AxelGlobe Privacy Policy – Addendum to the Axelspace Privacy Policy

Axelspace Corporation (“Axelspace”) hereby sets forth this AxelGlobe Privacy Policy (this “Policy”) regarding the handling of personal data of the Users of the services provided on the AxelGlobe platform (the “Services”). “Users” in this Policy include the Registered Users and the Non-signed up Users as defined in the Terms of Use of the Services, as well as individuals who intend to become such users and who make inquiries regarding the use of the Services. This Policy shall apply in conjunction with the privacy policy separately established by Axelspace. In the event of any inconsistency between the two, this Policy shall prevail in connection with the Services.

1. Acquisition of Personal Information

Axelspace may acquire personal data such as name, date of birth, address, telephone number, email address, bank account number, and credit card number when the Users register for use of the Services. In addition, Axelspace may automatically acquire access logs and other usage information when the Users browse or use the Services. Axelspace may also acquire personal data such as name, telephone number, and email address when the Users make inquiries, regardless of whether they are to register as users.

2. Purposes of Use for Personal Information

Axelspace shall use personal data for the following purposes:

Personal data of the users:
1. To provide and operate the Services;
2. To register users and verify identity when using the Services, and manage user accounts;
3. To respond to inquiries from the users;
4. To notify users of new features, updates, campaigns, and other information related to the Services or products or services of Axelspace or its group companies (the “Services, etc.”);
5. To contact users as necessary regarding maintenance, important notices, or other matters;
6. To identify users who violated the Terms of Use or attempt to use the Services for fraudulent or improper purposes, and to refuse their use;
7. To allow users to view, correct, delete, or review their registration information and usage status;
8. To bill users for fees related to paid services;
9. To conduct marketing activities, including proposals, advertisements, and promotions for the Services, etc. of Axelspace or its group companies other than the Services actually used; such activities may include cases where information such as a user’s browsing history and usage history of the website, services, etc. is analyzed and used in accordance with the user’s needs, interests, and preferences;
10. To improve the Services, etc. including the Services, and for planning, researching, developing, and marketing new services provided by Axelspace, as well as for related reference purposes; or
11. Purposes incidental to the above.
Personal data of users other than the Users:
1. To respond to inquiries; or
2. To provide information regarding Services, etc. or newly developed Services, etc. of Axelspace or its group companies.

3. Provision of Personal Data to Third Parties

With respect to GRUS Data Products (as defined in the Terms of Use) provided by　Axelspace to users upon their requests under the Services, Axelspace may allow other users to view or otherwise use such GRUS Data Products within the Services.
In addition to the preceding paragraph, Axelspace will not provide personal information to any third party (including those located outside Japan) without obtaining the prior consent of the Users, except in the following cases; provided, however, that this shall not apply where such provision is permitted under the Act on the Protection of Personal Information or other applicable laws and regulations:
1. When it is necessary to protect the life, body, or property of an individual and it is difficult to obtain consent;
2. When it is particularly necessary to improve public health or promote the sound development of children;
3. When cooperation is required with a national government, local government, or a party entrusted thereby, and obtaining consent may hinder the execution of such affairs; or
4. When personal data is provided to an academic research institution for academic research purposes, provided that there is no risk of unjustly infringing the rights and interests of individuals.
Notwithstanding the provisions of the preceding paragraph, in the following cases, the recipient of such information shall not be deemed a third party:
1. When Axelspace entrusts all or part of the handling of personal data to the extent necessary to achieve the purpose of use;
2. When personal data is provided due to succession of business as a result of merger or other reasons; or
3. When personal data is jointly used with the entity specified below:
  1. Jointly used personal data: personal information of Users, such as their name, date of birth, address, telephone number, email address, bank account number, and credit card number, as well as transaction records and payment-related information containing the User’s personal information that are made between the User and business partners (including information providers, advertisers, and advertising distribution partners);
  2. Entity jointly using the data: Axelspace Holdings Corporation
  3. Purpose of joint use: identifying and managing management risks of group companies and ensuring compliance management;
  4. Person responsible for management of personal data: Yuya Nakamura, Representative Director.

4. Use of Cookies and Similar Technologies

The Services use Google Analytics, a service provided by Google LLC. Data collected through the use of Google Analytics is managed in accordance with Google’s Privacy Policy.

For details regarding Google Analytics and opt-out procedures, please refer to Google Analytics Terms of Service and How Google uses information from sites or apps that use our services.

5. Contact Point

Axelspace shall make sincere and prompt efforts to respond to inquiries, opinions, or complaints regarding the handling of personal data. Please contact us through the inquiry form available on Axelspace’s website.

Yuya Nakamura

President and CEO

Axelspace Corporation

Effective date: February 26, 2026