Twipet Privacy Policy

NTT QONOQ, Inc. (“QONOQ,” “we,” ”us,” ”our,” or “ours”) collects and uses your (“you” or “your”) personal information in accordance with this Privacy Policy (this “Policy”) upon the provision of Twipet’s app and related services (together, the “App”). This Policy applies to the collection and use of personal information (any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household; the same shall apply hereinafter) of consumers who reside in the United States as a supplement to NTT QONOQ Privacy Policy. In the event of any discrepancy between the provisions of this Policy and NTT QONOQ Privacy Policy, the provisions of this Policy shall prevail.

1. Categories of Personal Information We Collect

We have collected in the last twelve (12) months and will continue to collect the following categories of personal information shown in the chart below.

Categories	Examples
Identifiers	Unique personal identifier, online identifier, or other similar identifiers.
Commercial Information	Records of products or services purchased.
Internet or other electronic network activity information	Browsing history, search history, and information regarding your interaction with the App or advertisement.
Audio, electronic, visual, or similar information	Data obtained from your camera, or images and videos you select.

2. Sources of Personal Information

We collect your personal information from the following categories of sources.

Directly from you.

Automatically from your devices when you use the App.

From third-party business partners, including tech vendors who support the App and other business systems.

3. Business or Commercial Purposes for Collecting Personal Information

We collect personal information for the following purposes.

To provide you with the APP, including services for displaying AR contents.

To improve your experiences on the App and develop the App.

To analyze the effectiveness of advertising.

To determine if you are a paid subscriber of the App.

4. Retention of Personal Information

We retain your personal information to the extent necessary for the purposes stated in this Policy.

The criteria for determining the retention periods, includes, but is not limited to, the duration of the contractual relationship between you and us; the legal obligations assumed by us; and a need to perform an agreement to which you are a party.

5. Disclosure of Personal Information

During the last twelve (12) months, we have disclosed the following categories of personal information to the categories of third parties and for the purposes shown in the chart below.

Categories	Third Party Categories	Purposes
Identifiers	Advertising service providers	To analyze the effectiveness of advertising.
Internet or other electronic network activity information	Analytic service providers	To improve your experiences on the App and develop the App.
Identifiers Commercial Information Internet or other electronic network activity information Audio, electronic, visual, or similar information	Third party platforms	For third parties to provide service on our behalf

6. Sale or Sharing of Personal Information

We will not sell or share any personal information. Also, we have not sold or shared any personal information in the preceding twelve (12) months.

In this Policy, the term “sale” means disclosing, etc. your personal information to a third party for monetary or other valuable consideration, and the term “sharing” means disclosing your personal information to a third party for cross-text behavioral advertisements, whether for monetary or other valuable consideration or free of charge.

7. Sale of Sharing Personal Information of Consumers under 16 Years of Age

We do not have knowledge that we sell or share personal information of consumers under 16 years of age.

Also, we don’t knowingly collect any information from anyone under the age of 13. The App is not directed at children under the age of 13.

8. Use or Disclosure of Sensitive Personal Information

We have not and will not collect sensitive personal information from you.

9. Do Not Track

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer's online activities over time and across third-party website or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

10. Your Rights and Choices Under the Applicable Law

The following describes your rights and how to exercise those rights under the applicable law which may include, but is not limited to, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”).

(1) Right to Access Specific Information

You have the right to request that we disclose certain information to you in relation to the collection, sharing, disclosure, or use of your personal information by us over the twelve (12) months preceding the date of your request. Upon receipt and confirmation of your verifiable consumer request, we will disclose to you any and all of the following information:

(i) The categories of your personal information that we have collected;

(ii) The categories of sources from which we have collected your personal information;

(iii) The business or commercial purposes of us for the collection, sale, or sharing of such personal information;

(iv) The categories of third parties to which we disclose, sell, or share such personal information;

(v) The categories of your personal information that we have disclosed, sold, or shared; and

(vi) The specific personal information that we have collected about you.

(2) Right to Request Deletion

You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Upon receiving your verifiable consumer request, we will delete your personal information from our records and will notify any service providers and contractors, as well as third parties to which we have sold or with which we have shared personal information if any, that they must delete such personal information from their records, unless an exception applies.

We may deny your request to delete your personal information if it is necessary for us or our service providers or contractors to retain your personal information in order to:

(i) Complete the transaction for which we collected the personal information, fulfill requirements for a product recall conducted in accordance with a written warranty or federal law, provide a good or service that you requested, enable you to take measures reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform an agreement between us and you;

(ii) Provide support to ensure the security and integrity of your personal information to the extent reasonably and proportionally necessary for the purpose of use;

(iii) Debug products to identify and repair errors that impair existing intended functionality;

(iv) Exercise free speech, ensure the right of other persons to exercise their free speech rights, or exercise other rights provided by law;

(v) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;

(vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres or adapts to all other applicable ethics and privacy laws, where our deletion of such information may render impossible or seriously impair the ability to compete such research, if you previously provided informed consent;

(vii) Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; or

(viii) Comply with legal obligations.

(3) Right to Request Correction of Inaccurate Personal Information

You have the right to request that we correct any of your inaccurate personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will correct your inaccurate personal information and will notify any service providers and contractors, as well as third parties to which we have sold or with which we have shared your inaccurate personal information if any, that they must correct such inaccurate personal information. We may deny your correction request if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

(4) Right to Opt Out of Sale or Sharing

We have not and will not sell or share any personal information collected from you.

(5) Right to Request Restriction of Use

We have not and will not collect sensitive personal information from you.

(6) Right of Non-Discrimination

We will not discriminate against consumers due to the exercise of any of their rights under the applicable law. Unless permitted by the applicable law, we will not engage in any of the following:

(i) Denying goods or services to you;

(ii) Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

(iii) Providing you with a different level or quality of goods or services;

(iv) Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services; or

(v) Retaliating against an employee, applicant for employment, or independent contractor.

(7) Exercising Your Rights to Access, Delete, and Correct

To exercise your rights to access, delete, and correct your personal information, please submit a verifiable consumer request to us by contacting us via the information in “Contact Information for Inquiries and Complaints.”

Only you, or a natural person or a person registered with the relevant authority that you authorize to act on your behalf, or a person who has power of attorney or is acting as a conservator for you, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

A “verifiable consumer request” must:

(i) Provide sufficient information that allows us to reasonably verify that you are the person whose personal information we have collected or an authorized representative thereof; and

(ii) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.

11. Contact Information for Inquiries and Complaints

Please contact us at the following address for inquiries or complaints about the processing of your personal information:

Contact Information: twipet_support@ml.nttqonoq.com

12. Amendment to this Policy

We may amend this Policy as necessary according to the laws and regulations and for business reasons. Amendments, etc. will be published on the website. In addition, we shall take measures pursuant to laws and regulations depending on the amendments.

Last Updated: 09/02/2024