Privacy Policy

1. This policy applies to every situation in which we handle personal information in the business of the Service, including the Service's website (https://addack.com/, the "Site"), each of the Service's offerings (PR through game media, influencer PR, and the Pre-launch Survey), the performance report (ADDACK REPORT) and tracking links.
2. The terms "personal information", "personal-related information", "personal data" and "retained personal data" in this policy follow the definitions in the APPI. For example, a name, an email address, and an affiliation or contact details linked to a name or an activity name are "personal information".

We collect the following information by lawful and fair means.

(1) Information from prospective clients and clients

• Contact form: company or studio name (optional), name, email address, game URL (optional), budget (optional), and the details of your inquiry
• Email, online meetings, chat and other communications: name, affiliation, job title, contact details, and the content of the communications. If we record an online meeting (video or audio), we will tell you in advance and ask for your consent.
• Contracts and transactions: names of the contract manager and the billing party, address, contact details, contract terms, records of your agreement to the contract (confirmation emails, electronically signed documents, etc.), and information on invoices, payments and refunds
• Approval of campaigns: When you approve an influencer PR campaign with the approval button in the email we send you (or on the page it links to), we keep the date and time of the approval, the email address to which we sent the approval request, and a copy of the details of the approved campaign as a record of the approval. This record does not include your IP address.
• Performance report: the email address used to log in, login records (date and time, IP address, browser type), and records of viewing the report. Passwords are stored in a form that cannot be reversed. You will be asked to change your initial password at your first login, so we cannot know the password after it has been changed.
• Payments: Payments are accepted by bank transfer for clients in Japan and by international bank transfer for clients outside Japan. Payments from outside Japan are received in an account with Wise (Wise Payments Japan K.K.). We collect the information needed to confirm payment, such as the name of the remitter, the amount, the transfer date and the sending bank.

(2) Information about companies we approach for business

To introduce the Service, we research and record information that companies publish on their websites and elsewhere (company name, location, business description, published contact details, and the names and job titles of contact persons, etc.). We also keep records of our communications with them.

(3) Information about influencers and other partners

• Publicly available information: activity name, channel or account name, public profile, published contact details (email address, social media accounts, etc.), and public statistics such as the number of channel subscribers and the views, likes and comments on posted videos. To discuss projects, we research and record information published on YouTube and elsewhere.
• Information from the individual or their agency: legal name, contact details, agency, fee and working conditions
• Contracts and payments: the name, address and date of birth entered on a dedicated page we issue when agreeing to a contract (if the individual is a minor, this includes the name, relationship and contact details of their parent or guardian), the date and time of agreement, the IP address and browser type at the time of agreement (kept as a record of the agreement), invoices submitted to us (including bank account details and the qualified invoice issuer registration number), and payment records
• Our records: the history of our communications, the content and results of past campaigns, and our evaluations and notes on campaigns

(4) Information about people who click tracking links

To measure the results of campaigns, we use short tracking links that we issue (in the form "xx.addack.com"). When such a link is clicked, we record the date and time of the click, the browser and device type, the referring page, and the country, region and city estimated from the IP address. We do not store the IP address itself and do not use cookies. We do not identify the individual who clicked from this information.

(5) Information collected automatically when you browse the Site

Identifiers from cookies and similar technologies, IP address, browser and device type, referring page, pages viewed, date and time of viewing, etc. (see "7. Cookies and analytics" for details). Our server also automatically records access logs to deal with failures and prevent unauthorized access.

(6) Information related to the Pre-launch Survey

In the Pre-launch Survey, we have members of a research company's panel (respondents) answer a questionnaire. We do not collect names, contact details or any other information that identifies respondents. What we receive from the research company is respondents' attributes such as gender, age group and region of residence, their answers, and an identification number assigned to each respondent by the research company. We cannot identify any individual from this identification number. We also research and tabulate publicly available reviews and comments. We do not store the names or account names of those who posted them, and we do not include them in the report.

(7) Information we do not collect

We do not collect special care-required personal information, such as race, creed, medical history or criminal record, except where permitted by law. Please do not include such information in the contact form or elsewhere.

We use the personal information we collect to the extent necessary to achieve the following purposes.

