Operational Policy

Privacy Policy
(Basic Policy for Personal Information Protection)

Enacted: July 7th, 2004
Revised: July 1st, 2022
Michio Fukuda, President and Representative Director
OKWAVE, Inc.

OKWAVE, Inc. (hereinafter, “the Company” or “we”) complies with the laws and other norms concerning personal information and declares that it will establish and comply with this “Privacy Policy” to manage personal information appropriately.

１．When the Company directly acquires the personal information, etc. of any individual, the purpose of use and acquisition method will be specified in advance, and the information will be obtained with the consent of the party concerned. However, when the purpose of use is clear from the circumstances at the time of acquisition, the purpose of use may be omitted.

２．When the Company handles personal information, etc., it will continuously take reasonable safety measures as well as corrective and preventive measures in terms of technology and organization for safety management, including prevention of destruction, leakage, loss, falsification, and damage of the information.

３．The Company will not disclose or provide personal information, etc. to a third party without the consent of the party concerned unless such disclosure is made based on laws and regulations or when making a declaration separately based on laws and regulations.

４．We have set up a complaint/consultation service desk for personal information, etc. to respond to complaints and consultations regarding the handling of personal information, etc., and we will respond in good faith. With regard to requests for disclosure, correction, or suspension of the use of personal information based on the Act on Personal Information Protection, we will respond to such requests within a reasonable period to a reasonable extent if we are able to verify the identity of the person making the request.

５．The personal information, etc. that we acquire shall handle as follows.

（１）Definition of personal information

In this policy, “personal information” means information related to a living individual that falls under any of the following.

1. ① Information containing a name, date of birth, or other description, etc. (any and all matters [excluding individual identification codes] stated, recorded, or otherwise expressed using voice, movement, or other methods in a document, drawing, or electromagnetic record [a record kept in electromagnetic form {meaning an electronic, magnetic, or other such forms that cannot be recognized through the human senses}] whereby a specific individual can be identified [including information that can be readily collated with other information to thereby identify a specific individual]).
2. ② Information containing an individual identification code.

（２）Content of personal information to be acquired

We may obtain information about an individual such as their name, username, password, postal code, address, email address, gender, nationality, date of birth (age), and occupations and hobbies, as well as log information related to Internet usage such as their customer number, cookies, IP address, subscriber/terminal ID, usage environment, and websites viewed. The above information is collectively called “personal information, etc.”

（３）How we obtain personal information, etc.

The Company may obtain your personal information, etc. using any of the following methods.

1. ① You directly enter the information on the designated page of the website or in writing (including by email).
2. ② You provide the Company with the information verbally over the phone or face-to-face.
3. ③ Any other methods specified by the Company.

When you use a service provided on the website that the Company operates that is available to Internet users (hereinafter, “Service”), your personal information, etc. will be automatically sent from your browser and recorded on the server of the respective Service.

（４）Purpose of use of personal information, etc.

The personal information, etc. acquired by the Company shall be used for the following purposes and not for any other purpose. We will give notice in advance when using the information for purposes other than the following.

＜Personal information, etc. regarding users of the Service＞

1. ① To provide you with the information necessary for the provision of the Service, such as important notifications and maintenance information.
2. ② To inform you of special services and campaigns in an appropriate manner.
3. ③ To display information on services provided by the Company or products or services of its affiliates that are considered to be useful to individual customers on the web page of the Company’s services that you have accessed or on your device, or to send such information by e-mail, including newsletters, messages, etc. (You can suspend or resume such handling by notifying the Company using the method that it specifies separately.)
4. ④ To send campaign gifts and notifications.
5. ⑤ To conduct surveys on the usage situation, usage environment, and posted content, and to create and use statistical materials to the extent that individuals cannot be identified.
6. ⑥ To respond to inquiries from customers, to confirm identification, and for various other procedures.
7. ⑦ To handle disputes and lawsuits.
8. ⑧ To otherwise enhance service content.

＜Personal information, etc. regarding business partners＞

1. ① For proposals regarding our services, business discussions, negotiations, the conclusion of contracts, and communication necessary for business.
2. ② To manage the information of business partners.

＜Personal information, etc. of participants in seminars and events＞

1. ① To inform the participants of seminars and events, and to send out materials.
2. ② To operate and manage seminars and events.

＜Personal information, etc. regarding applicants for our recruitment selection＞

1. ① To contact and give notification to applicants.
2. ② For judgement of acceptance.

＜Personal information, etc. regarding those who have responded to questionnaires and provided their opinion＞

1. ① For research, evaluation, and analysis to improve the Service.
2. ② To provide information on the Service.

（５）Joint use of personal information, etc.

As described below, we may jointly use the personal information, etc. acquired from you, within the scope of the purpose of use mentioned above.

