PRIVACY POLICY

Good Measure Limited (hereinafter referred to as "Good Measure," "we," "us," or "our") recognizes the importance of protecting personal information. We comply with the Act on the Protection of Personal Information (hereinafter referred to as the "APPI") and endeavor to properly handle and protect your personal information in accordance with the privacy policy set out below (hereinafter referred to as this "Privacy Policy"). Unless otherwise provided in this Privacy Policy, the terms used in this Privacy Policy shall have the meanings as defined in the APPI. The term "the Suntory Group" means the companies of the Suntory Group as listed on its website (https://www.suntory.co.jp/company/group/), together with the Suntory Foundation for the Arts.

1. Collection of and purpose of using Your User Information

1.1 "Your User Information" (this collectively means your personal information and information relating to you that is not classified as personal information, and the same shall apply hereinafter) we collect from you and how we collect Your User Information is described below:

(1) Information you directly provide to us

1. Information you enter when you register or use our service (e.g. your name, address, date of birth, telephone number, email address, customer number, etc. including your information that is verified when you log in if a login function is provided);

2. Information relating to your use of the SAKAZUKI members-only service provided by us, and any other services provided by us (if the names or contents of such services are revised for any reason, such services shall include the services that have been revised and shall be hereinafter collectively referred to as "Our Services"; such information may include data on your use of Our Services, your purchase history, and survey and questionnaire survey results);

3. Information automatically collected from your electronic device or terminal (e.g. information such as cookies, terminal identifier, terminal information, browser type and version, operating system, IP address, usage history, browsing history, log data on advertising exposure, online behavior history, and location data);

4. Your wallet address; and

5. Any other information you provide to us at your option

(2) Information indirectly provided to us by providers of services you use etc. and publicly available information

1. Information relating to your use of other services (e.g. information such as cookies, terminal identifier, terminal information, browser type and version, operating system, IP address, user ID, information about your attributes linking to the foregoing, information about your interests, usage history, browsing history, purchase history, search history, log data on advertising exposure, online behavior history, TV viewing data, research panel data, questionnaire survey results, location data, publicly available information, and any other information about behavior on electronic networks including websites and the Internet and analysis results of such behavior);

2. Information made available on blockchains; and

3. In addition to the above, any other information you agree to provide to us.

(3) Information collected through an Information Collection Module

Information about your attributes, behavior history, log information, crash information, terminal and network information, and any other information relating to your use;

"Information Collection Module" means a program provided by an independent third party other than Good Measure to analyze the display of advertisements, the state and frequency of the use of applications, etc.

1.2 We use Your User Information for the following purposes:

(1) To provide Our Services (including providing a login function (e.g. identity verification, input assistance, and maintaining a connection), verifying user eligibility, linking services, managing and organizing events, requesting questionnaire survey participation, sending products, receiving payments, and providing after-sales service) and to sell our products, including Phygital NFTs, and provide services;

(2) To provide information or respond to inquiries about Our Services (including retaining and managing inquiry records);

(3) To provide information about our products and services (including distributing email newsletters and sending direct mails);

(4) To deal with conduct in violation of our terms and conditions or policy for Our Services (hereinafter referred to as the "T&Cs, etc.");

(5) To notify you of any changes to the T&Cs, etc. for Our Services;

(6) To communicate and deal with you for business purposes and manage contracts and agreements;

(7) To improve Our Services or develop new services by analyzing information about how users use each of Our Services;

(8) To perform outsourced work, such as work relating to Your User Information;

(9) To investigate, prevent, and deal with fraud etc.;

(10) To create, in connection with Our Services, statistical data processed into a format that cannot identify an individual; and

(11) For any other purposes associated with the above.

2. Use of Your User Information

2.1 Except as otherwise permitted by the APPI or any other laws, we will not use Your User Information without your consent as the subject of Your User Information beyond the scope necessary to achieve the purposes of use.

2.2 We will not use Your User Information in a manner that may encourage or induce illegal or improper conduct.

3. Appropriate collection of Your User Information

We will appropriately collect Your User Information and will not collect Your User Information by deception or by any other fraudulent means.

4. Safeguarding your personal information

We will strictly supervise our employees as necessary to ensure that your personal information (including your personal information we intend to collect) is safely and securely protected from any potential loss, destruction, modification, or divulgence. If we outsource all or part of the handling of your personal information to an outsourcing service provider, we will strictly supervise the outsourcing service provider as necessary to ensure that your personal information is safely and securely protected. An overview of our security safeguards to protect retained personal data is establishing our organizational structure, maintaining a personal information ledger, conducting regular inspections and audits, providing staff training, preventing unauthorized access, and monitoring the external environment. We will promptly respond if you contact us at the address given in paragraph 8 below for specific details of the security safeguards.

5. Provision to third parties

Except in cases of joint use in accordance with the provisions of paragraph 6 below or except as otherwise permitted by the APPI, we will not provide your personal information to any third parties without your prior consent.

6. Joint use

6.1 We jointly use Your User Information as described below and provide Your User Information to the following user for joint use:

(1) Items of information jointly used
Your User Information described in paragraph 1.1 above

(2) Scope of our joint user
The Suntory Group

(3) Our joint user's purpose of using Your User Information
The purposes described in paragraph 1.2 above

(4) The name, address, and corporate representative of the entity responsible for managing the above information
Good Measure Limited

(Please see paragraph 8 below for our address and corporate representative.)

6.2 For the purpose of this paragraph, the following information shall be included in Your User Information and subject to joint use as set forth above.

Your personal information we collected when you used a service provided by the Suntory Group before using Our Services if you had used the service provided by the Suntory Group before using Our Services

7. Disclosing, Correcting, etc., and Discontinuing Use, etc. of personal information, etc.

If you request that we disclose to you your personal information and our records of providing your personal information to third parties, or that we correct, add, or delete your personal information (hereinafter referred to as "Correct, etc."), or discontinue our use of, erase, or discontinue our provision to third parties of, your personal information (hereinafter referred to as "Discontinue Use, etc.") in accordance with the provisions of the APPI, we will first verify that you have made the request and will respond to your request in accordance with the APPI. Please note that we will ask you to pay a fee (839 yen per request) when disclosing to you your personal information and our records of providing your personal information to third parties.

8. Inquiries

Please contact us below if you request us to disclose, Correct, etc., or Discontinue Use, etc. of, your personal information, or if you have any feedback, questions, complaints, or any other inquiries about our handling of your personal information:

Name, address, and corporate representative of a business operator handling personal information:

Good Measure Limited (Atsushi Takeuchi, Representative Director)

3-3 Daiba 2-chome, Minato-ku, Tokyo, 135-8631

Email: info@goodmeasure.co.jp

9. Continuous improvement

We review how we use Your User Information from time to time in an effort to make continuous improvements. We may revise this Privacy Policy as and when required.

Established on May 15, 2024