ADVERTISING PLATFORM PRIVACY POLICY

1. Who are we?

We at fluct, Inc. ("we", "us", "our" or "fluct") value your privacy and are committed to taking care of your Personal Data, which is a responsibility that we take very seriously. fluct operates and serves ads, including but not limited to targeting ads ("Ads") to PCs and smartphones though the so-called internet ad serving service "fluct" ("fluct Service").

This Privacy Policy explains the privacy practices on fluct's advertising platform and the data it uses for delivering advertising to you. Items 1 to 11 of this policy apply to all residents. For residents of California, USA, the 12. CCPA compliance clause additionally applies.

Administrators of websites that have deployed the "fluct" or providers of applications that have deployed the Fluct SDK should provide a link to this policy accordance with applicable laws and regulations.

Please note, that this Privacy Policy does not govern the collection and use of personal data about visitors to our website and/ or in the context of our corporate business activities. If you wish to find out more fluct's processing activities in these regards, please see Basic Privacy Policy.

2. Definitions

In this policy, "Personal Data" (referred to as "User Information" in the Japanese policy) refers to information related to the identification of the user, behavioral history on communication services, and any other information generated or accumulated on the user's smartphone, computer, or other terminals in connection with the user or the user's terminal, as well as information linked thereto, which we handle based on this policy. The Data may be in certain jurisdictions considered information or data subject to legal obligations under applicable privacy and data protection laws and regulations.

3. What type of Personal Data do we collect from you?

When interacting with a website that uses the fluct Service, we collect certain data about you and your device. The data we are provided with, does not include data which allows us to directly identify you as an individual, for example such as your name or email address.

(1) Information Acquired via the Advertisement Distribution Program

When you interact with a website or apps that uses our technology, we and our clients use and deploy tracking technologies, in particular cookies, to automatically collect certain information about you or your device via our advertisement distribution program, and store it in the advertisement distribution system operated by us.

The following Personal Data may be processed:

(i) Web Browsers

• Usage data / Log data: information about the domain, the date/time of your visits, the search terms you enter, visitor activities and actions, viewability data, the video title, video player size, description or category being displayed, click data, types of advertisements viewed, IP address, usage environment/region, browsing history of websites and applications, advertisement viewing history, distributed advertisement data, distributed advertisement click information, information on time zones when viewing or clicking occurred, and information regarding OS and browsers;
• Cookie Information

(ii) FluctSDK

• Device data / Location data: information about the computer or mobile device you use, including device type, device model, device operating system, device operating system version, Advertising Identifiers (IDFA, Google Advertising ID), IP address, usage region, language settings of the device, and mobile carrier information;
• User-Input Information: Information regarding gender and age entered into the application by the customer.

Cookie information is widely used for the purpose of providing better services by identifying customers' web browsers, such as managing visits to the Service and displaying advertisements. Cookie information itself does not contain any information that concerns customers' privacy, such as personal information. Customers can deactivate the Cookie function by changing their web browser settings; however, please note that some services may become unavailable in that case.

(2) Other Acquired Information

(i) We may conduct various questionnaires for users and acquire the content voluntarily answered by the users. The acquired information includes age, gender, and other details, which vary depending on the content of the questionnaire. The information to be acquired is intended to display more beneficial advertisements to users and does not include any information that identifies a specific individual.

(ii) We create industry-standard categories based on information provided by NTT DOCOMO, INC. (hereinafter referred to as "DOCOMO"), which includes advertising identifiers, attribute information, location information, and behavioral history. If you do not wish to have your information provided from DOCOMO to us, please perform the opt-out operation for third-party provision through the Personal Data Dashboard provided by DOCOMO.

4. What Personal Data do our Clients and Vendors collect?

Our clients, our vendors, and our clients' vendors may use their own tags, pixels, cookies, or other similar technology (or those of their other affiliates) within advertisements services. We are not responsible for our clients', vendors' and/or our clients' vendors' use of such tracking technologies or for their privacy practices.

5. How do we collect your Personal Data?

We (and our service providers) use different technologies to collect Personal Data, including cookies, and other similar technologies to collect information automatically from your device when you visit a website which uses our technology.

Among the technologies cookies serve multiple functions such as delivering personalized ads and tracking their performance. We also utilize SDK (Fluct SDK) mediation to integrate with third-party ad networks, enhancing our ad delivery capabilities. Additionally, we may use other tools like cookie syncing and frequency capping to optimize ad delivery and maintain a consistent user experience. This collected data enables us and our partners to deliver more relevant advertisements across various platforms and devices, ultimately improving the quality of our services.

