Date Last Updated: April 1, 2025

"MICWARE CO., LTD." (the "Company") shall comply with Japanese Act on the

Protecon of Personal Informaon, the law of the EU concerning the protecon of Personal

Data including the GDPR and other related laws, ordinances and guidelines and appropriately

handle the Personal Data obtained from the user as follows for the protecon of the Personal

Data.

If you are a California "consumer" within the meaning of the California Consumer

Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, please

read Addendum for California Consumer Privacy Act for addional informaon.

1 . Personal Data to Be Processed

The Company shall process (meaning any operaon or set of operaons which is performed

upon personal data or sets of personal data, whether or not by automated means, and such

operaon means acquision, recording, organizaon, structuring, storage, reccaon,

alteraon, recovery, retrieval, consultaon, use, disclosure by transmission, disseminaon or

otherwise making available, alignment, combinaon, restricon, erasure or destrucon;

hereinaer the same) the Personal Data of the user that you give us through the service,

including but not limited to the following informaon.

User ID, Nickname, Locaon informaon of user (including during background operaon),

Use log of NaviCon and NaviBridge applicaon (including locaon and me of use), and

History of access to Company's server (including me, IP address and Cookie)

Since it is necessary for the Company to receive such informaon from the user to provide the

user with the service, the user who cannot provide such informaon may not use the service.

2. Legal Basis for and Purpose of Processing Personal Data

We will process your personal data on the following legal bases unless such data

processing would conict with applicable laws and regulaons:

- Contract. When we need to process your personal data to perform a contract we

enter into with you.

- Legal Obligaon. When we need to comply with a legal obligaon.

- Legimate Interests. When the processing of your personal data is necessary for

the fullment of legimate interests pursued by us or a third party and your

interests and fundamental rights do not override those interests.

- Consent. When you have given consent for us to process your personal data.

However, even if we obtain consent from you, we may process your personal data

based on other legal grounds. The withdrawal of your consent shall not aect the

lawfulness of processing performed based on the consent before your withdrawal.

We use the personal data that we hold about you for the following purposes. We will

only use your personal data to the extent that it is necessary to do so to full the

purposes described below.

- To provide merchandise or services that you request (based on contract or

legimate interests)

- To improve our merchandise or services we provide to you (based on contract or

legimate interests)

- To provide informaon and communicaons; to conduct quesonnaires relang

to products, services, various events, campaigns, and similar maers (based on

legimate interests)

- To conduct sales analysis, invesgaons, and research; to develop new services

and products (based on legimate interests)

- To conduct web analycs (see our Cookie Policy)

- To ensure compliance with legal obligaons (such as record keeping obligaons),

export control and customs, compliance screening obligaons (to prevent

whitecollar or money laundering crimes), and our policies or industry standards

(based on legal obligaon or legimate interests)

- To solve disputes, enforce our contractual agreements and to establish, exercise

or defend legal claims (based on legal obligaon or legimate interests).

You may experience disadvantages if you refuse to provide your personal data, such as

being unable to make use of some of our services.

The Company shall keep the Personal Data of the user as long as it is necessary to

provide the user with the service but promptly erase it if it is no longer necessary.

3. Provision to Third Party

The Company shall provide the companies which the Company entrusts to develop and

operate the service to and es up with to provide the service or new related service

with the Personal Data of the user for the purpose of accomplishing the purposes of

use specied above.

4. Ensuring of Accuracy

The Company shall endeavor to keep the Personal Data up to date and if it is inaccurate

or insucient, recfy it.

5. Security

To prevent unauthorized access to Personal Data or divulgence of Personal Data, the

Company evaluates and determines the risk of breach of the Personal Data privacy in a

comprehensive manner aer taking into account the category of Personal Data, degree

of sensivity, inuence including economic and mental damage to the user when the

Personal Data privacy is breached, and takes personnel, organizaonal and technical

safety management measures that are necessary and appropriate according to the risk

of breach of Personal Data privacy, set the process to inspect and correct such safety

management measures as necessary and makes ceaseless eorts to improve security.

