Effective August 9, 2024.

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We have established this privacy policy (the “Policy”) to set forth guidelines regarding how we collect, handle, and manage your Personal Information collected by us in connection with participating in our market research studies or using or interacting with our websites, mobile or software applications or any other services provided by us (our “Services”). Please also read our Terms of Service which sets out the terms governing our Services.

Personal Information

In this policy, “Personal Information” refers to “Personal Information” as defined in the Act on the Protection of Personal Information (the “APPI”), and means information about living individuals, including the name, date of birth, address, telephone number and contact information of an individual, and any other description or information that can be used to identify a specific individual, such as the appearance and voice of an individual or other types of personal identification information.

Information that We Collect

We collect information about individuals who participate in our market research studies or use our Services, including information that directly or indirectly identifies an individual to the extent this information is voluntarily shared with us.

When individuals participate in our market research studies or use our Services, we collect certain basic profile and background information. We also collect basic account information from users who create an account on our Services and any Personal Information provided to us by users in connection with the use of our Services. The type of information collected may include an individual’s name, date of birth, address, telephone number, email address, educational background, gender, weight, interests/hobbies, and appearance or voice data. Additionally, users of our Services may choose to voluntarily share certain Personal Information while using the Services. For example, a user may upload a picture or video, create posts or logs containing geo-location information, or import personal health information such as heart rate from other applications or devices.

Why We Collect Personal Information

We collect and use Personal Information for the following purposes (the “Purposes”). We may use your Personal Information in combination with your account data or other information such as your age, gender, physical data, usage history, or other similar data to fulfill the Purposes listed below.

• To administer, conduct, or analyze the results of market research, interviews, surveys, or testing sessions.
• To provide or improve the Services.
• To manage and perform analysis of the usage of the Services.
• To handle inquiries regarding the Services.
• To investigate any unauthorized access to or misuse of the Services or breach of our Terms of Service.
• To contact research participants or users when necessary to provide updates, important notices, etc.
• To contact research participants or users in the event of a disaster or other emergency.
• All other purposes incidental to the purposes listed above.

Sharing Your Information

We will not share your Personal Information with third parties without your prior consent unless we are permitted or required by applicable laws to share your Personal Information.

In accordance with the APPI, in order to run our business, provide the Services, and fulfill any of the Purposes listed above, we may retain a third party to handle all or part of the processing of your Personal Information. If we retain a third party to process your Personal Information, we may share your Personal Information to the extent that it is necessary for the processing of your Personal Information and we will supervise the third-party processor to ensure that your Personal Information is processed in a manner that is compliant with applicable laws. The third party handling your Personal Information will not be allowed to use the Personal Information it receives for any other purpose except as directed by us. Here are the situations where we may share your Personal Information in accordance with the APPI:

• We may share information with third parties who assist us with conducting or analyzing the results of our market research, studies, or testing sessions.
• We may share information with third parties who provide services that we use to support, improve, promote, or secure our Services, including payment processing and content management. The service providers will only have access to the Personal Information necessary to perform their limited functions on our behalf and they are required to protect your information.
• We may share information, including with law enforcement, public or governmental agencies, or private litigants, within or outside of your country of residence, if we are required to do so by law. This may include situations where we are asked to respond to court orders, warrants, subpoenas, or other legal or regulatory requirements.
• We may share information if it is reasonably necessary to protect the life, body, or property of Launchpad and our Shared Parties, our participants or users, or a third party, and it is difficult to obtain your consent.

Additionally, in accordance with our Terms of Service, we may share information as necessary to enable us to provide our Services or to address important matters.

• If you are using a Service through your organization or have an account assigned by your organization, we may share your information with your administrator or the representative of your organization for account management purposes such as to manage how users from your organization use the Service or to help users reset passwords.
• We may share information to address any issues of national security or of public importance, to prevent or detect fraud, security or technical issues, or violations of our Terms of Service, or to address any abuse of our Services or their users.
• We may share information with our legal counsel and other consultants or third parties to protect our business operations or our legal rights.

Lastly, you should be aware that depending on the Service you are using, some of the information or content you provide to the Service may be shared with other users and the public. These may include information such as your username, or pictures and videos that you voluntarily upload to the Service. In these situations, such sharing will be in accordance with your privacy controls and settings on that Service and you will have the option to change your privacy settings on the Service you are using.

