{# SPDX-License-Identifier: AGPL-3.0-or-later #}
{# SPDX-FileCopyrightText: 2023 JWP Consulting GK #}
<h1>GDPR Privacy Policy</h1>
<p>
    JWP Consulting GK (hereinafter referred to as "the Company") is intent on
    protecting the privacy of any user of the Company's website(s) and the
    Company’s service(s) (hereinafter collectively referred to as “Website,
    Etc.”) (such a user is hereinafter referred to as “User”) with respect to
    handling the Personal Information, etc. in the Website, Etc. The Company
    would like the User to read this privacy policy (hereinafter referred to as
    "Privacy Policy") carefully and thoroughly before using the Website, Etc.
</p>
<h2>Article 1 (Definitions)</h2>
<p>The terms used in the Privacy Policy are defined as follows:</p>
<ol type="1">
    <li>
        <p>
            "Applicable Privacy Laws and Regulations” means any applicable laws
            and regulations including the GDPR, the Data Protection Act of the
            U.K., other enforcement laws in each country in relation to the
            GDPR.
        </p>
    </li>
    <li>
        <p>“GDPR” means the General Data Protection Regulations.</p>
    </li>
    <li>
        <p>
            “EU” means the European Union including any member country of the
            European Union and Ireland, Lichtenstein and Norway in accordance
            with the European Economic Area Agreement.
        </p>
    </li>
    <li>
        <p>
            “Controller” means any natural person, legal person, governmental
            institution and other person or entity that determines the purposes
            and means of the Processing the Personal Data alone or jointly with
            any other person or entity. In the Privacy Policy, it means the
            Company.
        </p>
    </li>
    <li>
        <p>
            “Personal Data” means any information relating to an identified or
            identifiable natural person (Data Subject). An identifiable natural
            person is the one who can be identified, directly or indirectly, in
            particular by reference to an identifier such as a name, an
            identification number, location data, an online identifier or to
            one or more factors specific to the physical, physiological,
            genetic, mental, economic, cultural or social identity of that
            natural person.
        </p>
    </li>
    <li>
        <p>
            “Data Subject” means and identified or identifiable natural person
            whose Personal Data is processed by the Controller.
        </p>
    </li>
    <li>
        <p>
            “Process Limitation” means any marking the spot on the Personal
            Data recorded and stored in order to limit any Processing thereof
            in the future.
        </p>
    </li>
    <li>
        <p>
            “Processing” means any operation or set of operations which is
            performed on the Personal Data or on sets of the Personal Data,
            whether or not by automated means, such as collection, recording,
            organization, structuring, storage, adaptation or alteration,
            retrieval, consultation, use, disclosure by transmission,
            dissemination or otherwise making available, alignment or
            combination, restriction, erasure or destruction.
        </p>
    </li>
    <li>
        <p>
            “Profiling” means any form of automated Processing of the Personal
            Data consisting of the use of the Personal Data to evaluate certain
            personal aspects relating to a natural person, in particular to
            analyze or predict aspects concerning that natural person's
            performance at work, economic situation, health, personal
            preferences, interests, reliability, behavior, location or
            movements.
        </p>
    </li>
</ol>
<h2>Article 2 (Scope of the Privacy Policy)</h2>
<ol type="1">
    <li>
        <p>
            The Privacy Policy applies to the User’s individual use and
            Processing of the Personal Data through the Website, Etc. to which
            the Applicable Privacy Laws and Regulations apply. The Controller
            of such Processing is the Company.
        </p>
    </li>
    <li>
        <p>
            The Website, Etc. may contain any third party information (e.g.,
            hyperlinks, banners, etc.). The Company does not control such third
            party information and is not responsible for compliance by any
            third party with the Applicable Privacy Laws and Regulations. The
            Company would like the User to carefully read any privacy policies
            of any third party websites the User visits.
        </p>
    </li>
    <li>
        <p>
            In case of any discrepancy between the Privacy Policy and any other
            rules and regulations established by the Company, the Privacy
            Policy prevail.
