ENVALITH, INC. Terms of Use

These Terms of Use (hereinafter referred to as the "Terms") set forth the conditions of use for the services relating to the distribution of corporate research reports (hereinafter referred to as the "Reports") and the provision of corporate information, as well as the services related thereto (hereinafter referred to as the "Service"), provided by ENVALITH, INC. (hereinafter referred to as the "Company"). All users of the Service shall use the Service upon agreeing to these Terms, and at the time a user agrees to these Terms, a contract concerning the use of the Service in accordance with the provisions of these Terms (hereinafter referred to as the "Usage Contract") is established between the member and the Company.

The Company conducts exclusive research coverage operations with the objective of contributing to the development of the global and Japanese capital markets (hereinafter referred to as the "Purpose") by providing information necessary for domestic and international institutional investors, as well as domestic individual investors, when they consider investing in Japanese listed companies.

The Company performs these operations primarily through exclusive research coverage fees paid by the research subjects and sponsors. In light of the Purpose, the Company prepares the Reports and corporate information independently from the research subjects, based on the Company's own analysis of corporate information and the like, and, at its sole discretion, distributes and disseminates the Reports and provides corporate information. Furthermore, the Reports and corporate information are prepared in the name of the Company and as the Company's opinions. Users shall use the Service upon agreeing to these points.

Article 1 (Application)

These Terms apply to all relationships between the user and the Company regarding the use of the Service.
The "Privacy Policy," "Guidelines," and the like posted by the Company on the Service shall constitute a part of these Terms.

Article 2 (Definitions)

The terms used in these Terms are defined as follows:

"User": All individuals or corporations that use or browse the Service, regardless of whether they have registered as a member.
"Member": Users who have completed membership registration in accordance with the procedures in Article 3 and have been approved by the Company.
"Visitor": Users who use only the browsing functions without registering as a member.
"Content": Information provided on the Service, such as the Reports, corporate information, and summaries thereof, as well as text, images, graphs, audio (podcasts), video, data, and software.
"Member-Only Functions": Functions determined by the Company that are provided only to members, such as the AI agent function and the clip function.

Article 3 (Service Usage Categories and Member Registration)

1. Usage Categories

Visitors may browse the Reports and corporate information pages published on the Service free of charge.
Members may use, in addition to the functions available to Visitors, the member-only functions separately determined by the Company. The details of the member-only functions are set forth in the help page or guidelines on the Service; please refer to those contents.

A person who wishes to register as a member in order to use the member-only functions of the Service (hereinafter referred to as a "Registration Applicant") may apply to the Company for registration to use the Service by agreeing to comply with these Terms and providing certain information determined by the Company (hereinafter referred to as "Registration Information") via the method determined by the Company.
An application for registration must be made by the Registration Applicant themselves, and, as a general rule, applications by proxy are not permitted. In addition, a Registration Applicant must provide true, accurate, and up-to-date information to the Company when applying for registration.
The Company may refuse registration if a person who has applied for registration pursuant to Paragraph 2 falls under any of the following items: (1) Where the Company reasonably determines that there is a risk of violating these Terms;
(2) Where all or part of the Registration Information provided to the Company contains falsehoods, misstatements, or omissions;
(3) Where the person has previously had their registration for the Service canceled;
(4) Where the person is a minor, an adult ward, a person under curatorship, or a person under assistance, and has not obtained the consent, etc., of a legal representative, guardian, curator, or assistant;
(5) Where the Company reasonably determines that the person is an Anti-Social Force, etc. (meaning organized crime groups, members of organized crime groups, quasi-members of organized crime groups, persons for whom five years have not yet passed since they ceased to be a member or quasi-member of an organized crime group, companies affiliated with organized crime groups, corporate racketeers (sokaiya), groups engaging in criminal activities under the pretext of conducting social campaigns, special intelligence violence groups, and other groups or individuals that pursue economic benefit through the use of violence, force, or fraudulent methods; the same shall apply hereinafter), or that the person is engaged in any interaction with or involvement in Anti-Social Forces, etc., such as cooperating with or being involved in the maintenance, operation, or management of Anti-Social Forces, etc., through the provision of funds or otherwise;
(6) Any other case where the Company reasonably determines that registration is inappropriate.
The Company shall determine whether or not to approve the registration of the Registration Applicant in accordance with the preceding paragraph and other standards of the Company, and, if the Company approves the registration, it shall notify the Registration Applicant to that effect. Registration of the Registration Applicant as a member is completed upon such notification.
If there is any change to the Registration Information, the member shall notify the Company of such change without delay via the method determined by the Company, and shall submit any materials requested by the Company.

