Compass Corp. (“the Company”) handles all personal information in accordance with the Personal Information Protection Act of Japan and other relevant laws. The Company protects the rights of data subjects and manages personal information safely and appropriately.

1. Definition of Personal Information
“Personal Information” refers to information defined under the Personal Information Protection Act.

2. Purpose of Use
The Company collects personal information such as names, addresses, phone numbers, email addresses, and device information. Data may be received directly, online, verbally, or from business partners.
 Personal Information is used for the following:
(1) When collected directly (including through websites or email)

• To provide and manage services.
• To send important notifications, billing information, product shipments, and aftersales support.
• To manage memberships and authenticate users.
• For marketing activities, surveys, campaigns, and service development.
• For contract execution, customer support, and business communications.
• For event guidance, recordings, PR activities, and publication on websites or promotional materials.
• For employment screening and HR-related communication.

(2) When collected indirectly or through non-written methods

• Call logs / online meetings / online events: confirmation, archiving, and provision of event materials.
• Credit card information: payment processing and fraud prevention.
• Photos & videos: event participation gifts and promotional purposes.

(3) Personal Information received from business partners

• To perform outsourced tasks (data processing, document preparation, shipping, etc.).
 (Such information cannot be disclosed by the Company.)

3. Outsourcing
The Company may entrust personal information to subcontractors as necessary, with appropriate supervision and contractual obligations to ensure proper handling.

4. Provision to Third Parties
Personal Information will not be disclosed to third parties except:

• When consent is obtained.
• When required by law.
• When necessary to protect life, body, or property.
• For public health or child development needs.
• When cooperating with government agencies.
• For cashless payments, where card information may be transferred overseas depending on the issuing company.

5. Joint Use
Personal Information may be jointly used with the Company’s group companies and affiliates.

• Shared data: customer details, contact information, purchase history, membership information.
• Purpose of use: the same as listed in Section 2.
• Management responsibility: Takahisa Hisayama, General Manager, Corporate Division, Compass Corp.

6. Public Notice Regarding Retained Personal Data
Company Information
Compass Corp.
 Ginza Kobiki Building 3F, 7-16-21 Ginza, Chuo-ku, Tokyo 104-0061
 Representative Director: Fumito Sasaki
Personal Information Manager
Executive Officer & CFO: Takahisa Kuyama
 TEL: 03-5801-5891
Purpose of retained personal data
Same as Section 2.
Certified protection organizations
The Company does not belong to any certified personal information protection organization.

7. Security Measures
The Company takes necessary measures to protect personal information, including:

• Establishing internal handling policies.
• Assigning a Personal Information Protection Manager.
• Conducting employee training.
• Implementing physical and technical access controls.
• Supervising subcontractors.
• Requesting parental consent for users under 16.

8. Disclosure, Correction, or Deletion of Personal Information
Requests for disclosure, correction, suspension of use, or deletion are handled in accordance with the Company’s procedures.

• A fee of 2,000 yen per request applies (plus postage).
• Identity verification (ID documents) is required; agents must provide authorization documents.

For cashless payments, the Company cannot identify foreign card issuers; therefore, certain disclosure items (such as the country’s privacy system) cannot be provided.
Contact Information
Corporate Headquarters, Compass Corp.
 Ginza Kobiki Building 3F, 7-16-21 Ginza, Chuo-ku, Tokyo 104-0061
 TEL: 03-5801-5894
 Email: info@compasscorp.jp

9. Cookies
The Company uses cookies to analyze website usage and improve services.
 Cookies do not contain personally identifiable information.
 Users may disable cookies, but some features may not function properly.

10. Changes to the Privacy Policy
This Policy may be updated without prior notice. Revisions apply from the date of publication.

Effective: December 20, 2022
Revised: March 21, 2024
Revised: April 1, 2024
Revised: April 1, 2025
Revised: December 1, 2025