G l o b a l   P r i v a c y   P o l i c y

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In compliance with applicable data protection laws and regulations (including, without limitation, the General Data Protection Regulation (EU) 2016/679 (GDPR)), LayerX Inc., (the “Company” or “we”) hereby prescribes the following Global Privacy Policy (this “Policy”) to cover the processing of personal information of Users residing outside of Japan in relation to the Bakuraku Series (hereinafter referred to as the “Service”).

For the processing of personal information of Users residing in Japan, the “Privacy Policy (for Users Residing in Japan),” shall be applied and be referred to, and for the processing of personal information of Users residing in the State of California in the United States, the “Appendix: Processing of Personal Information of California Residents,” shall be applied and be referred to in addition to this Policy. 

1. Categories of Personal Information We Collect

The Company will collect and process the following personal information in relation to the Service:

  • Basic information of the Users (name, company name, position/role, email address, telephone number, address, etc.);
  • Information regarding inquiries from the Users 
  • Information obtained from the Users’ devices (type of device, OS, device identifier, IP address, browser type and other browser information, referrer information, cookie ID, information related to browsing history and purchase history obtained by using cookies and cookie-like technologies, advertising identifiers, etc.).

Please see our Cookie Policy for information on how we handle cookies (including cookies and cookie-like technologies).

2. Purposes of Use of Personal Information and Legal Grounds for Processing

The Company collects and processes personal information based on our legitimate interests to carry out our business, including providing products and services that better meet the Users’ needs and requests, and preventing the fraudulent use of the services, as well as based on the User’s consent and legal obligations for the following purposes of use in connection with the Service. In cases where the basis of the use is for our legitimate interest, we will balance the impact on the Users’ privacy against the relevant legitimate interest. Please note that the Company does not make decisions that may have legal or similar material effects on Users based solely on automated processing, including profiling, using Users’ personal information.

  • To authenticate and confirm the identity of the Users;
  • To provide the Service to the Users and companies or organizations to which the Users belong;
  • To inform the Users of events such as exhibitions and seminars;
  • To request feedback on the Service from the Users;
  • To provide the Users with promotional marketing, advertising and publicity (including, without limitation, surveys) relating to the Service and services related to the Service, the Company, and related entities of the Company;
  • To investigate and analyze the usage of the Service by the Users and to maintain, protect and improve the Service;
  • To respond to inquiries about the Service;
  • To respond to actions that violate the Company’s terms, guidelines, or the like, regarding the Service;
  • To notify the Users of changes in the terms, guidelines, or the like, regarding the Service; 
  • To prevent the occurrence of failures, malfunctions, and incidents in the systems of the Service, and to promptly respond thereto when they occur; and
  • To perform processing to comply with legal obligations to which the Company is subject.

3. Disclosure of Personal Information

The Company may provide the User’s personal information to the following businesses, etc.:

  1. The Company uses outsourcing companies such as service providers, security service providers, and data analysis service providers, to offer the Service, and these contractors will access and process the Users’ personal information to the extent necessary to offer the Service;
  2. The Company outsources the sales of the Service to sales partners, and these sales partners will access and process the Users’ personal information to the extent necessary in order to achieve the purposes of use described in Section “2. Purposes of Use of Personal Information and Legal Grounds for Data Processing”; and
  3. The Company may disclose personal information to public authorities in order to comply with applicable laws and regulations (including ordinances, court rulings, and administrative orders and recommendations).

4. Sources of Personal Information

The Company primarily collects the Users’ personal information directly from the Users or companies or organizations to which the Users belong.

5. Required Personal Information

The personal information that Users are required to provide for the provision of the Service is indicated in the form to be completed by the User. The User is under no obligation to provide such personal information, but if such personal information is not provided, the Company is unable to offer the Service.

6. International Transfer of Personal Information

The Company may transfer the Users’ personal information to countries outside the Users’ country of residence (for Users residing in the EU, to outside of the EU), including Japan and United States of America (the “International Transfer”), for the purpose described in “2. Purposes of Use of Personal Information and Legal Grounds for Data Processing”.

When the Company conducts the International Transfer of Users’ personal information to other countries we will take necessary measures for the protection of personal information, such as implementing an adequate level of protection and executing standard contractual clauses as set forth by the supervisory authority. If Users would like more information, such as obtaining a copy of the standard contractual clauses, etc., they are requested to contact us by mailing a letter to the address or by sending an e-mail to the e-mail address listed in Section “12. Inquiries” below.

7. Retention Period of and Security Measures for Personal Information

The Company will retain Users’ personal information for as long as it is necessary to fulfil the purposes of use prescribed in this Policy.

To determine the appropriate retention period for personal information, we consider: (i) whether the Company has an ongoing relationship with the User; (ii) whether the Company is legally obligated to store the User’s personal information; and (iii) whether storing the User’s personal information is necessary to fulfill the contract with the User.

In order to retain Users’ personal information, the Company has implemented internal rules, an organizational structure, and appropriate supervision of employees, and has taken measures to prevent unauthorized access, etc., in order to protect against the risk of loss, destruction, alteration, or leakage of personal information.

8. Rights for Disclosure, Correction, Addition, Deletion etc., of Personal Information

The Users may have the following rights with respect to their own personal information, in accordance with applicable laws and regulations:

  1. the right to seek access to their personal information (including copies thereof);
  2. the right to request correction of their personal information;
  3. the right to seek removal of their personal information (the right to be forgotten);
  4. the right to restrict (cease) the processing of their personal information; and
  5. the right to receive their personal information in a structured, machine-readable form (the right to data portability).

These rights may be limited, on an exceptional basis, if complying with a User’s request would infringe upon the rights of the Company or a third-party, or if we are requested to delete information that we are required to retain in accordance with the laws and regulations. The exceptions to these rights are set out in the applicable laws and regulations.

If Users wish to exercise these rights, they are requested to contact us by mailing a letter to the address or by sending an e-mail to the e-mail address listed in Section “12. Inquiries” below.

9. Right to Object to the Processing of Personal Information

The Users may have the right at any time to object to the processing of their personal information that is being processed on the basis of legitimate interests under the applicable laws and regulations.

If Users wish to exercise these rights, they are requested to contact us by mailing a letter to the address or by sending an e-mail to the e-mail address listed in Section “12. Inquiries” below.

10. Right to Withdraw Consent

The Users have the right to withdraw their consent whenever the Company handles their personal information based on their consent under applicable laws and regulations. Even if a User withdraws their consent, the legality of any treatment on the basis of consent before the withdrawal of consent will not be affected.

If Users wish to exercise these rights, they are requested to contact us by mailing a letter to the address or by sending an e-mail to the e-mail address listed in Section “12. Inquiries” below.

11. Right to File a Complaint with a Supervisory Authority

The Users may have the right to file a complaint with a supervisory authority under applicable laws and regulations. The supervisory authorities to which complaints can be filed may include the supervisory authorities where the User resides or works.

12. Inquiries

For any inquiries regarding personal information, Users are requested to contact us as set forth below:

LayerX Inc. Privacy Policy Contact Desk

5F Ginza Shochiku Square, 1-13-1 Tsukiji, Chuo-ku, 104-0045, Tokyo

E-mail：privacy@layerx.co.jp

Established: 4 1, 2025