＜Items of personal information, etc. to be jointly used＞

1. ① Personal information, etc. regarding users of the Service
2. ② Personal information, etc. regarding business partners
3. ③ Personal information, etc. of participants in seminars and events
4. ④ Personal information, etc. regarding applicants for our recruitment selection
5. ⑤ Personal information, etc. regarding those who have responded to questionnaires and provided their opinion

＜Scope of joint users＞

OKWAVE, Inc. and our group companies

＜Manager of joint use＞

OKWAVE, Inc.

（６）Provision of personal information, etc. to third parties

We will not disclose your personal information, etc. to a third party except in the following cases.

1. ① When you consent in advance to the disclosure of your personal information, etc. for yourself.
2. ② When there is an urgent need due to an imminent danger to human life, health, or property.
3. ③ When it is especially necessary to improve public health or promote the healthy development of children, and it is difficult to obtain your consent.
4. ④ When the Company has received a formal inquiry from a public institution based on law, such as a judicial court or the police.
5. ⑤ When the Company is required to disclose or provide personal information, etc. based on other related laws and regulations.
6. ⑥ When your actions on the Service are contrary to the terms of use, prohibitions, rules, or manners, and the provision of information is deemed necessary to protect our rights to the Service, properties, services, etc.

（７）Outsourcing the handling of personal information, etc.

We may outsource all or part of the handling of acquired personal information, etc., to the extent necessary to achieve the purpose of use. In that case, we will conclude the necessary contracts regarding the handling of personal information, etc. and supervise the contractors as necessary and appropriate.

（８）Use of cookies

1. ① Cookies refer to identifying data of individual customers sent from the server used to operate the website to the customer’s browser. The use of cookies allows customer information to recorded on the hard disk of the customer’s computer. Many browsers are initially set to accept cookies, and many websites acquire and use cookies to provide useful functions. While cookies identify the computer you use, they do not identify the user on an individual basis.
2. ②In the Service, cookies are acquired in order to obtain information on login to your individual page (“My Page”), and overall trends and patterns on the site. We use the acquired information to analyze access trends, provide better services, and deliver advertisements, and will not use it for any other purposes, nor will it affect your privacy or usage environment.
3. ③You can reconfigure your browser to refuse to accept cookies or to indicate that cookies are sent, but if you decline cookies, parts of the Service may not work properly.
4. ④For more information on the cookies used for the services described on our website under Individual Customers > Service Lineup (hereinafter, “Service for individuals”), see the “Cookies” page.
5. ⑤The Service uses Google Analytics, an access analysis service provided by Google, to interpret your usage environment. While Google Analytics uses cookies to collect information on your usage environment, this data is collected anonymously and does not include any information that can identify a specific individual. Moreover, such information is managed based on Google’s Privacy Policy.
   You can also stop Google Analytics from collecting your information by disabling Google Analytics in theadd-on settings of your browser.
   Please refer to the Google Analytics Terms of UseandPrivacy Policyor the mechanism of data collection and processing by Google Analytics.

（９）Your rights regarding personal information, etc.

1. ① If the processing of personal information, etc. is based on your consent, you have the right to withdraw your consent as regards your personal information, etc. at any time.
2. ② You have the right to request access to your personal information, etc.
3. ③ You have the right to request the correction of your personal information, etc. held by the Company.
4. ④ You have the right to request the deletion of your personal information, etc.
5. ⑤ You have the right to object to the processing of your personal information, etc. conducted by the Company for legitimate interests.
6. ⑥ You have the right to seek restrictions on the processing of your personal information, etc.
7. ⑦ You have the right to request the transfer of your personal information etc. to you or any third party.
8. ⑧ No cost is required to exercise the above rights.
9. ⑨ In addition to the above rights, you have the right to file a complaint to the supervisory authority at any time. However, before contacting the supervisory authority, we would like you to contact us to give us the opportunity to respond to your complaint.

（１０）Our response to the exercise of your rights

We respect your rights as described in the preceding paragraph, and will respond to your request within a reasonable period and scope only in cases where we can confirm that you were the one to make the request yourself. If your request is clearly unfounded or excessive, we may charge you a reasonable fee or decline to respond, especially if the request is repeated.

（１１）Deletion of personal information, etc.

We will not store the collected personal information beyond the extent necessary for the purpose of collection. In addition, you may request that the Company delete your own personal information, etc. via the inquiry form at any time, and if the personal information, etc. is no longer necessary for the purpose of collecting or processing, we will promptly delete the personal information, etc.

６．Anonymously processed information, etc.

The Company will take necessary and appropriate safety management measures for the management of anonymously processed information, etc., including prevention of leakage, loss, or damage. We will also supervise the employees and contractors (including subcontractors) who handle anonymously processed information, etc. as necessary and appropriate.

＜Information items included when creating anonymously processed information＞

1. ① Gender
2. ② Occupation
3. ③ Date of birth (age)

＜Information items included when providing anonymously processed information to a third party＞

1. ① Gender
2. ② Occupation
3. ③ Date of birth (age)

＜Method of providing anonymously processed information to a third party＞

① Data format (Word, Excel, PowerPoint, PDF, etc.)