        </p>
    </li>
</ol>
<h2>Article 3 (Consent)</h2>
<ol type="1">
    <li>
        <p>
            By indicating the User’s consent to the Privacy Policy, the User
            shall be deemed as having consented to the Privacy Policy.
        </p>
    </li>
    <li>
        <p>
            In case an User under 16 years old uses the Websites, Etc. the
            person(s) with parent authority of the User shall consent to the
            Privacy Policy.
        </p>
    </li>
</ol>
<h2>Article 4 (Personal Data to be Collected)</h2>
<p>
    The Company may obtain the following Personal Data from the User, and, If
    the User does not provide the Company with these Personal Data, the User
    may not be able to use all or part of the Website, Etc.:
</p>
<ol type="1">
    <li>
        <p>
            information obtained directly from the User’s registration on the
            Website, Etc., changes to the registration information, or
            inquiries or communications from the User:
        </p>
        <ol type="i">
            <li>
                <p>Name;</p>
            </li>
            <li>
                <p>
                    Contact information (including, but not limited to, email
                    address and telephone number);
                </p>
            </li>
            <li>
                <p>Employer, position, affiliation, or other organization;</p>
            </li>
            <li>
                <p>Date of birth;</p>
            </li>
            <li>
                <p>User name and password;</p>
            </li>
            <li>
                <p>
                    Information regarding the subscription plan (including
                    contract information, payment information, validity period,
                    etc.);
                </p>
            </li>
            <li>
                <p>
                    Information regarding contract status, such as before,
                    during or at the end of the contract, etc.; and,
                </p>
            </li>
            <li>
                <p>
                    Feedback information from the User such as evaluations,
                    complaints or improvement methods, etc.
                </p>
            </li>
        </ol>
    </li>
    <li>
        <p>
            Information automatically obtained through the use of the Website,
            Etc. by the User:
        </p>
        <ol type="i">
            <li>
                <p>Location information;</p>
            </li>
            <li>
                <p>
                    Information regarding the usage of the Website, Etc.
                    (including, but not limited to, information on operational
                    settings, number of file uploads, etc.);
                </p>
            </li>
            <li>
                <p>Date and time of access of the Website, Etc.;</p>
            </li>
            <li>
                <p>
                    Type of device application and browser used when using the
                    Website, Etc. and the pages viewed (including any website
                    of any third party services that the User used prior to
                    using the Website, Etc.); and,
                </p>
            </li>
            <li>
                <p>
                    Information on the device used to access the Website, Etc.,
                    IP address, Cookies information,
                    language selection.
                </p>
            </li>
        </ol>
    </li>
    <li>
        <p>Information obtained through services operated by any third party:</p>
        <p>
            Personal Data that the User have authorized the Company to obtain
            through services operated by any third party.
