This document is translated from Japanese language version. You must understand that this document is provided ONLY for your convenience and legally valid document is always Japanese language version ONLY.If there is any contradiction between what the Japanese language version says and what a translation says, then the Japanese language version takes precedence.

Policy on the Protection of Personal Information

ibis inc. (hereinafter referred to as “our company”) develops software for mobile devices and web applications and provides services for mobile phones. Our company recognizes that the protection of personal information is an important social responsibility. In order to protect the rights of individuals, our company complies with the laws and regulations related to personal information and has constructed a personal information management system based on the policy shown below.

1. Our company only acquires, uses, and provides personal information within the scope of the purpose of utilization and not for any other purposes.
2. Our company takes reasonable security measures against the risks of unauthorized access, loss, destruction, falsification, and leakage of personal information. Further, our company is constantly improving our security system in relation to personal information, implementing measures to prevent and correct leaks, loss, and damage.
3. Our company complies with the laws, national guidelines, and other regulations related to personal information.
4. Our company reviews our personal information protection management system in a timely and appropriate manner, and constantly works to improve it.

In addition to releasing this policy externally, our company informs our employees and partners about it, working to educate and enlighten every individual, and striving to enhance awareness of personal information protection. For response to inquiries, consultation, or complaints related to personal information and this policy, please contact us at the following address.

Further, there is no fixed format to request the disclosure of personal information, but our company will ask you some questions to confirm your personal information. Also, there is no fee for the disclosure of personal information.

Privacy Policy

1. Definition of terms

1. “ibisPaint services” (hereinafter referred to as “our services”) is a general name for the services offered by the ibisPaint app (hereinafter referred to as “our app”), by ibispaint.com (hereinafter referred to as “this site”), and ssl.ibis.ne.jp (hereinafter referred to as “this portal site”).
2. “Users” are all persons using our services.
3. “Personal information” refers to information related to an identified or specified individual, or information related to an individual who can be directly or indirectly identified or specified.

2. Purpose of use

ibis Inc. (hereinafter referred to as “our company”) uses personal information obtained from users for the following purposes.

1. For provision of our services.
2. To prevent fraudulent use of our services and to resolve operational troubles.
3. As a basis for decisions on improving our services and providing new services.
4. To create statistical data on user trends after processing the data so that individuals cannot be identified.
5. In order to distribute advertisements optimized for the users.

3. Use restrictions

Our company uses the personal information obtained from users within the limits necessary to achieve the purpose of use stated above except in the following cases.

1. When the user has given consent in advance.
2. In instances grounded in law.
3. When there is difficulty obtaining the individual’s consent and it is necessary in order to protect a person’s life, body, or property.
4. When our company has been asked by a national institution, local government, or one entrusted by said institution or government, to disclose registered content in accordance with the law.

4. Methods of obtaining personal information

1. Our company obtains personal information through the following methods.
   1. Input into our services by the users.
   2. The transmission of information from web browsers.
   3. The transmission of information from our app.
   4. Provision by third parties.
2. When products from our services have been purchased using the following third-party purchasing services, our company receives information from those third parties.
   1. Apple
   2. Google
3. When our services have been linked using the following third-party account authentication services, our company receives the corresponding account information from those third parties.
   1. Twitter
   2. Facebook
   3. YouTube
   4. CLIP STUDIO PAINT
   5. Apple
   6. HUAWEI (HMS Version only)

5. Type, purpose, and storage period of personal information

The personal information processed through use of our app is listed in “Appended Table: Personal information processed by our services.”

6. Management of personal information

1. Users have the following rights in relation to the processing of personal information.
   1. The right to request from our company the disclosure of personal information.
   2. The right to request from our company the revision of personal information.
   3. The right to request from our company the deletion of personal information.
   4. The right to request from our company limitations on processing.
   5. The right to file an objection to processing with our company.
   6. The right to file an appeal to a supervising authority.
2. When the user himself has made a request, our company will disclose the personal information managed by our company except in the following cases.
   1. When there is a risk of harm to the life, body, property, or other rights of the user himself or to those of a third party.
   2. When it will create a considerable obstacle to the business operations of our company.
   3. When it violates the law.
   4. When there is a possibility that it may lead to filing a lawsuit.
   5. When our company is unable to confirm that the request came from the user himself.
3. When the user himself has made a request, our company will revise or delete the personal information managed by our company except in the following cases.
   1. When there is a risk of harm to the life, body, property, or other rights of the user himself or to those of a third party.
   2. When it will create a considerable obstacle to the business operations of our company.
   3. When it violates the law.
   4. When there is a possibility that it may lead to filing a lawsuit.
   5. When it is not possible to enforce the rights of freedom of expression and information transmission.
   6. When it is not possible to realize the purpose of storage for public benefit, the purpose of scientific or historical research, or the purpose of statistics.
   7. When our company is unable to confirm that the request came from the user himself.