７．Exemptions

The website of a third-party link on the Service for consumers via an advertisement or posted content may require you to enter your personal information, etc., or may automatically acquire such information. In such cases, this policy does not apply.

８．Changes to Privacy Policy

1. （１） The Company may change this policy without obtaining your approval in advance. Any changes to this policy will be notified on the Company’s website.
2. （２） The changed Privacy Policy shall take effect from the date posted by the Company, and you are deemed to have accepted the changed content of this policy by using the service provided by the Company after the policy is changed.

９．Contact information

For inquiries regarding this policy and personal information, etc., please use theinquiry form.

Basic Policy on Proper Handling of
Specific Personal Information, etc.

Enacted: February 1st, 2016
Michio Fukuda, President and Representative Director
OKWAVE, Inc.

Based on the “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures,” we recognize that it is our important social responsibility to protect personal information and specific personal information (hereinafter, “specific personal information, etc.”) in doing business where specific personal information, etc. is handled, and we have established a basic policy for ensuring proper handling of specific personal information, etc. as follows.

1. Scope and system of handling specific personal information, etc.

We will specify the scope of work that handles individual numbers and the range of specific personal information, etc., and clarify the person in charge of administrative work. In addition, we will formulate rules and establish a system for handling specific personal information.

2.Safety management measures

egarding safety management measures for specific personal information, etc., we will take necessary measures to prevent the leakage, loss, or damage of specific personal information and for other appropriate management of the same.
If information leakage, etc. occurs, we will promptly take corrective actions depending on the case. We will provide education, training, audits, etc. to those who handle specific personal information, etc.

3.Compliance with related laws and guidelines

We will comply with laws and regulations concerning personal information and specific personal information, guidelines established by the government, guidelines regarding the proper handling of specific personal information and any other norms, and will handle specific personal information, etc. in an appropriate manner.

4.Purpose of use

The purpose of use of specific personal information, etc., that we obtain from our employees or a third party is within the scope of the administrative affairs handling of individual numbers listed below.

1.Administrative affairs related to individual numbers for employees

1. ①Employment insurance reporting*
2. ②Health insurance/Employee pension insurance reporting
3. ③Administrative affairs related to claims based on the Industrial Accident Compensation Insurance Act
4. ④Withholding slip preparation work for salary and retirement income

2.Administrative affairs related to individual numbers for individuals other than employees

1. ① Preparation of payment record of compensation and fees, etc.
2. ② Preparation of payment records of dividends, distribution of surplus, and interest on guaranty capital
3. ③ Reporting of third insured persons in the national pension plan
4. ④ Preparation of payment record of real estate usage fees, etc.
5. ⑤ Preparation of payment record of consideration for transfer of real estate, etc.

Administrative affairs associated with 1 and 2 above (including work for handling specific personal information)

5. Contact for specific personal information, etc.

We will respond appropriately and promptly to complaints and inquiries from the party concerned about the handling of specific personal information. For inquiries about our handling of specific personal information, etc., please use theinquiry form.

We will make this policy thoroughly known to all employees, and make it publicly available. In addition, we will continuously review and improve the management system of specific personal information, etc.

End of document

Security Policy
(Basic Policy on Information Security)

Enacted: January 7th, 2005
Revised: November 1st, 2010
Michio Fukuda, President and Representative Director
OKWAVE, Inc

OKWAVE, Inc. (hereinafter, “the Company” or “we”) declares that it will formulate and comply with the following basic policy on information security in order to protect its information assets from all threats and to prove that it is worthy of society’s trust. ISO27001 (Information Security Management System) certification was acquired for the entire company on January 21, 2005, and certification is maintained at present.

1. 1、 We will comply with laws and regulations related to information security, guidelines established by the government, and separately specified related regulations and contracts.
2. 2、 We will clarify the responsibilities related to information security and establish an organizational structure for implementing measures.
3. 3、 In order to promote proper management and operation of information assets, we identify information security risks, carry out risk assessments, and implement organizational, physical, human, and technical measures as necessary. In addition, if an information security problem occurs, we will handle the problem promptly to minimize the damage.
4. 4、 We will ensure that all employees are fully informed through regular education and awareness activities on information security based on this basic policy.
5. 5、 Personal information will be managed based on our “Personal Information Protection Policy (Privacy Policy).”
6. 6、 We will regularly review the information security management system including the above items and make continuous improvements.

Terms of Use of
OKWAVE Media Service

Last updated: October 11th, 2021
Michio Fukuda, President and Representative Director
OKWAVE, Inc.

Article 1. Scope of Application and Changes of the Terms of Use of the OKWAVE Media Service

1.The Terms of Use of OKWAVE Media Service (hereinafter, “the Terms”) apply to all relationships between users and OKWAVE, Inc. (hereinafter, “the Company” or “we”) in using the service provided by us (hereinafter, “Service”). Users shall use the Service at their own responsibility after agreeing to the Terms and the Privacy Policy. Regarding services in the Service that can be used without procedures, such as member registration, you are deemed to have agreed to the Terms and the Privacy Policy by using the services.

