1. Scope of Personal Information

1. Name, address, date of birth, corporate name, department, e-mail address, educational background, employment history, and registration information required to use the Company’s solutions.
2. Information related to transactions, such as the content of usage solutions and the billing of their fees.
3. User IDs and passwords assigned by the Company for use of the Company’s solutions.
4. Information such as statements, questions, answers, responses to questionnaires, and replies to questions and answers made in the course of using the Company’s solutions. However, remarks made in the open general forum will not be covered as they are publicly disclosed.
5. Login, logout and other information recorded in the process of using the Company’s solutions.
6. Other information such as inquiries and applications made to and from the Company by email, telephone, fax, letter, etc., as well as the Company’s answers and responses to such inquiries and applications.

2. Scope of Eligible Customers

The term “customer” as used in this statement refers to the following persons:

1. Corporations and individuals who are about to use or have used the Company’s solutions.
2. Corporations and individuals who make inquiries to the Company by telephone, e-mail or letter, etc., and where the identity of the inquirer can be determined.

3. Purpose of Use of Personal Information

We disclose the purpose of using personal information as follows, according to Articles 21 and 32 of the Laws for the Protection of Personal Information.

1. Personal Information (Name, email address) of Customers and Other Persons Contacting Us
   • To provide the Company’s solutions.
   • To perform duties incidental to the provision of the Company’s solutions, such as billing for the use of solutions, to respond to inquiries from recipients, and to respond to requests for materials, consultations, and inquiries.
   • To research and analyze trends in the use of the Company’s solutions.
   • To research or develop new solutions for the Company.
2. Personal Information of Investors (Name, corporation, address, telephone number, email address, inquiry contents)
   • For the exercise of privileges and fulfilment of responsibilities in accordance with corporate laws on shareholder management, etc.
   • To implement measures for more efficient investor relations
   • To prepare and manage IR data (including lists of investors and shareholders, shareholding amount, etc.) according to due standards in accordance with all applicable laws
3. Personal Information of Those Who Seek Employment at Our Company (Name, photographic likeness, birthdate, gender, address, telephone number, email address, personal history, career history)
   • To provide information to and facilitate communication with those who are interested in employment at our company, and those who have submitted job applications to us
   • For use in the recruitment and employment screening process
4. Personal Information of Our Executives and Employees (Name, birthdate, gender, address, telephone number, and information about relatives, bank account, and other necessary items)
   • For personnel administration, including the appropriate placement of staff members, payment of salary, and other human resource management matters
   • In connection with staff welfare and benefits, labor safety and health management
   • For staff training and development
   • For issuing notices and reports in accordance with all applicable laws, rules, and regulations
   Additionally, in the case of other purposes than those mentioned herein, separate notification will be issued, and usage will strictly adhere to the purposes outlined therein.

4. Safety Management Measures

The following measures have been implemented for managing the safety of personal information entrusted to us by our customers, to prevent the leaking, loss and/or damage of personal information.

5. Handling of Personal Information

We will use your personal information only for the following purposes.

1. When we receive personal information from customers
   When we are required to provide a customer’s personal information, we will inform that customer of the purpose for which the information will be used and obtain the customer’s consent to such use.
   If you are an individual, other than the personal information stipulated by the Company, you will never be asked to provide any information such as ideology, beliefs, religion, race, ethnicity, family origin, legal domicile (excluding information related to the prefecture where you live) physical or mental disability, or criminal record.
2. Acquisition of personal information
   Other than receiving personal information provided by our customers, the Company will not acquire personal information by any unauthorized method, nor will we use customer information that has been acquired illegally.
3. Use of personal information
   The Company will not use personal information for any purpose other than that to which the customer has given consent.
   In addition, the personal information provided by customers will be disclosed to NetLearning Holdings, Inc. and NetLearning, Inc. to whom we outsource part of our business.
4. Provision of personal information to third parties
   Without prejudice to the application of the provisions of the preceding article, the Company will not provide the personal information in its possession to any third party, except in the following cases:
   1. With the prior consent of the individual.
   2. When personal information is handled jointly with or entrusted to a third party in order to achieve the purpose of use.
   3. When personal information is passed on to a third party in order to continue the solution as part of operating assets due to a business transfer, spin-off, etc.
   4. When personal information is used mutually with a specific third party, and the purpose of use and the specific third party are notified to the individual in advance or made public.
5. Management of personal information
   In addition to ensuring that personal information received from customers is not illegally accessed, lost, destroyed, illegally leaked outside the company, or tampered with, the Company will ensure that employees manage personal information, encrypt personal information provided by customers during communication, take measures against unauthorized computer access, take measures against viruses, and maintain data backup systems.

6. Disclosure of Personal Information

Regarding inquiries and other requests about personal information
When we receive the following requests from customers regarding their own information that we manage, we will respect the customer’s wishes and take the necessary action to a reasonable extent after confirming the customer’s identity.