        </p>
    </li>
</ol>
<h2>Article 5 (Purpose of Data Processing and Legal Grounds)</h2>
<ol type="1">
    <li>
        <p>
            The Company may collect and process any Personal Data only for the
            purposes described below:
        </p>
        <ol type="i">
            <li>
                <p>
                    To provide, maintain, protect, and improve the Website,
                    Etc. such as by accepting registrations, verifying the
                    identity of any User, calculating usage fees, etc.;
                </p>
            </li>
            <li>
                <p>
                    To notify the public of any information regarding the
                    contents of the Website, Etc. any updates thereof, any
                    events and campaigns thereof, and any changes, etc. to any
                    terms and conditions thereon;
                </p>
            </li>
            <li>
                <p>
                    To respond to any notice or inquiry regarding the Website,
                    Etc.;
                </p>
            </li>
            <li>
                <p>
                    To respond to any violation of the Company's terms and
                    conditions or other rules and regulations concerning the
                    Website, Etc.;
                </p>
            </li>
            <li>
                <p>
                    To compile any statistical data on the use of the Website,
                    Etc.;
                </p>
            </li>
            <li>
                <p>
                    To plan, draft or implement any future activities related
                    to the Website, Etc.;
                </p>
            </li>
            <li>
                <p>
                    To authenticate the identity of any User when or after such
                    a User logs in in using the Website, Etc.;
                </p>
            </li>
        </ol>
    </li>
    <li>
        <p>
            The Company may process any Personal Data on the following legal
            grounds:
        </p>
        <ol type="i">
            <li>
                <p>
                    The Data Subject has given its consent to the Processing of
                    its Personal Data for one or more specific purposes;
                </p>
            </li>
            <li>
                <p>
                    The Processing is necessary for the performance of a
                    contract to which the Data Subject is a party or for the
                    performance of a procedure at the request of the Data
                    Subject prior to the execution of the contract;
                </p>
            </li>
            <li>
                <p>
                    The Processing is necessary to comply with a legal
                    obligation to which the Controller is subject;
                </p>
            </li>
            <li>
                <p>
                    The Processing is necessary to protect the vital interests
                    of the Data Subject or any other natural person;
                </p>
            </li>
            <li>
                <p>
                    The Processing is necessary for the performance of a task
                    carried out in the public interest or in the exercise of
                    the official authority vested in the Controller; and,
                </p>
            </li>
            <li>
                <p>
                    The Processing is necessary for the legitimate interests
                    pursued by the Controller or any third party; provided,
                    however, that any Processing shall be excluded if any
                    fundamental rights and freedoms to require the protection
                    of any Personal Data owned by the Data Subject, in
                    particular in case of such Data Subject being a child,
                    prevail over the above legitimate interests.
                </p>
            </li>
        </ol>
    </li>
</ol>
<h2>Article 6 (Cross-Border Data Transfer)</h2>
<ol type="1">
    <li>
        <p>
            The Company may transfer the Personal Data of the User to any
            business establishment in Japan or to any third party in any
            country outside the EU (including, but not limited to, the
            following business operators), and the Company will endeavor to
            ensure that the third party to which the Personal Data is
            transferred takes appropriate and adequate protective measures in
            accordance with the GDPR:
        </p>
        <ol type="i">
            <li>
                <p>Name: Hetzner Online GmbH</p>
                <p>Country: Germany</p>
                <p>Address: Industriestr. 25, 91710 Gunzenhausen</p>
            </li>
            <li>
                <p>Name: Lettermint B.V.</p>
                <p>Country: The Netherlands</p>
                <p>Address: Willemsvaart 16B, Unit 1.08, 8019 AB Zwolle</p>
            </li>
        </ol>
    </li>
    <li>
        <p>
            The User hereby acknowledges and agrees that any country outside
            the EU may not have adequate laws and regulations protecting the
            Personal Data, and that the same level of protection measures set
            forth in the GDPR cannot be always guaranteed.
        </p>
    </li>
</ol>
<h2>Article 7 (Storage Period)</h2>
<p>
    The Company will not store the Personal Data beyond the extent necessary
    for the purposes for which the Personal Data was collected, except as
    required by laws and regulations. The specific storage period will be
    determined by taking into consideration the purpose for which the Personal
    Data was collected and processed, the nature of the Personal Data, and the
    legal or business necessity for storing the Personal Data.
</p>
<h2>Article 8 (Cookies)</h2>
<ol type="1">
    <li>
        <p>
            The Company uses any Cookie to ensure the proper functioning of the
            Website, Etc.
        </p>
    </li>
    <li>
        <p>
            Cookies are information stored on the User’s computer by any
            browser, and the Company uses any different types of Cookies for
            any different purposes as follows:
        </p>
        <ol type="i">
            <li>
                <p>
                    Functional Cookies: These Cookies are necessary for the
                    correct functioning of the Website, Etc., and include any
                    Cookies necessary to create an account; and,
                </p>
            </li>
        </ol>
    </li>
    <li>
        <p>
            The Company will use any Cookies only for the purposes of improving
            the quality and effectiveness of the Website, Etc.
