Privacy and Cookie Policy

ZenGroup Co., Ltd. (the "Company") operates the ZenStudio website https://zenstudio.osaka/ (the "Site"). This Privacy and Cookie Policy (this "Policy") describes the information we collect about you, information provided to us, information provided to us by third parties, and information we process when you use the Site, and explains our policy regarding the collection and handling of personal information through the Site. By using the Site, you agree to the collection and use of information in accordance with this Policy.

Definitions

Personal Data

Personal Data means data relating to a living individual who can be identified from that data (or from that data together with other information that is in, or is likely to come into, our possession).

Usage Data

Usage Data is data collected automatically through the use of the Site or from the Site's infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on your device (a computer or mobile device).

Data Controller

A Data Controller means a natural or legal person who, alone, jointly, or in common with others, determines the purposes and methods of processing personal information, or the manner in which it is processed. For the purposes of this Policy, we are the Data Controller of your Personal Data.

Data Processor (or Service Provider)

A Data Processor (or Service Provider) means a natural or legal person who processes data on behalf of the Data Controller. We may use the services of various service providers in order to process your data more effectively.

Data Subject (or User)

Data Subject means any living individual who is using the Site and who is the subject of Personal Data.

Name and Address of the Business Handling Personal Information, and the Name of its Representative

Name (or Title), Department, and Contact Information of the Personal Information Protection Manager (or their Representative)

Compliance with Laws, Regulations, and Guidelines Relating to Personal Information

When handling personal information, the Company complies with the Act on the Protection of Personal Information, guidelines, internal regulations and agreements, and other applicable rules, as well as the obligations set forth in the guidelines published by the Personal Information Protection Commission and the competent authorities, and this Policy. When handling personal information, the Company will comply with the related laws, internal regulations, and other rules listed in the table above, and will endeavor to ensure the proper protection and use of customers' personal information.

Types of Data Collected

Personal Data While using the Site, we may ask you to provide us with certain personally identifiable information ("Personal Data") that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• First and last name
• Phone number
• Physical address, state/prefecture, postal code, city
• Cookies and Usage Data
• IP address
• IP address geolocation

Tracking and Cookie Data

We use cookies and similar tracking technologies to operate the Site. Cookies are files containing a small amount of data, which may include an anonymous unique identifier. Cookies are sent from a website to your browser and stored on your device. The tracking technologies we use also include beacons, tags, and scripts to collect and track information and to improve and analyze the Site. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Site. Examples of cookies we use: Session Cookies: We use session cookies to operate our Service.

How We Use Your Data

We use the data we collect for various purposes: - To verify your identity - To contact you - To monitor the usage of the Service - To detect, prevent, and address technical issues

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you reside in the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Policy depends on the Personal Data we collect and the specific context in which we collect it. We may process your Personal Data because:

• We need to perform a contract with you.
• We need to provide the Service to you and deliver products.
• You have given us permission to do so.
• The processing is in our legitimate interests and is not overridden by your rights.
• For payment processing purposes.
• To comply with Japanese law and international law.

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain data to comply with Japanese tax law), resolve disputes, and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, prefecture, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you reside outside Japan and choose to provide information to us, please note that we transfer the data, including Personal Data, to Japan and process it there. Your consent to this Policy, followed by your submission of such information, represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Outsourcing of Personal Data

In order to conduct our business smoothly and provide you with better service, we may outsource the handling of your Personal Data to partner companies. However, the Personal Data we outsource is limited to the minimum necessary information to carry out the outsourced work. In addition, when outsourcing, we confirm that the partner maintains a level of personal information protection equal to or higher than our own before proceeding.

Provision of Personal Data

We will not provide any personal information entrusted to us to third parties, except in any of the following cases: - Where we have obtained your prior consent - Where outsourcing is necessary within the scope required to achieve the purpose of use - Where disclosure is required by law - Where necessary to protect a person's life, body, or property, and it is difficult to obtain your consent - Where it is particularly necessary for improving public health or promoting the sound development of children, and it is difficult to obtain your consent - Where it is necessary to cooperate with a national or local government body in carrying out affairs prescribed by law, and obtaining your consent would impede the performance of such affairs - Where provided to a party listed within the scope of joint use described above

Disclosure of Data

Disclosure for Legal Action Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). Legal Requirements We may disclose your personal information in the good-faith belief that such action is necessary to: - Comply with a legal obligation - Protect and defend our rights or property - Prevent or investigate possible wrongdoing in connection with the Service - Protect the personal safety of users or the public - Protect against legal liability

Procedures for Disclosure of Retained Personal Data, etc.

