atena Inc. (hereinafter referred to as "the Company") has established the following policy regarding the protection of personal information handled by the Company (hereinafter referred to as "the Policy") and promotes the protection of personal information. (hereinafter referred to as "the Company") has established the following policy for the protection of personal information handled by the Company (hereinafter referred to as the "Policy") and promotes the protection of personal information.

Article 1 (Personal Information)

In this policy, "personal information" refers to "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act"). Personal information" as used in this policy refers to "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act"), and refers to information about a living individual that can identify a specific individual by name, date of birth, or other description, or that contains a personal identification code.

Article 2 (Acquisition and Use of Personal Information, etc.)

1. The Company shall use personal information for the following purposes. If it becomes necessary to change the purpose of use, we will promptly notify or publicly announce such change.

• To provide specific services offered by the Company (hereinafter referred to as the "Services") To provide after-sales services related to the Services

• To provide information on the Company's products, services, etc. by e-mail, telephone, mail, etc.

• To respond to requests and inquiries regarding the Service

• To conduct marketing activities such as improving our service level and developing new services

• To conduct campaigns, questionnaires, etc.

• For other purposes as individually determined for each of the Company's services

2. We will acquire personal information only within the scope of the purpose of use, and will use personal information within the scope of the purpose of use without deviating from it. If the Company intends to use personal information beyond the scope of the purpose of use, the Company shall obtain prior consent from the person in question by appropriate means.

3. In order to make the services and advertisements we provide more suitable for you, we may acquire and use information that cannot identify specific individuals, such as cookies, URLs accessed, and behavioral history.

Article 3 (Management and Protection of Personal Information)

The Company shall strictly manage personal information. In consideration of security, the Company shall take measures to prevent and correct risks such as unauthorized access to personal information, loss, destruction, falsification, and leakage of personal information.

Article 4 (Provision of Personal Data to Third Parties)

We will not provide to any third party any personal information (hereinafter referred to as "Personal Data") that we have obtained and that constitutes a collection of information systematically organized so that it can be retrieved using a computer or a collection of information systematically organized so that specific personal information can be easily retrieved by organizing, classifying, and adding a table of contents, codes, etc., in accordance with certain rules. Personal Data"). Personal data (hereafter referred to as "personal data"), which consists of a collection of information that is systematically organized in such a way that specific personal information can be easily retrieved by classifying it according to certain rules, by attaching a table of contents and by attaching a code, will not be provided to third parties except in the following cases

• When we have received prior consent to provide such information to a third party.

• When required by the Personal Information Protection Law or other laws and regulations

• When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual.

• When outsourcing part or all of the handling of personal information to an outside company based on a business consignment contract (including storage on a server, etc.). (2) When the Company is unable to obtain the consent of the individual to whom the personal information relates. In such cases, the Company will enter into a contract regarding the handling of personal information and appropriately supervise the consignee to ensure the safe management of personal information.

• In the event of succession of business due to merger, company split, business transfer, or other reasons.

Article 5 (Disclosure of Personal Information)

When a person requests disclosure of his/her personal data (personal data for reasons of digging as defined in Article 2, Paragraph 7 of the Personal Information Protection Law), the Company shall disclose the personal data in its possession to the person in question. (Personal Information Protection Law, Article 2, Paragraph 7), we will disclose it to the person in question without delay. However, if the disclosure falls under any of the following cases, the Company may decide not to disclose all or part of the information, and if the Company decides not to disclose the information, it will notify the person to that effect without delay. A fee of 1,000 yen will be charged for each case of disclosure of personal information.

• When there is a risk of harm to the life, body, property, or other rights or interests of the person concerned or a third party

• If there is a risk of significant hindrance to the proper conduct of our business

• If it violates any other laws or regulations.

Article 6 (Correction and Deletion of Personal Information)

1. If the personal data held by the Company is incorrect, the Company will correct or delete the personal information in accordance with the procedures prescribed by the Company upon request of the person in question.

2. If we receive a request from the person in question as described in the preceding paragraph and deem it necessary to respond to the request, we will correct or delete the relevant personal information without delay and notify the person in question of such correction or deletion.

3. Paragraphs 1 and 2 shall not apply in cases where personal information must be kept for a certain period of time as required by law.

Article 7 (Suspension of Use of Personal Information, etc.)

In the event that the Company is requested by the individual to cease use or erase (hereinafter referred to as "cease of use, etc.") the retained personal data on the grounds that it has been handled beyond the scope of the purpose of use or that it has been obtained by wrongful means, the Company shall cease use or erase the retained personal data without delay. In the event that a customer requests the suspension of use or deletion of personal information (hereinafter referred to as "Suspension of Use, etc."), we will conduct the necessary investigation without delay, and based on the results, we will suspend the use of the personal information and notify the customer to that effect. However, in cases where it is difficult to suspend the use of personal information due to the large amount of costs involved or other reasons, and alternative measures can be taken to protect the rights and interests of the person, these alternative measures will be taken.

Article 8 (Compliance and Review of Laws, Regulations, and Standards)

We will comply with Japanese laws, regulations, and other norms applicable to personal information in our possession, and will review and improve this Privacy Policy as appropriate.

Article 9 (Data Retention Policy)

The Company stipulates the following regarding the various data collected and retained in the course of providing the "atena Service."

atena Data Retention Policy

Article 10 (Changes to Privacy Policy)

The contents of this Privacy Policy may be changed without notice to the user, except as otherwise provided by law or otherwise in this Policy. Unless otherwise specified by the Company, the revised Privacy Policy shall become effective when posted on the Website.

Article 11 (Response to Complaints and Consultations)

The Company shall accept complaints and consultations from the person concerned regarding the handling of personal information, and respond to such complaints and consultations appropriately and promptly. The Company shall also respond promptly and appropriately to requests from the person in question to disclose, correct, add to, delete, or deny the use or provision of the relevant personal information.

Article 12 (Contact for Inquiries)

For inquiries regarding the handling of personal information by the Company, please contact the following

• Representative contact of the company: inquiry@atena.inc

In addition, for inquiries regarding the service, please contact the following

• atena Support Desk: supportdesk@atena.life