Mantra Inc.(the "Company") sets forth this Privacy Policy (this "Policy") with regard to the treatment of user information, including but not limited to personal information, in the course of the performance of Service provided by the Company (the "Service"), as follows;

1 Company name, address, and the representative name

1. Company name
   Mantra Inc.
2. Address
   2-2-14, Nakagawa, Adachi-ku, Tokyo
3. The representative name
   Shonosuke Ishiwatari

2 User Information to be Collected and Method of Collection

For purposes of this Policy, "User Information" means information identifying users, history of actions in the Service and other information created or accumulated in relation to users or their devices, that are collected by the Company pursuant to this Policy.

The User Information that the Company may collect in the course of the Service is as follows, depending on the method of collection.

1. Information provided by the user

   The information to be provided by the user for or through the use of the Service is as follows:

   • name, date of birth, sex, occupation and other profile information;
   • e-mail address, telephone number, address and other contact information;
   • credit card information, bank account information, e-money information and other information regarding payment method;
   • information of image containing the user's portrait; and
   • information transmitted by the user through entrance forms or other methods specified by the Company;
2. Information automatically collected by the Company in the course of the user's use of the Service

   The Company may collect information regarding access to or use of the Service, which includes the following.

   • referer
   • IP address
   • information regarding server access logs
   • cookies, ADID, IDFA and other identifiers

3 Purpose of Use

Specific purposes of use of the User Information for the provision of the Service are as follows:

1. provision, maintenance, protection and improvement of the Service, including but not limited to acceptance of registration for the Service, identification, record of user settings and payment of use fees that are related to the Service;
2. measurement of traffic and actions of the user
3. distribution, display and measuring effect of advertisements
4. guidance and response to inquiries relating to the Service;
5. addressing a violation of rules, regulations or policies of the Company relating to the Service (the "Rules"); and
6. notice of modification to the Rules or related matters.

4 Method of Notice, Publication and Consent; Method of Requiring Discontinuance of Use

4.1 The user may require the Company to discontinue the collection or use of the all or a part of the User Information by choosing the applicable setting as prescribed in the Service, and promptly upon such request the Company shall discontinue such collection or use in accordance with the rules prescribed by the Company. Certain User Information is necessary to be collected or used for providing the Service, and the Company shall discontinue such collection or use of the User Information only if the user withdraws from the Service pursuant to the procedures as determined by the Company.

5 Outside Transmissions; Provision to Third Parties; Information Collection Modules

5.1 The following affiliated parties may save cookies in the user's devices and thereby accumulate and use the User Information.

(1) Affiliated Party	Google
(2) URL of Privacy Policy of Affiliated Party above	https://policies.google.com/privacy
(3) URL for Opt-out (invalidation) of Affiliated Party above	https://policies.google.com/privacy https://tools.google.com/dlpage/gaoptout

5.2 The following information collection modules are incorporated into the Service. Thus, the Company provides the User Information to the providers (including but not limited to those outside Japan) of such information collection modules in accordance with the following descriptions:

(1) Name of Information Collection Module	Google Analytics
(2) Provider of Information Collection Module	Google
(3) Purposes of Use by above Provider	https://marketingplatform.google.com/about/analytics/terms/us/
(4) URL of above Provider's Privacy Policy	https://policies.google.com/privacy

6 Provision of Personal Information to Third Parties

The Company shall not provide to any third party (including the same outside Japan) personal information contained in the User Information without the prior consent of the user, except where such provision is required due to any of the following circumstances:

1. The Company authorizes such third party to handle the personal information in whole or in part to the extent necessary to accomplish the purpose of the use;
2. The personal information is provided through a business transfer by way of merger or other similar transactions;
3. The personal information is provided to an affiliated party or a provider of an information collection module pursuant to Section 4 hereof;
4. The Company is required to cooperate with state or local governmental organizations or their agents to perform their duties or obligations pursuant to applicable laws and regulations, and such performance is likely to be precluded if the consent of the user must be obtained; and
5. In addition to the foregoing, the Company is entitled to provide information pursuant to the Act on the Protection of Personal Information (the "Act") or other applicable laws and regulations.

