The Company respects the privacy of its users and is committed to protecting their personal information.

This Privacy Policy (hereinafter referred to as the “Policy”) sets forth how the Company handles personal information and other information in connection with the video calling service and related functions provided by the Company (hereinafter referred to as the “Service”).

For purposes of this Policy, “personal information” means personal information as defined under the Act on the Protection of Personal Information of Japan and other applicable laws, including information that identifies a specific individual or can be readily combined with other information to identify a specific individual.

The Company may collect the following information by appropriate and fair means to the extent necessary to provide the Service:

(1) Information provided by the User

Name, email address, telephone number, account information, and other information provided by the User to the Company.

(2) Age and identity verification information

Date of birth, age-verification results, identity-verification results, information used for verification, and other information necessary for legal compliance or operation of the Service.

(3) Access and location-determination information

IP address, access date and time, device information, browser information, approximate location information, state or other geographic determination information, and information relating to the possible use of VPNs or other anonymization technologies.

(4) Information relating to use of the Service

Usage history, browsing history, point purchase and usage history, call history, message history, communication logs, account activity, and other information relating to use of the Service.

(5) Information relating to use of the Service

The Company may collect or retain usage history, access logs, account activity, records relating to transmissions and other related information as necessary for legal compliance, safety, investigation of violations, response to reports or complaints, or other necessary purposes.

(6) Payment-related information

Payment status, transaction information, information provided by payment providers, and other information relating to payments.

(7) Information required for legal compliance

Where required for compliance with 18 U.S.C. §§ 2257, 2257A, or other applicable laws, the Company may collect or retain identification documents, age-verification records, related Content identifiers, and other required records.

The Company may use collected information for the following purposes:

1. To provide and operate the Service.
2. To respond to inquiries from Users.
3. To improve the Service and develop new services.
4. To investigate and respond to violations of the Terms of Use, fraud, unlawful activity, or other improper use of the Service.
5. To conduct age verification, identity verification, and eligibility checks.
6. To determine the country, state, or other region from which a User accesses the Service and to apply access controls required by applicable law.
7. To identify the possible use of VPNs or other anonymization technologies and take measures reasonably necessary for safety and legal compliance.
8. To investigate and respond to disputes, violations, reports, or complaints involving calls, messages, or other communications.
9. To address reports, removal requests, or other matters involving CSAM, NCII, exploitation, trafficking, or other unlawful or prohibited Content.
10. To comply with recordkeeping or other requirements under 18 U.S.C. §§ 2257, 2257A, or other applicable laws.
11. To process payments, refunds, fraud prevention, chargebacks, and other payment-related matters.
12. To comply with applicable laws, regulations, court orders, card-network rules, payment-provider requirements, and other compliance obligations.

The Company will not disclose a User’s personal information to third parties without the User’s consent, except as permitted by applicable law.

The Company may disclose information where necessary in the following circumstances:

1. Where the User has given consent.
2. Where required or permitted by law.
3. Where necessary to protect the life, body, or property of a person and it is difficult to obtain the User’s consent.
4. Where the Company receives a lawful request from law enforcement authorities, regulatory authorities, courts, or other public authorities.
5. Where a report to the National Center for Missing & Exploited Children (“NCMEC”) or another appropriate organization is required in connection with CSAM or other reportable conduct.
6. Where necessary to investigate, remove, or otherwise respond to NCII, illegal Content, infringement, or other reports or complaints.
7. Where information is provided to payment providers, acquiring institutions (“Acquirers”), card networks, or other payment-related entities for payment processing, fraud prevention, chargeback handling, compliance, or other necessary purposes.
8. Where necessary information is provided to identity-verification providers, recordkeeping providers, or other third-party service providers used by the Company for age verification, identity verification, Section 2257-related recordkeeping, or other compliance purposes.
9. Where the handling of information is entrusted to a service provider to the extent necessary to operate the Service.

The Company is located in Japan, and User information may be processed or stored in Japan or in other countries or regions where the Company or its contractors and service providers operate.

Where Users located in the United States or other countries outside Japan use the Service, their information may be transferred to, stored in, or processed in Japan.

The Company will take appropriate measures for internationally transferred information in accordance with applicable law.

The Company retains collected information for as long as necessary to fulfill the purposes for which it was collected, for any period required by applicable law, or for any period reasonably necessary for dispute resolution, investigations, safety, compliance, or other legitimate purposes.

Retention periods may vary depending on the type of information and the purpose for which it is used.

Where information must be retained pursuant to applicable law, 18 U.S.C. §§ 2257 or 2257A, obligations arising from reports to NCMEC, payment or card-network requirements, litigation, or other legal obligations, the Company may retain such information for the required period notwithstanding its ordinary deletion practices.

Information that is no longer necessary will be deleted or anonymized in accordance with applicable law.

The Company will take necessary and appropriate measures to protect personal information and other information against unauthorized access, leakage, loss, destruction, or other risks.

Where the Company uses external service providers or contractors, it will appropriately manage such providers and, where necessary, review their information-security practices.

1. Users may request access to, correction of, deletion of, or other actions regarding their personal information in accordance with applicable law.
2. Users may request correction where their personal information is inaccurate.
3. To the extent permitted by applicable law, Users may request deletion, restriction of processing, or cessation of disclosure of their personal information.
4. The Company may be unable to comply with a deletion or similar request where retention is required by law or is reasonably necessary for an investigation, safety, dispute resolution, establishment, exercise or defense of legal claims, or other legitimate purposes.
5. The Company may require reasonable verification of the requester’s identity before processing a request.

Residents of certain U.S. states may have rights under applicable state privacy laws concerning personal information held by the Company, which may include rights to access, confirm, correct, delete, obtain a copy of, or object to certain processing of personal information.

The Company will provide any additional privacy notices required by applicable law and will respond to applicable privacy-rights requests based on the User’s place of residence and applicable law.

Where prohibited by applicable law, the Company will not unlawfully discriminate against a User for exercising applicable privacy rights.

Where the Company receives a report or complaint concerning CSAM, NCII, trafficking, exploitation, copyright infringement, or other unlawful or prohibited Content, the Company may preserve relevant information and Content and conduct an investigation.

Where required or permitted by applicable law, the Company may remove or restrict access to Content, suspend Accounts, preserve information, make reports, or provide information to law enforcement authorities, NCMEC, or other appropriate organizations.

The Company may amend this Policy as necessary.

The amended Policy will become effective when it is posted or otherwise made available through the Service, or on another effective date specified by the Company.

Established: November 1, 2026