We respond promptly to requests from data subjects regarding retained personal data, including requests for notification of the purpose of use, disclosure, correction, addition or deletion of content, suspension of use, erasure, suspension of provision to third parties, and disclosure of records of provision to third parties. If you wish to make such a request, we will confirm that the requester is the individual concerned (or their authorized representative) and respond within a reasonable period and scope. Please direct requests for disclosure, etc. of retained personal data to the contact point listed below. Once we receive your inquiry, we will send you our designated "Retained Personal Data Disclosure Request Form" by mail, fax, or email. Please complete the form, enclose the required documents, and submit it by mail or email. (Postage costs are borne by the requester.) After confirming your identity (or that of your representative), we will respond using your preferred method of disclosure. To handle personal information appropriately, we have established regulations concerning personal information based on a personal information protection policy compliant with JIS Q 15001, and we operate a personal information protection management system. We take necessary safety management measures from four perspectives — organizational, physical, personnel, and technical — to ensure the proper handling of personal information. *For details on our safety management measures, please contact our Personal Information Inquiry Desk. Personal Information Inquiry Desk: General Manager, Logistics Center, Logistics Division Address: Osaka Sakaisuji L Tower 10F, 1-7-7 Kawaramachi, Chuo-ku, Osaka, 541-0048 Phone: 06-4560-4070 Email: corporate@zen.group

Security of Data

We implement appropriate technical and organizational security measures to protect the personal information we process about visitors to this website from unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We recommend that you exercise caution when disclosing personal information online, and that you use firewalls, secure email, and other technologies where appropriate. Sensitive and private data exchanges between the Company and its users take place over SSL-secured communication channels, and are encrypted and protected with digital signatures. If we discover an unauthorized intrusion that materially affects you, ZenGroup will notify you as soon as possible and will report on the measures we have taken within a reasonable period of time.

Do Not Track

We do not support Do Not Track. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track in the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to know what Personal Data we hold about you, or if you would like it removed from our systems, please contact us. In certain circumstances, you have the following data protection rights: The right to access, update, or delete the information we have on you: Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. The right of rectification: You have the right to have your information corrected if it is inaccurate or incomplete. The right to object: You have the right to object to our processing of your Personal Data. The right of restriction: You have the right to request that we restrict the processing of your personal information. The right to data portability: You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format. The right to withdraw consent: You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information. We may ask you to verify your identity before responding to such requests. You have the right to lodge a complaint with a Data Protection Authority (DPA) about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third-party companies and individuals ("Service Providers") to facilitate the Service, to provide the Service on our behalf, or to assist us in analyzing how the Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party service providers to monitor and analyze the use of the Site. Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Site. This data is shared with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. You can opt out of having made your activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visit activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Behavioral Remarketing

After you visit our Site, we use remarketing services to display advertisements to you on third-party websites. We and our third-party vendors use cookies to inform, optimize, and serve ads based on your past visits to our Site. Google Ads Google Ads remarketing service is provided by Google Inc. You can opt out of Google Analytics for Display Advertising and customize Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout for your web browser. The Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Storage

We use third-party web hosting and storage services to securely store our website and databases, including your personal information.
The service we use for data storage is Microsoft Azure. For Microsoft Azure's privacy policy, please see below:
https://www.microsoft.com/en-us/TrustCenter/Privacy/default.aspx

Links to Other Sites

Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

Children's Privacy

Our Site does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Updates to This Policy

We may review and revise the content of this Privacy Policy from time to time as necessary. In such cases, the revised Privacy Policy will apply from the date the revised version is published.

Contact Us

If you have any questions about this Policy, please contact us as follows.
Visit the following page:  https://zen.group/contact
By mail: [Mailing Address] Osaka Sakaisuji L Tower 10F, 1-7-7 Kawaramachi, Chuo-ku, Osaka 541-0048, c/o ZenGroup Co., Ltd.

"Basic Information Security Policy"

ZenGroup Co., Ltd. Head Office is within the scope of ISO 27001 certification. Above all, we aim to be a trusted and reliable company by earning the satisfaction of our customers, as well as everyone involved in cross-border e-commerce, all related operations, export business, shopping platform provision, marketing, and consulting services. Guiding Principles 1. We implement organizationally and technically appropriate measures to reliably protect the confidentiality, integrity, and availability of information assets, and respond to changing information technology and emerging threats. 2. We provide information security education to all employees and thoroughly communicate our policy in order to raise and maintain awareness. 3. We establish objectives related to our management system and information security, review them periodically, and continuously implement and maintain improvements. 4. We delegate responsibility and authority to management representatives in order to implement, maintain, and improve the management system.

