PRIVACY POLICY

This Privacy Policy ("Privacy Policy") applies to learningBOX, Inc, "our" and "us This Privacy Policy sets out how we will, as a data controller, process the personal This Privacy Policy sets out how we will, as a data controller, process the personal This Privacy Policy sets out how we will, as a data controller, process the personal This Privacy Policy sets out how we will, as a data controller, process the personal This Privacy Policy sets out how we will, as a data This Privacy Policy sets out how we will, as a data controller, process the personal data of our customers and business partners and their employees ("you" and " your") and the measures and processes we have put in place to ensure its adequate protection in accordance with the laws and regulations in in relation to personal information protection.

We may revise this policy at any time by amending this page. You are expected to check this page from time to time to become aware of any changes we make, as they are binding on you.

1 Personal Data We Process

address, telephone number, email address); online identifiers (e.g., IP address, cookie information, username, password); payment details; payment details information about your use of our websites; information about your interactions with our services, promotions or advertising; and any views or opinions you provide us.

2 Purpose of Processing Personal Data

We will process your personal data for the following purposes:

• Responding to brochure requests, general enquiries, bug reports, online meeting requests;.
• Providing e-learning services; and
• Mailing materials to the owner account of learningBOX;.
• Informing customers of other services for the owner's account of learningBOX; and
• Responding to various inquires and sending notifications; and
• Settling the payment for our service; and
• Compliance with legal and regulatory obligations to which we are subject; and
• Other legitimate interests, including analyzing the use of our website or services, tailoring website and news content, setting preferences in our website or electronic mailings, improving our websites, offering and managing programs and events, fulfilling our obligations to our clients and others, and managing our client and vendor relationships; or
• Any other purpose incidental to those listed above.

3 Voluntariness and Consequences of Providing Personal Information

Personal information can be provided at your own discretion; however, if all or part of the necessary personal information is not provided, our services may not be provided.

4 Legal Grounds for Processing Personal Data

We may process your personal data based on the following legal grounds:

• To process your instructions or fulfill the obligations under any contracts with you or your organization; and
• Your consent expressly given to us to process your personal data in such manner. You may withdraw your consent to this processing at any time; however, this will not affect the lawfulness of any processing carried out before such withdrawal of your consent; however, this
• To protect important interests of the data subjects; and
• To comply with our legal and regulatory obligations; and
• Our legitimate interests, public interests, or those of any third-party recipients of your personal data, provided that such interests are not Our legitimate interests or fundamental and freedoms.

5 Provision and Sharing of Personal Data

We may share personal data and information with the following third parties for the purposes above. If this is necessary, we will comply with applicable privacy laws and regulations.

• Our group of companies,
• Occupational professionals such as lawyers, tax accountants, and certified public accountants; and
• Third parties approved or designated by you; and
• Payment service providers, including PayPal Pte, GMO Payment Gateway, Inc., Stripe, Inc. and ZEUS Co. We share your credit card information including card holder's name, card number, and validity period, provided, however, that we will not retain your credit card information after sharing it to payment service providers; and
• Third parties who process your personal data on our behalf; and
• Any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request .

6 Management of Personal Data

We manage your personal data within the scope necessary to achieve the purpose of use, in order to avoid illegal access to, or loss, destructions, manipulation or any personal data, by implementing necessary and appropriate rules and regulations concerning the protection of personal data. In addition, we provide appropriate supervision to our employees regarding the handling of personal data. Furthermore, we will not provide personal data to any third party unless we have the client's consent or are otherwise required or permitted to do so by laws and regulations or as stated in this policy.

7 Contact Information regarding Personal Data

Regarding disclosure, corrections or deletions of personal data, please contact us using the contact information found on the webpage to which you have provided your personal data, or by sending an inquiry to the below. In that case, we will verify your identity and respond within a reasonable period of time:

learningBOX, Inc.
Personal Information Inquiry Desk
216-1 Domoto, Tatsuno-cho, Tatsuno-shi, Hyogo 679-4129 Japan
Telephone: +81-791-72-8421
Data Processing Officer：Masao Monda
corporate@learningbox.co.jp

8 Outsourcing Management

We may outsource part of our operations pertaining to personal information to another company. In this case, we select the company who meet or exceed our standard of personal information protection and specify their responsibilities. We also demand of the company appropriate handling of personal information and will continue to supervise and evaluate them to safeguard operations.

