covelline, LLC. (hereinafter referred to as "the Company," "we," "us," or "our") has established the following Privacy Policy (hereinafter referred to as "this Policy") regarding the handling of user personal information in connection with the services provided on this website (hereinafter referred to as "the Service").

1. Personal Information

"Personal Information" refers to "personal information" as defined by applicable privacy laws and means information relating to a living individual that can be used to identify that specific individual. This includes:

• Name, date of birth, address, phone number, contact information, and other descriptions that can identify a specific individual

2. Collection Methods

We collect personal information through the following methods:

1. When users register for our services, we may request the following information:

   • Name
   • Date of birth
   • Address
   • Phone number
   • Email address
   • Bank account number
   • Credit card information

2. Transaction records and payment information (including users' personal information) may be collected from our partners (information providers, advertisers, ad delivery destinations, etc.)

3. Purpose of Collection and Use

We collect and use personal information for the following purposes:

• To provide and operate our services
• To respond to user inquiries (including identity verification)
• To send notifications about new features, updates, campaigns of services being used, and information about other services offered by our company
• To send necessary communications such as maintenance information and important notices
• To identify users who violate our Terms of Service or attempt to use the service for fraudulent or improper purposes
• To allow users to view, modify, delete their registration information, and check their usage status
• To process payments for paid services
• For purposes incidental to the above purposes

We do not use any user data obtained through the Google Workspace API for the development, training, or improvement of general artificial intelligence (AI) or machine learning (ML) models.

4. Cookies, Analytics, and Advertising Technologies

We use cookies and similar technologies to send the information described below to the following third-party services for service quality improvement, usage analysis, and advertising delivery.

1. Google Analytics 4 (Google LLC)

2. Google Ads (Google LLC)

3. Meta Pixel (Meta Platforms, Inc.)

4. Yahoo Ads (LY Corporation)

Opting Out

If you do not wish to have your data collected by these services, you can opt out through the following methods:

• Adjust cookie settings on our website
• Use the "Do Not Sell or Share My Personal Information" link in the footer of our website
• Disable cookies in your browser settings
• Use the opt-out tools provided by each service

5. Privacy Rights for California Residents

This section applies to California residents pursuant to the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

Categories of Personal Information Collected

We may collect the following categories of personal information:

• Identifiers (name, email address, IP address, etc.)
• Internet or other electronic network activity information (browsing history, search history, interaction information with websites)
• Geolocation data (approximate regional information inferred from IP address)

Sale and Sharing of Personal Information

Under CCPA/CPRA, "sale" refers to providing personal information to a third party in exchange for monetary consideration, and "sharing" refers to providing personal information to a third party for cross-context behavioral advertising (targeted advertising) purposes.

We do not "sell" personal information. However, we may "share" personal information for targeted advertising purposes through the advertising services described in Section 4.

Rights of California Residents

California residents have the following rights:

• Right to Know: The right to know the categories and specific pieces of personal information we have collected
• Right to Delete: The right to request deletion of personal information we hold
• Right to Opt-Out: The right to opt out of the "sharing" of personal information
• Right to Correct: The right to request correction of inaccurate personal information
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising these rights

How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided in Section 14. We will respond to your request within 45 days.

6. International Transfer of Personal Information

In connection with our use of the third-party services described in Section 4, we may transfer your personal information outside of Japan (primarily to the United States).

The destination countries may not have personal information protection systems equivalent to Japan's. However, we ensure appropriate protection through the following measures:

• Entering into contracts with recipient entities regarding the appropriate handling of personal information
• Confirming the privacy policies and security systems of recipient entities

7. Changes to Purpose of Use

We may change the purpose of use of personal information only to the extent that the changed purpose can be reasonably considered to be related to the original purpose. If such changes occur, we will notify users or announce the changes on our website through one of the following methods:

• Notification through our designated method
• Announcement on our website

8. Security Measures

We implement appropriate security measures to protect personal information against risks such as loss, destruction, alteration, and leakage:

• We implement technical and organizational security measures to prevent unauthorized access, loss, destruction, alteration, and leakage of personal information
• We use encryption technology to protect data during transmission and storage
• We restrict access to personal information to only those employees who require it for business purposes through access controls
• We conduct regular security reviews and audits to continuously improve our security measures
• We provide education and training to our employees regarding the protection of personal information

Through these security measures, we strive to protect the confidentiality of your personal information.

9. Disclosure to Third Parties

We will not provide personal information to third parties without obtaining the user's consent in advance, except in the following cases (unless otherwise permitted by applicable privacy laws):

1. When necessary for the protection of a person's life, body, or property, and obtaining the individual's consent is difficult
2. When particularly necessary for improving public health or promoting the sound growth of children, and obtaining the individual's consent is difficult
3. When a national government organization, local government, or contractor is performing legally mandated duties, and obtaining the individual's consent may impede the performance of those duties
4. When we have previously disclosed or announced the following matters and filed a notification with the Personal Information Protection Commission:
   • That the purpose of use includes providing information to third parties
   • The categories of data provided to third parties
   • The means or method of provision
   • That provision will be stopped upon request from the individual, and how such requests can be made

The following cases are not considered disclosure to third parties:

• When we outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use
• When personal information is provided due to a business transfer, merger, or other succession of business
• When personal information is used jointly with specific parties (provided that users are notified in advance or can easily find out about the fact of joint use, the items of personal information being jointly used, the scope of joint users, the purpose of use, and the name or title of the party responsible for management)

10. Disclosure of Personal Information

When requested by an individual to disclose their personal information, we will do so without delay. However, we may not disclose all or part of the information in the following cases, and we will notify the individual promptly if disclosure is denied. A fee of 1,000 yen per request will be charged for disclosure of personal information.

• When disclosure may harm the life, body, property, or other rights or interests of the individual or a third party
• When disclosure may significantly interfere with the proper conduct of our business
• When disclosure would violate other laws or regulations

As a general rule, we do not disclose non-personal information such as browsing history or characteristic information.

11. Correction and Deletion of Personal Information

Users may request correction, addition, or deletion (hereinafter referred to as "correction, etc.") of their personal information held by us through the prescribed procedure if it contains errors.

When we determine that a user's request is legitimate, we will promptly implement the correction, etc., and notify the user accordingly.

12. Suspension of Use of Personal Information

When requested by an individual to suspend the use of or delete their personal information (hereinafter referred to as "suspension of use, etc.") for the following reasons, we will promptly conduct the necessary investigation:

• When the information is being handled beyond the scope of the stated purpose of use
• When the information was acquired through deceptive or otherwise improper means

Based on the results of the investigation, if we determine that suspension of use, etc., is necessary, or if we decide not to implement suspension of use, etc., we will promptly take action and notify the user accordingly.

However, if suspension of use, etc., would require significant cost or is otherwise difficult to implement, we may instead take alternative measures to protect the user's rights and interests when such alternative measures are available.

13. Changes to this Privacy Policy

The content of this Policy may be changed without notice to users, except for matters stipulated by law or otherwise specified in this Policy.

The revised Privacy Policy will be effective from the time it is posted on this website (unless otherwise specified).

14. Contact Information

For inquiries regarding this Policy, please contact us at:

• covelline, LLC.
• Address: Towa Ikebukuro Coop 801, 5-8-9 Nishi-Ikebukuro, Toshima-ku, Tokyo
• Representative Member: Ryohei Kameyama
• Email address: info@covelline.com