The name and address of the business, the names of the company representative, and the Personal information protection manager are as follows.

1. Business name: 2. Business address and Name of representative: 3. Personal information protection manager: 4. Contact:

We may acquire customers’ personal information (including recordings of telephone calls) for the purposes set forth in Article 4. Please note that if the necessary personal information is not provided, certain services may be unavailable, or we may not be able to respond to certain inquiries.

Our websites are not intended for use by children under the age of 13, or those under the age of majority in their local jurisdiction, but we acknowledge that this is a possibility. We shall not knowingly collect personal information for children under the age of 13, or those under the age of majority in their local jurisdiction. Users are required to create an account to use our services. If we determine that the user is under 13 years of age when registering for an account to use our services, we will implement a system to seek the consent of the parent or guardian of the user for the purposes of creating an account. We request that guardians of children who would like to, or are intending to, use our website to take note, and in the event that consent is granted, take action to grant such consent. In the unlikely event that such matters cannot be resolved, please contact us as per Article 10 “Contact for grievances and disclosures.”

1. We process personal information provided by customers for the following purposes. In the event that the personal information is to be used for purposes not listed below, we shall inform customers in advance of such purpose to obtain permission.

2. We may receive information on customers, including identifiers and action history, from third parties who do not possess personally identifiable information (such as customer names). Such information may be taken as personal information by means of linking it with the personal information of customers that we manage. We may use such information in accordance with the purposes set forth in the preceding paragraphs unless a separate purpose is stated. In such cases, personal information will be handled appropriately according to the law.

3. Provided personal information shall be held and managed by Celsys for the period necessary to achieve the purpose stated in Article 1, based on our Personal Information Management Ledger, or for the period we are obliged by law to retain such information. We do not retain any personal information beyond the purposes for which it was obtained or as required by law.

Customers acknowledge that the personal information may be used by outsourced third parties ("Outsourced Contractors," including parties outside of Japan) for its business operation to the extent defined by us in the previous article. Customers accept that we may provide the Outsourcing Contractor with a portion of the personal information (including but not limited to: name, address, phone number, and email addresses) for the relevant purposes only to the extent deemed necessary. In this case, we shall enter a contract with the Outsourced Contractor, forbidding the Outsourced Contractor from using the personal information for purposes other than those specified. We shall supervise and ensure that the Outsourced Contractor manages the personal information appropriately.

The details of the Outsourced Contractors are as follows.

Celsys may provide a third party with personal information in its entirety or in part without prior approval from customers in the following cases; Celsys may also provide your personal information to third parties, including our group companies and partner companies, in accordance with applicable laws and regulations.

1. When required by law.

2. When required to protect human life, person, or personal property in cases where it would be difficult or time-consuming to obtain prior approval from related persons.

3. When required to improve public health or promote healthy development of children in cases where it would be difficult to obtain prior approval from related persons.

4. When required by the national or local government or their commissioned parties to cooperate with the paperwork required by law, in cases where obtaining prior approval from concerned persons may impede such operation.

Details of the Third Parties are as follows.

1. Cookies are used by some of our services for purposes such as obtaining information to enable more convenient use and to continually improve such services. Cookies are information sent from a server related to the operation of the service to the customer's browser and are saved on the customer's computer. The saved information does not contain any personally identifiable information such as names, telephone numbers, or addresses. Furthermore, there are no directly harmful effects on the computer. You can adjust the settings on your browser to prevent the receipt of cookies. However, doing so may prevent some functions from operating.

2. Services we provide use behavioral targeting advertising (advertising method that delivers adverts that are matched with customer interests based on information such as site viewing information) that utilizes programs provided by advertisement distributors or organizations (“advertisement distributors”). Cookies are used at this time to collect information on the customer's site visit history (URL of the site visited by the customer, IP address, user agent, etc.) and to transmit such site visit history information to the advertising distributor. Advertisement distributors then use the cookies to collect and analyze customer’s browsing history information and broadcast advertisements according to the customer’s interests based on past access information. When you access our website, we will provide instructions on how you can place restrictions on the use of cookies, including implementing an opt-in banner as appropriate or by other means as required by your local laws and regulations.
・ Google
・ Network Advertising Initiative