(1) Information about prospective clients and clients

1. Answering inquiries and responding to consultations
2. Communicating about proposals, quotations and the conclusion of contracts, and keeping records of agreement to contracts and approval of campaigns
3. Providing the Service (including planning, arranging and managing PR campaigns, designing, conducting and tabulating the Pre-launch Survey and preparing its report, and measuring results)
4. Issuing accounts for the performance report, managing logins, and providing the report
5. Invoicing, confirming payments, refunds and other transaction management
6. Important notices about the Service (changes to the Service, failures, maintenance, etc.)
7. Information about our services for clients who have done business with us or who have asked to receive it. You may ask us to stop sending such information at any time.
8. Communicating about listing a project as a case study (we will obtain your consent in advance before listing a client's name or a contact person's name)

(2) Information about companies we approach for business

1. Introducing and proposing the Service
2. Managing records of our communications

If you do not wish to receive information from us, please let us know at info@addack.com. We will not contact you again. So that we do not contact you again by mistake, we will keep a record of your request and your contact details.

(3) Information about influencers and other partners

1. Consulting on and requesting projects, and arranging terms
2. Explaining project details, concluding contracts and recording agreement (including confirming and recording a parent's or guardian's consent if the individual is a minor)
3. Managing the progress of campaigns, and confirming and measuring what was carried out and the results
4. Making proposals to clients and reporting campaign results to them (as set out in items 3 and 4 of "4. Provision to third parties")
5. Paying fees and other transaction management
6. Keeping records so that we can approach you about future projects

(4) Tracking link information

Measuring the results of campaigns and reporting the results to clients (reported as aggregated figures)

(5) Pre-launch Survey information

Tabulating and analyzing survey responses and publicly available reviews and comments, preparing the report, and reporting the results to clients (we report aggregated results; we do not provide data on individual respondents)

(6) Common purposes

1. Analyzing the use of the Site and improving the quality of the Service
2. Preventing misuse, ensuring security and dealing with failures
3. Fulfilling legal obligations (including keeping books and documents for tax purposes)
4. Dealing with disputes if they arise

If we change a purpose of use, we will do so only to the extent reasonably considered to be duly related to the original purpose, and we will announce the changed purpose on the Site.

1. We do not provide personal data to third parties without the individual's consent, except in the following cases:
   • Where required by law
   • Where necessary to protect a person's life, body or property and it is difficult to obtain the individual's consent
   • Where especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the individual's consent
   • Where it is necessary to cooperate with a national government body, a local government, or a person entrusted by either of them in carrying out duties prescribed by law, and obtaining the individual's consent is likely to interfere with those duties
2. The following cases do not constitute "provision to third parties" as described above:
   • Where we entrust the handling of personal data to the extent necessary to achieve the purposes of use (see "5. Outsourcing and use of external services")
   • Where personal data is provided as a result of the succession of a business
3. Proposals to clients: Before sharing an influencer's activity name, channel information, profile, past results and the like with a client for a proposal, we obtain the consent of the individual or their agency. Consent is obtained for each project, or, from influencers who have carried out campaigns with us, for future proposals.
4. Reporting campaign results: We share the activity name of the influencer who carried out a campaign and the results of the campaign (published posts, views, clicks on tracking links, etc.) with the client as part of our report. Influencers agree to this in their contract with us.
5. Sharing contact details: In the Service, we act as the single point of contact between clients and influencers, and as a rule we do not share their contact details with each other. If contact details need to be shared, we will tell the individual in advance what will be shared and with whom, and obtain their consent.
6. We do not sell personal information.