Article 4 (Nature of the Service and Disclaimers)

1. Purpose of Information

The Content is prepared solely for the purpose of providing information and does not constitute a solicitation to acquire, sell, or hold securities or other financial instruments. Nor does it constitute any specific investment, financial, or tax advice. No opinion, judgment, or recommendation contained in the Content is intended to induce investment activity, and investment decisions should be made based on the user's own responsibility and judgment.

2. Information Sources, Accuracy, and Disclaimer of Warranty

The Content is prepared based on formal requests from subject companies, using interviews with such companies, information provided by them, and securities reports as well as timely disclosure information. Users shall use the Service, including browsing the Reports, upon confirming and accepting the following points:

Information Sources: In preparing the Content, the Company judges publicly available information, information disclosed by subject companies, and information provided through interviews and the like to be reliable, and treats such information as fact (correct). The Company does not conduct its own independent factual confirmation or verification of the truthfulness of such information.
Accuracy: The interpretations and analyses of the provided information set forth in the Content, and the hypotheses and conclusions based thereon, are derived independently by the Company using its own unique perspective and analytical methods, based on information disclosed by subject companies and information provided through interviews and the like.
Disclaimer of Warranty: If there are any errors or omissions in the information disclosed by a subject company, the Company shall bear no responsibility whatsoever for any resulting errors in the content of the Content. The Company makes no warranty whatsoever, whether express or implied, as to the accuracy, safety, validity, completeness, or the like of the Content.

3. Limitation of Liability

The Company shall bear no responsibility whatsoever for any costs, damages, or losses (including direct, indirect, incidental, consequential, or punitive damages) arising from the use of the Content or information obtained from the Content. Users shall use the Content at their own responsibility.

4. Potential Conflicts of Interest

The Company may have, currently or in the future, investment banking operations, other financial services, or business relationships with the companies analyzed in the Content. Accordingly, investors should recognize that conflicts of interest may exist that could affect the objectivity of the Content.

5. Disclaimer of Any Obligation to Change or Update Content

The contents and opinions of the Content are as of the date of preparation and are subject to change without notice. The Company bears no obligation to update the contents of already-distributed Content to the latest information.

6. Language Priority

The Content is prepared in Japanese, English, Chinese, and other languages designated by the Company. In the event of any discrepancy or difference in interpretation among the versions in each language, the Japanese version shall be treated as the authentic text, and the contents of the Japanese version shall prevail.

7. Disclaimer Regarding AI Functions

Responses generated by the AI agent (such as the "Ask AI" function), which is a member-only function, are generated probabilistically using a large language model, and the Company does not guarantee their completeness, accuracy, or timeliness. Please refrain from acting solely in reliance on the AI's responses.

8. About the Company

The Company does not fall under the category of a "Financial Instruments Business Operator" or "Investment Advisory and Agency Business Operator" under the Financial Instruments and Exchange Act. This Service does not provide investment advice.

9. Copyright

All rights (including copyrights) relating to the Content belong to the Company. Users are permitted only to browse the Content and to perform other acts permitted under these Terms, and may not reproduce, redistribute, or otherwise use all or part of the Content without the prior written permission of the Company.

10. Use for Other Investment Products

Except where approved in advance in writing by the Company, the Content and the trademarks and trade names of the Company and the subject companies may not be used in connection with the information distribution, trading, sales promotion, or advertising of any investment product (an investment product whose price, return, or performance is based on or linked to the Content, such as financial derivatives, structured products, investment trusts, and investment assets).

Article 5 (User Obligations)

Users shall bear the following obligations when using the Service:

1. Principle of Self-Responsibility

Users shall bear all responsibility for all acts performed using the Service and the results thereof (including, but not limited to, damages arising as a result of investment decisions).

2. Guarantee of the Authenticity of Registration Information

Members guarantee that the information they provide to the Company upon membership registration and when using the Service (such as survey responses and questions to the AI) is true, accurate, and up-to-date. The Company shall bear no responsibility even where a member is unable to receive the appropriate provision of the Service as a result of having entered false or inaccurate information.

3. Responsibility for Account Management

Members shall strictly manage and safeguard, at their own responsibility, their own ID and password relating to the Service (hereinafter referred to as "Account Information"), and shall not allow any third party to use it, or lend, transfer, change the name on, or trade it. If the Company confirms that the Account Information matches, it shall deem the relevant use to be use by the member themselves. The member shall bear responsibility for any damage caused by inadequate management of the Account Information, errors in use, use by a third party, or the like.