3. The services we provide may contain the following information-gathering modules provided by third parties (“module providers”) for the purpose of providing features in the services, displaying advertisements, and understanding usage statistics. At that time, we will send the following information to be collected to the module provider, analyze the customer's site visit history information generated by the module provider, and use it for the following purposes.
・Google Analytics (to understand how our products and websites are used)
　Information we collect: Customer’s app launch information and site visit history information (activation OS, OS language, some information about app grade/version/serial, tablet driver information, URL of the site visited by the customer, IP address, user agent, etc.)
・Firebase (to collect crash reports and optimize promotions)
　Information we collect: Customer’s app launch information (activation OS; OS language; region; device information; some information about first launch, launching, purchases, and updates; number of sessions; length of session; crash reports)
・Apps Flyer (to analyze efficacy of placed advertising)
　Information we collect: Customer’s app launch information (ad ID, activation OS, OS language, region, device information, app version, AppsFlyer SDK version)
・Rollbar (to collect information about the incidence of errors and understand the content of errors)
　Information we collect: Customer site visit history information (user identification ID (CLIP user ID) where an error occurred, IP address, time, error details)

4. Please visit the relevant websites or follow the instructions below to stop usage information from being sent to advertising distribution companies or companies providing information-gathering modules.
・Clip Studio Paint (Windows/macOS): Go to [Privacy Settings] and turn off [Support bug fixes] and [Help with quality improvement].
・Clip Studio Paint (iPad/iPhone/Galaxy/Android/Chromebook): Go to [Privacy Settings] and turn off [Support bug fixes] and [Help with quality improvement].
・CLIP STUDIO MODELER (Windows/macOS): Go to Help and disable “Automatically send anonymous usage logs.”

5. These settings need to be configured again if you change your computer or browser or delete cookies.

We collect and use personal information based on the following bases.
・Consent
　Note: If personal information processing is based on customer consent, the customer retains the right to withdraw such consent.
・Performance of contracts
・Fulfillment of legal obligations
・Protection of the public interest and exercise of public authority
・Protection of the vital interests of the customer or another third party
・Protection of legitimate business interests within the scope of business activities performed by Celsys (performance of duties, improvement of products, services, etc.)

We may transfer the personal information of our customers to companies (including subcontractors of such companies) located in the following countries and regions. There is a possibility that your information may be transferred to a country or region that does not have legislation on personal information protection comparable to those in your country or region of residence. In such cases, we will take the appropriate measures to protect your personal information in accordance with the requirements of applicable laws.
Countries/regions: United States of America
Title: Google (Measures taken by Google to protect personal information)

We may transfer your personal information from the EEA or UK to countries and regions outside the EEA or UK. In such cases, we will, in accordance with applicable laws and regulations, rely on the country of transfer’s Adequacy Certification if such certification has been granted or, if transferring to a country without such certification, enter into Standard Contractual Clauses (SCC) with the country of transfer.

When we transfer your personal information overseas, we will follow the applicable laws and regulations in accordance with the following.

• Type of Personal Information: Transferred Website identifier, mobile device identifier
• Transfer date: (All devices) At any time while the app is launched
  (PC) When the “Launch” button is tapped in Clip Studio
  (PC) When the user taps the "Obtain serial number" button after the Clip Studio Paint license period has expired and the product page is shown in Clip Studio
• Transfer method: Based on API provided by the transfer destination
• Purpose of use at transfer destination: Providing, maintaining, and improving services, developing new services, measuring advertising effectiveness, preventing fraud, and customizing content and advertising displayed on the sites and apps of the transfer destination and its partners.
• Storage & usage period at transfer destination: Max. 26 months
• How to opt out of international transfers of personal information: Users may decline permission using the opt-out feature in Clip Studio Paint
• Effect of opting out of international transfers of personal information: If you decline permissions, you may not be able to use the related services.

You may check on your personal information by the method we have set out and correct, update, or delete the information yourself. Upon request, we will comply with customer requests for: the notification and disclosure (including the divulging of records provided to third parties) of usage purposes for any personal information we possess that is eligible for disclosure; correction, addition, deletion, suspension of use, deletion of personal information; objection to the handling of personal information; data portability; and the exercise of other rights related to personal information granted to customers (“Disclosure”). The contact for grievances regarding handling personal information subject to disclosure and responding to Disclosure requests is as follows.

Contact for grievances and disclosure requests
Pacific Marks Shinjuku 2F, 4-15-7 Nishi-Shinjuku, Shinjuku, Tokyo, Japan 160-0023

Grievance and Disclosure Request Office, Celsys, Inc.
Email: support@celsys.com

(1) Procedure
If you wish to request Disclosure of your personal information, please submit the following documents to Grievance and Disclosure Request Office either by (1) post or fax, (2) email, or another means of online communication.

(2) Necessary documents for submission
If you would like to terminate usage, delete, correct, or request disclosure for your own personal information, please submit the information, as well as the forms of identification set forth below. If the request is made by a representative, please also submit information to prove your identity as the representative, as detailed below. Once your identity has been verified, you will be contacted by our Personal Information helpdesk within a few business days. Documents used to verify your identity will be destroyed in accordance with internal regulations immediately after we respond to your request.

