This Privacy Policy sets forth a policy for protecting personal information, as defined in the Act on the Protection of Personal Information (the "Personal Information Protection Act"), obtained from the users who use Taxnote (the "Service") provided by free K.K. ("freee"). The other privacy policy set forth by freee shall not apply to the Services.

1. Compliance with Laws and Regulations

In order to protect personal information, freee will comply with the Personal Information Protection Act, the guidelines of each ministry and agency, and other relevant laws and regulations.

2. Collection of Personal Information and Purpose of Use

freee will collect your personal information in connection with this Service.

freee will establish a management system for the protection of personal information in accordance with our hands-on experiences and use such personal information properly and carefully only for the following purposes (the “Purpose of Use”):

• to provide and control the Service;

• to check the usage of the Service by the user and operation status of the Service;

• to provide information and notices about the Service or freee;

• to improve and develop the Service;

• to respond to inquiries;

• to conduct surveys;

• to provide customized contents for the users;

• to use for our marketing and campaigns;

• to create statistical data for the use of the Service in a form processed so as not to be able to identify individuals or specific user; or

• for other matters incidental or related to each of the preceding items.

freee may supplement your personal information obtained through the Service by other information acquired or retained by freee. Personal information obtained in connection with the Service shall not be used for any purpose other than the Purposes of Use.

In addition, in the event that freee indirectly acquires personal information from a third party, freee will use such personal information only for the Purpose of Use after confirming whether or not such third party has properly obtained such personal information from the third party.

3. Provide Personal Information to Third Parties

freee will not provide personal information obtained by the user to any third party without obtaining the prior consent of the user. Provided, however, that this shall not apply to the following events.

• In the event that it becomes necessary to provide personal information to our subcontractors for the Purpose of Use
  When it becomes necessary to provide personal information to our subcontractors, freee shall conduct appropriate supervision to such subcontractor for information management. freee will subcontract certain services required for the provision of the Service to Likha-iT Inc, our group company located in the Philippines, and, accordingly, provide your personal information to it. The details of such provision are as follows:

1. Personal information protection system in the Philippines
   https://www.privacy.gov.ph/data-privacy-act/

2. Obligations or rights of an entity that comply with the eight principles of OECD Privacy Guidelines
   Applicable

3. Information on measures for the protection of personal information taken by Likha-iT Inc.
   freee, as contractors, will conduct appropriate supervision to ensure that the measures taken by Likha-iT Inc to protect personal information are at the same level as the measures required to a personal information handling business operator in our country.

• In the event of the following sharing uses:

  • Information to be shared: personal information obtained by freee

  • Purpose of the sharing use: same as the Purpose of Use described in 2 above. Provided, however, that "freee" in the Purpose of Use shall be read as "freee and our subsidiaries and Affiliates" and the "Service" in the Purpose of Use shall be read as the "services provided by freee and our subsidiaries and affiliates."

  • Scope of the sharing use: freee and our subsidiaries and affiliates.

  • Managers in charge of sharing use: freee.

  • In the events permitted under the Personal Information Protection Act.

4. Technical Information such as Log File, Cookies and Web Beacon

freee will collect log files, sends cookies (including cookies sent from a third-party server to measure advertising effects), and installs a web beacon to collect information such as the user's IP address, the number of accesses, the used browser, the operating system, and other information of your device through the Service. When using the Service, the ID of your device and information related to wi-fi connection shall also be obtained from the use of this Service. The user may reject the cookies on the browser settings, however, in that case, some of the Service may not be available. The information are collected for the purpose of analyzing trends in use of the Service and investigating the causes of problems, and are not used for the purpose of identifying individuals.

5. Methods of Disclosure, Correction, Suspension of Use of Personal Information

The user may request disclosure, correction, suspension of use of his/her personal information in accordance with the Personal Information Protection Act. If the user has any requests for disclosure, correction, or suspension of use of his/her personal information, as well as requests for opinions, questions, complaints, and other inquiries regarding the handling of personal information, please contact the following our address. freee will respond to each request after confirming your identity.

freee@freee.co.jp

6. Limitation of Liability for Disclosure

In the event that freee receives a request for disclosure by the national government, local governments, courts, police, or other authorities authorized by law or ordinance pursuant to applicable laws, freee may disclose the user’s information to such authorities without the consent of the user.

7. Supervision of Employees and Subcontractors

freee will use our best effort to provide education, raise awareness, and make development for security and personal information protection in our company. In addition, freee may subcontract the whole or part of handling personal information to a third party. In this case, freee will select the subcontractors who can handle the personal information properly. In addition, free will set forth the matters related to the handling of personal information in the subcontract agreements, and conduct necessary and appropriate supervision on the subcontractors.

8. Security Measures

freee will take reasonable precautions to protect the personal information, exercise extreme caution in handling personal information, and make it accessible only to authorized personnel who are required for business purposes.

9. Use for Different Purposes from Original Purpose

In principle, freee will not use personal information of the user for any purpose other than the Purposes of Use specified in this privacy policy at the time freee obtained such information (the “Original Purpose of Use”). In the event that freee uses personal information for purposes other than the Original Purposes of Use, freee shall obtain the prior consent of the user.

10. Handling Personal Information in External Services

This privacy policy applies only to the Service. For information on the handling of personal information on external websites and services, please refer to the privacy policy provided in those external websites and services.

11. Modification to Privacy Policies

freee regularly review and improve the Service and, as a result, may modify this privacy policy. In the event any material modification in this privacy policy is needed, freee will notify the date of such modification and the details of such modification to the user on the application software or website for the Service or by any other means.

This is an English translation of the Japanese language version of the privacy policy (the “Japanese Version”) and, in the event of any conflict between the Japanese Version and an English translation thereof, the provisions in the Japanese Version shall take precedence over any other translation.