# Privacy Policy

Last update: Jan 30, 2024

Japan Radio Co., Ltd. (“we”, “us” or “our”) processes your personal data collected in the context of our Smart Ship Viewer services (“Services”) in accordance with the applicable laws and this Privacy Policy (this “Policy”). In this Policy, personal data primarily refers to any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access and is defined under the applicable personal data protection laws.

#### Contact Information

We are responsible for your personal data as a data controller. If you have any question or would like to uphold your rights, please contact us at:
Mail: Japan Radio Co., Ltd.
NAKANO CENTRAL PARK EAST 4-10-1 Nakano, Nakano-ku,
Tokyo 164-8570, Japan
Fax: +81-3-6832-0436
Inquiry: J-MARINE CLOUD Inquiry Form

#### Categories of personal data we collect

We collect and process the following personal data in the context of our Services.

Information You Provide

- Information from the application form - When you start using our Services, an application form will be needed. This form includes the following information: company name, department, the name of the contact person, and the contact person's email address.
- Account Information - User registration is done by the user themselves. When you register an account in our Services, you will need to provide us with your account name, user ID, email address, and password.
  *You are required to provide us with certain personal data when you register or sign in our Services. Personal data that is mandatory is indicated in the relevant forms. We are not able to provide our Services to you if such data is not provided.
- The information provided through you inquires or contact.
- The information submitted to us through screens, emails, documents, and other means (including chat log).
- GPS information of the device (used only within the device to provide service functions with the prior consent of the user, and will not be transmitted or stored outside the device)

Information We Collect Automatically

- Usage Information - When you interact with our Services, we automatically collect technical data regarding your usage of our Services, including pages that you visit and links you click on, online identifier (cookie etc. But We do not collect IP address) or device information (language, browser type, etc.).

No Sensitive Personal Data or Personal Data of Minors

- In principle we do not obtain sensitive personal data and personal data relating to criminal offences except in cases where it meets the requirements of the applicable laws. We also do not intend or wish to obtain personal data of or from minors.

To learn more about our use of cookies or similar technology please check our Cookie Policy.

#### How we use your personal data

We use personal data for the following purposes:

1. for registration to our Services, identity authentication when using our Services, and user management. The lawful basis for these uses is your consent or to pursue our legitimate interests in providing our Services.
2. to prevent and respond to fraudulent or unauthorized activities and other unlawful actions. The lawful basis for these uses is your consent, to pursue our legitimate interests in protecting our users, or to comply with our legal obligations.
3. to provide and maintain our Services. The lawful basis for these uses is your consent or to pursue our legitimate interests in improving our Services and giving our users the best experience.
4. to collect and settle the fees of our Services. The lawful basis for these uses is your consent or to pursue our legitimate interests in providing our Services.
5. to provide information about our products and services. The lawful basis for this use is your consent.
6. for the ongoing improvement of our services, conducting surveys, and implementing marketing initiatives. The lawful basis for these uses is your consent or to pursue our legitimate interests in improving our Services and giving our users the best experience.
7. for responding to inquiries and communicating with you. The lawful basis for this use is your consent.

#### How we share your personal data

We may share your personal data in the following ways:

1. Our Agents or our Group Companies
   We may obtain your personal data through our agents or group companies to initiate and provide your use of our Services.
2. Subsidiaries as Business Partners
   To provide and enhance our services, we may provide your personal data to group companies to whom we have entrusted the development of our Services.
3. Sharing Registration Information with Your Company
   We share your registration information to your company to use our Services.(a) We may share your personal data with third parties to the extent necessary to comply with any court order, law or legal process, including to respond to any government or regulatory request;
4. We may share your information with a third party to the extent permitted under the applicable law and/or your consent;
5. We may share your registration information with your company for its use of our Services; and
6. We may share your personal data with software vendors, payment service providers and other service providers to the extent necessary for the operation of our Services.

You acknowledge and agree that your information (including your personal data) may be hosted, disclosed, accessed by, and/or transferred to third parties outside of your country of residence (including for storage or processing). We will ensure that where personal data is transferred outside of your country of residence, such recipients will protect such personal data to a standard at least comparable to the standard afforded under the applicable law of your country of residence and such transfer will be undertaken without any violation of the appliable law of your country of residence.

#### Data security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. For more information on the measures we take, please contact us at the address listed in Contact Information above.

#### Data retention

We retain your personal data for a period of 7 days maximum after your account is deleted, except where legal requirements imposing that we keep your personal data longer or less longer apply.

#### Your rights

You have the right to ask us: for a copy of your personal data; to correct or delete your personal data; to restrict (stop any active) processing of your personal data; and to send you a copy of your personal data you have provided to us in a structured, machine readable format. In addition, you can object to the processing of your personal data under certain conditions (for further information, see the section below entitled “Your right to object to processing”). Please note that these rights are subject to the exceptions under the applicable laws.
To exercise any of these rights, please contact us in writing at the address listed in Contact Information above.

#### Your right to object to processing

You have the right to object at any time to the processing of your personal data which is based on our legitimate interests. When we process your personal data for direct marketing purposes, you have an absolute right to opt out of such processing.
To exercise this right, please contact us in writing at the address listed in Contact Information above.

#### Withdrawing consent

Wherever we rely on your consent in order to process your personal data, you have the right to withdraw that consent at any time. Such withdrawal does not affect the lawfulness of any processing performed pursuant to the consent given prior to the withdrawal.
To exercise this right, please contact us in writing at the address listed in Contact Information.

#### Change of this Policy

We may change this Policy from time to time and notify you of the changes by posting them on this page or the home page of our Services, sending emails to your registered email address or other measures we think appropriate. You are responsible for periodically visiting our Service and this Policy to check for any changes. Your continued access and use of our Services after we make such changes will be deemed to be acceptance of those changes.