PRIVACY POLICY FOR USERS RESIDING IN THE EUROPEAN ECONOMIC AREA (EEA) and the UK

BookLive Co., Ltd. (the “Company” or “we”) recognizes the importance of protecting Personal Information and strives to handle properly the Personal Information provided by you, the users residing in the European Economic Area (EEA) and the UK. We are committed to protecting your privacy in compliance with the General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 and related laws and regulations (“Laws”).

Before using our website and receiving services from the Company, please read this Privacy Policy carefully.

Xfolio is a platform that connects creators with users who support them.

“Personal Information” means any information that can be used to identify a customer as a specific individual, including address, name, telephone number, and any other information that falls under the definition of “Personal Data” in Article 4 of the GDPR.

1. Personal Information we collect

The Company the following Person Information:

For Users

Obtained directly from Users:

• Nickname
• Date of Birth
• Email Address
• Password
• Purchase History
• Subscribed Fan Communities
• Follow List
• Favorites List
• A record of which works you clicked the “Like” button.
• Views per work
• Comments on works and fan communities
• IP Address
• Cookie

Name/Address/Phone Number (delivery address, Only for mail-order purchases)

Issued by Xfolio:

• User ID
• User Identification Code

For creators

Obtained from Users:

• Creator ID
• Portfolio Name
• Posted Information
• Bank Account Information
• Name/Address/Phone Number (shipment origin)

Issued by Xfolio:

• Internal Code
• Internal Creator ID

2. Purpose of Use of Personal Information We Collect

The Company will collect Personal Information from you mainly in the following cases. The purposes of our use of the Personal Information we collect and the legitimate basis for the use are as follows:

• To process your registration for a service and provide you with the service (Performance of a contract)
• To process your application for a prize, gift, contest, or similar event, to notify you if you are a winner or entitled to receive a prize, and to deliver the prize, goods, or similar item to you, or to give you the prize money (Performance of a contract)
• To process your application for participation in an interview survey, to request your participation in said survey, and to provide you with a reward or similar compensation (Performance of a contract)
• To confirm your order for goods or a fee-based service, to confirm your payment, and to deliver the goods to you (Performance of a contract)
• In cases where you use a certain service jointly provided by the Company and one of our business partners, to provide your user information to the said partner only to the extent minimally required for the provision of the service to you (Performance of a contract)
• To process your application for employment, to decide whether to hire you, or to notify you of a career seminar or similar event (Legitimate interests)
• To recommend goods or services, or to provide you with other information about new goods, services, or similar items based on your user history (Legitimate interests)
• To conduct market research, planning, or research and development (Legitimate interests)
• To develop new goods, services, or similar items (Legitimate interests)
• To improve your experience on our website by personalizing advertisements and content shown to you on our website or any of our services (Legitimate interests)
• To provide you with a service based on your visit, shopping, browsing, and shopping behavior history, or location information, and to understand and analyze your usage patterns (Legitimate interests)
• To aggregate Personal Information and create statistical materials that cannot identify any specific individual, to conduct marketing, to develop new goods or services, and to improve the quality of our services based on this material (Legitimate interests)

3. Sharing of Personal Information with third parties

The Company may share your Personal Information with third parties, in the following situations:

With Service providers:The Company may engage third parties such as marketing companies and IT service providers to facilitate specific services. In such cases, your Personal Information may be shared as necessary for the provision of those services. Any shared Personal Information will be used strictly in accordance with the Company's instructions and for the purposes stated.

Credit card company:We have implemented measures to prevent fraudulent use of credit card transactions. As part of these measures, we provide personal information collected from customers to their credit card issuers so that they can detect and prevent fraudulent use. For details, please refer to the terms of use, etc., which are clearly stated at the time personal information is collected for each service and website. If the card issuer you are using is located in a foreign country, this information may be transferred to the country to which the issuer belongs. Since we cannot identify the card issuing company you use or the country or region where the company is located from the information we collect from you, we cannot provide you with information about card issuing companies located in foreign countries. The website of the Personal Information Protection Commission (https://www.ppc.go.jp/) provides information on personal information protection systems in various countries.

Based on Legal obligations:In compliance with applicable laws, the Company may disclose your Personal Information to public authorities responsible for law enforcement, pursuant to legal obligations, court orders, or governmental requests (including those related to national security or law enforcement measures). This may also include disclosures required by authorities or courts in jurisdictions where the Company operates.

4. Storage of Personal Information

As a Japan based company, we will securely process your personal data in Japan. On January 23, 2019 the European Commission has adopted an adequacy decision on Japan, allowing personal data to flow freely between the two economies on the basis of strong protection guarantees. We will retain your personal data for the period required to fulfill the purpose mentioned above. The specific retention period will be determined by taking into account the purpose for which the personal data is acquired and processed, the nature of the personal data, and the legal or business necessity for retaining the personal data. Once this time period has expired, we will promptly delete personal data from our storage media.

5. Precaution Notice

Our company-operated website on the Internet may include external links. Please be aware that the Company does not assume responsibility for the handling of your Personal Information on these external websites. Additionally, third parties other than the Company may independently collect your Personal Information through advertisements placed on our products, such as a magazine published by the Company. In such cases, we also do not assume responsibility for the handling of your Personal Information.

6. Specific rights of the data subjects

You are entitled to the following data protection rights:
The right to access ‒You have the right to request the Company for copies of your personal data.
The right to rectification ‒You have the right to request the Company to correct any information Data they believe to be inaccurate. You also have the right to request the Company to complete the information they believe to be incomplete.
The right to erasure ‒You have the right to request the Company to erase your personal data, under certain conditions.
The right to restrict processing ‒You have the right to request the Company to restrict the processing of you personal data, under certain conditions.
The right to object to processing ‒You have the right to object the Company to process your Personal Data, under certain conditions. In particular, where you have provided Personal Data voluntarily, or otherwise consented to its use, you have the right to withdraw your consent.
The right to data portability ‒You have the right to request the Company to transfer the data that the Company has collected to another organization, or directly to you, under certain conditions.
If you make a request based on the above, the Company has one month to respond. If you who would like to exercise any of these rights, you can contact the Company, by using the contact form available under the following contact details:

7. Contact for Inquiries

If you have any questions about the company’s Privacy Policy, the Personal Data held by the Company about you, or if you would like to exercise your data protection rights, you can contact the Company using following contact details:

You also have the right to contact the appropriate supervisory authority if you wish to report a complaint or if you feel that the Company has not addressed your concern satisfactorily.

8. Handling of Personal Data for users under 16 years old

If you are under the age of 16, please note that the Company will require the consent of your parent or guardian before collecting your Personal Data, where necessary.

9. Policy regarding use of Cookies

The Company uses information collection modules provided by third-party companies to analyze browsing behavior on our web pages and to measure and improve the effectiveness of advertisements, among other purposes. Cookies and similar technologies are utilized for these purposes. The specific module names, providers, and purposes of use are as follows. Please note that the information collected, recorded, and analyzed by the following information collection modules does not include any information that can identify individual customers.

10. Amendments to Privacy Policy

The Company may revise the details of this privacy Privacy policy if necessary. Any changes made to this Privacy policy will be published on the Company’s website and / or otherwise communicated to the users.

Effective Date: November 28, 2024
Amendment Date: March 17,2025
Amendment Date: may 7,2025

BookLive Co., Ltd.
Representative: Tadashi Awano
Address:11F, Mita First Building, 4-2-8 Shibaura, Minato-ku, Tokyo 108-0023
https://www.booklive.co.jp/en/company