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 an individual in the European Economic Area (EAA, comprising the European

Union member states as well as Iceland, Liechtenstein and Norway), please read

Addendum for Individuals in EEA 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 Policv)

- 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

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 Individuals in EEA

Last Updated: April 1, 2025

If you are an individual in the European Economic Area (the "EEA",

comprising the European Union member states as well as Iceland,

Liechtenstein and Norway), this addendum applies to you. This addendum

supplements our privacy policy (the "Policy") and prevails over any

conicng provisions in the Policy.

1 . Legal Basis for and Purpose of Processing

Personal Data

We will process your personal data on the legal bases and for the purposes

outlined in the Policy (see item 2.). In addion, the following applies:

Legimate Interests. Our legimate interests for processing

your data could be, in parcular, to merchandise our services, to conduct

market research and to analyze trends, as well as to develop new

services and products (more informaon on the balancing test is

available upon request).

Consent. In case we obtain consent from you, we may process

your personal data based on other legal grounds, but only as far as such

processing is not already covered by your consent.

2. Your rights

You have a number of legal rights in relaon to the personal data that we

hold about you. The following is a summary of each of the rights you may

exercise. Please note that these rights might be limited under applicable

naonal data protecon law.

* the right to obtain informaon regarding the processing of your

personal data and access to the personal data which we hold about you;

* the right to request that we recfy your personal data if it is inaccurate

or incomplete; the right to request that we erase your personal data in

certain circumstances. This may include (but is not limited to) circumstances

in which: - it is no longer necessary for us to retain your personal data for

the purposes for which we collected it;

* we are only entled to process your personal data with your consent,

and you withdraw your consent (provided there is no other legal ground for

the processing); or

* you object to our processing of your personal data for our

legimate interests, and our legimate interests do not override your

own interests, rights and freedoms (if your personal data is processed

for direct markeng purposes, you have the right to object at any me

to the processing of your personal data for such markeng);

* the right to request that we restrict our processing of your personal

data in certain circumstances. This may include (but is not limited to)

circumstances in which:

* you dispute the accuracy of your personal data (but only for the period

of me necessary for us to verify its accuracy);

* we no longer need to use your personal data for our processing,

but you require them for the establishment, exercise or defence of

legal claims; or - you object to our processing your personal data for

our legimate interests (but only for the period of me necessary for

us to assess whether our legimate interests override your own

interests, rights and freedoms);

* the right to object to us about our processing of your personal data; *

the right to receive any personal data which we process about you on the

basis of your consent or for the performance of a contract with you (as

opposed to any other legal ground) in a structured, commonly used and

machine-readable format and/or request that we transmit that data to a

recipient where this is technically feasible. Please note that this right only

applies to personal data which you have provided to us, and on the

condion that the processing is carried out by automated means;

* the right to withdraw your consent to our processing of your personal data

at any me. Please note, however, that we may sll be entled to process your

personal data if we can rely on another legal ground for doing so.

*You can exercise your rights by contacng us using the informaon about us

indicated in Secon 10 of the Policy. You can also lodge a complaint with a data

protecon authority if you think that any of your rights have been infringed by us.

The provision of personal data is necessary for the conclusion of the

contract between us and/or the performance of the services provided by us,

and it is voluntary. However, if you do not provide the personal data, the

provision of the services might be delayed or impossible.

3. Data Transfer Outside EEA countries and UK

Personal data is transferred to us in Japan. The EU Commission has made an

adequacy decision to the eect that an adequate level of data protecon

exists in Japan.

In the event that the recipients of your personal data are located in third

countries for which the EU Commission has not made an adequacy decision

to the eect that an adequate level of data protecon exists in these third

countries, we will take other measures to implement appropriate

guarantees for the protecon of your personal data in accordance with the

GDPR.

Personal data is only transferred to external recipients in third countries if

they have concluded EU standard contractual clauses with us.

For further informaon on the respecve guarantee, please refer to the

following link:

- EU Standard Contractual Clauses

Further informaon and a copy of the implemented measures can be

obtained upon request from us (see the informaon about us indicated in

Secon 10 of the Policy).

4. Retenon Period

Your personal data is stored by us and/or our service providers to the extent

necessary for the performance of our obligaons and for the me necessary

to achieve the purposes for which the informaon is collected, in

accordance with applicable data protecon laws. When we no longer need

to use your personal data to comply with contractual or statutory

obligaons, we will remove it from our systems and records and/or take

steps to properly anonymize it so that you can no longer be idened from

it, unless we need to keep your personal data to comply with legal or

regulatory obligaons to which we are subject, e.g. statutory retenon

periods which can result from commercial and tax laws and usually contain

retenon periods from six to ten years, or if we need it to preserve evidence

within the statutes of limitaon, which is usually three years but can be up

to 30 years.

5. Automated Decision-Making

We do not engage in automated decision-making in the context of data

processing as outlined in the Policy including this addendum to the Policy.

6. Contacts

If you have any quesons about the Policy, this addendum, your rights, or

any other issues regarding the protecon of your personal data, or if you

wish to exercise any of your rights, you may contact us as follows:

"MICWARE CO., LTD."

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

Kobe-shi, Hyogo, Japan

navicon_support@micware.ip