2.If additional terms of use are provided for the Service other than the Terms, the user must comply with the terms of use together with the Terms. In that case, to the extent that there is any inconsistency between the Terms and the additional terms of use, the additional terms of use shall prevail. Moreover, if separate terms of use are provided for individual services in addition to the Terms, the terms of use shall be applied when using the services.

3.The Company shall notify the user in advance by the method specified by the Company when the Terms are revised (hereinafter, “revision”). In addition, when the Company makes the revision, it shall be limited to the following cases.

1. ①When the contents of this revision match the common interests of user, or
2. ②When the content of this revision does not violate the purpose of the usage contract and is reasonable in light of the necessity of change, the appropriateness of the content after the change, and other circumstances related to the change.

4.The user is deemed to have agreed to the changed revision by continuing to use the Service after this revision, and the changed Terms shall be applied to any relationship between the user and the Company. In addition, the Company shall not be liable for any damages to the user regarding the content of this revision after the user has consented to this revision.

Article 2. Definition of Terms

1.”Member” means a person who has registered as a member through the method prescribed by the Company and who uses the Service via ID authentication coordination.

2.”User” means any person who uses the Service, including members.

3.“Certified Member” means an entity or person who is a member of OKWAVE and who has been certified and identified by the Company as a person with expertise.

4.”Member information” means the information disclosed by the member to the Company in the member registration, use of ID authentication coordination and the Service, and the Thanks Index.

5. “ID authentication coordination” means a mechanism that enables users to use the IDs and passwords for online services other than the Service when using the Service as a member, which also enables us to receive information on users from the internet services based on user consent.

6.”Authentication information” means the ID/password of the account issued in member registration through the method prescribed by the Company, and the ID/password of online services other than the Service used by the user through ID authentication coordination.

7.”Posted content” is a generic term for text data and multimedia data such as images, videos, audio files, and handwriting functions that are posted by users on the Service and made public.

8.”Merchandise, etc.” means tradable goods or services offered for sale on the Service.

9. “Seller” means a user who has agreed to the Terms, etc. and has put up the Merchandise, etc. to have us sell it or to sell it by themselves on the Service.

10. “Purchaser” means a user who has agreed to the Terms, and has provided us with the information specified by us at the time of purchase with the intention to purchase the Merchandise, etc.

11. The “Thanks Index” is a multi-faceted index of appreciation based on the users’ usage status, such as posts on the Service.

12.“OK-Tips” means a tip that can be sent or received between members of the Service to express gratitude in association with the Service.

Article 3. Special Rules regarding OK-Tips

1.Overview of OK-Tips

1. (1) OK-Tips that can be sent to other members are called “OK-Tips To Give.”
2. (2) The OK-Tips sent by other members are called “Received OK-Tips.”
3. (3) Only the Received OK-Tips can be used for the services provided by OKWAVE, etc.
4. (4) Regarding the services provided by the Company, there may be restrictions on the use of Received OK-Tips, such as cases when there is usage limit of Received OK-Tips or when some services are unavailable.
5. (5) The Company shall be able to send OK-Tips To Give and Received OK-Tips to the members.

2.Expiration date of OK-Tips

There is no expiration date.

3.Suspension or return of OK-Tips

（1）The use of OK-Tips may be suspended in the following cases.

1. ①When the Company believes that there is the possibility of illegal use of OK-Tips.
2. ②When any of the acts specified in Article 6 are performed.

（2）OK-Tips will be returned to us in the following cases.

　　

1. ①When the Company invalidates the Service registration after receiving notification from the members themselves that the OKWAVE ID and password were, or are suspected to have been, stolen or used by a third party.
　　
2. ②When the member cancels their membership.
　　
3. ③When the Company confirms that OK-Tips are being illegally used.
　　
4. ④When any of the prohibited acts specified in Article 10 is conducted.

4.Disclaimer regarding OK-Tips

1. (1) The Company shall not be liable for any damages suffered by the members regarding the Service provided by the Company, etc. whereby the users can use Received OK-Tips.
2. (2) The Company shall not be liable for any damages suffered by members regarding the transfer of OK-Tips between members.
3. (3) The Company shall not be liable for any loss of OK-Tip data that is not attributable to its willful misconduct or gross negligence.

Article 4. Disclosure and Use of Member Information

1. In principle, the Company will not disclose member information other than that published on the Service to any third party without the prior consent of the member themselves. However, this shall not apply to inquiries from public institutions or cases where the Company has an obligation to disclose information based on laws and regulations.

2. Members shall register genuine information as member information, and shall have the obligation to promptly register any changes in the content to keep the information in an authentic state.

3. The Company shall not be liable for any damage caused by any member’s failure to comply with the obligations set forth in the preceding paragraph.

