flaggs Inc. ("flaggs") complies with the Act on the Protection of Personal Information and sets forth this Privacy Policy to ensure the appropriate handling of information entrusted by customers. This Privacy Policy applies to the use of applications ("Apps"), websites, and services distributed by flaggs, and where individual privacy policies are provided for specific services, this Privacy Policy shall apply alongside those individual policies.
Supplemental provisions in accordance with regulations applicable outside Japan are stated in the Country-specific Addendum (https://flaggs.jp/addendum/en/) and take precedence as necessary. For the Japanese version of this Privacy Policy, please refer to:https://flaggs.jp/privacypolicy/jp/.

Article 1: Personal Information

In this Privacy Policy, "personal information" refers to information defined as such under the Act on the Protection of Personal Information, which includes information related to a living individual that can identify a specific individual such as name, date of birth, and other descriptions, as well as personal identifiers. It also includes information such as email addresses that are used in connection with a specific individual.
We also obtain the following information by appropriate means and treat it as information similar to personal information:
- User identifiers (e.g., device ID, advertising ID, SNS-linked ID)
- App usage history, behavioral logs, access data
- Payment information (e.g., store ID, transaction ID, payment amount)
- Inquiry details
- Other information provided based on user consent

Article 2: Purpose of Use of Personal Information

flaggs uses personal information to fulfill the purposes set forth below. If personal information is to be used beyond these purposes, we will obtain prior consent through appropriate means. Even in the case of acquisition of personal information due to mergers or other reasons, we will not use such information beyond the scope of previously agreed purposes without obtaining the individual's consent, except in the following cases:
- When required by law
- When it is necessary to protect the life, body, or property of a person and obtaining the individual's consent is difficult
- When it is especially necessary to promote public health or sound upbringing of children and obtaining the individual's consent is difficult
- When it is necessary to cooperate with national or local government agencies performing legally mandated duties, and notifying the individual or making such use public may hinder such duties
- When notifying the individual or making the purposes public may harm the life, body, property, or other rights and interests of the individual or a third party
- When notifying the individual or making the purposes public may harm flaggs’s rights or legitimate interests
- When the purpose of use is considered obvious from the circumstances of collection

The purposes of use include:

1. (1) Provision, planning, development, and improvement of flaggs's content, services, and products; identity verification
2. (2) Statistical analysis, usage trends analysis, and marketing activities such as surveys to improve quality of flaggs’s offerings
3. (3) Responding to inquiries and consultations
4. (4) Notices regarding flaggs’s content, services, and products (including campaigns and sweepstakes); provision and shipping of prizes and gifts ("prizes, etc.")
5. (5) Investigation and prevention of illegal or fraudulent activities, and security management
6. (6) Recruitment screening, communication with applicants, and HR management after hiring
7. (7) Compliance with legal obligations in various countries (e.g., tax reporting, supervisory authority requirements)
   *Additional purposes per country are listed in the Country-specific Addendum(https://flaggs.jp/addendum/en/).

Article 3: Campaigns and Surveys

flaggs may conduct campaigns or surveys ("Campaigns") for users or purchasers ("Users") of its content, services, or products, in line with the purposes described in Article 2. All intellectual property rights (including copyrights) related to Users’ responses shall be transferred to flaggs at the time of submission, and flaggs may use such responses in accordance with this Privacy Policy.
Users shall not exercise moral rights over their responses.If a campaign is held, flaggs may offer prizes, etc. to selected Users ("Winners") and may ask both Users and Winners to register necessary information using flaggs’s designated method. If registration is not made, or is false, or suspected to be false, Winners may not receive the prizes, etc., and flaggs bears no responsibility for any damage arising therefrom.
Users and Winners may not transfer, assign, pledge, or otherwise dispose of rights related to the prizes.

Article 4: Personal Information of Minors

flaggs does not intentionally collect personal information from minors without the consent of a parent or legal guardian.
In the following regions, we do not collect or process minors' personal information without parental consent and perform reasonable age verification as required:
United States: under 13 years old
- EU member states: under 16 years old, or the age specified by each country
- South Korea: under 14 years old

Article 5: Security Management of Personal Information

flaggs implements necessary and appropriate measures to prevent leakage, loss, damage, or unauthorized access to personal information. In addition, flaggs appropriately supervises its employees handling personal information and, when outsourcing handling to external parties, concludes confidentiality agreements aligned with this Privacy Policy and performs necessary and appropriate supervision.