9 Acquisition of Personal Information by a Method that the Person cannot Easily Recognize

We use Google Analytics and Cookies on the websites operated by us. We also use the SSL (Secure Sockets Layer) data encryption system for all the parts where personal information is entered on the website operated by us. However, please note in advance that due to the nature of Internet communication, security is not completely guaranteed.

10 Google Analytics

1. About Google Analytics
   Google Analytics is a technology which obtains statistics on the facts of access to, the usage rates of, and other factors regarding specific websites by grasping the access status to the websites.
2. Use of Google Analytics
   We may use Google Analytics for the purposes described below; however, we do not acquire any personally identifiable information.
   • To understand the access to specific websites and the display of the page
   • To acquire detailed statistical information by using it in combination with cookies
   • To provide services that are more tailored to the visitor based on the above
   • To improve the websites based on the above

11 cookies

1. About Cookies
   You are allowed to modify the settings for sending and receiving cookies from your browser. Different browsers have different methods for modifying Check your browser's "Help" menu to learn how to modify your cookie settings. You should note that if you block all or some of the cookies from the websites operated by us, you may not be able to enjoy services that require authentication or you may be restricted from using the various services provided by us. You should note that if you block all or some of the cookies from the websites operated by us, you may not be able to enjoy services that require authentication or you may be restricted from using the various services provided by us.
2. Cookie Settings
   You are allowed to modify the settings for sending and receiving cookies from your browser. Different browsers have different methods for modifying You should note that if you block all or some of the cookies from the websites operated by us, you may not be able to enjoy services that You should note that if you block all or some of the cookies from the websites operated by us, you may not be able to enjoy services that require authentication or you may be restricted from You should note that if you block all or some of the cookies from the websites operated by us, you may not be able to enjoy services that require authentication or you may be restricted from using the various services provided by us. You should note that if you block all or some of the cookies from the websites operated by us, you may not be able to enjoy services that require authentication or you may be restricted from using the various services provided by us.
3. Our Use of Cookies
   We use cookies for the following purposes:
   • To display the most appropriate advertisement on the websites operated by us or on other websites based on the content of your interest and the usage status To display the most appropriate advertisement on the websites operated by us or on other websites based on the content of your interest and the usage status
   • To understand and investigate the visit history and usage details of the websites operated by us.
   • To improve the service of websites operated by us
   • To provide services that suit you
4. Opt-Out of Cookies
   Should you wish to disable behavioral targeting advertising by cookies, you may opt out of cookies from the links of the following companies:
   • Google LLC:. https://support.google.com/ads/answer/2662922
   • HubSpot Inc. https://legal.hubspot.com/cookie-policy#remove-cookies
   • Facebook
   • Twitter
   • LinkedIn
   • YouTube

12 Cross Border Transfer

Personal data may be transferred to entities in countries or jurisdictions outside the European Economic Area ("EEA"), such as Japan, if required for purposes as described above. Please note that such countries or jurisdictions may not have the same data protection laws as the EEA and that they may not afford many of the rights conferred upon you in the EEA. We will ensure that any such international transfers are made subject to appropriate and suitable safeguards as required by the GDPR or other relevant laws. When doing so, we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data.

13 Retention of Personal Data

We will retain your personal data for the period necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law.

14 Your Rights

You have the right to access, request correction of, request deletion of, request the limitation of processing of, and request the data on the possibility of your personal data retained by us. When we receive a request based on such right, we will conduct any necessary investigation without delay and provide you or a nominated third party with personal data or respond to such request without delay.

15 How to Lodge a Complaint to the Regulator

You are entitled to lodge a complaint with a competent data protection regulator if you consider that we have breached your data protection rights.

Supplemental Provision
The Terms shall be effective from July 1, 2018.

Supplemental Provision (revised on February 22, 2023)
The Terms after the revision dated February 22, 2023 shall be effective from February 22, 2023.

END