Privacy Policy

Sustainable Pavilion 2025, Inc. (hereinafter referred to as the "Company") establishes this Privacy Policy (hereinafter referred to as the "Policy") regarding the protection of personal information of customers (including business partners' representatives and Company employees; collectively referred to as "Customers"), and will handle Customers' personal information appropriately in accordance with this Policy. Terms used in this Policy shall have the meanings ascribed to them under the Act on the Protection of Personal Information (hereinafter referred to as the "APPI").

1. Personal Information Collected
The Company collects the following categories of personal information from Customers.
Identity Verification InformationName, address, postal code, gender, date of birth, phone number, email address, etc.
Payment InformationBank account information, payment and payment method information, etc.
Information Collected Through Use of the ServiceOnline identifiers such as cookie IDs, device information, location information, browsing history, and other service usage data (including access logs, IP addresses, browser information, browser language settings, etc.)
Other InformationInquiries, correspondence, and other communications from Customers to the Company

2. Purposes of Use
The Company collects and uses Customers' personal information for the following purposes (hereinafter referred to as the "Purposes of Use").
Customer Personal Information
To provide, maintain, and manage the Service
To research and analyze marketing data and to consider and implement related measures
To provide, solicit, advertise, and conduct other marketing activities for products and services of the Company or third parties through Company or third-party media, based on analysis of customers' attributes and behavioral history
To improve the Service and to plan, research, and develop new services
To respond to inquiries and to contact Customers
To provide to third parties in the manner described in this Policy
Business Partners' Personal Information
To communicate regarding business negotiations and meetings
To manage billing and payments
Company Employees' Personal Information
To communicate regarding business operations
To manage attendance and other human resources matters
To implement salary, bonuses, and employee benefits
To handle tax and social insurance matters

3. Third-Party Provision
The Company will not provide personal information it handles to third parties without the prior consent of Customers, except in the following cases:
When required by applicable laws and regulations
When necessary to protect a person's life, body, or property, and it is difficult to obtain the user's consent
When especially necessary to improve public health or promote the sound development of children, and it is difficult to obtain the user's consent
When it is necessary to cooperate with a national or local government agency or its delegated party in carrying out affairs stipulated by law, and obtaining the user's consent would be likely to impede the execution of such affairs
In other cases permitted by applicable laws and regulations

4. Security Management Measures
The Company takes necessary and appropriate measures to prevent leakage, loss, or damage of the personal information it handles and to otherwise ensure the security management of such information. For details on the Company's security management measures, please contact the inquiry window listed in Section 9.

5. Notification of Purposes of Use and Disclosure of Personal Information or Third-Party Provision Records
When a Customer requests notification of purposes of use or disclosure of personal information or third-party provision records in accordance with the APPI, the Company will verify that the request is made by the Customer themselves and will provide notification or disclosure without delay (or notify the Customer if no such information exists). Please note that a fee of 1,000 yen per request will be charged for such notification or disclosure.
The preceding paragraph does not apply where the Company is not obligated to make disclosures under the APPI or other applicable laws and regulations.

6. Correction of Personal Information and Suspension of Use
When a Customer requests correction, addition, deletion, or suspension of use or third-party provision of personal information in accordance with the APPI, the Company will verify that the request is made by the Customer themselves, conduct necessary investigations without delay, and take appropriate action based on the results. If the Company decides not to correct, add, or delete personal information, or not to suspend its use or third-party provision, the Company will notify the Customer accordingly.
The preceding paragraph does not apply where the Company is not obligated to correct, add, delete, or suspend use or third-party provision of personal information under the APPI or other applicable laws and regulations.

7. Retention Period of Personal Information
The Company will retain Customers' personal information for the period necessary to achieve the Purposes of Use described in Section 2. As a general rule, such period shall be the period during which contractual, transactional, or other rights and obligations between the Company and Customers subsist; provided, however, that where required for tax, labor, or other applicable legal or regulatory purposes, such period shall exceptionally be the longer of (i) the period during which such rights and obligations subsist, or (ii) seven years from the date of acquisition of the personal information.
Please note that even after the retention period described in the preceding paragraph has elapsed, or upon a request for deletion of personal information pursuant to Section 6, the Company may defer deletion of Customers' personal information for the periods set forth below if any of the following circumstances apply:
Where the Company has taken measures to prohibit a Customer from using any of the Company's services and it is necessary to prevent re-registration or re-use in connection therewith
Five years from the date of such prohibition measure
Where the Company has reasonable grounds to retain Customers' personal information, including fraudulent or prohibited conduct on the Company's services, outstanding payments owed to the Company, or pending inquiries, complaints, or claims submitted to the Company
Until such grounds are resolved

8. About Cookies
The Company uses cookies for purposes including improving the functionality of its website, delivering advertisements, and collecting statistical data. Customers may choose whether to consent to the Company's use of cookies. Please note that if you decline the Company's use of cookies, certain features of the Company's website may become unavailable.
The Company uses Google Analytics, a service provided by Google. The Company may receive from Google the results of Google's collection and analysis of Customers' browsing histories based on cookies set by the Company or Google, and may use such results to understand Customers' usage patterns and to improve the Company's services. For details on how Google handles data in Google Analytics, please refer to the following Google policy page:
"How Google uses information from sites or apps that use Google's services" (https://policies.google.com/technologies/partner-sites)

9. Contact
For opinions, questions, complaints, or other inquiries regarding the handling of user information, please contact:
Name: Sustainable Pavilion 2025, Inc.
Address: Partnerham House, 3-8-16 Koyama, Shinagawa-ku, Tokyo
Email: mb-support@sp-2025.com
Person in Charge: Security Officer

Last revised: June 25, 2026
Revised: September 26, 2025
Enacted: January 31, 2025