4. Maintenance of the Usage Environment

Users shall, at their own responsibility and expense, arrange the communication equipment, software, communication lines, and other usage environment necessary to use the Service.

5. Proper Use of AI and Interactive Functions

When using the function for asking questions to the AI agent or the survey function, members bear the obligation to avoid inputting content that is contrary to public order and morals, repeatedly posting meaningless strings of characters, or making inputs that place an excessive burden on the Company's servers or AI models.

Article 6 (Acquisition and Use of Behavioral Data)

The Company acquires, accumulates, and analyzes the usage status of the Service by users (pages viewed, time spent, etc.) and the following specific behavioral data of members:
- Text selections and highlighted portions within the Reports (clip information)
- The content of questions to the AI agent and dialogue history
- The content of survey responses
The Company has the authority to monitor, delete, and edit, at its discretion, the usage status of the Service by users (such as content contrary to public order and morals or inappropriate questions and answers).
The Company may, after processing the data acquired under the preceding paragraph into statistical data that cannot identify individuals, use such data for the following purposes and provide it to third parties (such as report subject companies), and users agree thereto:
- Analysis of investor insights and feedback to companies (visualization of investors' interests and concerns)
- Quality improvement of the Service and the training and optimization of AI models
- Marketing and the development of new services

Article 7 (Handling of Personal Information)

1. Compliance with the Privacy Policy

The Company shall appropriately handle the personal information of users acquired through the use of the Service in accordance with the separately established "Privacy Policy."

Article 8 (Intellectual Property Rights, etc.)

Intellectual property rights relating to the Service (meaning copyrights, patent rights, utility model rights, trademark rights, design rights, know-how, and other intellectual property rights (including the right to acquire such rights or to apply for the registration and the like of such rights); the same shall apply hereinafter) all belong to the Company or to the legitimate right holders who have granted licenses to the Company.
Users may use the Service (browsing, saving clips, downloading PDFs, sharing) only within the scope of private use.
Users shall not perform the following acts without the prior written permission of the Company:
- Reproducing, reprinting, selling, publishing, publicly transmitting, distributing, or altering the Service
- Crawling or scraping the Service as data for AI training
- Disassembling, decompiling, or reverse engineering the Service, or otherwise analyzing the source code, structure, ideas, and the like of the Service

4. Rights to User-Posted Content

All intellectual property rights and all other rights relating to text, images, and any other information posted or otherwise transmitted by a user through questions to the AI agent, survey responses, or other methods on the Service (hereinafter referred to as "User-Posted Content") are reserved by the user who posted or otherwise transmitted such User-Posted Content.
Users grant to the Company a royalty-free, non-exclusive, perpetual, irrevocable, and sublicensable right to use the User-Posted Content within the scope necessary for the provision, operation, improvement, and promotion of the Service and the Company's business activities (including, but not limited to, display and reproduction within the Service, the provision of feedback to report-subject companies and the like, use for the training and optimization of AI models, and the planning, development, and provision of new services by the Company).
Users shall not exercise moral rights of authorship regarding the User-Posted Content against the Company or any third party licensed by the Company.

Article 9 (Prohibited Matters)

Users must not perform any of the acts listed in the following items when using the Service. If the Company reasonably determines that an act of transmitting information by a member on the Service falls under, or is likely to fall under, any of the following items, the Company may, without prior notice to the member, take measures such as deleting or suspending the transmission of all or part of the relevant information. The Company shall bear no responsibility whatsoever for any damage incurred by a member as a result of measures taken by the Company pursuant to the preceding sentence, except in cases of the Company's willful misconduct or gross negligence.

Acts that violate laws and regulations or public order and morals
Acts that infringe the intellectual property rights, portrait rights, privacy, honor, or other rights of the Company, other users, or third parties
Acts that destroy or interfere with the functions of the Service's servers or networks
Acts of intentionally inputting false information into the AI functions in an attempt to have them learn it
Acts of inputting into the AI functions personal information, confidential information, or material non-public facts that may fall under insider trading regulations
Acts of improperly manipulating or obtaining achievements (meaning badges, ranks, and the like granted to a user in response to that user's actions within the Service)
Acts of directly or indirectly providing benefits to Anti-Social Forces
Any other act that the Company determines to be inappropriate

Article 10 (Withdrawal)

1. Withdrawal Procedure

A member may withdraw from the Service (delete their membership registration) at any time by completing the procedures prescribed by the Company.

