Privacy Policy

Users to Whom the Privacy Policy Applies

This Privacy Policy applies tothe handling of personal data (Article 4(1) of the General Data ProtectionRegulation 2016/679 (the “GDPR”)) of the users who use the services of theCompany (defined as below) from EU, Iceland, Liechtenstein, and Norway (hereinaftercollectively referred to as "EU")

User Personal Data to be Collected

the Company may collect fromthe user(s) (the “User(s)) the following personal data (the “User PersonalData”):・Name (including nicknames andpen names)
・Age or date of birth

・Gender
・Occupation, work history andeducational background
・E-mail address
・Phone number
・Address
・Photos and videos
・Information regarding means ofpayment of the Users, such as credit card, bank accounts or electronic money
・ID used by the Users forexternal services or any other information which the Users authorize theservice providers of such external services to disclose by privacy settings ofsuch external services
・Identification informationgenerated by using cookies
・Information regarding the OSand the terminal used by the User, such as ID generated by the OS, the type ofthe terminal, and the terminal identifier
・History of the Users’activities on the Company’s website, such as time spent on the Company’swebsite, input history, and purchase history
・Usage history of the Company’sapplications such as startup time, input history, and purchase history of theCompany’s applications
・ Location information of the Users

Purpose of Use of the User Personal Data

The Company uses the UserPersonal Data collected from the User for the following purposes, on the legalbases including legitimate interests (Article 6(1)(d) of the GDPR), performanceof contractual obligations (Article 6(1)(b) of the GDPR), the User’s consent(Article 6(1)(a) of the GDPR) or compliance with legal obligations in EU andits member states (Article 6(1)(c) of the GDPR):

When processing is required forthe pursuit of legitimate interests (Article 6(1)(d) of the GDPR)
・to register or verify theUser’s identity and authenticate with the Company’s services (the “Services”)
・to manage the User’s usagehistory of the Services
・to analyze the User’s activityhistory in the Services to maintain and improve the Services
・for market analysis andmarketing
・to inform the User of theServices
・to correspond to actions thatviolate the Company's terms and conditions, laws and regulations
・to inform the changes etc. tothe Company’s terms and conditions
・in addition, to provide,maintain, protect and improve the Services

When processing is required forthe performance of contractual obligations to provide the Services to theUser(Article 6(1)(b) of the GDPR)
・to settle usage fees
・to inform the User of changesto, discontinuance of, termination of, or cancellation of the Services
・to respond to the User’sinquiries

When the User’s express consentis obtained in advance (Article 6(1)(a) of the GDPR)

To deal with any act whichviolates the laws and regulations of EU and its member states which applies tothe Company(Article 6(1)(c) of the GDPR)
・To deal with any act whichviolates the laws and regulations of EU and its member states

Transfer of the User Personal Data to Japan

The Company will transfer theUser Personal Data to Japan for the purposes of fulfilling any contractualobligations with the User or any pre-contractual procedures requested by theUser. Japan has been accredited by the European Commission for the protectionof personal data.

Retention Period

The Company will retain theUser Personal Data for as long as necessary to fulfill the purposes forobtaining and processing the User Personal Data as set out in this PrivacyPolicy. Specific retention periods are decided by taking into account thepurposes for obtaining and processing the User Personal Data, the nature of theUser Personal Data and the necessity of retaining the personal data for legalor business reasons.

User’s Rights

The User has the right underthe GDPR to obtain information regarding processing of the User Personal Data,to access the User Personal Data, to request corrections to or deletion of theUser Personal Data, to restrict the processing of the User Personal data, todata portability, to be free from automated decision-making (includingprofiling) and to object to the processing of the User Personal Data. Inaddition, if the User is dissatisfied with the processing of the User PersonalData, the User may lodge a complaint with the Data Protection SupervisoryAuthority of the User’s country of residence, place of workplace or place of thealleged infringement.

Withdrawal of Consent

The User may withdraw itsconsent to the Company’s use of the User Personal Data at any time by the meansotherwise specified by the Company at the time the Company obtaining the User’sconsent. However, the legality of any action taken based on the User’s consentprior to the withdrawal is not affected by the User’s withdrawal of consent.

Automated Decision-making

The Company does not makedecisions solely based on automated data processing that produces any legal orsimilar material effect on the User.

Amendment to Privacy Policy

The Company will amend thisPrivacy Policy as necessary. In such case, the Company will announce or notify,in an appropriate manner, the timing when the amended Privacy Policy will be enforcedand the contents thereof.

Contact Information

If you have any questionregarding this Privacy Policy, please contact the data administrator at:

info@ikg-fas.com

IKG FAS B.V.
Prof. J.H. Bavincklaan7, 1183ATAmstelveen, The Netherlands

IKG FAS LLC
2F Nihonbashi CET Building, 28-4 Higashi-Nihonbashi 2-chome,Chuo-ku, Tokyo, Japan

Prescribed on 03, 16, 2023