PRIVACY POLICY

Almoha LLC (hereinafter referred to as "our company," "we," or "us") is committed to safeguarding a range of data, including personal information of individuals (hereinafter "customers") who use our services, gathered during our business operations. Our officers and employees adhere to the privacy policy outlined herein (hereinafter "this policy") in their professional duties. This policy covers "personal information" as defined by applicable laws and regulations, encompassing any data that, alone or combined with other information, can identify a customer (hereinafter "user information"). This includes personal attributes and behaviors obtained through our company's business activities.

Management of User Information

Our company will clearly define the purpose of collecting user information as precisely as possible and employ suitable methods for its acquisition.
User information obtained will only be utilized or disclosed to third parties to the extent necessary to fulfill the stated purpose of collection.
Beyond the uses outlined in this policy, we will not share user information with any third party without the user's explicit consent or unless legally mandated.

Adherence to Legal Standards

This policy will comply with the laws and regulations of the countries and regions where we operate.
Our business practices will align with this policy within the legal framework of each specific country or region where we conduct business.

Queries and Consultations

Our company commits to responding adequately and impartially to customer inquiries and consultations concerning the disclosure, editing, addition, deletion, termination of usage, elimination, termination of third-party sharing, or other management of user information in our possession.
For inquiries and consultations, please refer to the "Contact Information" section.

Application Scope

This policy is applicable to all products and services developed or overseen by this company, across all countries and regions.

Data Collection

We gather user information as follows:

Customer-Provided Data: Information provided by customers upon account creation or during updates to account details on services managed by our company.
Company-Generated Data: Information generated through the use of services managed by our company, including service usage patterns.
Third-Party Data: Information from external providers, including business partners and third parties utilizing our company's APIs.

1. Customer-Provided Data

This category encompasses the following information:

Customer Profile: Data collected during account creation or modification on our platforms, potentially including name, email address, phone number, login credentials, payment details, date of birth, gender, profile picture, and usernames for third-party social networking services.
Demographic Information: We may gather demographic details through focused surveys or similar methods.
Location Data: Location information may be collected from your device, strictly with your explicit permission.
Customer Inquiries: Should you submit an inquiry that includes user information, it may be collected in line with this Policy.

2. Company-Generated Data

This category includes:

Usage Data: Information on your interaction with our services, encompassing access times, visited features or pages, identifiers like referrers and cookies, and system activities including notifications sent to you, as well as error and crash reports.
Device Data: Details about the devices you use to access our services, including the operating system, language preferences, IP address, and network information.

3. Data from Other Sources

This category encompasses:

Data from External Services: If you grant permission to connect your account with a service managed by us, we collect the information you agreed to share at the time of consent.
Public Agency Data: Information available from public entities.
Marketing Service Provider Data: Data received from marketing service providers.

Purpose of Use of User Information

The data we collect, including user information, is utilized for the following purposes:

To deliver, sustain, and enhance the services we manage, aiming for increased reliability and convenience.
To provide customers with analysis results and improvement suggestions regarding the state of their organization, generated through analysis using artificial intelligence (AI).
To offer various customer support services.
To distribute, display, and evaluate the effectiveness of advertisements.
To inform customers about updates to this policy or other specific terms and conditions.
To directly engage in marketing activities.
To share information about services, products, events, seminars, and community news from our company and our partner firms.
To solicit participation in interviews, surveys, promotional campaigns, monitoring activities, etc.
In relation to the services operated by our company, we create or use statistical data processed in a manner that cannot identify individuals, or create, use, or provide research and analysis materials as well as marketing materials within a range where individuals cannot be identified by third parties.
To adhere to legal requirements.
For purposes related to the aforementioned uses.

User information held by us will not be shared with any third party for reasons outside those listed in this policy, without explicit customer consent.

Cookies and Additional Usage Data

In alignment with the objectives outlined in this policy, we employ cookies, IP addresses, details about your browser and operating system, along with other technologies capable of identifying you within our services, emails, and online advertisements.

A cookie is a small text file saved on your browser or device by websites, emails, advertisements, etc. It is generated and dispatched by our company to recognize you personally. The use of cookies and analogous technologies is for purposes such as:

Authenticating customers.
Analyzing access frequencies and patterns.
Delivering and assessing the impact of advertising initiatives.