2. Loss of Membership and Data

Simultaneously with the completion of withdrawal, the member loses their membership, and the member-only functions (AI agent, clip list, my page, etc.) immediately become unavailable. In addition, with respect to data such as clip information, bookmarks, and AI dialogue history saved by the member on the Service, upon withdrawal the user's personal information is deleted and the behavioral data is anonymized, and such data can no longer be viewed or restored.

3. Use of Data After Withdrawal

The Company shall handle user information after a member's withdrawal as follows:

Personal Information: In accordance with the separately established Privacy Policy and applicable laws and regulations such as the GDPR, the Company shall, within an appropriate period, delete it or anonymize it into a state where individuals cannot be identified.
Behavioral Data (Insights): With respect to data such as clip information, survey responses, and the content of questions to the AI generated by the member during the usage period, the Company may continue to hold and use it (including provision to companies) as statistical data that cannot identify individuals or as anonymously processed information.

4. Survival of Debts

If, at the time of withdrawal, a member owes any debt to the Company, the member shall continue to bear responsibility for the performance of such debt even after withdrawal.

Article 11 (Discretion Regarding Report Publication and Coverage)

1. Decisions on Publication and Coverage

The Company may, at its discretion and judgment and in a manner that complies with the separately established "Sponsored Research Policy," determine the selection of subject companies on the Service (the commencement, continuation, and termination of coverage) and the publication or non-publication of Reports.

2. Suspension of Publication, etc.

The Company may, without prior notice to users, temporarily suspend or delete the publication of Reports concerning a specific company if the Company reasonably determines that any of the following applies:

Where the contract with the subject company has terminated, or grounds for termination under the Sponsored Research Policy have arisen
Where there is a possibility that the content of the Report contains a misperception of fact, a violation of laws and regulations, or other inappropriate content
Where the Company otherwise reasonably determines, from an operational standpoint, that continued publication is inappropriate

3. Disclaimer

The Company shall bear no responsibility for any damage arising from a user's inability to view the relevant information due to the suspension or deletion of the publication of a Report, or the termination of coverage, pursuant to the preceding paragraph.

Article 12 (Change, Interruption, and Termination of the Service)

1. Change of Service Content

The Company may, without prior notice to users, change, add to, or abolish all or part of the content, functions, or specifications of the Service.

2. Suspension of Publication, etc.

Where the contract with the subject company has terminated, or grounds for termination under the Sponsored Research Policy have arisen
Where there is a possibility that the content of the Report contains a misperception of fact, a violation of laws and regulations, or other inappropriate content
Where the Company otherwise reasonably determines, from an operational standpoint, that continued publication is inappropriate

3. Disclaimer

4. Disclaimer

The Company shall bear no responsibility for any damage incurred by users as a result of measures taken by the Company pursuant to this Article.

Article 13 (Usage Restrictions and Deregistration)

1. Usage Restrictions and Deregistration

The Company may, without prior notice or demand, restrict a user's use of all or part of the Service, or temporarily suspend or delete (cancel) a user's user ID (membership), if the Company reasonably determines that the user falls under any of the following:

Where the user has violated any provision of these Terms
Where it is found that there is a false fact in the registration items
Where there has been no response to communications from the Company for six months
Where there has been no use of the Service for six months since the last use
Where the user falls under any item of Article 3, Paragraph 4
Where the user has died
Where the user has interfered with the operation of the Service by any means whatsoever
Any other case where the Company reasonably determines that use of the Service is inappropriate

2. Disclaimer

The Company shall bear no responsibility for any damage incurred by a user as a result of any act performed by the Company pursuant to this Article.

Article 14 (User Liability for Compensation, etc.)

If a user causes damage to the Company by violating these Terms (including a breach of the representations and warranties under Article 5, Paragraph 2) or in connection with the use of the Service, the user must compensate the Company for such damage.
If a user receives a claim from another user or a third party, or a dispute arises with such person, in connection with the Service, the user shall immediately notify the Company of the details thereof, handle such claim or dispute at the user's own expense and responsibility, and report the progress and results thereof to the Company at the Company's request.
If, in connection with a user's use of the Service, the Company receives any claim from another user or a third party on the grounds of infringement of rights or for any other reason, the user must compensate the Company for the amount that the Company is compelled to pay to such third party based on such claim.

