Privacy Policy

modo Inc. (hereinafter "we" or "the Company") establishes the following Privacy Policy (hereinafter the "Policy") regarding the handling of user information, including users' personal information, in "memStock" and its related services provided by the Company (hereinafter the "Service").

1. User information we collect and how we collect it

In this Policy, "user information" means information related to a user's identification, behavioral history on the communication service, and other information generated or accumulated in relation to a user or a user's device, that we collect under this Policy.

The user information we collect in the Service, by collection method, is as follows.

1. Information provided by users

The information provided by users to use, or through the use of, the Service is as follows.

• Profile information such as name, date of birth, gender, and occupation
• Information about the family, such as family composition
• Household budget information and asset information
• Contact information such as email address, phone number, and address
• Still-image information including a user's likeness
• Information that a user enters or sends through input forms or other methods we specify

2. Information provided by other services that the user permits us to link with

If a user permits linking with another service such as a social networking service when using the Service, we collect the following information from that external service based on the consent given at the time of authorization.

• The ID the user uses on that external service
• Other information that the user has permitted to be disclosed to the linked service based on the privacy settings of that external service

3. Information we collect when a user uses the Service

We may collect information about access to and methods of using the Service. This includes the following.

• Referrer
• IP address
• Information about server access logs
• Cookies, ADID, IDFA, and other identifiers

4. Information we collect based on a user's individual consent when using the Service

If a user individually consents by the method set out in 3 above, we collect the following information from the device in use.

• Location information

2. Purpose of use

The specific purposes for which user information related to providing the Service is used are as follows.

1. To provide, maintain, protect, and improve the Service, including accepting registration, identity verification, user authentication, and recording user settings
2. To measure user traffic and behavior
3. To deliver, display, and measure the effectiveness of advertising
4. To respond to inquiries and provide information about the Service
5. To respond to acts that violate our terms, policies, etc. ("Terms, etc.") regarding the Service
6. To notify users of changes to the Terms, etc. regarding the Service

3. Methods of notification/publication or obtaining consent, and methods for requesting cessation of use

1. For the following user information, we obtain the user's consent before such information is collected.

• Location information
• Access to the photo library
• Use of the camera

2. By performing the prescribed settings in the Service, a user may request that the collection or use of all or part of their user information be stopped, in which case we will promptly stop such use in accordance with our procedures. However, because the collection or use of certain items of user information is a prerequisite for the Service, we will stop such collection or use only when the user withdraws from the Service by the method we prescribe.

4. External transmission, provision to third parties, and presence of information-collection modules

1. In the Service, we may install information-collection modules created by third parties for the purpose of understanding usage and delivering advertising. Details of the installed modules and external transmission are published on the following page.

memStock External Transmission Policy

5. Provision to third parties

We will not provide personal information among user information to third parties (including those outside Japan) without obtaining the user's prior consent. However, this does not apply in the following cases where provision to a third party (including those outside Japan) is necessary.

1. Where we entrust all or part of the handling of personal information within the scope necessary to achieve the purpose of use
2. Where personal information is provided in connection with a business succession due to a merger or other reason
3. Where personal information is provided to a partner or an information-collection module provider in accordance with the provisions of Section 4
4. Where it is necessary to cooperate with a national agency, a local government, or a party entrusted by them in performing affairs prescribed by law, and obtaining the user's consent is likely to impede the performance of such affairs
5. In other cases permitted by the Act on the Protection of Personal Information (the "Personal Information Protection Act") or other laws and regulations

6. Disclosure of personal information

When a user requests disclosure of personal information based on the Personal Information Protection Act, we will, after confirming that the request is from the user themselves, disclose it to the user without delay (if such personal information does not exist, we will notify the user accordingly). However, this does not apply where we are not obligated to disclose under the Personal Information Protection Act or other laws. Please note that a fee (1,000 yen per request) applies to disclosure of personal information.

7. Correction and suspension of use of personal information, etc.

1. If a user requests, based on the Personal Information Protection Act, (1) correction of personal information on the grounds that it is not true, or (2) suspension of its use on the grounds that it is being handled beyond the scope of the previously published purpose of use, or that it was collected by deception or other improper means, we will, after confirming that the request is from the user themselves, conduct the necessary investigation without delay and, based on the results, correct the content of the personal information or suspend its use, and notify the user accordingly. If we decide not to make a correction or suspend use, we will notify the user of that fact.
2. If a user requests erasure of their personal information and we determine that we need to comply with the request, we will, after confirming that the request is from the user themselves, erase the personal information and notify the user accordingly.
3. Sections 7-1 and 7-2 do not apply where we are not obligated to make corrections, etc. or to suspend use, etc. under the Personal Information Protection Act or other laws.

8. Contact

For opinions, questions, complaints, or other inquiries regarding the handling of user information, please contact us at "info@modo.co.jp".

9. Procedures for changing the Privacy Policy

We will change this Policy as necessary. However, when we make changes to this Policy that require the user's consent under laws and regulations, the changed Policy applies only to users who have consented to the change by the method we prescribe. When we change this Policy, we will notify users of the timing and content of the changed Policy by posting on our website or by other appropriate methods.

10. Children's Privacy (U.S. Children's Online Privacy Protection Act (COPPA))

The Service is intended to be used by families, including parents and guardians, under the management of a parent or guardian (the Administrator).

1. We do not intend to collect personal information directly from children under the age of 13 without the consent of a parent or guardian. Children under the age of 13 may use the Service only under the management of a parent or guardian (the Administrator).
2. Where an Administrator (parent or guardian) enters or registers information about a child (including name, date of birth, and other profile information) within a Family Group, that Administrator is deemed, as the child's parent or guardian, to have consented to the collection, use, and handling of such information under this Policy.
3. If we become aware that we have collected personal information from a child under the age of 13 without the consent of a parent or guardian, we will take reasonable measures to promptly delete such information.
4. If you are a parent or guardian and believe that your child's personal information has been provided to us without your consent, or if you wish to review or delete such information, please contact us at the contact point set out in Section 8 (info@modo.co.jp). We will respond after verifying that you are the parent or guardian.

11. Rights of California Residents (U.S. California Consumer Privacy Act (CCPA/CPRA))

Where the California Consumer Privacy Act (as amended by the CPRA; the "CCPA") applies, California residents have the following rights:

• The right to know: the right to request disclosure of the categories of personal information we collect, use, or disclose, the sources of collection, the purposes of use, and the categories of recipients of disclosure.
• The right to delete: the right to request deletion of the personal information about the resident that we have collected.
• The right to correct: the right to request correction of inaccurate personal information that we hold.
• The right to opt out: the right to opt out of any "sale" or "sharing" of personal information, where applicable.
• The right not to be subject to discriminatory treatment for exercising these rights.

We do not "sell" personal information to third parties in exchange for money or other consideration. We also do not "share" personal information for the purpose of cross-context behavioral advertising.

If you wish to exercise any of these rights, please contact us at the contact point set out in Section 8 (info@modo.co.jp). We will respond in accordance with applicable laws after verifying your identity. We will not subject you to discriminatory treatment in the provision of the Service for exercising your rights.

[Established March 12, 2024]

[Revised October 30, 2025]

[Revised June 9, 2026]