Synesthesias Inc. (hereinafter referred to as "the Company") has established the following privacy policy (hereinafter referred to as "the Policy") with respect to users' personal information. (hereinafter referred to as "the Company") has established the following privacy policy (hereinafter referred to as "the Policy") regarding users' personal information. This Policy explains what kind of personal information we collect, how we use and share it, and how users can manage their own personal information. The "Service" in this policy refers to ConstructTwin, a service operated by the Company.

Corporate Name: Synesthesias Inc.

Address: 3F Jacom Building, 1-12-10 Kita-Shinagawa, Shinagawa-ku, Tokyo

Representative: Akihiro Aritoshi, President and Representative Director

When a user registers to use the service, we will obtain personally identifiable information such as name, address, telephone number, and e-mail address.

When you submit an inquiry form or comment, we will collect your name, e-mail address, and other personally identifiable information.

Personal information will be used for the following purposes and will not be used for any other purposes.

1. Examination of contracts for use and registration of this service.

2. To authenticate users and provide various services for users.

3. Billing and settlement of usage fees for the Service.

4. To send various communications and notices in connection with the use of the Service.

5. Temporary backup storage for the operation of the Service.

6. To respond to opinions and inquiries regarding the Service.

7. To conduct statistical research to improve the Service.

8. To prevent and detect fraud.

9. To comply with legal obligations.

10. To distribute advertisements, offers, and other information regarding our products and services.

The Company endeavors to keep personal data accurate and up-to-date, and to implement appropriate security measures to protect it from unauthorized access, alteration, leakage, loss, or damage. Personal information is stored in a secure environment that is inaccessible to general users.

The Company will jointly use personal data within the scope of the purposes of use stipulated in Article 3 as follows

- Company with which personal data will be jointly used

AMELA Technology Joint Stock Company

Address 5F, Building A, Keangnam Tower, E6 Cau Giay, Pham Hung, Me Tri, Nam Tu Liem, Ha Noi, Vietnam

CEO: Duong Minh Khoa

- Security Measures

The company is ISO 27001:2013 Information Security Management System certified. In addition, the company has implemented measures to protect personal information in compliance with the OECD Privacy 8 Principles.

- Purposes of Use by Joint Users

Same as "Purposes of Use" above.

- Items to be used

Personal information such as name, address, telephone number, e-mail address, etc.

- Information on personal information protection in Vietnam

https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_vietnam/

In principle, we will not provide personal data to third parties without the consent of the customer. We will provide such information only after specifying the recipient and the content of the information to be provided and obtaining the consent of the customer. However, in the following cases, personal data may be provided without the consent of the customer to the extent that it does not violate related laws and regulations.

1. When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the customer's consent is likely to impede the execution of those affairs.

2. When disclosure of personal information is requested by a court of law, public prosecutor's office, police department, bar association, consumer affairs center, or any other organization with equivalent authority.

3. When the customer himself/herself explicitly requests disclosure or provision of personal information to a third party

4. When disclosure or provision is permitted by law

5. When we outsource part or all of the operations handling personal information within the scope necessary to achieve the purpose of use

6. Cases in which personal information is provided in connection with the succession of business due to merger or other reasons, and is handled within the scope of the purposes of use before the succession.

1. Users' information will be stored on the cloud services of Amazon Web Services, Inc. (hereinafter referred to as "AWS"). User information may also be transferred outside Japan via AWS's cloud services. For details, please refer to AWS's regulations.

2. User information may be transferred to AMELA Technology Joint Stock Company for the development and operation of the service. AMELA Technology Joint Stock Company has acquired ISO 27001:2013 certification for its information security management system.

AMELA Technology Joint Stock Company shall not be liable for any personal information obtained by a third party if any information that can identify an individual customer (ID, password, etc.) is obtained by a person other than the customer himself/herself.

Whenever the Company is requested by a customer to disclose his/her personal information, the Company shall disclose such information. Those who wish to be notified of the purpose of use of their personal information, or to request correction, addition, deletion, suspension of use, or suspension of provision to a third party of their personal information should send a written request to the following address by postal mail. We will respond to your request within two weeks after confirming your identity in accordance with our prescribed procedures.

Address

Jacom Building 3F, 1-12-10 Kitashinagawa, Shinagawa-ku, Tokyo 140-0001, Japan SynesthesiasCorporation ConstructTwin Privacy Policy Contact

However, we may not respond in the following cases

1. When there is a risk of harm to the life, body, property, or other rights or interests of the user or a third party

2. If there is a risk of significant hindrance to the proper implementation of this service

3. When it would violate other laws and regulations.

4. In addition, in cases where the suspension of use or provision to a third party of the relevant personal information (hereinafter referred to as "suspension of use, etc.") requires a large amount of money, or in other cases where it is difficult to suspend use, etc., and alternative measures necessary to protect the rights and interests of the user are taken, the Company may not comply with the suspension of use, etc. Article 10.

We will make every effort to accurately process the personal information provided by you. However, the customer is responsible for ensuring that the personal information provided is accurate and up-to-date.

If you have any questions, concerns, complaints, or other inquiries regarding our handling of personal information, please contact us using the Contact Us form, or send a written letter by postal mail to the address stated in Article 9.

We reserve the right to change this policy at any time, except as otherwise provided by law.

This Policy shall be written in Japanese. Even if an English translation of this Policy is prepared for reference purposes, only the Japanese original shall be effective as a contract, and the English translation shall have no force or effect whatsoever.

Enacted: May 1, 2023