4. The Company shall be able to use the member information for the purpose of providing information that the Company considers useful (including information on the products and services of the Company, advertisers, and partners).

5. The Company shall collect and analyze member information for the purpose of improving the Service and our marketing, etc.

6. The Company manages member information in accordance with our Privacy Policy.

7. Members shall agree that the Company will handle and retain member information as set forth in this Article, and shall not make any objections.

Article 5. Management of Authentication Information

Members shall manage the authentication information at their own responsibility. Even if any person other than a member uses the Service through fraudulent or illegal use of the authentication information or due to any other circumstances, we will not take any responsibility for damages incurred by the member when we confirm using our prescribed method that the entered authentication information matches the registered information and deem that the Service has been used by the member.

Article 6. Suspension of Use, etc.

1. In the event that the user falls under any of the following items, the Company may take necessary measures such as suspension of use of the Service by the user, changing of the password of the user, cancellation of the membership of the user, etc., without prior notice and without the consent of the user. In addition, the Company shall not be obligated to disclose the reason for taking such measures to the user.

1. (1) When the Terms are violated.
2. (2) When it is found that member information is false.
3. (3) When the authentication information is used illegally.
4. (4) When the information provided by the Service is used illegally.
5. (5) When there is a risk of damage to the Company or a third party.
6. (6) When any of the prohibited acts specified in Article 10 is conducted.
7. (7) If the user does not pay the usage fee to be paid when using paid content or functions specified by the Company.
8. (8) When we consider the use of the Service to be inappropriate.

2. The Company shall not be liable for any damages caused to the member due to the measures we take as specified in the preceding paragraph.

Article 7. Disclaimer

1.The Company and the partners that have cooperative relationships therewith do not guarantee the accuracy, completeness, and security of the information provided by the Service. Even if the user or a third party suffers damages due to the information, the Company and the partners with which it has cooperative relationships shall not be liable for the damages.

2. The information, wording, and content provided within the Service in the name of the partners that have cooperative relationships with the Company are based on the choice and judgment of the partners and do not reflect the opinions or views of the Company or its employees.

3. The Company may provide some functions and services in cooperation with other online services, etc. in connection with the Service. In such case, the user may not object to the Company or any third party designated thereby with regard to the case where the content posted on the Service may be disclosed to other online services etc. under certain conditions.

4. The Service is an online service, and in using this Service, the user shall manage their posting history and the disclosure/non-disclosure of information regarding themselves and the posted content at their own responsibility. The Company shall not be liable for any damages arising from the disclosure or posting of information at the user’s option.

5. The Company will not take any responsibility for missed opportunities of use, loss of data, interruption of business, or any kind of damage (including indirect damage, special damage, incidental damage, consequential damage, and lost profit) that occur to the user, even if the Company is informed of the possibility of such damages in advance.

6. The Company shall not be liable for any damages caused to other users or third parties by the user’s use of the Service, or for any damages and disputes caused to users themselves.

7. The connection to the Internet to use the Service shall be made at the user’s own expense, and the Company shall not be responsible for any expenses or liability.

8. If the user is subject to the Consumer Contract Act, which is a Japanese law, and the user suffers damage due to the Company’s willful misconduct or gross negligence in the course of the provision of the Service, the provisions regarding exclusion of our liabilities in the Terms shall not apply.

9. If the user is subject to the Consumer Contract Act, which is a Japanese law, and the Company provides the Service for a fee to the user, the provisions of this Article and the provisions regarding the entire exclusion of the Company’s liabilities in the Terms shall not apply when the user suffers damage due to slight negligence on the Company’s part, and the Company shall be liable only for ordinary damages actually caused to the user directly due to such slight. In that case, the amount of damages that we pay to the user shall be limited to the amount equivalent to the usage fee that the user incurred to use the Service.

10. When users send and receive Bitcoin in using the Service, the transmission is made through the Bitcoin exchange selected by the user (such as a service provider that enables the trading of Bitcoin, for example buying and selling of Bitcoin or mediating the exchange). In relation to the transmission of Bitcoin by users, we will not take any responsibility for the handling of Bitcoin or the content of transactions, such as confirmation/cancellation of transmission or reception, confirmation of destination/receiver or sender/receiver, incorrect transmission by the user or erroneous specification of the receiving method, or any tax processing, and the user shall handle the same based on their own judgement and responsibility.

Article 8. Medical Content

1. In the Service, there is content that allows the exchange of medical information between users, and content in which we provide medical information (hereinafter, collectively “medical content”).

2. The user shall use the medical content at their own discretion and responsibility, understanding that any method of use of the Service does not constitute a doctor-patient relationship between the user and the provider of the medical content, and that it is not intended to conduct medical treatment (including those prescribed in the Medical Act and those that should be regarded as medical treatment based on social conventions) to the user or to present solutions to the users’ personal, individual, or specific medical problems. In addition, the user shall accept in advance that they cannot hold the Company or other users responsible for any damages resulting from their use of medical content at their own discretion and responsibility.