Handling of Personal Information in Inquiries and Job Applications

(1) Name of the Business Operator ZenGroup Co., Ltd. (2) Name (or Title), Department, and Contact Information of the Personal Information Protection Manager (or their Representative) Personal Information Protection Manager: Sugahara Shin Email: privacy@zen.group Phone: 06-4560-4070 (3) Purpose of Use of Personal Information To respond to inquiries received To use in recruitment-related operations (providing recruitment information, making hiring decisions, communications related to the recruitment process, etc.) (4) Provision of Personal Information to Third Parties We will not provide the personal information we obtain to third parties, except as required by law. (5) Outsourcing of Personal Information Handling We may outsource all or part of the handling of the personal information we obtain. In such cases, we select outsourcing partners with an established personal information protection framework. (6) Consequences of Not Providing Personal Information Providing personal information is voluntary. If you do not provide certain personal information, we may be unable to respond to your inquiry. (7) Disclosure of Retained Personal Data and Contact Point for Inquiries At the request of the data subject, we will respond to requests for disclosure of retained personal data, notification of the purpose of use, correction/addition/deletion of content, suspension of use, erasure, suspension of provision to third parties, and disclosure of records of provision to third parties (collectively, "Disclosure, etc."). For the contact point for Disclosure, etc., please refer to "Contact for Complaints and Inquiries Regarding Our Handling of Personal Information" below. (8) Acquisition of Personal Information by Methods Not Easily Recognizable by the Individual We acquire personal information by methods not easily recognizable by the individual, such as through the use of cookies and web beacons. For details, please refer to our Privacy and Cookie Policy. (9) Safety Management Measures for Personal Information We take the necessary and appropriate measures for the safety management of personal information, including preventing and correcting leaks, loss, or damage. After responding to an inquiry, the personal information obtained is deleted within our systems. (10) Personal Information Protection Policy Please see the Personal Information Protection Policy within the "Privacy and Cookie Policy" section of our corporate website. (11) Contact for Complaints, Consultations, and Inquiries Regarding Our Handling of Personal Information

Personal Information Protection Policy

In conducting purchasing agency services, cross-border e-commerce, shopping platform provision services, marketing business, and consulting business, ZenGroup Co., Ltd. deeply recognizes that customers' personal information constitutes important information that forms part of their privacy. When handling personal information in the course of our business, we establish laws and internal regulations relating to personal information and personal information protection, and put in place an organizational structure, thereby striving to appropriately protect personal information, respecting our customers, and meeting the expectations and trust placed in us.

Acquisition, Use, and Provision of Personal Information

We specify the purpose of use of personal information within the scope of our business activities, and acquire, use, and provide personal information fairly and appropriately to the extent necessary to achieve that purpose. We also take measures to ensure that personal information obtained is not used for purposes other than those specified.

Compliance with Laws and Norms

We comply with laws relating to personal information, guidelines established by the government, other norms, and public order, and strive for the appropriate protection of personal information.

Appropriate Management of Personal Information

We fully recognize the risks of unauthorized access, loss, destruction, falsification, and leakage relating to the personal information we handle, and we implement reasonable safety measures while taking appropriate corrective action whenever an issue arises.

Responding to Inquiries

We respond appropriately to inquiries from data subjects regarding the personal information we handle, including requests for disclosure, correction, suspension of use, and complaints or consultations.

Continuous Improvement

We establish management regulations and a management structure relating to the protection of personal information, thoroughly implement them across the entire company, conduct periodic reviews, and strive for the continuous improvement of our personal information protection management system.

Regarding the Personal Information We Handle

Based on our "Personal Information Protection Policy," we are committed to the appropriate protection of personal information. We provide the following notice regarding personal information we acquire or hold for use in our business.

(1) Name and Address of the Business Handling Personal Information, and the Name of its Representative

(2) Name (or Title), Department, and Contact Information of the Personal Information Protection Manager (or their Representative)

(3) Purpose of Use of Personal Information

1. Retained Personal Data

Other purposes of use will be as separately and explicitly stated in writing.

2. Other Personal Information Acquired

(4) Contact Point for Inquiries Regarding Personal Information

(5) Name of the Accredited Personal Information Protection Organization to Which We Belong, and Where to Direct Complaints

(6) Disclosure Procedures

(7) Reception Method / Contact Point for Disclosure Requests

(8) Safety Management Measures Taken for Personal Information

To handle personal information appropriately, we have established regulations concerning personal information based on a personal information protection policy compliant with JIS Q 15001, and we operate a personal information protection management system. To ensure the proper handling of personal information, we take necessary safety management measures from four perspectives: organizational, personnel, physical, and technical.

[Organizational Safety Management Measures]

We take the necessary measures regarding the establishment of an organizational structure, operations conducted in accordance with rules governing the handling of personal data, the establishment of means to confirm the status of personal data handling, the establishment of a system to respond to leakage incidents, and the review of the handling status and safety management measures.

[Personnel Safety Management Measures]

We conduct regular training for employees on matters to be observed in the handling of personal data. We also obtain written pledges from employees, including confidentiality provisions relating to personal data.

[Physical Safety Management Measures]

We take the necessary measures regarding the management of areas where personal data is handled, the prevention of theft of devices and electronic media, the prevention of leakage when carrying electronic media, and the deletion of personal data and disposal of devices and electronic media.

[Technical Safety Management Measures]

With respect to information systems, we take the necessary measures regarding access control, identification and authentication of those accessing systems, prevention of unauthorized external access, and prevention of leakage arising from the use of information systems.

We outsource certain operations to third parties located overseas, and we implement appropriate safety management measures, including understanding the external environment in which they operate.

For details on our specific safety management measures, please contact the [Inquiry Desk] below.

[Inquiry Desk]