Personal Information and Specified Personal Information Protection Policy

ecobike Inc. recognizes that the protection of personal information and specific personal information of customers, users, and our employees is an important social responsibility in the course of providing cycle sharing services. We have established the following policy for the protection of personal information and specified personal information, and declare that we will make company-wide efforts to ensure the proper handling of such information. 1. Personal information and specified personal information, etc. shall be obtained and provided in an appropriate manner only to the extent necessary for the business entrusted to us and for the employment and personnel management of our employees. In addition, we will not use personal information beyond the scope necessary to achieve the specified purposes of use (use for purposes other than those specified), and will take measures to ensure that this is the case. 2. We will take reasonable security measures through education, audits, and improvements to continuously improve our personal information and specified personal information protection system in order to prevent risks such as unauthorized access to personal information and specified personal information, or loss, destruction, falsification, or leakage of personal information. 3. We will comply with laws, regulations, and other rules applicable to personal information and specified personal information, etc. held by us. 4. We will respond appropriately and promptly to questions and complaints regarding personal information and specified personal information, etc. 5. We will continuously review and improve our personal information and specified personal information protection system in a timely and appropriate manner in light of social needs, individual requests, or the latest information technology trends.

Effective March 1, 2022 ecobike Inc. Representative: Kozo Yuki

Privacy policy regarding your personal information

ecobike Inc. (hereinafter referred to as 'the Company') recognizes the importance of personal information in the operation of its business and believes that its greatest responsibility is to protect it. In order to provide a sense of security and reliability, the following policies have been established, and all employees will be thoroughly informed and personal information will be protected. The Company will handle not only personal information but also information on customers of corporations and other organizations in the same manner as personal information.

1. Compliance with laws and regulations

In order to protect personal information, the Company will comply with laws related to the protection of personal information, guidelines of each ministry and agency, and other related laws and regulations.

2. Handling of personal information

We will handle private personal information through legal and fair means, for providing our cycle sharing service (hereinafter referred to as the "Service"). We will take necessary and appropriate measures to prevent leakage, loss, or damage of that information, and manage the information in secure manner. (1) Acquisition of personal information When acquiring personal information, we will use the lawful and fair means by clarifying the purpose of use and using methods such as websites, written applications, and verbal methods. In addition, the service may be acquired from a service provider or joint user, or may be acquired with the succession of a business due to a merger or other reasons. When answering calls with customers, calls may be recorded for accurate understanding of orders, opinions, requests, inquiries, etc., and for future service improvements. (2) Use and provision of personal information The Company strictly manages personal information, and uses and provides personal information only within the scope of the purpose with the consent of the principal, unless otherwise required by law. In addition, if the purpose is to provide to a third party, the scope of the third party will be specified and specified.

3. Measures for safety management

(1) In order to ensure the accuracy and safety of personal information, the Company will take reasonable measures against risks such as unauthorized access to personal information, leakage of personal information, loss or damage. (2) All employees will handle the personal information entrusted to us under strict information management (limited access rights, internal education and awareness activities, etc.). In addition, with respect to specified personal information, etc., the Company will limit the number of persons in charge of handling such information and will handle such information appropriately in controlled areas and on controlled equipment. (3) For security on the Internet, we use the industry standard SSL (Secure Socket Layer) to encrypt data transmitted over the Internet to prevent interception.

4. About supervision of employees and contractors

(1) In order to ensure safety management measures and other appropriate handling of personal information, the Company will provide employees with necessary education and training. (2) The Company may entrust all or part of the handling of personal information in sales and reception of various products and services, after-sales service, fee-related business, marketing business and other business. In this case, the Company shall select items that are deemed to handle personal information properly, and in the consignment contract, appropriately determine the safety management measures, confidentiality, conditions for subcontracting, and other matters related to the handling of personal information. Implement appropriate supervision.