Article 15 (Confidentiality)

In these Terms, "Confidential Information" means all information relating to the Company's technology, sales, operations, finances, organization, and other matters that a user is provided or disclosed by the Company in writing, orally, or via recording media and the like, or otherwise comes to know, in connection with the Usage Contract or the Service. However, the following shall be excluded from Confidential Information: (1) information that was already publicly known, or was already known to the user, at the time it was provided or disclosed by, or learned from, the Company; (2) information that became publicly known through publications or otherwise, due to reasons not attributable to the user, after being provided or disclosed by, or learned from, the Company; (3) information lawfully obtained from a third party with the authority to provide or disclose it, without being subject to a confidentiality obligation; (4) information independently developed without relying on Confidential Information; and (5) information confirmed in writing by the Company as not requiring confidentiality.
Users shall use Confidential Information only for the purpose of using the Service, and shall not provide, disclose, or leak the Company's Confidential Information to any third party without the written consent of the Company.
Notwithstanding the provisions of Paragraph 2, a user may disclose Confidential Information based on an order, demand, or request of a law, court, or governmental agency. However, in the event of such an order, demand, or request, the user must promptly notify the Company to that effect.
When reproducing documents, magnetic recording media, or the like containing Confidential Information, a user shall obtain the prior written consent of the Company, and shall strictly manage the reproductions in accordance with Paragraph 2.
A user shall, whenever requested by the Company, without delay and in accordance with the Company's instructions, return or dispose of the Confidential Information and all documents and other recording media that describe or contain the Confidential Information, as well as all reproductions thereof.

Article 16 (Effective Term)

The Usage Contract shall take effect on the date the user agrees to these Terms and shall remain validly in effect between the Company and the user: in the case of a user who is a member, until the earlier of the date on which the member's registration is canceled or the date on which the provision of the Service ends; and in the case of a user who is a Visitor, until the date on which the provision of the Service ends.

Article 17 (Changes to These Terms, etc.)

The Company may change these Terms (including the rules, various provisions, and the like relating to the Service that are posted on the Company's website; the same shall apply hereinafter in this Article). When the Company changes these Terms, it shall, by the time the change takes effect, announce the content of the change and the time at which the change takes effect via a method prescribed by the Company. Where such change requires the consent of members under laws and regulations, the Company shall obtain the consent of registered users via a method prescribed by the Company.

Article 18 (Assignment of These Terms, etc.)

A user may not, without the prior written consent of the Company, assign, transfer, provide as security, or otherwise dispose of, to a third party, its status under the Usage Contract or its rights or obligations under these Terms.
In the event that the Company transfers the business relating to the Service to a third party (regardless of the form, whether by business transfer, company split, or otherwise), the Company may, in connection with such transfer, assign its status under the Usage Contract, its rights and obligations under these Terms, and members' Registration Information and other customer information to the transferee of such transfer, and users shall be deemed to have agreed in advance in this paragraph to such assignment.

Article 19 (Entire Agreement)

These Terms constitute the entire agreement between the Company and users regarding the matters contained in these Terms, and supersede any prior agreements, representations, and understandings between the Company and users regarding the matters contained in these Terms, whether made in writing, orally, or by any other means.

Article 20 (Severability)

Even if any provision of these Terms or any part thereof is determined to be invalid or unenforceable under the Consumer Contract Act or other laws and regulations, the remaining provisions of these Terms and the remaining part of the provision determined to be invalid or unenforceable in part shall continue in full force and effect, and the Company and users shall endeavor to modify the invalid or unenforceable provision or part to the extent necessary to make it lawful and enforceable, and to ensure the intent of the invalid or unenforceable provision or part and legally and economically equivalent effect.

Article 21 (Surviving Provisions)

The provisions of Article 4, Article 5, Paragraphs 2 and 3, Article 6, Article 8, Article 10, Paragraphs 2 through 4, Article 11, Paragraph 3, Article 12, Paragraphs 3 through 4, Article 13, Paragraph 2, Article 14, Article 15, and Articles 17 through 23 shall remain validly in effect even after the termination of the Usage Contract. However, Article 15 shall survive only for three years after the termination of the Usage Contract.

Article 22 (Governing Law)

The validity, interpretation, and performance of these Terms shall be governed by the laws of Japan and interpreted in accordance with the laws of Japan.

Article 23 (Agreed Jurisdiction)

The Tokyo District Court shall be the exclusive court of first instance by agreement for any and all disputes arising out of or in connection with the Service or these Terms.

Enacted: December 29, 2025
Revised: July 21, 2026