6. Access to Personal Data, Reccaon, Erasure, Restricon on Processing, Right

of Data Portability

The user may request the Company make the Personal Data concerning the user

retained by the Company available to the user, recfy or restrict the processing of such

informaon or take procedures for data portability within the scope which is

recognized by the laws and regulaons of each county and region. Further, the user

shall have the right to raise an objecon to the Company or data protecon authority

governing the locaon where the user resides with respect to the processing of the

Personal Data related to the user within the scope which is recognized by the laws and

regulaons of each county and region. If the user requires the procedures for

exercising various types of rights granted to the user with respect to the Personal Data,

please contact us at the following e-mail address.

navicon_support@micware.jp

7. Amendment to Privacy Policy

The Company may amend the privacy policy at any me. If the Company amends this

8. Company's Policy for Children

The Company makes sure to obtain the consent of a guardian when obtaining Personal

Data from the user under 16 years of age. The Company shall request the user under

16 years of age ask his/her guardian to give consent aer his/her guardian has

conrmed the details of the privacy policy without fail, but shall not request the user

himself/herself give consent, before using the service. Further, if a guardian or other

person nds the user under the age of 16 who consents to the privacy policy and uses

the service without obtaining the conrmaon and consent of his/her guardian, please

nofy the Company at the following contact point.

9. Inquiries

If the user has any maer for consultaon or queson with respect to the privacy policy or the

processing of the Personal Data by the Company, or request with respect to the access to,

reccaon or erasure of the Personal Data, restricon on processing or right of data

portability, please contact the Company at the following website.

navicon_support@micware.jp

10. Administrator and Representave

The Company determines the purposes of use and method of processing of the Personal Data of

the user. The contact informaon of the Company is as follows.

"MICWARE CO., LTD."

Kobe Crystal Tower 9F 1-1-3, Higashikawasaki-cho,

Chuo-ku, Kobe-shi, Hyogo, Japan

navicon_support@micware.ip

Addendum for California Consumer Privacy Act

Last Updated: April 1, 2025

If you are a California "consumer" within the meaning of the California

Consumer Privacy Act of 2018 ("CCPA"), as amended by the California

Privacy Rights Act ("CPRA this Addendum for California Consumer Privacy

Act ("CCPA Addendum") applies to you. The CCPA Addendum supplements

our privacy policy (the "Policy") and prevails over any conicng provisions

in the Policy. We are both a "business" and a "service provider" under the

CCPA. This CCPA Addendum applies to informaon we collect in our role as

a business. If you would like more informaon about how your personal

informaon is processed by such other companies, including companies

that engage us as a service provider, please contact those companies

directly.

This CCPA Addendum uses certain capitalized terms that shall have the

meanings given to them in the CCPA

1 . Our Collecon, Use, and Disclosure of

Personal Informaon

A. Categories, Sources, and Purposes of Your Personal Informaon

Collected or to Be Collected

The table below describes the categories of Personal Informaon (as listed

in the CCPA) that we may collect, and have collected during the 12-month

period prior to the eecve date of this CCPA Addendum.

Category of Personal

Informaon Collected Example

A. Ideners

User ID, IP address, Nickname

use log of NaviCon and NaviBridge applicaon (including

locaon and me of use, userID,), and history of access

to F. Internet or network acvity informaon

Company' s server (including me, IP address, HTTP

version, URLs, and cookies)

G. Geolocaon data Locaon informaon of user(including during background

operaon)

Purposes Of Collecon. The business or commercial purposes for which the

categories of Personal Informaon will be collected or used, or was

collected or used during the 12-month period prior to the eecve date of

this CCPA Addendum, is as described in "2. Legal Basis for and Purpose of

Processing Personal Data" in the Policy.

Categories of Sources. The categories of sources from which Personal

Informaon was collected during the 12-month period prior to the eecve

date of this CCPA Addendum are as described in "I . Personal Data to Be

Processed" in the Policy.

B. Sharing of Your Personal Informaon

(A) Sale of Your Personal Informaon

There is Personal Informaon that we may have sold during the 12-

month period prior to the eecve date of this CCPA Addendum.

Children's Personal Informaon and Opt-ln Right. We do not sell, and have

not sold, the Personal Informaon of minors under 16 years of age.

(B) Disclosure of Personal Informaon for a Business Purpose

The table below describes: (i) the categories of Personal Informaon (as

listed in the CCPA) that we may have disclosed for our operaonal business

purposes during the 12-month period prior to the eecve date of this CCPA

Addendum; and (ii) the categories of third pares to whom we have

disclosed such Personal Informaon for our operaonal business purposes

during the 12-month period prior to the eecve date of this CCPA

Addendum.

