Privacy Policy

1. Acquiring Personal Information

   The personal information acquired by the company is for the primary purpose of providing our services to you and it will be collected in a manner that is both lawful and fair.

2. Use of Personal Information

   Personal Information acquired by us will be properly maintained and used only for the purposes for which it is provided in the conduct of our business, except where permitted by law.

3. Proper Management of Personal Information

   To ensure the safety and accuracy of Personal Information, we will take appropriate security measures to prevent unauthorized access, leaks, loss or damage of personal information. In addition, in the event of security breach incidents being reported in the market or upon customers’ requests for security improvement, we shall promptly take corrective actions and strive to enhance security.

4. Legal Compliance

   The company shall comply with national legal requirements, guidelines and other regulations relating to personal information. We shall also endeavor to ensure that our management system complies with these legal requirements, national guidelines and other regulations at all times.

5. Continuous Improvement

   In accordance with national legal requirements, guidelines and other regulations relating to personal information, we strive to implement continuous improvements to our management system to ensure that it remains in the best possible condition at all times.

6. Handling of Complaints and Inquiries regarding Privacy Policy

   We shall provide an appropriate system to respond to complaints and inquiries regarding personal information in accordance with our rules. For inquiries, please contact 'Personal Information (Specified Personal Information) Inquiry Desk' at the bottom of this page.

Mutsumi Ota
CEO
giftee Group, Inc.
Date of establishment: 1 July 2026

The personal information is handled in the company as follows.

1. Company Name

   giftee Group, Inc.

2. Manager in Charge of Personal Information Protection

   Manager, General Affairs Group, Corporate Headquarters

3. Purpose of Use of Personal Information

   The personal information we acquire will be handled for the following purposes, except where permitted by law.

   1. Customer Information and Membership Information

      1. To be used for customer management, membership management and operation of our services.
      2. To be used for the implementation of campaigns, surveys, and distribution of email magazines, etc.
      3. To provide and deliver services and products purchased, and to provide after-sales services for such services and products.
      4. To carry out information analysis and research for the purpose of improving and enhancing the services we provide.

   2. Business Partner Information

      1. To contact, respond to and manage our business partners (including potential business partners; the same applies hereinafter)
      2. To manage applications for our services and any other information from our business partners.
      3. To carry out activities with respect to distributing notice of campaigns and surveys and email magazines, etc.
      4. To carry out information analysis and research for the purpose of improving and enhancing the services we provide.

   3. Personal Information Acquired through Entrusted Business

      1. To carry out services entrusted by business partners (including the local government, by which the company is entrusted with the handling of personal information) for providing and delivering products, and for providing after-sales services for such products.
      2. To distribute information including notice of campaigns and surveys and confirmation of purchase histories and any information in the course of the entrusted business.
      3. To carry out information analysis and research using the commissioned information when requested by the entruster.
      4. To develop, operate and maintain our services and systems provided in the entrusted business.

   4. Recruitment Information

      1. To receive recruitment applications.
      2. To contact applicants (notice of screening results, delivery of recruitment documents, etc.).
      3. To conduct recruitment screening.
      4. To analyze information on past applicants to set up job information and recruiting positions.

   5. Employee Information

      1. Human resource management (personnel change, appraisal for salary increase/promotion, and employee training)
      2. Labor management and payroll management (time attendance management, payment of salary/bonus, withholding, and year-end adjustment)
      3. Welfare (employment insurance, medical insurance, employees’ pension insurance, and management of participation in and maintenance of property savings)
      4. Health management (conduct periodical medical checkups, store and manage medical checkup record, and support long-term absentees)
      5. Safety management (theft prevention by maintaining access record)
      6. Sales and Public Relations (for promoting sales activities and recruitment)

   6. Personal Information Related to Inquiries

      To respond to and contact customers / business partners in the event of inquiries.

   7. Shareholder Information

      1. To exercise rights and perform obligations under the Companies Act and other laws and regulations.
      2. To manage shareholders, including preparing shareholder data in accordance with prescribed standards under various laws and regulations.
      3. To implement various measures to facilitate the relationship between shareholders and the company.
      4. To respond to and handle various inquiries.