        </p>
    </li>
    <li>
        <p>
            Most browsers are set by default to enable Cookies. It is possible
            to disable Cookies or indicate when Cookies are being sent by
            setting the browser of the User; provided, however, that if Cookies
            are disabled, some features or services on the Website, Etc. or any
            website of any third party may not function properly.
        </p>
    </li>
</ol>
<h2>Article 9 (Rights of the User)</h2>
<ol type="1">
    <li>
        <p>
            In case the Processing of the Personal Data is based on the consent
            of the User, the User has the right to withdraw such consent
            relating to its Personal Data at any time; provided, however, that,
            in case the User withdraws its consent, the User may not be able to
            use the Website, Etc. that requires the use of information the
            Company has obtained based on the User’s consent.
        </p>
    </li>
    <li>
        <p>
            The User has the right to request access to the Personal Data in
            accordance with the Applicable Privacy Laws and Regulations, which
            can cause the User to receive a copy of the Personal Data held by
            the Company.
        </p>
    </li>
    <li>
        <p>
            The User has the right to request correction of its Personal Data
            held by the Company in accordance with the Applicable Privacy Laws
            and Regulations, which can cause the User to correct any incomplete
            or inaccurate data on the User held by the Company.
        </p>
    </li>
    <li>
        <p>
            The User has the right to request the deletion of its Personal Data
            in accordance with the Applicable Privacy Laws, which can cause the
            User to delete its Personal Data the Company continues to process
            without due cause.
        </p>
    </li>
    <li>
        <p>
            The User has the right to object to the Processing of its Personal
            Data by the Company for legitimate interests in accordance with the
            Applicable Privacy Laws and Regulations.
        </p>
    </li>
    <li>
        <p>
            The User has the right to request a restriction of the Processing
            of the Personal Data in accordance with the Applicable Privacy Laws
            and Regulations.
        </p>
    </li>
    <li>
        <p>
            The User has the right to request the transfer of its Personal Data
            to the User itself or to any third party in accordance with the
            Applicable Privacy Laws and Regulations. The Company will provide
            the Personal Data to the User or to any third party designated by
            the User in a structured, commonly used, machine-readable format.
            In addition, this right applies only to the information whose
            Processing is automated and for which the Company has first
            obtained the User’s consent or used to fulfill a contract with the
            User.
        </p>
    </li>
    <li>
        <p>
            The User has the right under the Applicable Privacy Laws and
            Regulations not to be subject to decisions based solely on
            automated Processing, such as Profiling, etc. that has legal effect
            with respect to the User or that has similar material effects on
            the User.
        </p>
    </li>
    <li>
        <p>
            The User has the right to lodge a complaint with the EU Data
            Protection Authority at any time. However, the Company would like
            to have the opportunity to address the User’s complaint before the
            User contacts the EU Data Protection Authority, and therefore the
            Company would like the User to contact the Company in advance.
        </p>
    </li>
</ol>
<h2>Article 10 (Controller and Contact Person for Inquiries)</h2>
<p>
    In case the User has any questions or complaints, or wishes to exercise any
    of the rights prescribed in the preceding Article 9, the Company would like
    the User to contact the Controller listed below:
</p>
<p>Name of Controller: JWP Consulting GK</p>
<p>Representative: Justus Wilhelm Perlwitz, Senior Partner</p>
<p>
    Address: Shimokitazawashinkosha Bldg. Room 305 Kitazawa 2-37-3 Setagaya
    City, Tokyo-to
</p>
<p>E-mail: hello@jwpconsulting.net</p>
<h2>Article 11 (Revision)</h2>
<p>
    The Company may revise the Privacy Policy as it deems necessary, and the
    User hereby consents to such revisions in advance. Any changes to the
    Privacy Policy shall become effective upon posting on the Website, Etc.
</p>
<p>Supplementary Provisions</p>
<p>Established as of December 20, 2023</p>
<p>Updated as of April 12, 2026</p>
<p>JWP Consulting GK</p>