5. Purpose of use of personal information and specified personal information, etc.

(1) The Company will handle the personal information described in (2) below within the scope necessary to achieve the following purpose of use in providing services. In addition, the Company may use personal information within the scope of the above purpose of use even after the service contract with the customer is terminated. Purpose of use of personal information I. For the implementation of other related services such as service provision / maintenance, after-sales service provision, usage fee calculation / billing, etc. II. For information on products, services, campaigns, events, etc.(Including advertising) of our company, our group companies, and partner companies(Includes third-party providers and joint users of personal information), and for shipping products, gifts, etc. incidental to services, campaigns III. To respond to opinions, requests, inquiries, etc. IV. Analysis / consideration for implementation of various measures such as analysis of usage status, improvement of customer satisfaction, measurement of effect of such measures, information collection / analysis for product / service planning, information collection / improvement for service quality, etc. For analysis and other analysis / survey implementation V. For prevention of fraudulent contracts, fraudulent use and non-payment, and for investigation and response (2) The Company uses the following personal information for the purposes described in (1) above. I. Information such as name, address, date of birth (name, address, date of birth, telephone number, e-mail address, driver's license, passport, Individual Number Card and other personal identification documents.) II. Information on contract details, usage fees, etc. (information on contract details such as contract type, contract date, information on usage fees such as billing amount and payment status, etc.) III. Payment method information (payment method, credit card number, IC card information, etc.) IV. Information on the service content you have applied for (information on the usage history of each service, information on questionnaire surveys, monitor surveys, etc.) V. Other information received along with the provision of various services, such as application application history, opinions, requests, and inquiries VI. Route Historry (e.g., information on the route of the bicycle used by the customer using the service) (3) Personal information handled by the Company in carrying out the work entrusted by other companies will be handled within the scope necessary for carrying out the work. (4) If we recognize that it falls under any of the following items, we may handle personal information for purposes other than the purpose of use while paying the utmost consideration to the rights and interests of the principal. I. When required by law. II. When it is necessary for the protection of human life, body or property, and it is difficult to obtain the consent of the person. III. When it is particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the consent of the person. IV. In cases where it is necessary for a national institution or local public entity or a person entrusted by it to cooperate in carrying out the affairs stipulated by laws and regulations, obtaining the consent of the principal will hinder the execution of the affairs. When there is a risk of effect. (5) The Company may provide the following information for the provision of various compensation services for accidents, etc. that occur during the provision of services. I. Personal information provided by a third party (personal information described in 5. (2) I, II, IV, V and VI above) II. Third-party provider (insurance company listed in our terms of service) III. Purpose of use provided by a third party (for provision of various compensation services for accidents, etc. that occurred during the provision of services) (6) Regardless of the provisions of (1) to (5) above, if we find that any of the following items is applicable, we will give personal information to a third party while paying the utmost consideration to the rights and interests of the principal. May offer. I. When consent is obtained from the person. II. When required by law. III. When it is necessary for the protection of human life, body or property, and it is difficult to obtain the consent of the person. IV. When it is particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the consent of the person. V. In cases where it is necessary for a national institution or local public entity or a person entrusted by it to cooperate in carrying out the affairs stipulated by laws and regulations, obtaining the consent of the principal will hinder the execution of the affairs When there is a risk of effect. (7) We may provide Specified Personal Information, etc. only in cases falling under each item of Article 19 of the My Number Act, and will not provide Specified Personal Information, etc. in any other cases.

6. Shared use

In order to achieve the purposes of use indicated in 5. above, we may share the personal information entrusted to us as described below. In the event that the "Purpose of shared use" and "Handling of Personal Data" are to be revised, the details of such revisions will be publicly announced in advance. (1) Personal information for joint use Personal information described in 5. (2) I, II, IV, V and VI above (2) Scope of joint users Service partner, local governments or persons entrusted by local governments, APAMAN Co., Ltd. (3) Purpose of shared use To provide services (including but not limited to member registration / management, bicycle rental / return, call center support and other related services), after-sales service, and other related operations (4) Name of the person responsible for the management of the above personal information ecobike Inc. Representative: Kozo Yuki (5)Services and Subjects of Shared Use Customers applying for cycle sharing service

7. Inquiries, disclosure and correction of personal information and specified personal information, etc.

(1)The Company will accept inquiries regarding the status of contracts for each service, corrections regarding personal information, etc. at the management office of each service. In addition, we will confirm that you are the customer and that you are the proper agent (A legal representative or an agent entrusted by you. The same applies hereinafter.) in the case of inquiries by the agent. (2) The Company will respond without delay to each service management office when the customer (or agent) requests the disclosure of personal information about the customer. (3) The Company will investigate without delay when requested by the customer (or an agent) to correct (Correction, addition or deletion, suspension of use, or suspension of provision to third parties) personal information regarding the customer. In this case, if the content of the personal information related to the request is not factual, or if the handling of the personal information is deemed inappropriate, correction will be made without delay. (For corrections, etc., please contact the management office of each service.) Even if there is a request for correction, the Company may not correct all or part of the personal information related to the request based on the provisions of laws and regulations. (4) If the principal (or agent) of the personal information requests correction of personal information about the principal, the Company will respond without delay at each service management office.

Procedure for Disclosure, etc. (1) Please contact the management office of each service by e-mail or telephone. (2) Please fill in the required information on the "Application for Disclosure of Personal Information" form that will be sent to you. (3) We will verify your identity based on the personal information in our possession. (4) If the inquiry is made by a proxy, we will confirm the identity of the proxy with a letter of attorney or proof of seal impression. Please enclose this with the "Application for Disclosure of Personal Information". (5) In principle, we accept inquiries by mail using the "Application for Disclosure of Personal Information" form. (6) Personal information provided on the "Application for Disclosure of Personal Information" will be used to contact and verify the identity of the inquiring customer. It will not be used for any other purpose. The documents will be kept for one year after the response to the request for disclosure, etc. is completed, after which they will be destroyed. *The procedures for disclosure, etc. of specified personal information are the same as above, but from the perspective of compliance with the My Number Act, the specified personal information protection administrator will determine whether or not disclosure is possible before disclosing the information.

The Company shall bear the shipping costs for "Requests for Disclosure, etc." and how to collect the shipping costs. Please enclose 800 yen worth of postage stamps with your application.

8. Consultation counter for handling personal information

If you have any opinions or requests regarding our handling of personal information, please contact the following consultation desk. 1-8-1, MARUNOUCHI TRUST TOWER N-19F MARUNOUCHI, CHIYODA-KU, TOKYO, Japan ecobike Inc. E-mail: support(at)ecobike.co.jp

9. About Authorized Personal Information Protection Organizations

We are a target business of JAPHIC Mark Certification Organization, an authorized personal information protection organization under the Act on the Protection of Personal Information. For inquiries about complaints and consultation regarding personal information, please click here. https://japhic.or.jp/office/info *This is not a contact for inquiries about our products and services.

ecobike Inc. Personal Information Protection Manager