robot home, Inc. and its subsidiaries (collectively, the “Company”) hereby establishes this Application Privacy Policy (this “Policy”) with respect to the handling of user information acquired through the smartphone apps provided by the Company (including the services provided through such apps; collectively, the “App”).
This Policy is based on the Japanese-language version as the original. In the event that any conflict or inconsistency exists between the Japanese version and this English-language version of this Policy regarding content or interpretation, the Japanese-language version shall prevail.

This Policy shall apply to users who use the App. With respect to matters not provided for in this Policy, the Company’s Privacy Policy (https://corp.robothome.jp/en/privacy_policy) shall apply. In the event of any conflict or inconsistency between the Privacy Policy and this Policy, the provisions of this Policy shall prevail. This Policy applies to user information acquired through the App. The handling of personal information acquired through the inquiry forms on the Company’s websites or through other contact channels shall be governed by the Privacy Policy and by the notice on the handling of personal information posted at the relevant channel.
For the Company’s policies regarding the handling of personal information in connection with the use of AI (artificial intelligence) in the App, please refer to the Company’s AI Privacy Policy (https://corp.robothome.jp/en/privacy_policy/ai-privacy). For the terms and conditions applicable to AI services provided through the App, please refer to the Company’s AI Service Terms of Use (https://corp.robothome.jp/en/privacy_policy/ai-terms).

The Company acquires user information through input by users or through automatic processing by the App. The user information acquired and the purposes of use thereof are as follows:

(1) User Information Acquired
• Information entered by users in the App (email address, nickname, gender, date of birth)
• Location information
• Name, address, and telephone number
• Communication history (including image data)
• Operation history
• Property location and room number
• Identification ID generated for each registration
• Device identification ID (iOS, Android)
• OS version
• App version

(2) Purposes of Use of User Information
The Company shall acquire and use personal information within the scope of the purposes set forth in each of the following items. The Company may analyze the personal information of Users in order to estimate their interests, tendencies, and other information, and may use personal information within the scope of the purposes set forth in each of the following items.
• Providing the App
• User management
• Communications as necessary, including important notices regarding the App and services provided through the App
• Responding to inquiries and requests, and recording the contents thereof and using such records to improve the quality of responses, verify facts, and provide internal training (including the recording of telephone calls)
• Proposals and descriptions of products and services
• Providing information regarding products and services
• Delivering advertisements (including the delivery of advertisements tailored to Users’ interests based on the results of analysis of their browsing history, purchase history, usage status, and similar information, whether on the Company’s websites, applications, or other media, or through advertising delivery service providers)
• Marketing research and analysis
• Providing property recommendations, property assessments, property monitoring, and other services utilizing AI
• Optimizing services through analysis of user attributes and app activity logs (profiling)

The Company may transmit or provide user information to third parties as set forth below.
(1) Transmission to Company Servers and Third-Party Servers
The Company transmits user information acquired as described in Section 2 (Items of User Information Acquired and Purposes of Use) above to servers managed by the Company via the App for the purpose of providing the App.
In addition, among such user information, the following information is also transmitted to servers managed by the following third parties via the App:
(i) Tuya Inc.
• Communication history (including image data)
• Operation history
(ii) Twilio Inc.
• Identification ID generated for each registration
(iii) AI Platform Service Providers
Part of the user information may be transmitted to AI platform service providers located in foreign countries (principally the United States) for the purpose of executing AI services provided through the App.

