and your personal information may be processed in any region or edge location stated in the following page.

https://aws.amazon.com/about-aws/global-infrastructure/regions_az/

Such personal information may be processed by such parties for the period of time necessary to achieve the purposes specified in Article 7 “Sharing with a third party.”

12. Third party service

This Privacy Policy applies only to information collected in relation to the Service. The Service may include links to other web services. The Company shall not bear any responsibility for the privacy practices or contents of such other web services.

13. Change of this Privacy Policy

The Company reserves the right to change this Privacy Policy from time to time. If the Company changes this Privacy Policy, the Company will also modify the “Last updated” date at the top of this Privacy Policy. In connection with partial change of this Privacy Policy, the Company may attempt to obtain your consent before implementing the change by publishing a notice on the Service. If you continue to use the Service after such notice, you shall be deemed to consent to such change, unless otherwise specified.

14. The Company’s policy regarding children

If the Company becomes aware that the Company has collected personal information from a child who is under the age of 13 years without a legal basis, the Company shall delete such information as soon as possible. If you firmly believe there is a possibility that the Company has any information from or a regarding a child who is under the age of 13 years without a legal basis, please contact the Company by email address .

15. Contacting the Company

If you have any questions about this Privacy Policy, the Company’s privacy practices, or information regarding data or the correction, blockage or deletion of data, please contact the Company by email .