Category of Personal

Informaon Disclosed Example

A. Ideners

User ID, IP address,

Nickname

use log of NaviCon and

NaviBridge applicaon

Third Pares to whom

Personal Informaon Was

Disclosed in the Last 12

Months

Our employees

Service providers including

applicaon development,

infrastructure construcon,

operaon monitoring, and

anomaly invesgaon

Our employees

Service providers including

F. Internet or

network acvity

informaon

(including locaon

and me applicaon

development,

of use, userID, user agent), infrastructure construcon,

and history of access to operaon monitoring, and

Company s server anomaly invesgaon

Third Pares to whom Personal

Category of Personal

Informaon Was Disclosed in

Informaon Disclosed

Example

the Last 12 Months

(including me, IP address,

HTTP version, URLs, and

cookies)

Our employees

Service providers including

applicaon development,

G. Geolocaon data

Locaon informaon of

infrastructure construcon,

user(including during

operaon monitoring, and

background operaon)

anomaly invesgaon

2. Your Rights and Requests

If you are a California consumer, you have certain choices regarding your

Personal Informaon, as described below:

- Access: You have the right to request, twice in a 12-month period,

that we disclose to you the categories and specic pieces of informaon

we have collected, used, disclosed, and sold about you during the 12

months preceding your request:

- Deleon: You have the right to request that we delete certain

Personal Informaon we collected from you, subject to certain

limitaons under applicable law.

- Sale: You have the right to disclosure of any Personal Informaon we

have shared for valuable consideraon.

- Non-Discriminaon: You have the right not to be discriminated

against for exercising certain rights under California law.

How to Submit a Request. To exercise the above rights , please submit

requests to:

E-mail: navicon_support@micware.jp

Please be as specic as possible in relaon to the Personal

Informaon you wish to access.

Verifying Requests. We will take steps to verify your identy before granng you

access to your Personal Informaon or complying with your deleon request.

Upon receiving an access or deleon request from you, we will rst verify your

identy by requiring you to submit your name and e-mail address, and by

matching the informaon you provide with what we already have on le.

If you use an authorized agent to make an access or deleon request on

your behalf, we may require you to (1 ) provide the authorized agent signed

permission to do so, (2) verify your own identy directly with us (as

described above), and (3) directly conrm with us that you provided the

authorized agent permission to submit the request.

3. Changes to this CCPA Addendum

We may change this CCPA Addendum from me to me. The "Date last

updated" at the top of this page states when this CCPA Addendum was last

updated; any changes will become eecve upon us posng the revised

California Addendum.

We will post a prominent noce on the site to nofy you of any signicant

changes to this CCPA Addendum and indicate the date it was most recently

updated.

4. Contact Us

If you have any quesons or concerns regarding this CCPA Addendum or our

privacy pracces, please contact us at our oce address described in " 10.

Administrator and Representave" in the Policy.

California Consumer Privacy Act Noce at Collecon

In this noce, "MICWARE CO., LTD." ("MICWARE") is addressing specic disclosure requirements

under the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California

Privacy Rights Act of 2020 ("CPRA"), vis-a-vis California residents who are not acng as an

employee, owner, director, ocer, or contractor of a company, partnership, sole proprietorship,

non-prot, or government agency (a "Business Representave") where MICWARE holds personal

informaon reecng a wrien or verbal communicaon or a transacon between MICWARE

and the Business Representave and the communicaons or transacon with MICWARE occur

solely within the context of MICWARE conducng due diligence regarding, or providing or

receiving a product or service to or from such company, partnership, sole proprietorship, non-

prot, or government agency.

1. Categories of Personal Informaon. MICWARE collects personal informaon through its

mobile applicaon. The personal informaon MICWARE collects depends on the parcular

request and the way you interact with the mobile applicaon. The categories of personal

informaon include unique user IDs, Nickname, your locaon informaon (including in the

background), log data including IP address, use log of NaviCon and NaviBridge applicaon

(including locaon and me of use, user agent), and history of access to MICWARE's server

(including me, HTTP version, URLs, and cookies).

2. Purposes. MICWARE uses personal informaon to provide merchandise or services that

you request to:

* improve our merchandise or services we provide to you; provide informaon and

communicaons; conduct quesonnaires relang to products, services, various events,

campaigns, and similar maers; conduct sales analysis, invesgaons, and research;

* develop new services and products;

* conduct web analycs;

* ensure compliance with legal obligaons (such as record keeping obligaons), export

control and customs, compliance screening obligaons (to prevent white-collar or money

laundering crimes), and our policies or industry standards (based on legal obligaon or

legimate interests); and

* solve disputes, enforce our contractual agreements and to establish, exercise or defend

legal claims.

3. Recipients of Informaon. MICWARE shares your personal informaon with our

employees and unaliated service providers for applicaon development, infrastructure

construcon, operaon monitoring, and anomaly invesgaon.

If you have a visual disability, you may be able to use a screen reader or other text-to-speech or

text-to-Braille tool to review the contents of this noce.