1. 1. Confirmation of the details of personal information
   2. Correction, updating, and deletion of personal information.
   3. Withdrawal of all or part of the consent to the use of personal information that you have given the Company
   4. Notification of purpose of use, disclosure, correction, addition or deletion of contents, suspension of use, elimination and suspension of provision to third parties

7. Other precautions and notes

1. Statement regarding customer information on linked websites
   The Company’s website may contain links to third party websites, but the Company does not manage these sites.
   Therefore, we recommend that you check the statement regarding your personal information (or privacy policy, etc.) of each linked site by yourself.
2. Use of cookies
   We use cookies on our website.
   Cookies are a feature that allows us to know which pages on our website have been accessed from your computer and when they were accessed.
   This helps to support the learning process by bringing up the next page when the student next accesses the site.
   Cookies also enable us to learn about the state of your learning and help us build a better e-learning system.
3. Revision of this statement
   If there are any revisions to this statement, they will be posted on this page.

1. Basic principles

Lecos, Inc. (hereinafter referred to as "LecoS") has established this Privacy Policy in accordance with GDPR with respect to the handling of personal data to which the EU General Data Protection Regulation (hereinafter referred to as "GDPR") applies. LecoS will take all possible measures to handle personal data by establishing an internal system, protecting personal data, managing it appropriately, and using it appropriately.

2. Collected personal data

1. We may obtain the following personal data from users of our website:
   • Name
   • Email address
   • Username and password
   • IP address
2. We do not collect sensitive personal data such as passport information or health data through our site, except in case they become required by applicable privacy laws.
3. We collect personal data when you
   • Perform registration on our site
   • Actually use our site

3. Purpose of personal data processing

We will handle the personal information of our users in accordance with Article 6.1.(b) of the GDPR in order to fulfill the following purposes of use in the performance of the contract with our users.

1. Purpose of processing

   We collect and process personal data only for the following purposes

   • To ensure that our services are presented to you in the most effective manner.
   • To inform you about changes to our services.
   • To manage users' accounts.
   • To provide our services to users.
   • To inform users of our policies and terms and conditions.
   • To improve safety and security by monitoring for fraudulent activity, investigating suspicious or potentially illegal activity, or violations of our policies or terms and conditions.
   • To provide, improve, and create services and advertising.
   • To use personal information for purposes such as data analysis, research, and auditing.
   • To ensure business continuity.
   • To respond to various types of inquiries.
   • To perform tasks incidental and related to the above items.
2. We process personal data on the legal basis of consent of the data subject, legitimate interests pursued by us or by a third party, performance of a contract between the data subject and us or preparation for entering into a contract, or compliance with a legal obligation to which we are subject.
3. If the processing of personal data by our company is based on the consent of the data subject, the data subject may withdraw the consent at any time. However, the legality of the processing of personal data based on the consent before the withdrawal is not affected by the withdrawal of consent.
4. In the event that the personal data acquired is to be handled for purposes other than those described above, this Privacy Policy will be revised to inform the data subject.

4. Providing and sharing personal data

We may need to share personal data with the following third parties for the purposes of the processing described above. Where this is necessary, we will comply with applicable privacy laws.

5. Personal data security administration

When handling personal data, we will manage it appropriately and take appropriate and reasonable security measures to prevent unauthorized external access, loss, destruction, falsification, leakage, and other risks. In the unlikely event of an accident, we will promptly take corrective measures.

6. Storing personal data

We store personal data in a manner that establishes appropriate security. LecoS will store personal data only for as long as is necessary to achieve the purposes of use described in this Privacy Policy and will promptly delete personal data that are no longer needed. The specific period of time will be determined by taking into consideration the purpose for which the personal data is acquired and handled, the nature of the personal data, and the legal or business necessity for storing the personal data.

7. About the（Cookie）

When you visit our website, we often use Cookies to store and retrieve information on your browser. This information may include information about you, your preferences, and your device. In many cases, this information is used to ensure that the website behaves as you expect it to. The information collected is generally not personally identifiable but helps us personalize your website experience. We respect your privacy and allow you to choose not to use some Cookies. Please note that blocking some types of Cookies may affect the usability of our site and the services we provide.

8. Expressing disagreement

You have the right to appeal to a supervisory authority, such as a national, regional, or international organization, regarding our processing of your personal information in accordance with the GDPR and other applicable laws. We would appreciate it if you gave us the opportunity to respond before you file a complaint with a supervisory authority. If possible, please contact us in advance using this contact form.

9. Contact information

If you have any questions or complaints, or if you wish to exercise any of your rights described in Section 8 of this Privacy Policy, please contact us at the following:

10. General conditions

This Privacy Policy takes effect as of October 31, 2023. We may change this Privacy Policy from time to time as required by law or by our business policy. However, we will not use the personal data of data subjects in any other way than originally intended without their consent.