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Privacy Policy

Envalith Co., Ltd. (hereinafter referred to as "the Company") recognizes the importance of appropriately handling the personal information of our customers (including investors and officers/employees of client companies who use this service) in the research report distribution service and related services provided by the Company (hereinafter referred to as "the Service"), and establishes the following privacy policy (hereinafter referred to as "this Policy"). Unless otherwise specified in this Policy, the definitions of terms in this Policy shall be in accordance with the Act on the Protection of Personal Information (Japan).

Last Enacted: December 29, 2025

Article 1 (Definition of Personal Information)

In this Policy, "Personal Information" refers to information as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"). This includes information that can be easily cross-referenced with other information, thereby allowing the identification of a specific individual.

Article 2 (Information Collected and Collection Methods)

The Company collects the following information in providing the Service:

1. Information Provided Directly by the Customer

• Account Information: Email address, password.

• Attribute Information: Age, gender, and attributes related to investment activities.

• (Examples: Investor category, investment style, investment scale, assets under management, sectors of interest, and other items the Company deems necessary for the provision of the Service.)

• Inquiry and Dialogue Data: Contents entered into inquiry forms, feedback on reports, questions to companies, and survey responses.

2. Information Automatically Collected Through Use of the Service

• Usage History and Action Logs:

• Report viewing history, duration of stay, and read-through rates.

• Usage status of the clip function (highlighted sections, saved text).

• Contents of questions to the AI agent and dialogue logs.

• Search keywords and filter setting history.

• Device and Connection Environment Information: IP address, browser type, OS version, Cookies, Advertising ID (ADID/IDFA), and device ID.

Article 3 (Purposes of Use)

The Company uses the collected personal information for the following purposes:

1. Provision and Operation of the Service

• Login authentication and identity verification for the Service.
• Distribution and notification of reports (coverage initiation, earnings previews, earnings flashes, briefing session flashes, interview flashes, video/audio content, etc.).
• Provision and accuracy improvement of multi-language translation functions.
• Report recommendations (personalized display) based on user attributes and action history.

2. Improvement and Development of the Service

• Improving response accuracy and optimizing training data (LLMO) for AI (Large Language Models).
• Analyzing user interests and viewing trends using access analysis tools.
• Planning, developing, and providing new features and services.

3. Feedback to Client Companies (Issuers) and Provision to Third Parties

• Analyzing user viewing trends, clipped sections, and questions to AI for the purpose of providing such data to the report-issuing companies (client companies) or other third parties (see Article 4 for details on third-party provision).

4. Marketing and Information

• Providing information on services, seminars, and events of the Company or partner companies.
• Creating and analyzing statistical data regarding service usage status.

Article 4 (Provision of Personal Data to Third Parties)

The Company will not provide personal data (referring to personal data as defined in Article 16, Paragraph 3 of the Personal Information Protection Act) to third parties without the prior consent of the customer, except in the following cases:

1. Cases based on laws and regulations.
2. Cases where it is necessary for the protection of a person’s life, body, or property, and it is difficult to obtain the consent of the individual.
3. Cases where it is especially necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the individual.
4. Provision to Client Companies (Issuers) (Provision accompanying use of the Service): The Service aims to promote dialogue and mutual understanding between investors and companies. Therefore, when a user performs an action on a specific company’s report (viewing, clipping, questioning the AI, responding to surveys, etc.), the feedback content and user attribute information related to that action will be provided to the client company (issuer) in a format that does not identify specific individuals (statistical information) as a report primarily intended to improve the issuer's IR activities.

• Examples of provided information: "When" an investor of "what attribute" (e.g., institutional investor, growth-oriented) "clipped which part" of a report or "what kind of question" (e.g., regarding growth strategy) they asked the AI.
• Purpose of provision: To enable companies to understand investor interests and concerns and to assist in improving information disclosure and management decisions.

5. Other cases where prior consent for provision has been obtained from the customer.

Article 5 (Entrustment of Personal Information Handling)

The Company may entrust the handling of all or part of personal information to external parties (cloud server providers, AI service providers, translation service providers, etc.) within the scope necessary to achieve the purposes of use. In such cases, the Company will perform necessary and appropriate supervision of the entrustee.

Article 6 (Use of AI Functions and External Services)

The Service utilizes the APIs of Large Language Models (LLM) provided by OpenAI, Google, and Anthropic for the AI agent and summarization functions. The Company has applied settings (opt-out settings) to these providers to ensure that data sent via the API is not used for training AI models. Consequently, user input data will not be reflected in AI-generated results for other users.

• Information entered by the user into the AI agent is used to generate responses from the AI agent.

Prohibited Items and Disclaimer

Users must not include the following information in inputs to the AI functions of the Service:

• Personal Information (name, address, contact information, account numbers, or other information that can identify a specific individual).
• Undisclosed Material Facts (including insider information or information that may violate the Financial Instruments and Exchange Act or other laws).

If a user enters information in violation of the above, Envalith Co., Ltd. shall not be held liable for any damages arising from the leakage or use of said information. Furthermore, the Company shall not bear any obligation to protect or manage such entered information as personal information.

Article 7 (Use of Cookies and Information Collection Modules)

The Service uses cookies to improve convenience and analyze usage status. Additionally, to analyze investor insights, we use proprietary tracking technology to record the viewing of specific sections and clipping actions within reports. These functions can be disabled through browser settings; however, doing so may prevent the use of some features of the Service.

Article 8 (Security Control Measures)

The Company shall take necessary and appropriate measures (encryption of communications, access restrictions, monitoring of unauthorized access, etc.) to prevent the leakage, loss, or damage of personal information and for other security management of personal information. For details regarding the security control measures taken by the Company, please contact the inquiry desk listed in this Policy.

Article 9 (Disclosure, Correction, and Suspension of Use of Personal Information)

If a customer requests the disclosure, correction, addition, deletion, or suspension of use of their personal information, the Company will promptly respond in accordance with laws and regulations after confirming the identity of the requester.

Article 10 (Changes to the Privacy Policy)

The Company will review the contents of this Policy as appropriate and may change it as necessary. The revised policy shall become effective from the time it is posted on this website, within the extent permitted by law.

Article 11 (Inquiry Desk)

For complaints or other inquiries regarding this Policy, please contact the following:

Envalith Co., Ltd. XC Shibuya Shinsen Bldg., 20-21 Shinsen-cho, Shibuya-ku, Tokyo Representative: Koichi Kawai Personal Information Protection Officer Email: Contact@envalith.com

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Regarding External Transmission Services

The services provided by Envalith Co., Ltd. (hereinafter referred to as "the Company") utilize the following external services provided by third parties for the purpose of providing better services to customers. Accordingly, customer information may be transmitted from the customer's terminal to the providers of these external services.

Based on the provisions concerning external transmission regulations in the Telecommunications Business Act (Article 27-12 of the Telecommunications Business Act) and the terms of use for external transmission tools set by providers or advertising distributors, we hereby disclose the matters related to the use of external transmission tools.