Opting Out of Cookies

Customers have the option to accept or decline cookies from our company by modifying their browser settings. It's important to acknowledge that cookies are integral to the functionality of our services. Please be aware that rejecting or removing cookies might limit your ability to utilize certain features of the service.

Disclosure of User Information

We may disclose the user information we collect to certain third parties (including those located in countries or regions different from your own) under specific conditions. Besides legal requirements, sharing may occur in scenarios such as:

Consent-Based Sharing: We might share user information with third parties after notifying you about the intended sharing and obtaining your consent, even if not previously mentioned in this policy.
Business Succession: In the case of a business transition due to merger, reorganization, or similar event, user information may be transferred to a succeeding entity.
Sharing with Business Partners: We might share data with business partners vital for delivering our services.

These "business partners" may include:

Payment processing companies.
Cloud storage service providers.
Providers of AI analysis and other data processing services.
Marketing platform providers.
Legal, accounting, and other professional service providers.

AI-Based Analysis

In the AI Report feature of our services, we send survey response data (answers to questions, aggregated scores by attribute, open-ended comments, and the survey name) to an external AI service provider engaged as a data processor for analysis.

The data sent does not include identifiers such as respondents' names or email addresses. Note, however, that open-ended comments are sent as written by the respondent.

The data will not be used by the provider to train its own AI models. The data may be retained on the provider's systems for a limited period (up to approximately 30 days) for purposes such as abuse monitoring, after which it is deleted.

Customer Rights

Our policy extends to all customers, yet we recognize that various international regulations offer specific protections for personal information.

We commit to adhering to such country- or region-specific regulations. Additionally, regardless of these regulations' applicability, you possess the following rights concerning your user information:

Right to Export: You have the right to receive all user information we have about you and to transfer it to third parties, including moving data to another organization or service within our operations.
Right to Know: This right allows you to access the user information we've collected about you, including details on how it's shared, stored, and processed. Should the requested user information not exist, we will inform you.
Right to Rectification: You can request the correction of any inaccuracies in the user information we hold about you.
Right to Erasure: You can ask for your personal data to be erased from our records and cease its use by our company. Account deletion may occur if such removal impedes the functionality of services we offer.
Right to Restrict Use: You have the right to limit how we use your information. This may involve restricting access to your account if it affects your ability to utilize our service features.
Right to File a Complaint: You are entitled to lodge a complaint with the relevant regulatory body about our management of your information.

Location of Data Management

Our services are based and operated out of Japan. For users in any location outside Japan, it's important to understand that data you provide will be transferred to and stored within our data centers in Japan. However, some of the external services we use to provide our services store or process data outside Japan. For details, please see "Provision to Third Parties Located in Foreign Countries." By initiating the use of our services, you are agreeing to this transfer of data.

Provision to Third Parties Located in Foreign Countries

Some of the external services we use to provide our services store or process data outside Japan (primarily in the United States and other countries). When using these providers, we take the measures required under the Act on the Protection of Personal Information of Japan. If you would like further details about such provision to foreign countries, including information about the personal information protection systems of the relevant countries, please contact us via the channel described in the "Contact Information" section.

Safety Management Measures

We will take necessary measures to prevent leakage, loss, or damage of user information and to ensure appropriate management of the collected information. Additionally, when outsourcing to external parties, we may also entrust the handling of user information. In such cases, we will take necessary measures to ensure that the entrusted party also takes appropriate measures to prevent leakage, loss, or damage of the collected information and to ensure its proper management.

Contact Information

For inquiries or further information, please reach out to Almoha LLC at:

Email: contact@almoha.com

Alternatively, you can use the inquiry form available on our website for any questions or concerns.

Information of Business Handling Personal Information

1-45-1 Nishikubo, Musashino-shi, Tokyo

Almoha LLC (Representative employee: Sotaro Karasawa)

Policy Updates

We reserve the right to amend this policy periodically. Should there be significant modifications to its content, we will provide advance notice through email or another communication method.

Continued use of the services managed by our company following such updates constitutes your acceptance of the revised Privacy Policy, in accordance with the legal framework of the applicable country or region.

Adopted on January 31, 2024

Amended on August 12, 2026