1. To the extent necessary to achieve the purposes of use, we entrust the handling of personal data to external businesses such as the following, or use external services:
   • Business services such as servers, email, file sharing, chat, online meetings and electronic contracts
   • Cloud services used to run the business tools we have developed (including the performance report and tracking links)
   • Analytics services (Google Analytics; see "7. Cookies and analytics" for details)
   • Money transfer services used to receive payments from outside Japan (Wise)
   • Internet research companies used to conduct the Pre-launch Survey
   • Subcontractors that carry out PR campaigns, such as influencers and production companies
2. We choose contractors after confirming that they have systems in place to handle personal information properly, require proper handling through contracts or terms of use, and supervise them as necessary and appropriate. With subcontractors such as influencers, we share only the minimum information needed for the work and require them to keep it confidential.
3. For the performance report, we issue a dedicated account to each client, set up so that each client can view only its own data.
4. Wise (Wise Payments Japan K.K.) handles the information it obtains directly from you in the course of the payment procedure in accordance with its own privacy policy: https://wise.com/jp/legal/privacy-notice-personal

1. The external services we use include services from businesses outside Japan and services that store and process information on facilities outside Japan. Personal information may therefore be stored and processed in the United States and the United Kingdom as well as in Japan. If it comes to be handled in any other country, we will revise this policy and let you know.
2. We take the measures necessary for security management after understanding the personal information protection systems of the countries concerned, based on sources such as the survey of foreign personal information protection systems published by the Personal Information Protection Commission of Japan.
   • United States: There is no comprehensive federal personal information protection law; personal information is protected by sector-specific federal laws and by state laws such as the California Consumer Privacy Act (CCPA).
   • United Kingdom: The Personal Information Protection Commission of Japan has designated the United Kingdom as a country with a personal information protection system at the same level as Japan's. Wise jointly uses personal information with Wise Payments Limited in the United Kingdom (the party responsible is Wise Payments Japan K.K.).
3. When we provide personal data to a contractor or other recipient outside Japan, we confirm that the recipient has established a system for continuously taking measures equivalent to the obligations under the APPI (including provisions on the handling of personal information in contracts or terms of use). On request from the individual, we will provide information on the measures taken by the recipient, in accordance with the law.

(1) What cookies are

Cookies are small pieces of data that a website stores in your browser. On the Site, we use cookies and similar technologies to display the Site, provide its features, and analyze how it is used.

(2) Google Analytics

To understand how the Site is used and to improve the Site and the Service, the Site uses "Google Analytics", an analytics tool provided by Google LLC. Google Analytics uses cookies to collect the following information and sends it to Google LLC.

• Main information sent: cookie identifiers, pages viewed, date and time of viewing, referring page, browser and device type, and approximate location estimated from the IP address
• Recipient: Google LLC
• Purpose: statistical understanding of how the Site is used, and improvement of the Site and the Service

We receive statistical information only, and we do not identify specific individuals through Google Analytics. Google Analytics data is automatically deleted no later than 14 months after collection.

For how Google handles information, please see "How Google uses information from sites or apps that use our services" (https://policies.google.com/technologies/partner-sites?hl=en) and the Google Privacy Policy (https://policies.google.com/privacy?hl=en).

If you do not want information to be collected by Google Analytics, please use the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout?hl=en) or disable cookies in your browser settings. Google Analytics cookies (those whose names begin with "_ga") are kept for up to two years.

(3) YouTube

The Site uses YouTube to present videos. When thumbnails are loaded or videos are played, information such as your IP address, information about your device and browser, and information about viewing and playback may be sent to Google LLC.

(4) Performance report

The performance report uses one cookie to keep you logged in (valid for 24 hours). This cookie is used only to manage logins. Video thumbnails in the report are loaded from YouTube (Google LLC), so when you view the report, your IP address and information about your device and browser may be sent to Google LLC.

(5) Managing cookies

You can refuse or delete cookies in your browser settings. However, if you disable cookies, some features of the Site may not work, and you may not be able to log in to the performance report.

(6) Use for advertising

We do not use cookies or tags for ad delivery on the Site. We also do not provide cookies or other personal-related information to third parties in a form that allows the recipient to identify individuals.

We take the following measures to prevent the leakage, loss or damage of personal information.