(2) Information Collection Modules
The App contains the following information collection modules for the purpose of analyzing usage conditions and crash conditions. The information transmitted by each information collection module is as set forth below. For the purposes of use of the transmitted information, please refer to the privacy policies of the respective module providers.
(i) Firebase (Provider: Google LLC)
https://firebase.google.com/support/privacy?hl=en
• Information transmitted: device identification IDs, OS version, app version, operation history, and crash information
• Purpose of use by the recipient: analysis of app usage and crash data, and the maintenance and improvement of Firebase services
(ii) Google Analytics (Provider: Google LLC)
https://policies.google.com/privacy?hl=en
• Information transmitted: device identification IDs, OS version, app version, and operation history
• Purpose of use by the recipient: analysis of app usage, and the maintenance and improvement of Google services

(3) Provision to Third Parties
The Company may provide user information to third parties in cases where the Company determines that any of the following apply:
(i) The user’s consent has been obtained;
(ii) Provision is based on the laws and regulations;
(iii) Provision is necessary for the protection of the life, body, or property of an individual, and it is difficult to obtain the consent of the individual;
(iv) Provision is particularly necessary for improving public health or promoting the sound development of children, and it is difficult to obtain the consent of the individual; or
(v) It is necessary in order to cooperate with a national government agency, a local government, or a person entrusted thereby in executing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of such affairs.

(4) Cross-Border Transfer of User Information
User information acquired through the App may be provided to service providers located in foreign countries for the purpose of providing the App and executing AI services. The principal transfer recipients are as follows:
• Google LLC: Located in the United States. Utilized for usage analysis (Firebase, Google Analytics).
• AI Platform Service Providers: Located principally in the United States. Utilized for the execution of AI services.
The service used for authentication and notifications (item (ii) in (1) above) does not constitute a provision to a third party located in a foreign country, because the counterparty to the relevant agreement is a Japanese corporation. The fact that the storage and processing take place in the United States is as set out in Section 7 (Safety Management Measures) (4)(e) of the Privacy Policy.
Likewise, the service used for the communication and control of IoT devices (item (i) in (1) above) does not constitute a provision to a third party located in a foreign country, because the counterparty to the relevant agreement is a Japanese corporation. The fact that the storage and processing take place in a foreign country is likewise as set out in Section 7 (Safety Management Measures) (4)(e) of the Privacy Policy.
The Company shall carry out such transfers only after confirming, pursuant to Article 28 of Japan’s Act on the Protection of Personal Information (the “APPI”) and the rules thereunder, that such provider has established a system conforming to the standards prescribed therein. The Company shall implement measures necessary to ensure the continued implementation of the equivalent measures by such provider, and information regarding such measures shall be provided upon request to the inquiry desk.

The Company shall notify users of the content of this Policy and provide an opportunity to obtain consent at the time of download, installation, or first launch of the App by users (including the first launch after an update).
Users are requested to review and understand the content of this Policy before using the App.

The App does not provide a function enabling the individual cessation of the acquisition and use of user information. Certain information, such as location information, may be disabled through the settings of the operating system of the user’s device.
Users who wish to cease the acquisition of user information should uninstall the App.
With respect to user information acquired by the Company at the time of uninstallation, the Company may continue to use such information within the scope of the purposes of use prescribed in Section 5 (Acquisition, Use, and Provision of Personal Information and Retained Personal Data) of the Privacy Policy. Users who also wish to cease such use must carry out the request procedures for disclosure of personal information in accordance with the provisions of Section 10 (Requests for Disclosure of Personal Information) of the Privacy Policy.

For information on the measures taken by the Company for the safety management of retained personal data (including measures associated with the entrustment of processing to service providers located in foreign countries), please refer to the Privacy Policy (https://corp.robothome.jp/en/privacy_policy).

The Company reserves the right to amend this Policy at any time in connection with updates to the App or other changes. If the Company amends this Policy, the Company shall notify users thereof by posting the amended Policy within the App or by other appropriate means. As set forth in Section 4, the content of the amended Policy shall be presented again, and an opportunity to obtain consent shall be provided, at the first launch of the App following the update.

Any questions, complaints, or other inquiries regarding this Policy or the handling of user information in the App should be directed to the Company through the inquiry procedures set forth in Section 14 (Inquiries) of the Privacy Policy (https://corp.robothome.jp/en/privacy_policy).