1. Data Controller’s Identity

   The Company collects and processes your personal data as a data controller. The Company’s details are as follows:

   Company Name	Neos Corporation
   Address	Sumitomo Fudosan Kanda Building 2, 10F, 1-23-1 Kanda Suda-cho, Chiyoda-ku, Tokyo

2. Personal Data that the Company Collects

   On the Website, the Company collects your personal data listed below from the terminals in your use, including any data related to you and collected or generated through automated technology, such as cookies or any technology similar thereto:

   • Information such as your access history and search history in connection with the Website or any other website; and
   • Device information, cookie information and anonymised ID, IP address, location (estimated geographical location based on the IP address) information as well as technical data including specific identification information.

   If you are located in the EU or the UK, you may refuse the Company acquiring certain parts of your personal data, by changing your cookie settings; provided, however, that with regard to certain other parts of your personal data, the Company will always acquire the same when you use the Website.

3. Purposes of Use and Legal Basis for Processing

   The Company’s purposes of using your personal data, and the legal basis therefor, in the event of the EU and UK GDPRs being applicable, shall be as follows:

4. Sharing of Your Personal Data with Third Parties

   Purpose	Legal Basis
   To provide any service on the Website; and To improve qualities of the Website and any other service of the Company.	Such processing is necessary for the Company’s legitimate interests (in order to provide you with high-quality service).
   To address any act against terms, general conditions, policy or any other related provisions pertaining to the Company’s services.	Such processing is necessary for the Company’s legitimate interests (in order for the Company to protect its rights and perform its legal obligations).
   To distribute personalized advertisements of products or content to you, taking into account your trends such as your tastes and preferences learnt through combining and analysing your personal data	Your consent.

   Your personal data may be shared with any third party under the following certain circumstances:

   • Service providers

     The Company may share your personal data with the service providers listed below, in order to allow such service providers to perform any service on behalf of the Company, or to provide you with the Company’s services or products:

     • Infrastructure and IT service providers; or
     • Marketing, advertising or telecommunications business operators.
   • Third parties permitted by law

     The Company may be required to disclose or share your personal data, under certain circumstances, in order to comply with legal obligations (e.g., the Company may disclose personal data in response to any request made by the police, or any governmental, judicial or administrative body).

     The Company may disclose your personal data to a third party, when such disclosure is permitted by law and is necessary for protection of the Company’s rights, national security, execution of law, the Company’s performance of agreements, or protection of your rights or public rights.

   • Third parties related to business transfer

     The Company may assign your personal data to any third party in connection with organisation restructuring such as organisation change, company split and merger, or business transfer to or from the Company; provided, however, that the Company acknowledges in advance that the relevant assignee will process your personal data in accordance with this Policy.

5. Transfer of Personal Data to Third Countries

   The Company may transfer your personal data to any country or region which is not the country or region where you reside (i.e. if you reside in the EU, any country or region outside the EU), including Japan, for any of the purposes listed in “3. Purposes of Use and Legal Basis for Processing” (the “Extraterritorial Transfer”).

   In the event of the Extraterritorial Transfer of your personal data, in accordance with the applicable laws and regulations, the Company will ensure a sufficient level of protection and take necessary measures for personal data protection such as execution of standard contractual clauses set forth by a supervisory authority. If you request further information such as copies of such standard contractual clauses, etc., please send any relevant document to the address specified in “10. Inquiries” or contact us via the email address also specified therein.

6. Personal Data Protection

   The Company strictly complies with laws and regulations concerning personal data processing, according to the confidentiality of personal data, as well as takes technical, organisational, physical and personnel security measures in order to protect personal data held by the Company from unauthorised access, leakage, falsification or damage.

7. Cookies

   The Company collects information pertaining to your access to the services provided by the Company, using cookies, pixel, beacon, tag and any other technologies similar thereto. The Company uses such collected information for any analysis for the purpose of improvement of services and distribution of content in line with your interest. For further information regarding the types and purposes of use of cookies, please confirm the details in “Privacy Settings” which start when you click the gear mark shown at the left bottom of the Website:

   f you are located in the EU, the UK or any other country or region designated by the Company, the Company will use its cookies after obtaining your appropriate consent thereto in accordance with the laws and regulations regarding data protection and privacy, including the EU and UK GDPRs.
   You may change whether or not you provide the Company with your consent pertaining to the Company’s use of cookies, depending on the type of cookies, in “Privacy Settings” which start when you click the gear mark shown at the left bottom of the Website.