7 Security Control Measures

The Company shall take necessary and appropriate safety management measures to manage User Information, such as preventing leakage, loss, or damage. The Company shall also supervise employees and contractors (including subcontractors) who handle User Information in a necessary and appropriate manner. The main contents of safety management measures for User Information are as follows:

• In order to ensure the proper handling of User Information, the Company has established this privacy policy for compliance with relevant laws and regulations, guidelines, and contact points for questioning and complaint handling.
• The Company has appointed a person in charge of the handling of User Information, and clarified the scope of employees handling user information and User Information handled by employees. Also, the Company has established a system for reporting information to the person in charge of the handling of User Information, in event that any fact or sign of violation of the Personal Information Protection Law or the Personal Information Handling Regulations is identified.
• The Company shall conduct periodic self-inspections of the status of the handling of User Information.
• The Company shall regularly train employees regarding the handling of User Information.
• The Company requires our employees to comply with the confidentiality of User Information, by receiving written pledges and other documents.
• The Company shall take measures to prevent theft or loss of equipment, electronic media, and documents related to the handling of user information, and measures to prevent User Information from being easily identified when transporting the equipment, electronic media, etc., including transportation within the business office.
• The Company shall implement access control to limit the scope of personnel in charge and personal information databases handled.
• The Company has introduced a mechanism to protect the information system that handles User Information from unauthorized access from outside or unauthorized software.

8 Disclosure of Personal Information

Upon request from the user to disclose its personal information under the Act, the Company shall, without delay, disclose to the user such information (or, in the event of non-existence of such personal information, notify the user to that effect) after confirming that the request is made by the user itself, to the extent required to do so under the Act and other applicable laws and regulations.
Please note that you must pay a commission (1,000 JPY per disclosure) for disclosure of personal information.

9 Correction and Suspension of Use of Personal Information

9.1 If the Company is required pursuant to the provisions of the Act by the user to (1) correct the content of personal information due to the reason that such information is false, or (2) suspend use of personal information due to the reason that such information is being handled beyond the scope of the purpose of the use previously made public, or has been collected in a fraudulent or otherwise illicit manner, then the Company shall, without delay after confirming that the request is made by the user itself, conduct an appropriate investigation and based upon the results thereof, correct the content or suspend the use of such personal information, and notify the party to that effect. In cases where the Company decides not to make such correction or suspension of the use, the Company shall notify the user to that effect.

9.2 In the event that the Company is required by the user to delete its personal information and has determined that it is necessary to accept such request, the Company shall, after confirming that the request is made by the user itself, delete such personal information and notify the party to that effect.

9.3 Should the Company not be obligated to correct, or suspend use of, information under the Act and other applicable laws and regulations, Sections 7.1 and 7.2 shall not apply.

10 Inquiries

Any suggestions, questions, complaints, or other inquiries on the handling of the User Information must be submitted to:

[Company Name] Mantra Inc.
[Name of Responsible Person for Handling User Information] Shonosuke Ishiwatari
[Contact Information] info@mantra.co.jp

11 Procedure to Amend this Privacy Policy

The Company may amend this Privacy Policy as necessary; provided, however, that in the event of an amendment to this Privacy Policy that legally requires the consent thereto of the users, this Privacy Policy after the amendment shall be applied only to the users that have given the consent in the manner specified by the Company. In the event of any amendment to this Privacy Policy, the Company shall inform the effective time and content of the amended Privacy Policy by posting on the website of the Company or other appropriate way, or notify the user of the same.

This Policy shall be executed in the Japanese language. Japanese shall be the governing language and any translation of this Policy into any other language is for convenience of reference only and shall not bind the parties hereto.