We also work with third parties who provide analytics and advertising services. These companies collect and use User Data separately to help our clients and their customers deliver targeted ads using our technology. For example, we partner with advertising companies that gather data about your visits to different websites or apps across various devices. They use this information to show you ads and content they believe you will find interesting on devices they think belong to you, such as for example web browsers, mobile apps. We, along with our advertiser clients, may combine this third-party data with the User Data we collect to deliver targeted ads across multiple devices. Additionally, our publisher clients may use this combined data to create audience segments, which are groups of users that can be targeted with ads on digital platforms.

6. Who we share your Personal Data with?

We understand that your privacy is important, and we are committed to being transparent about how we handle your data. In the course of providing our fluct Services, we may need to share your data with certain trusted third parties.

We may share your personal data with the following third parties:

• Clients: We may disclose User data with our clients who use our fluct Services. These clients may use the data for purposes such as optimizing their advertising campaigns, targeting audiences, and measuring the effectiveness of their advertisements.
• Vendors, and other service providers: We may disclose User data with our vendors, and service providers(including DataCurrent Corporation: Toranomon Hills Station Tower 36F, 2-6-1 Toranomon, Minato-ku, Tokyo, but not limited) who perform functions on our or our clients' behalf and require access to such information to provide us with services or do work for us. Examples include: analyzing data, reporting, fraud prevention, hosting or providing data, auditing, engaging technical support for our technology platform, and performing analysis related to our technology platform and related services.
• Partners: We may disclose User data with partners, including third party advertising platforms. These partners use the information we provide to provide services to us and our clients and may use the data for their own purposes.

We do not disclose Personal Data to anyone else except as set out above unless we have your consent, or we are legally obliged to do so. For example, to any competent law enforcement or government body, or court, as a matter of applicable law or regulation, or to exercise our legal rights. These recipients will only process your Personal Data to perform tasks and duties on our behalf and in compliance with governing data protection laws.

7. Your Privacy Choices

Cookies

To opt out of receiving advertising targeted to your interests from our Ad Services through the use of cookies in your current browser, and for more information on what it means to opt out, please visit our opt-out page. Your opt-out choice will be linked to your browser only; therefore, you will need to renew your opt-out choice if you use a new device or browser, or if you clear your browser's cookies.

Mobile Apps

Your device may also include a feature that allows you to opt out of the use of information about the apps you use for targeted advertising purposes. To learn more about these practices, please visit https://thenai.org//opt-out/mobile-opt-out/.

Connected TVs

Your Internet connected television (e.g. a smart TV or device that allows you to stream video program) may give you the ability to opt out of targeted ads. To determine if your Internet connected television has these options, please visit your device's settings menu. To learn more about these practices, please visit https://thenai.org/opt-out/connected-tv-choices/.

8. How long do we keep your Personal Data for?

Generally, we will retain your Personal Data for as long as we need it for the purposes for which it was collected. We further will retain your user data for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

We retain the user data we collect from your device, such as your IP address and other information as described above, in our systems typically for 90 days and up to two years before we anonymize and aggregate that data into summary reports.

In addition, we may be allowed to retain your data whenever you have given consent to such processing as long as such consent is not withdrawn.

9. Data security

We take the security of your information very seriously and only handle Personal Data as permitted by data protection regulations. We use a variety of technical and organizational measures to help protect your Personal Data from unauthorized access, disclosure, modification, loss or destruction in accordance with applicable data protection laws. When handling Personal Data, our employees are obliged to comply with the applicable data protection regulations.

10. Changes to our data protection provisions

We reserve the right to modify this Privacy Policy, so it is always in compliance with the current legal requirements or to implement changes to services in the Privacy Policy, e.g., when introducing new services. In this case, your future visits to our website will be subject to the updated Privacy Policy.

If you have additional questions regarding the processing of your Personal Data, please feel free to contact us directly, either by email at privacy@fluct.jp or via mail to fluct, Inc., Toranomon Hills Station Tower 36F 2-6-1 Toranomon, Minato-ku, Tokyo, 105-5536.

11. Contact Information

General

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your data, or your choices and rights regarding such use please do not hesitate to contact us by:

Email at: privacy@fluct.jp
Postal Address: Toranomon Hills Station Tower 36F, 2-6-1 Toranomon, Minato-ku, Tokyo, 105-5536 fluct, Inc.

12. CCPA compliance clause

California's California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA") provide California applicants with certain rights:

• Knowledge of information collected;
• Deletion of information collected;
• Opt-out of information collected;
• Opt-in of information collected;
• Correction of information collected;
• Go to court;
• Limit use of information collected;
• Not to be discriminated or retaliated against for exercising rights under the law.

Where We Get Your Information From. See 3.

Sharing of Personal Information. See 6.

Data Retention. See 8.