Privacy Policy

Iron Networks, Inc. ("we," "us," or "the Company") establishes this Privacy Policy ("this Policy") governing the handling of personal information in connection with our file-sharing service, "FILE SHIPPER" ("the Service"), as set out below.

Article 1 (Name, Address, and Representative of the Personal Information Handling Business Operator)

The personal information handling business operator for the Service is as follows.

• Name: Iron Networks, Inc.
• Address: 4-16-24 Nishi-Gotanda, Shinagawa-ku, Tokyo, Japan
• Representative: Yuki Tsuda, Representative Director

Article 2 (Information We Collect)

1. In providing the Service, we collect the following personal information and usage-related information from users.
   • (1) Account registration information: email address, company name, department name, and contact person's name
   • (2) Inquiry and identity-verification information: inquiry content, contact details, and logs such as one-time codes required for authentication
   • (3) Usage and device information: IP address, device type, browser type/OS, access logs, and identifiers obtained via cookies and similar technologies
2. Company logo data and similar assets uploaded with the intent of public display are collected and used to display them on the Service at the user's direction.

Article 3 (Protection of File Data and "Secrecy of Communications")

We perform automated processing of User Data only for the following purposes.

• (1) Storing files, converting formats, and transmitting/transferring to the destination the user specifies
• (2) Automated virus scanning and malware detection to secure the safety of the Service and its recipients
• (3) Exceptional handling required by a legally binding compulsory measure (e.g., a warrant), or self-defense/emergency-necessity situations

Article 4 (Purposes of Using Personal Information)

We use the personal information collected under Article 2 (excluding User Data) for the following purposes.

1. To provide, operate, maintain, and troubleshoot the Service
2. To verify user identity, authenticate users, manage accounts, and calculate/bill usage fees
3. Statistical analysis for improving Service functionality, UI/UX, and developing new features (used only as processed information that cannot identify an individual)
4. To respond to user inquiries, provide support, and notify users of important announcements
5. To detect, investigate, and respond to conduct that violates the Service's Terms of Service (e.g., unauthorized access, excessive load, transmission of unlawful files)
6. For ad delivery and effectiveness measurement by third-party advertising providers on the Service (where ads are displayed, e.g. on the free plan)

Article 5 (Third-Party Provision, Outsourcing, and Cross-Border Transfer of Personal Information)

1. We will not provide personal information to third parties without the user's prior consent, except in the following cases.
   • (1) Where required by law
   • (2) Where necessary to protect a person's life, body, or property, and obtaining the individual's consent is difficult
   • (3) Where specially necessary for improving public health or promoting the sound development of children, and obtaining the individual's consent is difficult
   • (4) Where cooperation with a national or local government body, or a party entrusted by such a body, is necessary for it to perform duties prescribed by law, and obtaining the individual's consent would risk impeding the performance of those duties
2. To the extent necessary to achieve our purposes of use, we may outsource all or part of the handling of personal information to external parties. In such cases, we conduct a rigorous security review of the outsourced party and provide necessary and appropriate supervision.
3. For payment processing and infrastructure provision for paid plans, we provide/entrust part of a user's personal information to the following third parties (cloud and payment providers) located overseas. We have confirmed that these providers maintain appropriate security and personal-information protection frameworks (including measures corresponding to the eight principles of the OECD Privacy Guidelines).

   Provider	Country	Information Provided/Entrusted	Purpose of Use
   Stripe, Inc.	United States of America	Email address and identifiers required for payment (credit card numbers are managed directly by Stripe and never pass through us)	Payment and billing processing for paid plans

Article 6 (External Transmission and Use of Cookies, etc.)

The Service uses cookies and information-collection modules to provide the Service, analyze usage, and deliver advertising (e.g., on the free plan); access information is automatically transmitted from a user's device to third-party servers as a result. The following is disclosed pursuant to the external transmission disclosure rules under the Telecommunications Business Act.

The video and slides shown in the "marketing kit" on a download page are embeds from an external service chosen by the sender (YouTube, Vimeo, Speaker Deck, SlideShare, Docswell, Google Slides or Canva). They are loaded only when the recipient chooses to play or open them; until that point no request is made to those services at all, thumbnail images included.

Article 7 (Summary of Security Control Measures)

To prevent the leakage, loss, or damage of personal information we hold, we have implemented the following security control measures in accordance with the Act on the Protection of Personal Information.

• (1) Basic policy and rules: We have established internal rules and operational guidelines for the proper handling of personal information.
• (2) Organizational security measures: We have appointed a person responsible for personal information handling and established a reporting line to that person for any facts or signs of a violation of law or internal rules.
• (3) Personnel security measures: We conduct regular security training for employees on the protection of personal information and the secrecy of communications.
• (4) Physical and technical security measures: We enforce access controls to limit who may handle personal information and the scope of what they may access, and we have deployed encrypted communication channels (SSL/TLS), intrusion-prevention systems, and anti-virus software.

Article 8 (Requests for Disclosure, Correction, or Suspension of Use of Retained Personal Data)

1. In accordance with the Act on the Protection of Personal Information, users may request that we notify them of the purpose of use, disclose, correct/add to/delete, suspend the use of, erase, or stop the third-party provision of retained personal data concerning themselves ("Disclosure, etc.").
2. To request Disclosure, etc., please contact the inquiry desk set out in Article 11. After confirming that the request comes from the individual concerned (e.g., by confirming it was sent from the registered email address, or by requesting identity-verification documents), we will respond within a reasonable period without delay, as required by law.
3. We may charge a handling fee of ¥1,000 (excluding tax) per request for disclosure of personal information or notification of the purpose of use.

Article 9 (Disclaimer and Damages)

Our liability for damages arising from our handling of personal information in connection with the Service, or from a user's use of the Service, where such damages are attributable to us, shall be governed by Article 10 (Disclaimer and Damages) of the Service's Terms of Service.

Article 10 (Changes to This Privacy Policy)

1. We may change the contents of this Policy in response to changes in law, social circumstances, technological advances, and similar factors.
2. When we change this Policy, we will give advance notice of the effective date and content of the change by posting on the Service or by email or another appropriate method. However, where a material change requiring user consent under law (such as an expansion of the purposes of use) is made, we will obtain user consent by our prescribed method.

Article 11 (Inquiries and Complaints Desk)

Questions about this Policy, complaints regarding the handling of personal information, and requests for Disclosure, etc. under Article 8 should be directed to the desk below.