1. Basic policy: This policy serves as our basic policy for the proper handling of personal information.
2. Handling rules: We set out how personal information is handled at each stage: collection, use, storage, provision and deletion.
3. Organizational measures: The operator is responsible for the handling of personal information. We regularly review how it is handled and have procedures for responding when a leak or similar incident occurs or may occur.
4. Human measures: Contractors and partners who handle personal information are bound by confidentiality obligations and informed of the handling rules.
5. Physical measures: We prevent the theft and loss of devices that handle personal information and set screen locks. Devices and documents that are no longer needed are disposed of in a way that prevents recovery.
6. Technical measures:
   • The business tools we have developed store information about clients, influencers and others in encrypted form, use two-factor authentication for our own logins, and keep logs of operations.
   • We also use two-factor authentication for the other main services that handle personal information, such as the administration screens of payment services and servers.
   • We manage passwords properly and limit access to personal information to those who need it.
   • We keep operating systems and software up to date and use anti-virus measures.
   • Communications with the Site and the performance report are encrypted with SSL/TLS.
7. Understanding the external environment: When personal information is handled outside Japan, we take measures after understanding the system of the country concerned, as described in "6. Handling outside Japan".

If a leak or similar incident involving personal data occurs and is likely to harm the rights and interests of individuals, we will report it to the Personal Information Protection Commission and notify the individuals concerned, in accordance with the law.

1. As a rule, we keep information about transactions, consultations, sales activities and communications with influencers and others so that we can respond to future transactions and consultations. We keep it for the same purpose after the viewing period of the performance report has ended.
2. If an individual asks us to delete their information, we will delete it, except for the following:
   • Information we are required by law to keep
   • Information needed to manage transactions (such as unsettled invoices)
   • Information needed to fulfil or manage contractual obligations (such as managing videos during their listing period, reporting to clients, and presenting case studies)
   • Information needed to confirm and deal with inquiries about contracts or with misunderstandings
3. Records of contracts, invoices, payments and refunds are kept for the period required by tax and other laws (up to seven years). They are kept for that period even if deletion is requested.
4. Google Analytics data is automatically deleted no later than 14 months after collection.
5. Data on individual respondents to the Pre-launch Survey (individual-level data) is deleted within 30 days after the report is delivered. The aggregated report is kept as a record of the transaction.
6. Information we no longer need to keep is deleted or disposed of in a way that prevents recovery.

(1) What you can request

With regard to the personal information we hold, you may request:

• Notification of the purposes of use
• Disclosure (including disclosure of records of provision to third parties)
• Correction, addition or deletion of the content
• Suspension of use or erasure
• Suspension of provision to third parties

(2) How to make a request

Please send the following to info@addack.com with the subject line "Request regarding personal information".

1. What you are requesting (which of the above it is)
2. Your name and contact details
3. Details that allow us to identify the information concerned (when you contacted us, the name of the contract, your activity name, etc.)
4. For disclosure, how you would like it to be made (electronic data, a document sent by post, etc.)

(3) Identity verification

To prevent leaks to third parties, we verify that the request comes from the individual concerned. We will confirm that the request comes from an email address registered with us or, if necessary, ask you to submit a copy of an official identity document such as a driver's license (please black out your registered domicile, Individual Number and similar details). For requests made by an agent, we ask for a document confirming the agent's authority (such as a power of attorney) and the agent's own identity document.

(4) Our response

Once we have verified your identity, we will respond without delay in accordance with the law (as a rule, within 14 days of receipt). As a rule, disclosure is made by sending electronic data (such as a PDF); if you would prefer another method, we will accommodate it where possible. If we cannot meet your request under the law, we will tell you why.

(5) Fees

There is no fee for requests.

When we approach minors about projects as influencers or in a similar capacity, we handle their personal information after obtaining the consent of their legal representative (parent or guardian, etc.). We ask for the date of birth when the contract is agreed, and if the individual is under 18, we keep the name, relationship and contact details of the parent or guardian together with a record of their consent.

1. The Service is operated by GREX. Operator details, such as the name of the representative and the address, are published on the Company Information page (https://addack.com/operator-en/).
2. We accept inquiries, requests, complaints and consultations about the handling of personal information at the following contacts:
   • Email: info@addack.com
   • Contact form: https://addack.com/en/#contact
3. We are not a member of any accredited personal information protection organization.

1. We may review and change this policy in response to changes in laws, changes to the Service, and other circumstances.
2. When we make changes, we will post the revised policy and its effective date on the Site. For important changes, we will announce them clearly on the Site. Where the law requires the individual's consent for a change, we will obtain it.