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.

Please refer to the “PRIVACY POLICY for ibis Paint in the EEA / the UK” for residents in the EEA / the UK.
Please refer to the “PRIVACY POLICY for ibis Paint in the United States of America” for residents in the United States of America.

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.
4. “iOS version” refers to the app which can be downloaded from the App Store operated by Apple.
5. “GMS version” refers to the app which can be downloaded from the Play Store operated by Google.
6. “HMS version” refers to the app which can be downloaded from the HUAWEI AppGallery operated by HUAWEI.
7. “Windows version” refers to the app which can be downloaded from the Microsoft Store operated by Microsoft.
8. “Paid version” refers to this application which requires a one-time purchase at the time of download.

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 (iOS version only)
   2. Google (GMS version only)
   3. HUAWEI (HMS version only)
   4. Microsoft (Windows version only)
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 (iOS and GMS versions only)
   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.
4. Our company accepts requests from users through the contact point specified in the <Contact address>.

7. Provision of personal information to third parties

1. For the sake of advertisement distribution and usage analysis, our company provides personal information that is defined in "Appended Table: Personal information provided to third parties" to the following third parties.
   • AppLovin (Excluding Paid and Windows versions)
     https://www.applovin.com/privacy/
   • Facebook
     https://www.facebook.com/msqrd/privacy
   • fluct (Excluding Paid and Windows versions)
     https://corp.fluct.jp/privacy/
   • Google Analytics
     https://policies.google.com/privacy
     
   • Google Ads (Excluding Paid and Windows versions)
     https://policies.google.com/technologies/ads
   • Google Firebase (iOS and GMS versions only)
     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=
   • InMobi (Excluding Paid and Windows versions)
     https://www.inmobi.com/privacy-policy/
   • Tapjoy (Excluding Paid and Windows versions)
     https://www.tapjoy.com/legal/advertisers/#privacy-policy
   • Microsoft
     https://aka.ms/privacy
   • YouTube (iOS and GMS versions only)
     https://www.youtube.com/intl/us/about/policies/#community-guidelines
2. Our company does not provide third parties with the personal information of users that is defined in "Appended Table: Personal information provided to third parties", 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. Notwithstanding the provisions of the preceding paragraph, in addition to the personal information that is defined in "Appended Table: Personal Information Provided to Third Parties", Windows version also provides the personal information specified below to third parties.
   1. The Windows version includes software provided by Microsoft.
      Information about the use of this application is collected by software provided by Microsoft and this information is transmitted to Microsoft.
      The information collected and transmitted is disclosed in Microsoft's Privacy Statement.
   2. The Windows version uses the Microsoft Edge WebView2 runtime to display web pages.
      This runtime includes Microsoft Defender SmartScreen, which collects and transmits user information to Microsoft as disclosed in Microsoft's Privacy Statement and Microsoft Edge Privacy Whitepaper.

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. About Security Control Measures

Our company continuously strives to take necessary and appropriate security measures against the dangers of unauthorized access, leaks, destruction, and damage in our handling of personal information.

1. Systematic Security Control Measures
   We maintain a system and rules to protect personal information and are thorough about appropriate handling and responses based on laws and ordinances. We also carry out regular voluntary inspections and audits regarding the circumstances of handling personal information.
2. Human Security Control Measures
   Regularly and when an employee joins the company, we educate all employees on the protection of personal information. In addition, we appropriately direct employees, such as by requiring them to accept the duty to maintain confidentiality based on work regulations.
3. Physical Security Control Measures
   We control an employee's entry into and exit from rooms in areas where an employee handles personal information. At the same time, we implement measures to prevent an unauthorized person from viewing personal information.
4. Technical Security Control Measures
   Due to access control, we limit the extent of viewing and handling information. At the same time, we take technical control measures, such as suitable information security measures against dangers such as illegal access and computer viruses.

11. Regarding personal information protection management

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

12. 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

Appended Table: Personal information provided to third parties