   8. Pseudonymized Information

      Personal information provided by customers when using the services provided by us as well as personal information entrusted by business partners for commissioned work, may be pseudonymized for the purpose of analysis of the use of the services, to ensure that the persons cannot be identified.

4. Provision of Personal Information, etc. to Third Party

   The company appropriately manages the acquired personal information and the information relating to individuals who may be identified by the recipient and does not provide personal information, etc. to any third parties, provided that:

   1. the individuals consent to the disclosure;
   2. exceptions are permitted by law including the cases that;
      1. the disclosure is required by law;
      2. the disclosure is required to protect the life or property of the person (including a legal entity) if there is no possible way to obtain the consent of the person;
      3. the disclosure is specifically required to improve public health or to promote sound upbringing of children if there is difficulty in obtaining the consent from the person;
      4. the disclosure is required to cooperate with local government or its entrustee in carrying out the affairs prescribed by law if obtaining the consent of the person may hinder the performance of the relevant duties; and
      5. the disclosure is required for academic study and research by an academic research institution, etc. (a university or other organization intended for academic research or those who belong to such an organization) and the third party needs to handle such personal information, etc. for the purpose of academic research (excluding the case where there is a risk of unjustified infringement of the rights and interests of the person)

   3. the disclosure is deemed necessary in the operation of our services.

      In the following cases, we may provide personal and personal-related information to any third parties for the operation of our services, and the personal information we provide to the third parties may be handled as personal data by the recipient:

      1. In case we are requested by financial institutions, credit card companies, or any other entities making settlement or agency services on behalf thereof to cooperate in an investigation of fraudulent payments, we may provide the information entered directly by you and track the record of your usage of the products, including digital gifts. In such cases, the data may be treated as personal data by the recipient for the purpose of conducting fraudulent payment investigations.
      2. For the purpose of detecting and preventing fraudulent use by credit card companies, we may provide to the credit card company you use the information we collect from you, including your IP address and device information. If the credit card company you use is located in a foreign country, such information may be transferred to the country where the credit card company is located. Because we cannot identify the credit card company and its country of location from the information collected from you, we cannot provide the following information about personal information protection measures:

         the name of the foreign country in which the recipient is located; information on the personal information protection system of that country; and the personal information protection measures of the credit card company.

         The website of the Personal Information Protection Commission ( https://www.ppc.go.jp/ ) provides information on personal information protection systems in each country.

      If you are a minor, you must obtain the consent of your parent or guardian before using this service.

5. Joint Use of Personal Information

   In accordance with the provisions of laws and regulations, the company may share personal information of customers lawfully and fairly acquired by the company as described below. The customers shall include not only those who had or have contracts and transactions with the company in the past or at present, but also includes potential customers who are expected to contract and trade with the company in the future. If those customers are corporations, the contact persons of the corporations shall also be included.

   1. Sharing of Personal Information

      1. Items of Information to be shared

         The items of information to be shared: names, postal codes, addresses, telephone numbers, fax numbers, email addresses, corporate names, job titles, department names, and transaction-related information of customers, business partners, job applicants, and our employees.

      2. Scope of those Sharing Personal Information

         giftee Group, Inc. and subsidiaries of giftee Group, Inc. with head offices located in Japan. For a list of group companies, please refer to the company overview.

         https://giftee-group.com/en/group/

      3. Purpose for Sharing Personal Information

         To enable our entire corporate group, including giftee Group, Inc. to provide services and conduct other business operations for our customers, and to build and strengthen relationships with customers.

      4. The party responsible for management of personal information

         Company responsible for data management: giftee Group, Inc.
         Please refer to the following link for the company profile, the name of the representative and the location.

         https://giftee-group.com/en/company/outline/

6. Entrustment of Personal Information

   In case of entrusting business to a third party, all or part of personal information will be entrusted to the entrustee to the extent necessary for the execution of the business; provided, however, that the company shall impose obligations of confidentiality, which are the same as those the company owes to the entrustee, and will strive to conduct necessary and appropriate supervision to ensure the personal information will be safely managed.

7. Disclosure of Personal Information

   The company shall respond to requests for disclosure, etc. of personal information (notification of purpose of use; disclosure of information or record provided to the third parties; correction, addition, deletion of contents; and cease of use of or of provision of information to the third parties). Please contact "Personal Information (Specific Personal Information) Inquiry Desk" at the bottom of this page.