3. The user shall not use the Service for the purpose of providing medical treatment under any circumstances.

4. Unless individually specified as the content of the Service, the Company or the provider of medical content will not introduce experts such as doctors or mediate between users and such experts. If the user needs to resolve personal, individual, or specific medical problems, they should promptly consult a doctor or other appropriate specialist.

5. The provisions of this Article shall apply regardless of whether the user or the provider of medical content is a doctor or other qualified person.

Article 9. Legal Content

1. In the Service, there is content that allows the exchange of legal information between users, and content in which we provide legal information (hereinafter, collectively “legal content”).

2. The user shall use such legal content at their own discretion and responsibility, understanding that any method of use of the Service does not constitute a requester-consultant relationship between the user and the provider of the legal content in relation to legal services (including those prescribed in the Lawyer Act and those that should be regarded as legal services based on social conventions) or similar services (hereinafter, “legal services, etc.”), and that the use of the Service does not present solutions to users’ personal, individual, or specific legal problems. In addition, the user shall accept in advance that they cannot hold the Company or other users responsible for any damages resulting from the use of legal content at their own discretion and responsibility.

3. The user shall not use the Service for the purpose of providing legal services, etc. under any circumstances.

4. Unless there are no legal restrictions and it is individually specified as the content of the Service, the Company or the provider of legal content will not introduce experts such as lawyers or mediate between users and such experts. If the user needs to resolve personal, individual or specific legal problems, the user should promptly consult a lawyer or other appropriate specialist.

5. The provisions of this Article shall apply regardless of whether the user or the provider of legal content is a lawyer or other qualified person.

Article 10. Prohibitions

1.The Company prohibits the acts listed below when the user uses the Service.

1. (1) Acts that violate laws, public order, or morals.
2. (2) Acts that encourage criminal behavior or imply the execution of such behavior.
3. (3) Acts that infringe or possibly infringe upon the legitimate rights of other users, third parties, or the Company, such as intellectual property rights, portrait rights and publicity rights, etc.
4. (4) Acts that infringe or possibly infringe upon the property, credit, honor, or privacy of other users, third parties, or the Company.
5. (5) Acts of disclosing information that can identify other users or third parties without the permission of the users or third parties.
6. (6) Acts of disclosing information related to users that can identify the individual users, unless separately authorized by the Company. (With regard to specific profile pages provided [the space with columns to indicate name, e-mail address, URL, etc.], the Company may rescind the prohibition of the acts listed in this paragraph, provided that the users themselves are responsible for the content posted.)
7. (7) Acts that violate laws and regulations in the area where the Service is provided.
8. (8) Acts that cause disadvantage or damage to other users or third parties.
9. (9) Acts that slander, infringe or discriminate other users/third parties, or acts that encourage them
10. (10) Acts that are intended to promote sales or advertising, unless separately authorized by the Company.
11. (11) Acts that are considered to be intended to excessively or inappropriately induce users to move to specific external websites.
12. (12) Acts that are considered to have adverse effects on children or young people.
13. (13) Linking to adult websites, dating websites, etc. that are considered to be illegal or harmful.
14. (14) Transferring or lending authentication information to a third party, or sharing authentication information with a third party.
15. (15) Acts that interfere with the provision of the Service.
16. (16) Duplicating, modifying, reverse engineering, decompiling or disassembling the Service and application software related to the Service.
17. (17) Acts that interfere with the normal operation of the facilities of the Company to provide the Service (meaning computers and other devices and software used or intended to be used by the Company; the same shall apply hereinafter), or that destroy or damage the equipment or data for services.
18. (18) Distributing harmful computer programs such as computer viruses through or in connection with the Service.
19. （19）Acts that violate theGuidelines on Prohibitionsspecified by the Company.
20. （20）Acts that violate the Terms.
21. （21）Other acts that the Company deems inappropriate.

2. If the Company suffers any damage due to the acts corresponding to any of the items in the preceding paragraph, it may claim compensation from the user.

Article 11. Prohibition of Unauthorized Use of Information

1. We prohibit users from using any information including the text, images, illustrations, videos, etc. on the Service without our permission, except for those specified in these Terms and those explicitly approved on the Service.

2. We prohibit users from editing, copying, or reprinting the description related to the Service (including notifications on the web and newsletter, etc.) without our permission.

3. If the Company suffers any damage due to any user’s violation of Paragraphs 1 or 2, the user shall compensate it for the damage.

Article 12. Setting Links to the Service

We prohibit the setting of links to the Service that fall under any of the following items. If a link is found to correspond to any of the following, we may block access from the website to which the link is set without prior notice.