7. Provision of personal information to third parties

1. For the sake of advertisement distribution and usage analysis, our company provides personal information to the following third parties.
   • AppLovin
     https://www.applovin.com/privacy/
   • Facebook
     https://www.facebook.com/msqrd/privacy
   • fluct
     https://corp.fluct.jp/privacy/
   • Glossom
     https://www.glossom.co.jp/privacy/glossom.html
   • Google Ads
     https://policies.google.com/technologies/ads
   • Google Firebase
     https://firebase.google.com/support/privacy
   • HUAWEI (HMS Version only)
     https://consumer.huawei.com/minisite/cloudservice/id/privacy-statement.htm?country=HK&language=en-us&themeName=
   • i-mobile
     https://www.i-mobile.co.jp/privacy.html
   • InMobi
     https://www.inmobi.com/privacy-policy/
   • MoPub
     https://www.mopub.com/legal/privacy/
     https://www.mopub.com/legal/partners/
   • Tapjoy
     https://www.tapjoy.com/legal/advertisers/#privacy-policy
   • Slack
     https://slack.com/privacy-policy
   • YouTube
     https://www.youtube.com/intl/us/about/policies/#community-guidelines
2. However, our company does not provide third parties with the personal information of users, except in the following cases.
   1. When the user has given consent in advance.
   2. When a part of our services is outsourced and it is necessary in order to execute that business.
   3. When statistical data is disclosed after processing the data so that individuals cannot be identified.
   4. In instances grounded in law.
   5. When there is difficulty obtaining the individual’s consent and it is necessary in order to protect a person’s life, person, or property.
   6. When our company has been asked by a national institution, local government, or one entrusted by said institution or government, to cooperate in disclosing registered content in accordance with the law.
3. The personal information provided to third parties among the personal information obtained through use of this site is listed in “Appended Table: Personal information provided to third parties.”

8. Consent to the handling of personal information

1. Users are required to consent to the handling of personal information by our company when initiating use of our services. If they do not consent, they cannot use our services.
2. Users under the age of 16 are required to have parental consent and our company verify that they have consent annually until they turn 16.

9. Revocation of consent

1. In case the handling of personal information by our company is based on user consent, users have the right to revoke that consent at any time.
2. By deletion of the app, deletion of the account link, deletion of browser cookies, the resetting of the advertisement ID, and deletion request, the user has revoked consent to the handling of personal information by our company.

10. Regarding personal information protection management

The protection of personal information is managed by PMS office in our company.

11. Regarding revisions to the privacy policy

Our company may change all or part of our privacy policy without prior notice. When it has been changed, it will be released on this site.

Appended Table: Personal information processed by our services

Type of Personal Information	Data Content	Processing Purpose	Storage Period
Account information	Twitter account name Twitter access token Facebook account name Facebook access token YouTube account name YouTube access token YouTube refresh token CLIP account name CLIP access token Apple account name Apple access token Apple refresh token Apple identity token HUAWEI Display Name (HMS Version only) HUAWEI ID token (HMS Version only)	User identification Simplification of user authentication Provision of useful information Usage analysis Function improvement Bug investigation	Until app deletion and account link deletion
App and device information	App UUID Device token FCM token Platform type App type	Provision of useful information Usage analysis Function improvement Bug investigation	Until app deletion and account link deletion
Purchase information	Purchase ID Purchased product Device information on purchase Date and time of purchase, continuation, and cancellation	Provision of useful information Usage analysis Function improvement Bug investigation	In order to maintain purchase-right information, it is retained until the end of the service
Access information	IP address User-Agent Access time Access URL	Usage analysis Function improvement Bug investigation Prevention of fraudulent operations	Seven days
User content, history, and settings information	Profile Artwork data “Like!” information Comment information Download information Subscription information Comment block information Display settings Notification settings Login history Artwork browsing history Artwork edit history Inappropriate artwork report history	User communication Storage of user content Usage analysis Function improvement Bug investigation Prevention of fraudulent operations	Until app deletion, account link deletion, and deletion of browser cookies
Inquiry information	Name Email address User-Agent Inquiry content	Usage analysis Function improvement Bug investigation	Until deletion upon request

Appended Table: Personal information provided to third parties

Type of Personal Information	Data Content	Processing Purpose	Recipient	Storage Period
User content, history, and settings information	Twitter account name Facebook account name Apple account name Device’s model name Artwork data	User communication Storage of user content	YouTube	Until deletion of artwork with the user’s YouTube account
	Inappropriate artwork report history	Usage analysis Function improvement Bug investigation Prevention of fraudulent operations	Slack	Until deletion upon request
Crash trace information	App UUID Platform type App type Model name OS version Region of use Crash trace	Usage analysis Function improvement Bug investigation	Google Firebase HUAWEI (HMS Version only)	Until loss of relation to personal information via deletion of app
Device and behavior information	Device token FCM token App UUID Platform type App type IP address User-Agent Device’s model name OS version Available storage space Region of use Terminal language settings Terminal carrier information Screen size, orientation, and resolution Sound volume Battery Memory use Country, time zone, and local settings Network connection type and speed Advertisement ID Cookies	Advertisement display Usage analysis	AppLovin Facebook fluct Glossom Google Ads HUAWEI (HMS Version only) i-mobile InMobi MoPub Tapjoy	Until loss of relation to personal information via deletion of app, deletion of browser cookies, and reset of advertisement ID