   If you do not wish your information to be collected through cookies, you may restrict or suspend the cookie function through “Privacy Settings” which start when you click the gear mark shown at the left bottom of the Website or browser setting; provided, however, that if you block cookies, certain inconvenience may arise, for example, you may become unable to use all or any part of the functions of the Website.
   The Company collects and analyses information regarding your access, using the services and tools mentioned below. Such information may also be provided to the service provider mentioned below and used in order to distribute any content to you.

   • Google Analytics:
     https://policies.google.com/technologies/partner-sites?hl=en-GB
   • Please check how to opt out from Google Analytics here:
     https://tools.google.com/dlpage/gaoptout?hl=en-GB
8. Your Rights

   In accordance with applicable laws and regulations, you may have the following rights. If you reside in the EU or the UK, you have the following rights which need to be exercised in accordance with requirements and procedures set forth by the applicable data protection law:

   • Access You have the right to obtain confirmation from the Company concerning whether or not your personal data is processed, and the right to request your access to such personal data. You also have the right to obtain a copy of such personal data being processed.
   • Correction You have the right to correct incomplete or incorrect personal data pertaining to you which is processed by the Company.
   • Deletion You have the right to request deletion of your personal data processed by the Company; provided, however, that the Company is not obliged to satisfy your request for deletion, if the Company needs to retain such personal data in order to comply with legal obligations or to file or defend a lawsuit.
   • Restriction If you believe that your personal data is incorrect, that the Company’s processing thereof is illegal, or that the Company no longer needs to process your personal data for a specific purpose, you have the right to restrict the Company’s processing of such personal data, unless the Company is required not to delete the relevant data due to its legal obligation or any other obligations, or unless you do not wish the relevant data to be deleted.
   • Portability : In the event that: (i) the Company processes your personal data based on your consent or in order to perform any contract between you and the Company; and (ii) such processing is performed in an automated method, you have the right to request that the Company provides you with such personal data in structured electronic form and sends the same to any other data controller.
   • Filing of objection If the Company processes your personal data with its legitimate interests as the grounds therefor, you have the right to file an objection to such processing on the grounds relating to your specific circumstances. The Company will satisfy your request, unless the Company has any unavoidable and reasonable reason which supersedes your interest and rights, or unless the Company needs to continuously process such personal data in order to file or defend any lawsuit.
   • Withdrawal of consent When you consent to the Company’s processing of your personal data, you have the right to withdraw such consent at any time without being required to pay any costs.
     Moreover, if you consider that the Company does not comply with applicable data protection law, you have the right to file a complaint to the local data protection supervisory body, in accordance with applicable law.
     If you wish to exercise any of such rights, please contact us via the email address specified in “10. Inquiries”. The Company may request that you provide the Company with any evidence of your identity or additional information before responding to your request, for the purpose of your privacy and security. The Company will exert its best efforts to provide the requested information or make the requested change, in accordance with applicable law.
9. Retention Period for Personal Data

   The Company normally retains your personal data for the period reasonably necessary for the purposes set forth in “3. Purposes of Use and Legal Basis for Processing”. Furthermore, your personal data will be retained for the necessary period to handle any dispute involving you. Such personal data may be required to be retained for a longer period in accordance with any law or regulation applicable to the Company’s business, depending on the situation. If possible, the Company will endeavour to anonymise such information or remove any unnecessary identifier from the record which needs to be retained beyond the initial retention period. When your personal data becomes no longer necessary, the Company will promptly delete or anonymise the same.

10. Inquiries

    For any request, inquiry, etc., as described above regarding the processing of personal data, please make contact as set forth below:

    Contact information for personal data:
    Person responsible for personal data management, Neos Corporation　
    e-mail: info@neoscorp.jp

11. Updates to this Policy

    The Company may update this Policy from time to time. The Company holds the right to make any revision, addition or deletion to any part of this Policy. When the Company decides on any change to this Policy, the Company will notify you to that effect on the Website.

This Policy was last updated on 3, Feb, 2025.