In accordance with the APPI, we may also share Personal Information collected from you with Fujitsu Limited and its subsidiaries and affiliates (the “Shared Parties”) and the Shared Parties may use your Personal Information for the Purposes set forth in this Policy, or so that the Shared Parties may provide their services to you or improve their services. Depending on the purpose, we may share basic information such as your name, date of birth, address, telephone number, e-mail address, or gender or we may share information about your interests/hobbies, educational background or work experience, or non-personally identifiable information and aggregated data. We will be responsible for the management and control of any Personal Information to be shared with the Shared Parties and you should contact us if you would like to know more about how your information may be used by the Shared Parties.

Additionally, we may share non-personally identifiable information publicly or with our business partners (such as publishers, advertisers or developers) to help support, improve, promote, or secure our Services.

Requests to Disclose, Correct or Delete Your Information

Disclosing Your Information

If we receive a request from you to disclose Personal Information, we will confirm your identity before responding your request. Once we are able to confirm your identity, we will review your request in accordance with the APPI. If we determine that we cannot or will not disclose the requested information, we will notify you of such decision. In some cases, a processing fee may be charged for each requested disclosure of Personal Information. If we charge a processing fee, we will notify you of the fee amount in advance.

We may refrain from disclosing Personal Information in the following cases.

• If there is a risk of harm to the life, body, property, or other rights or interests of another third party or us.
• If there is a risk that the disclosure could have an adverse effect on the operations, integrity, or security of our business or the Services.
• If the disclosure would violate any laws or regulations or a legal enforcement authority’s orders.

Correcting and Deleting Your Information

If you become aware that any part of your Personal Information is incorrect, you ask that you correct the inaccuracies as soon as possible. In many cases, you may be able to update your Personal Information on your profile or account by logging into the Service you are using. If you need further assistance correcting inaccurate information, you may contact us directly via the Service or by using the contact information listed at the bottom of this Policy. We will evaluate all requests we receive and if we determine that a correction is necessary, we will correct the relevant Personal Information. If we determine that a correction is not necessary or warranted, we will notify you of our decision.

You may also delete your profile or account by logging into the Service you are using and following the instructions on the Service, or you may contact us and request that we delete your Personal Information held by us. After you make a deletion request, we will delete your Personal Information from our systems but we may retain a copy of your information for as long as necessary to comply with our internal data retention policies or with applicable law. Once an account is deleted, all your data, including your profile and account information cannot be reinstated. Therefore, if you would like to retain all or part of your data, including any content you have uploaded, please follow the instructions on the Service you are using to download your data. After you delete your account from a Service or make a deletion request of Personal Information held by us, it may take up to 60 days for us to fully erase your Personal Information from our systems. Additionally, we may retain certain Personal Information despite a deletion request if it is reasonably necessary to retain such information to comply with laws and regulations or to take other actions permitted by law.

Our Retention Period

We will retain your Personal Information for the period necessary to carry out the Purposes set forth in this Policy subject to any internal or legal obligations to retain your Personal Information for further periods.

Data Security

We have implemented technical, physical, and organizational measures and controls to safeguard and protect the transmission and storage of the information we collect. We employ reasonable protections for your Personal Information that are appropriate to its sensitivity. While we endeavor to use reasonable security measures to protect against unauthorized access to your Personal Information under our control and strive to prevent any leak or loss of, or damage to, Personal Information, we cannot guarantee absolute security to the Personal Information you provide or that our security measure will prevent unauthorized or illegal access to your Personal Information. If any leakage of Personal Information or other security incident occurs, we will notify you and take necessary actions in accordance with the procedures set forth under the relevant laws and regulations.

Changes to this Policy

As we are constantly launching new services and improving our current offerings, we may update this Policy at any time and for any reason in our sole discretion. Any time we make changes to this Policy, we will provide you with reasonable advance notice of the revisions before the effective date of the amended Policy. The amended Policy will be posted on our website and will become effective on the effective date.

This Policy was written in English. To the extent a translated version conflicts with the English version, the English version controls.

Contact Information

If you have any questions regarding this Policy, please contact the Fujitsu Launchpad data privacy team at [email protected].