Privacy Policy

This Privacy Policy explains how Assem Co., Ltd. (“we”, “our”, or “the Company”) handles personal data and personal information on this website (“the Site”). We comply with applicable laws and regulations, including Japan’s Act on the Protection of Personal Information (APPI) and the EU General Data Protection Regulation (GDPR), and we process data with transparency.

Please note that we do not meet the applicability thresholds of the California Consumer Privacy Act (CCPA). Therefore, rights and obligations under the CCPA are not included in this Policy.

1. Information We Collect

We may collect the following types of information through the Site:

1-1. Information Provided Voluntarily by Users

• Email addresses and message content included in inquiry emails

1-2. Information Collected Automatically (Access Logs)

The servers operated by Xserver Inc., which hosts the Site, automatically record the following information:

• IP address
• Date and time of access
• Requested URL
• Referrer (referring URL)
• Browser information (User-Agent)
• Status codes (e.g., 200, 404)

This information is not used to identify individual users.

1-3. Use of Cookies

The Site does not use cookies for behavioral tracking or analytics.

2. Purposes of Use of Personal Data

We use the collected information for the following purposes:

• Responding to inquiries
• Ensuring stable operation of the Site and preventing unauthorized access
• Maintaining records for legal compliance

3. Legal Basis for Processing (GDPR Article 6)

When processing personal data of individuals residing in the EU/EEA, we rely on the following legal bases:

• Legitimate Interests (GDPR Article 6(1)(f))
  Obtaining access logs for server operation and security purposes
• Contract or Pre-contractual Measures (GDPR Article 6(1)(b))
  Processing data as necessary to respond to inquiries
• Consent (GDPR Article 6(1)(a))
  When a user voluntarily sends us an email, that action may be regarded as an expression of consent to process personal data to the extent necessary to respond.

4. Handling of Personal Information under the APPI

We handle personal information in accordance with the APPI as follows:

• We use personal information only to the extent necessary to achieve the stated purposes.
• We implement appropriate security measures to prevent unauthorized access and other risks.
• We do not provide personal information to third parties except as permitted by law.
• We appropriately respond to requests for disclosure, correction, or suspension of use in accordance with applicable laws.

5. Provision of Personal Data to Third Parties

We do not provide personal data to third parties except as required by law.

However, Xserver Inc. may retain access logs for server operation purposes. This constitutes outsourced data processing and does not fall under “third-party provision.” We appropriately supervise our service providers.

6. Data Retention Period

• Access logs: Retained for the period specified by Xserver (generally several months to around one year)
• Inquiry emails: Retained only for the necessary period after responding, then deleted

7. Rights of Data Subjects (GDPR Articles 15–21)

Individuals residing in the EU/EEA have the following rights under applicable laws:

• Right of access to personal data
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to data portability
• Right to object to processing on legitimate grounds

To exercise these rights, please contact us using the information below. Please note that we may not be able to comply with certain requests where permitted by law.

8. Security Measures

We implement necessary and appropriate technical and organizational measures to prevent the leakage, loss, or damage of personal data and personal information. We also review and improve these measures as needed.

9. Use by Minors

The Site is not specifically designed for minors, nor do we intend to actively collect personal data from minors. If a minor contacts us, we recommend that they do so with the consent of a parent or guardian.

10. Changes to This Privacy Policy

We may revise this Privacy Policy in response to changes in laws or service content. The revised Policy will take effect when posted on the Site.

11. Contact Information

For inquiries regarding this Policy or our handling of personal data and personal information, please contact us at the following email address:

Email: assem@assem.biz

End

Enacted on: December 12, 2025