1. (1) Links from websites containing content that are or may be contrary to public order, morals, or laws.
2. (2) Links that use the frame function or links in other formats that infringe on the Company’s copyright, such as by making it unclear that the content is the Company’s.
3. (3) Links from websites containing content that slanders, defames, or otherwise infringes upon the Company, its products and services, or the users.
4. (4) Commercial links (links for the purpose of making a profit), unless separately authorized by the Company.
5. (5) Other, links from websites that the Company deems inappropriate.

Article 13. Change and Deletion of Posted Content

1.The Company may change or delete the posted content or displayed content without obtaining the consent of the user who posted the content, if the posted content falls under any of the following items. In that case, we may claim compensation for damages caused to us from the user who posted the content, including personnel expenses related to the person who was engaged in the work of changing or deleting the posted content, and other reasonable expenses.

1. （1）When the content violates laws and regulations or the Terms.
2. （2）When the content falls under any of the prohibitions specified in Article 10.
3. （3）When we determine that it is necessary to change or delete the content immediately.

2.Even if a member cancels their membership with the Service, their posted content will not be deleted but will be saved in the Company and displayed on the Service or on other websites.

3.Notwithstanding the provisions of the preceding two paragraphs, we may provide an area within the Service where the users themselves can change, correct, or delete posted content at their discretion. In addition, when determined by the Company, users can delete posts of other users in the area, and users whose posts are changed, modified, or deleted shall not be able to make any objection to the user who changed, modified, or deleted the posts or to the Company.

4.We will not change, modify, or delete the posted content of any user, even if requested to do so by the user themselves. However, this will not apply if the content is changed, modified, or deleted in an area other than that specified in the preceding paragraph, and the content posted and displayed falls under any of the items in Paragraph 1

Article 14. Guarantee on Posting

A user who has posted any content (hereinafter, “poster”) shall guarantee that they have all patent rights, trademark rights, trade secrets, copyrights, and other property rights related to the posted content, and privacy rights including personal information, portrait rights, or other rights, or that they have the licenses, rights, consent, and permissions required to allow the Company to use the posted content specified in the Terms. If any dispute between the Company and a third party occurs, the poster shall solve the problem at their own expense and responsibility, and shall not cause any inconvenience or damage to us.

Article 15. Rights to Posted Content

1. The Company shall be able to save the posted content and use it as appropriate in accordance with the provisions of this Article.

2. The attribution of copyright, etc. of the posted content shall be as specified in the following items.

1. (1) Concerning the rights defined in Articles 18 to 20 of the Copyright Act of Japan, the poster shall not exercise or have a third party exercise rights against the Company or a third party designated by the Company.
2. (2) The rights defined in Articles 21 to 28 of the Copyright Act of Japan are reserved by the poster themselves or the original rights holder. Based on the above, the poster shall grant the Company unlimited and indefinite licenses (sublicensable and transferable) to nonexclusively display, edit, reproduce, reprint, and distribute the posted content all over the world and, if the Company considers it useful, to use the content (including the case of creating and using derivative works such as publication, video, translation, broadcast content, and dramatization) free of charge.

3. The Company shall be able to edit, duplicate, or reprint the posted content based on the license specified in Paragraph 2, and, if the Company considers it useful, to use the content (including the case of creating publication, video, translation, broadcast content, and dramas), and to allow third parties designated by the Company to use the posted content. When using the posted content, the Company shall not be required to make any payment to the poster, and may choose not to display the poster’s ID, nickname or other names, or other information representing the poster.

4. Even after the poster withdraws from the Service, the Company shall be able to use the content posted on the Service by the poster based on the license specified in Paragraph 2. However, it shall be used after taking measures not to display the information that identifies the poster.

5. The Company shall not be liable for any damages caused to the user or a third party due to the use of the posted content.

Article 16. Rights to Posted Text in the Service.

1. Regardless of the provisions of the preceding Article, the attribution of copyright, etc. to posted text in the Service (meaning, from among posted content, text data such as questions, answers, supplementary questions, expressions of thanks, topics, and self-introduction of public profiles) shall be as specified in the following items.

1. (1) The rights defined in Articles 21 to 28 of the Copyright Act of Japan are transferred from the user who posted the text and belong to the Company.
2. (2) Concerning the rights defined in Articles 18 to 20 of the Copyright Act of Japan, the user who posted the text shall not exercise or have a third party exercise the rights against the Company or a third party designated thereby.
3. (3) The Company shall not be required to make any payment to the user who posted the text as consideration for Items (1) and (2).

2. The Company authorizes the user to use the posted text whose copyright belongs to the Company in accordance with Paragraph 1 in the Service or other services provided by the Company.

3. The Company authorizes users who posted texts whose copyright belongs to the Company based on Paragraph 1 to use the posted texts at their options. The provisions of this paragraph do not permit the users to use the posted content of other users (including texts posted by other users).

Article 17. Special Provisions regarding Certified Members

1. When any Certified Member is no longer a person with expertise—for example, if they have lost the required qualifications—we may take measures to cancel the certification of the Certified Member without prior notice and without the consent of the Certified Member.