Information to be submitted:
・Your name, address, date of birth, telephone number, email address
・The category of your request (disclosure, correction, addition, deletion, or suspension of use of your personal information by Celsys or a Third Party to whom you have consented to provide personal information through this Privacy Policy)
・Details of your request
・(If in possession) Your Celsys user ID or email address and password associated with a Clip Studio ACCOUNT

Payment of processing fees
A. For Disclosure requests, the following processing fees will be charged.
・Notification of usage purpose: JPY 1,000 (inc. tax) per request
・Disclosure request: JPY 1,000 (inc. tax) per request

B. Upon receipt of a Personal Information Disclosure request, we will notify you of the bank account to which you should pay the processing fee. Responses to the requesting party, or their representative, will be rendered only after the details of the Disclosure request(s) and receipt of the processing fee have been confirmed.

Please note that the costs involved with mailing the Personal Information Disclosure Request Form and executing the bank transfer to pay the processing fee will be borne by the requesting party.

You may check on your personal information by the method we have set out and correct, update, or delete the information yourself. Notwithstanding this Article, we will also, upon your request, and in accordance with applicable law, provide you with access to, allow you to correct or delete, restrict or object to the processing of, or exercise your rate to data portability of your personal information in our possession (to the extent permissible by applicable law we may charge a reasonable fee to respond to such requests). You also have the right to object to our processing of your personal information with a regulatory authority. The contact information for exercising the aforementioned rights is as described in this Article.

1. This site employs SSL (Secure Socket Layer) encryption. SSL is a communication protocol that encrypts data sent over IP networks such as the Internet.
SSL encrypts transmissions between two devices that send and receive data, preventing the falsification or modification of data by other devices on the same network, such as a communication relay.

2. We will handle your personal information appropriately, in accordance with the Act on the Protection of Personal Information and this Privacy Policy. To handle personal information in an appropriate manner, we shall duly undertake the following security measures:
1) Appoint an officer responsible for the handling of personal information;
2) Clearly identify employees who handle personal information and the scope of the personal information they handle, and establish a reporting system to the responsible officer(s) in the event of a violation, or indications thereto, of the Act on the Protection of Personal Information or internal rules regarding the handling of personal information have occurred;
3) Regularly educate employees on the proper handling of personal information;
4) and manage the access to personal information of employees who handle such personal information, restrict access to devices and rooms and implement measures to prevent unauthorized persons from accessing personal information.

3. We regularly review our security guidelines to ensure the proper implementation of the measures set forth in the previous section.

4. In the event that we subcontract the handling of personal information to a third party, we will enter into a contract with the Outsourcing Contractor and duly manage their operations.

5. In the event of an indecent (leakage, loss, damage, or infringement) related to personal information (including the threat of such an incident), we will immediately conduct an internal investigation to establish the facts and cause of the incident, take measures to prevent its reoccurrence and report the incident to overseeing authorities and customers in accordance with relevant laws and regulations.

With respect to the handling of personal information of customers residing in the State of California, United States of America, the following special provisions (“Special Provisions”) shall apply in addition to the Privacy Statement (the “Statement”). Should any conflict between the Statement and the following Special Provisions arise, the Special Provisions shall prevail.

The types of personal information and the purposes of use for which we may use the personal information that we may have collected during the twelve (12) months prior to the last revision of the Statement and these Special Provisions are as described in Article 5 of the Statement. The source of such personal information is the person to whom the personal information pertains.

1. We do not sell the personal information of any of our customers, including that of minors, and have not sold any personal information in the twelve (12) months prior to the last revision of the Statement and these Special Provisions. Sale refers to the sale, lease, publication, disclosure, dissemination, making available, transferring, or communication orally, in writing, electronically, or by any other means of personal information of a consumer from us to another business or Third Party, for money or other forms of compensation.

2. The types of information that may have been disclosed for business purposes during the twelve (12) month period prior to the last revision of the Statement and these Special Provisions are as stated in Article 4 of the Statement; the types of Third Parties to whom personal information may have been disclosed to is as stated in Articles 6 and 7 of the Statement.

1. You may check on your personal information by the method we have set out and correct, update, or delete the information yourself. Notwithstanding Article 10 of the Statement, upon your request and in accordance with applicable law, we will provide you with access to and delete the personal information in our possession as follows.

2. For access or deletion requests, please contact:

3. In order to protect the privacy of our customers and maintain security, we will verify your identity before providing you with access to your own personal information or responding to a deletion request.

4. Should you choose to exercise any of the rights set forth in this Article, you retain the right to be treated without discrimination by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.