Article 6: Restrictions on Provision to Third Parties

Except when permitted by law (including provision of personal information to contractors within the scope of the purpose of use), flaggs will not provide personal information to third parties without the individual's consent. When transferring or outsourcing to third parties, appropriate contracts (including SCCs for cross-border transfers) will be concluded under the following conditions:
- Explicit consent from the user is obtained
- Required by law
- Outsourcing necessary for service operations (e.g., cloud services, analytics tools)

Article 7: International Data Transfers

flaggs may transfer users’ personal information to countries outside the user's location. In such cases, the following safeguards will be applied:
- Transfers from within the EU: Execution of Standard Contractual Clauses (SCCs)
- Other regions: Measures based on country-specific standards as set out in the Country-specific Addendum (https://flaggs.jp/addendum/en/)

Article 8: User Rights (Disclosure, Correction, Suspension of Use, Deletion, etc.)

flaggs appropriately handles requests from individuals concerning disclosure, correction, suspension of use, or deletion of personal information, in accordance with applicable laws. However, all or part of the requested information may not be disclosed if such disclosure may:
- Harm the life, body, property, or rights of the user or a third party
- Significantly hinder flaggs’s proper operations
- Violate other laws or regulations
In such cases, we will notify the individual of the reason without delay.
If the user requests correction, addition, or deletion ("Correction, etc.") of personal information on the grounds that it is not true, flaggs will investigate without delay and make necessary changes, notifying the user accordingly.
If the user requests suspension or deletion ("Suspension, etc.") of personal information because it exceeds the scope of disclosed purposes or was obtained through fraudulent means, flaggs will investigate and take action as needed. If Suspension, etc. is difficult due to excessive cost or technical reasons, alternative measures will be taken to protect the user's rights and interests.
Please contact us using the online form provided in Article 15. If we decide not to notify, disclose, or suspend information despite a user request, we will explain the reason as much as possible.

Article 9: DPO and Representative Contact

For regions where a Data Protection Officer (DPO) or representative is designated, please refer to the Country-specific Addendum (https://flaggs.jp/addendum/en/)

Article 10: Use of Cookies and Similar Technologies

flaggs’s websites may use cookies and similar technologies (including advertising identifiers such as IDFA and AAID, access logs, IP addresses, etc.).
Users can disable or delete cookies via browser settings. However, doing so may affect available services. For browser setting details, please refer to the respective browser provider’s site.

Article 11: Use of Google Analytics

flaggs may use Google Analytics, a service by Google LLC, to collect data on website usage.
For details on data collection and processing by Google, refer to:
https://www.google.com/intl/ja/policies/privacy/partners/
To opt out of Google Analytics, use the opt-out add-on provided by Google:
https://tools.google.com/dlpage/gaoptout?hl=en

Article 12: Use of Adjust

flaggs uses Adjust, provided by Adjust GmbH, to collect data for ad effectiveness measurement and service quality improvement.
Data such as app user ID, advertising ID, device ID, behavior within the app, ad interaction data, in-app purchase activity, device OS and settings (e.g., language, time zone), device and connection info (e.g., IP address, carrier), and country/region info may be collected and transmitted to Adjust for analytics.
To opt out of Adjust, please refer to:
https://www.adjust.com/ja/forget-device

Article 13: Data Retention Period

flaggs retains personal information only as long as necessary for the intended purpose. When no longer needed, information is promptly deleted or anonymized. If retention is required due to legal obligations or disputes, data will be stored for an appropriate period in accordance with relevant regulations.

Article 14: Revisions

flaggs may revise this Privacy Policy. If the purposes of use of personal information are to be changed, such changes will remain within a reasonably related scope to prior purposes. Major changes will be notified to users or published on flaggs’s corporate site.

Article 15: Contact

For inquiries or requests related to personal information handling, please contact us via the online form available on our corporate site:
https://flaggs.jp/contact/
(Business hours: Weekdays 10:00 AM – 7:00 PM JST)

End

Established: July 1, 2025