Japan (APPI) Supplement

The Act on the Protection of Personal Information (Act No. 57 of 2003, as amended, “APPI”) applies extraterritorially to operators outside Japan that handle personal information of persons in Japan in connection with the supply of goods or services to those persons (APPI Art. 171). We accept that the APPI applies to our processing of personal information about users in Japan.

Local representative. APPI Art. 50 obliges a foreign business operator that handles personal information of persons in Japan in a manner that meets certain thresholds to designate a representative in Japan. Our current processing volume does not meet those thresholds; if it does in the future, we will designate a representative and publish the appointment in this Supplement before relying on it.

We handle the categories of personal information described in the global Privacy Policy §3. We do not handle “special care-required personal information” (要配慮個人情報) within the meaning of APPI Art. 2(3) (race, creed, social status, medical history, criminal record, fact of being a victim of crime, etc.).

We use personal information for the following specified purposes, in accordance with APPI Art. 17:

• To provide and maintain the Service you have subscribed to.
• To bill, invoice, and process payments.
• To respond to your inquiries.
• To prevent fraud, abuse, and security incidents.
• To comply with applicable laws.
• To send service-related notifications and, on opt-in, marketing emails.

We will not use your personal information beyond the scope necessary to achieve these purposes without your consent (APPI Art. 18).

We do not provide personal information to third parties for their own purposes without your consent (APPI Art. 27), except as permitted by law (legal obligation, protection of life or property, etc.) and except for provision to entrusted parties (commissioned processors) under Art. 27(5).

Cross-border transfers (APPI Art. 28). Your personal information is transferred to, and processed in, the United States and the European Union. We provide you with the following information in compliance with Art. 28(2):

• Destination countries: United States; European Union member states; United Kingdom; Switzerland.
• Personal-information protection systems in those countries: EU/UK/CH provide comprehensive protection considered to be at a level equivalent to the APPI; the United States does not have a single comprehensive law, and protection is achieved through sectoral law and contractual measures.
• Measures taken by the recipient: contractual obligations to apply standards comparable to the APPI; technical and organisational safeguards described in the global Privacy Policy §13.

• Notification of purpose of use (Art. 32).
• Disclosure of retained personal data (Art. 33), including by electronic means.
• Correction, addition, or deletion (Art. 34).
• Cease of use or erasure (Art. 35) where data has been processed in violation of the Act or beyond the necessary scope.
• Cease of third-party provision (Art. 35).
• Records of third-party provision and receipt (Art. 29 and 30).

We respond to verified requests without undue delay. No fee is charged for routine requests; we will inform you in advance if a fee applies for repeated or excessive requests.

Where a leak, loss, or damage of personal data occurs that is likely to harm the rights and interests of an individual, we will notify the Personal Information Protection Commission (PPC) and the affected individuals as required by APPI Art. 26 and the PPC rules thereunder.

You may submit a complaint or request mediation through the Personal Information Protection Commission — ppc.go.jp — at any time. We ask that you contact us first.

Email privacy@poigeo.app. Operator: [Şirket — kuruluş aşamasında].