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Privacy Policy

Date of Enforcement: 22 Dec 2017
Last Updated: 20 Jun 2018

Cryptact Ltd. (the “Company”) hereby prescribes this Privacy Policy (“this Policy”) as follows with regard to the
handling of the user information including the personal information in the services (collectively, the “Service”)
provided on the Company’s website. Please note that this English Privacy Policy is provided for reference
purposes only and the Japanese original version shall supersede if there are any differences between the English
and Japanese versions.

Article 1 (User Information)

  1. The user information collected by the Company in the Service includes the following information:
    1. information input by the customer upon registering the Cryptact Account (email address, user name and the
      like);
    2. information input, data uploaded and information acquired via API and the like (history data of the
      customer’s cryptocurrency transactions and the like) by the customer upon using the Service;
    3. Cookies, IP address, or information pertaining to the use of Google Analytics™; and
    4. in addition to each of the preceding items, information provided by the customer upon using the Service.
  2. The term “personal information” in the user information shall mean the personal information defined in
    Article 2, Paragraph 1 of the Personal Information Protection Act in Japan.

Article 2 (Purpose of Collection and Use of User Information)

The Company shall collect and use the user information for the following purposes:

  1. to provide and develop products and the Services;
  2. to announce various campaigns of products and the Services;
  3. to perform marketing, survey and analysis for improving or enhancing products and services of the Company;
  4. to provide maintenance and support offered by the Company;
  5. to deal with acts in breach of the Company’s rules, policies and the like (collectively, the “Rules”) in
    relation to the Service of the Company;
  6. to notify amendments to the Rules in relation to the Service of the Company;
  7. to use information which is necessary to provide the Services to the user such as contents of inquiries,
    information regarding billing, and the service usage status, the user’s contact information and the like;
  8. to make communication in times of emergency; and
  9. any other purpose associated with the foregoing purposes of use.

Article 3 (Amendment to Purpose of Collection and Use of User Information)

The Company may amend to the purpose of use of the user information to the extent that is reasonably considered
that the purpose of use after the change is duly related to that before the change, and in such case the Company
would notify or publicly announce such amendment to the customer.

Article 4 (Restriction on Use of Personal Information)

Excluding the following cases, the Company may not handle the personal information beyond the scope required for
achieving the purpose of use without obtaining the user’s consent in advance; save for cases that are permitted
under the Personal Information Protection Act in Japan and other applicable laws:

  1. cases in which the handling of the personal information is based on laws and regulations;
  2. cases in which the handling of the personal information is necessary for the protection of the life, body, or
    property of an individual and in which it is difficult to obtain the consent of the person;
  3. cases in which the handling of the personal information is especially necessary for improving public health
    or promoting the sound growth of children and in which it is difficult to obtain the consent of the person; and
  4. cases in which the handling of the personal information is necessary for cooperating with a state organ, a
    local government, or an individual or a business operator entrusted by either of the former two in executing
    the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to
    impede the execution of the affairs concerned.

Article 5 (Proper Acquisition of User Information)

The Company would acquire the user information through proper means, and would not acquire the user information
through deceit or other wrongful means.

Article 6 (Safety Control of Personal Information)

The Company shall offer necessary and appropriate supervision to employees of the Company for the safety control
of the personal information against risks such as loss, destruction, falsification or divulgence of the personal
information. Moreover, if the Company subcontracts all or a part of the handling of the personal information to a
subcontractor, the Company shall offer necessary and appropriate supervision so that the safety control of the
personal information is ensured by the subcontractor.

Article 7 (Disclosure of Personal Information)

  1. In the event that the Company receives a request from the person to disclose his/her personal information,
    the Company would promptly disclose the personal information to the person after the Company confirms that such
    request was made by the customer himself/herself; save for cases where the Company is not obligated to disclose
    the personal information under the Personal Information Protection Act in Japan or other applicable laws;
    provided, however, that, upon corresponding to any of the following items as a result of disclosing the
    personal information, the Company may decide not to disclose all or a part of the personal information and,
    upon deciding not to disclose all or a part of the personal information, the Company would promptly notify the
    person to such effect. Incidentally, when the Company is to disclose the personal information, the Company
    would charge a fee of 1,000 yen (including tax) per case:
    1. cases in which disclosure is likely to harm the life, body, property, or other rights or interests of the
      person or a third party;
    2. cases in which disclosure is likely to seriously impede the proper execution of the business of the
      Company; and
    3. cases in which disclosure violates other laws and regulations.
  2. Notwithstanding the provisions of the preceding paragraph, as a general rule, the Company would not disclose
    information other than the personal information such as history information and characteristic information.

Article 8 (Correction of Personal Information)

In the event that the Company is requested by the customer to correct, add, or delete (the “Correction”) the
customer’s personal information pursuant to the provisions of the Personal Information Protection Act in Japan on
grounds that the personal information is contrary to facts, the Company would promptly conduct necessary
investigation after the Company confirms that the request was made by the customer himself/herself to the extent
required for achieving the purpose of use, and perform the Correction of the subject matter of the personal
information based on the investigation results, and notify the customer to such effect (if the Company decides
not to perform the Correction, the Company shall notify the customer to such effect); provided, however, that,
where the Company is not obligated to perform the Correction under the Personal Information Protection Act in
Japan or other applicable laws.

Article 9 (Suspension of Use. of Personal Information)

In the event that the Company is requested by the person to suspend the use or erase (the “Suspension of Use”)
his/her personal information pursuant to the provisions of the Personal Information Protection Act in Japan on
grounds that the personal information is being handled beyond the scope of purpose of use, the Company would
promptly conduct necessary investigation and perform the Suspension of Use of the personal information based on
the investigation results, and notify the person to such effect; provided, however, that, where the Company is
not obligated to perform the Suspension of Use under the Personal Information Protection Act in Japan or other
applicable laws.

Article 10 (Provision of Personal Information to Third Party)

The Company would not provide the personal information in the user information to any third party without
obtaining the customer’s prior consent excluding cases where disclosure is permitted under the Personal
Information Protection Act in Japan or other applicable laws; provided, however, that the following cases do not
apply to the foregoing provision of the personal information to a third party set forth in this Article10:

  1. Cases in which the Company entrusts the handling of the personal information in whole or in part within the
    scope necessary for the achievement of the purpose of use; or
  2. Cases in which the personal information is provided as a result of the succession of business in a merger or
    otherwise.

Article 11 (Use of Cookies and other Technologies)

The Service may use Cookies and similar technologies. These technologies are useful for the Company to
comprehend the usage status of the Service and improve the quality of the Service. A user who wishes to
invalidate Cookies may do so by changing the setting of the web browser; provided, however, that, when Cookies
are invalidated, the user may be unable to use certain functions of the Service.

Article 12 (Continuous Improvement)

The Company shall review the operational status concerning the handling of the user information appropriately
and endeavor to continuously improve the same, and may revise this Policy as necessary.

Article 13 (Inquiry Counter)

Please send inquiries concerning this Policy shall be made to the following inquiry counter.

Cryptact Ltd.

Email address: contact@cryptact.com