8. Voluntary Provision of Personal Information

   In order to provide various services, we have consent from users to voluntarily provide personal information deemed necessary by the company. If the users do not wish to provide personal information, there is a possibility that some services may not be available.

1. Procedures for Disclosure and other requests

   We shall respond to your request for disclosure, etc. of personal information (disclosure, correction, addition or deletion, and cease of use of information or record provided to third parties, and erasure of and cease of provision of such information or record provided to the third parties) in any one of the procedures described below. Please note that we may not respond if your request does not follow these procedures.

   1. Apply for disclosure at us.
      Please contact "Personal Information (Specific Personal Information) Inquiry Desk" at the bottom of this page. We will send you the "Request Form for Disclosure, etc. of Personal Information (Self)".

   2. Send the following documents to us by post

      1. "Request Form for Disclosure, etc. of Personal Information (Self)"
      2. A copy of the identification document (*1).
      3. Fees (Please refer to Item 10. Fees and Payment Methods）

      In the case of making the request through a representative, please include an identification document of the representative (*2).
      (Please black out a registered domicile area.)

      ※1 [Identification Documents of Requestor]
      Any one of the following documents is required. Please ensure that the name and address of the requestor match those in the “Request Form for Disclosure, etc. of Personal Information (Self)
      Also, please black out the sections other than name and address, such as registered domicile, insurance number, and individual number.

      • Driver's license
      • Passport
      • Health insurance card
      • My number card (individual number card)

      ※2 [Identification Documents of Representative]

      1. In the case of a legal representative of a minor or ward

         1. Documents that can verify the identity of the representative (*1)
         2. One copy of the family register of the requester (in the case of minors) or the registration certificate prescribed in Article 10 of Ward Registration Act (in the case of a ward).

      2. In the case of authorized representative

         1. Documents that can verify the identity of the representative (*1)
         2. Power of attorney with the seal of the requester (original)

         <Postal address>
         Attention to: Manager, General Affairs Group, Corporate Headquarters, giftee Group, Inc.
         12th Floor, Higashigotanda Square, 2-10-2 Higashigotanda, Shinagawa-ku, Tokyo 141-0022

         ※The company shall destroy the "Request Form for Disclosure, etc. of Personal Information (Self)" upon completing the procedures.

2. Method of Disclosure, etc.

   The information shall be disclosed in writing or electromagnetic record.

3. Notification of the result of Request for Disclosure, etc.

   1. We will notify you in writing of the contents amended by the company as a result of addition, correction, or deletion in accordance with the request for disclosure, etc.
   2. We will notify you in writing or electronically whether we will accept your requests for ceasing to use, erasing or ceasing to provide information to third parties.

4. Non-disclosure reasons

   In the event that any of Conditions 1-8 below is valid, we reject the request for disclosure, etc. We will notify you in writing of the basis and reason for rejecting the request.

   1. When the name and address of the requester listed in the "Request Form for Disclosure, etc. of Personal Information (Self)" do not match those listed in the identification documents.
   2. 4.2 When the name and address of the representative listed in the "Request Form for Disclosure, etc. of Personal Information (Self)" do not match the name and address listed in the identification documents.
   3. When the information requested for disclosure, etc. does not fall under the personal information subject to disclosure.
   4. When we are not legally obliged to cease to use, erase or cease to provide to third parties the personal information subject to such disclosure.
   5. When there is a risk of harm to the life, body, or property of the requester or a third party by revealing the existence of the personal information requested for disclosure, etc.
   6. When there is a risk of promoting or inducing illegal or unjust acts by revealing the existence of the personal information requested for disclosure, etc.
   7. When there is a risk of compromising the security of the country, damaging the relationship of trust with other countries or international organizations, or causing disadvantage in negotiation by revealing the existence of the personal information requested for disclosure, etc.
   8. When there is a risk of hindering the prevention, suppression or investigation of crimes or the maintenance of any other public safety and order by revealing the existence of the personal information requested for disclosure, etc.

5. Fees and Payment Methods

   A fee of 1,500 yen is required per request for disclosure of personal information subject to disclosure or record provided to any third-parties.
   You also need to pay the actual postage fees arising out of the disclosure (including general registered mail, certified mail with delivery restricted to the addressee, etc.).