2. The provisions of Paragraph 3 of Article 9 (Legal Content) shall not be applied to persons who are Certified Members and who have no legal restrictions.

3. The provisions of Item 6 and Item 10 of Paragraph 1 of Article 10 (Prohibitions) shall not apply to Certified Members to the extent explicitly permitted by the Company.

4. The provisions of Article 16 (Rights to Posted Text in the Service) shall not apply to the text in the Service posted by Certified Members, and the provisions of Article 15 (Rights to Posted Content) shall be applied.

Article 18. Temporary Interruption of the Service

The Company may temporarily suspend the provision of the Service without notifying the user in advance for any of the reasons listed below. We shall not be liable for any damages caused by the interruption of the Service.

1. (1) When performing maintenance, inspection, repair, etc. of our system.
2. (2) When the Service cannot be provided due to fire, power failure, or natural disaster.
3. (3) When the Service cannot be provided due to operational or technical reasons.
4. (4) Other cases where we judge that we have no choice but to suspend the Service.

Article 19. Addition, Modification, Suspension, or Abolition of the Service

1. The Company may add or change the content of the Service without prior notice to the user.

2. The Company shall be able to suspend or abolish the Service without prior notice to the user.

3. The Company shall not be liable for any damages caused to a user or a third party based on the preceding two paragraphs.

Article 20. Fee

1. The user shall pay the usage fee specified by the Company by the method prescribed by the Company by the specified due date when using the paid content or functions determined by the Company. In addition, the Company will not refund any usage fees already paid for any reason, unless otherwise specified.

2. If the user does not pay the usage fee specified by the Company by the specified due date, the user shall pay a late charge to the Company at a rate of 14.6% per year from the day after the payment date.

3. The user shall agree that the payment agent will collect the usage fee on behalf of the Company. Since the Company outsources the collection of information charges to a payment agent, it does not have the payment information of the user or the information related to settlement, and will not take any responsibility for the handling of the information or any settlement failure not attributable to the Company.

4. The usage fee does not include communication charges, packet connection charges, internet connection charges, etc. Individual users are responsible for such charges.

Article 21. Elimination of Antisocial Forces

1. In using this Service, the user shall represent that they are not an antisocial force (a generic term for the gangs and related organizations defined in the Japanese “Act on the Prevention of Unjust Organized Crime Group Members,” or for extortionists, groups engaging in criminal activities under the pretext of conducting social campaigns or political activities, special intelligence gangsters, or any other antisocial forces), and shall promise not to be affiliated or involved with or correspond to antisocial forces in the future.

2. If we determine that the user belongs to, corresponds to, or is involved with an antisocial force, we may take necessary measures such as suspending use of the Service by the user, changing the password of the user, cancelling the membership of the user, etc. without prior notice.

Article 22. Use from Abroad

1. When using the Service from outside Japan, the user shall comply with the laws of their country of residence and relevant international treaties.

2. When a user uses the Service from outside Japan, we shall not be liable for any damages caused to the user or to any third party because the use of the Service violates Japanese law but not the laws of the country of residence or related international treaties.

Article 23. Governing Law

The Terms shall be interpreted in accordance with Japanese law.

Article 24. Court of Competent Jurisdiction

If any dispute arises between the Company and the user regarding the Service, the Tokyo District Court of Japan shall be the exclusive agreement jurisdictional court of the first instance.

Article 25. Severability

Even if any provision of the Terms is judged as invalid due to the amendment of laws and regulations, the application of the Consumer Contract Act, or other special laws, applicable laws, etc., the other provisions of the Terms shall not be affected and shall remain in effect.

Article 26. Effect of the Terms

These Terms shall come into effect on July 1st, 2020 and shall take precedence over past terms.

Charter on Human Rights

Last updated：October 11th, 2021
Michio Fukuda, President and Representative Director
OKWAVE, Inc.

Declaration

Respecting all human rights is a prerequisite for corporate activities of OKWAVE, Inc. (hereinafter “we,” “our,” or “us”)under the mission of “Contributing to the world development through the creation of platforms for mutual aid, thus fulfilling people’s physical and mental well-being.” This Charter sets out our approach with respect to human rights and our responsibilities.

Policy

We will promote efforts to respect human rights based on the International Bill of Human Rights (Universal Declaration of Human Rights and the International Covenant on Human Rights), the Declaration of the International Labor Organization on the Fundamental Principles and Rights at Work, and the United Nations’ Guiding Principles on Business and Human Rights (UNGPs).

Scope of Application

The policy applies to all board members and employees of our company. In addition, we encourage our business partners to support and adopt the same policy and work together to promote respect for human rights continuously.

Responsibility to Respect Human Rights

We will continue to provide appropriate education and training to all of our board members and employees, not infringe on the human rights of those affected by our business activities. In addition, if there is an adverse impact on human rights in our business activities, we will take the appropriate measures to correct and continuously preventing them to fulfill our responsibility to respect human rights.