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Nagori Soft Privacy Policy

Version 1.0 Language: English (Authoritative Version) Established and Effective Date: September 1, 2026 Operator: Nagori Soft

1. Scope and Definitions

  1. This Privacy Policy (the “Policy”) describes how information relating to users is handled in software, websites, web services, APIs, official download services, and other products or services provided under the Nagori Soft name that expressly state that this Policy applies to them (collectively, the “Services”).
  1. “Operator” means the individual, company, or other entity that provides the applicable Service under the Nagori Soft name and is legally responsible for the handling of User Information in connection with that Service.
  1. “User” or “you” means an individual who uses a Service.
  1. In this Policy, “User Information” is a convenient collective term for personal information, personal data, information relating to individuals, online identifiers, device information, network information, and other information handled in connection with a User or use of a Service. This definition does not alter, expand, or narrow the meaning of “personal information,” “personal data,” or any other legally defined term under applicable law.
  1. Specific handling of User Information for each Service is described in this Policy together with applicable “Product-Specific Privacy Information” or an equivalent notice (“Product-Specific Information”).
  1. This Policy is intended to explain how User Information is handled. Merely reviewing this Policy or using a Service does not constitute blanket consent to any processing for which separate consent is required under applicable law.

2. Basic Principles

  1. Nagori Soft seeks not to collect or retain User Information beyond what is necessary for providing and legitimately operating the Services.
  1. Where technically and reasonably practicable and compatible with the functionality and secure operation of a Service, Nagori Soft gives preference to designs that process User Information on the User’s device or in storage controlled by the User rather than requiring centralized processing by the Operator.
  1. Nagori Soft does not sell User Information to third parties as a “sale” or equivalent transaction under applicable privacy law.
  1. Nagori Soft does not share or disclose User Information to third parties for cross-context behavioral advertising or similar third-party behavioral or targeted advertising.
  1. Nagori Soft seeks to ensure that the descriptions in this Policy and applicable Product-Specific Information accurately reflect the actual data-processing behavior of the Services.

3. Product-Specific Privacy Information

  1. Product-Specific Information will be provided for individual Services where appropriate.
  1. Depending on the nature of the applicable Service and applicable law, Product-Specific Information will describe:

(a) categories of User Information handled;

(b) methods and sources through which User Information is obtained or processed;

(c) purposes of processing;

(d) whether User Information is processed on a device, between devices, on systems operated by the Operator, or through third-party services;

(e) third-party services, processors, or other recipients;

(f) storage locations and retention periods or criteria used to determine them;

(g) applicable legal bases for processing, where required;

(h) whether providing User Information is required by law or contract, or is necessary to use the Service, and the main consequences of not providing it;

(i) where automated decision-making or profiling produces legal or similarly significant effects, an overview of such processing and its effects on Users;

(j) settings, deletion options, withdrawal of consent, and other controls available to Users;

(k) where international transfers occur, an overview of such transfers and, where required, applicable safeguards;

(l) contact details for a data protection officer, representative in the European Union, or other representative where appointment or disclosure is required by law; and

(m) other information reasonably necessary to understand the handling of User Information in the applicable Service.

  1. This Policy and applicable Product-Specific Information together constitute the privacy information applicable to a Service.
  1. Product-Specific Information supplements this Policy and provides more specific information about processing unique to the applicable Service. Where the descriptions differ, the more specific Product-Specific Information controls with respect to that particular processing.
  1. Notwithstanding the foregoing, Product-Specific Information will not implicitly reduce the common privacy protections established by this Policy to the detriment of Users. A material change to a common principle will be made by revising this Policy in accordance with Section 18.

4. Categories of User Information That May Be Handled

  1. Depending on the Service and how it is used, the following categories of User Information may be handled. This list does not mean that every Service collects or transmits all such information to the Operator. Information actually handled by each Service will be described in applicable Product-Specific Information or another applicable notice.
  1. Information entered, created, or selected by Users

Text, messages, tasks, schedules, files, images, audio, settings, display names, and other information entered, stored, created, or selected by Users.

  1. Account and contact information

Where a Service provides account or contact functionality, this may include display names, email addresses, account identifiers, and other information necessary for that functionality.

  1. Device and network information

IP addresses, port numbers, device information, operating-system information, application Version, browser information, connection information, technical information associated with HTTP requests, and other technical information required for communication or operation of a Service.

  1. Settings and usage-state information

Service settings, license-acceptance status, language settings, feature status, and other information required for operation of the Service.

  1. Nagori Soft Contribution information

Where a User makes a Nagori Soft Contribution, Nagori Soft may handle a Contribution Code, information necessary for confirmation or verification, a signed Receipt, registration status, timestamps, the Contribution amount and currency, payment status, transaction identifiers, and other information necessary to receive and confirm the Contribution, respond to inquiries, and operate Contribution Codes. Where a third-party payment provider processes the payment, the information actually received by Nagori Soft depends on that provider’s operation and the information presented at the time of Contribution.

  1. Inquiry and support information

Where a User contacts the Operator regarding support, bug reports, vulnerability reports, or other matters, this may include a name or display name, email address, message content, attachments, and other information provided by the User.

  1. Diagnostic and technical information

If a Service collects or transmits crash reports, error logs, diagnostics, usage statistics, or other technical information, the specific information, destination, and purpose will be described in applicable Product-Specific Information or another applicable notice.

  1. Cookies and similar technologies

Where a web-based or other Service uses cookies, local storage, or similar technologies, their purposes and any required choices or controls will be described in Product-Specific Information or another applicable notice.

  1. Where information treated as sensitive information or a special category of personal data under applicable law is processed, additional protections appropriate to the nature of that information will be applied, including consent where required by law.

5. Information Processed on Devices or Between Devices

  1. Where a Service processes User Information only on a User’s device and does not transmit that information to the Operator, the information does not become information collected or held by the Operator merely because the Service processes it.
  1. Where a Service transmits information directly between a User’s devices or between Users of the Service, the Operator may not receive, store, or view the content of those communications.
  1. Even in the circumstances described above, third-party network or other services may be used to establish communications and may process IP addresses or other technical information. Where applicable, this will be explained to a reasonably necessary extent in Product-Specific Information.

6. Purposes of Processing

Where the Operator collects or otherwise processes User Information, it will be used for the specific purposes described in applicable Product-Specific Information or another applicable notice and primarily for the following purposes:

  1. To provide the Services and perform functionality requested by Users.
  1. To store, verify, or synchronize settings, Contribution status, or other Service state.
  1. To receive and confirm Contributions, issue, verify, or revoke Contribution Codes, and handle related inquiries, refunds, or other transaction matters.
  1. To maintain the security, stability, and proper operation of the Services.
  1. To investigate, diagnose, and correct failures, bugs, or security issues.
  1. To respond to inquiries, requests, reports, and other communications from Users.
  1. To prevent, detect, or investigate abuse, security threats, or other activity harmful to the Services or Users.
  1. To comply with applicable legal obligations.
  1. For other purposes disclosed to the User when the information is collected or before the relevant processing begins.

7. Legal Bases for Processing

  1. Where applicable law requires identification of a legal basis for processing, the Operator will process User Information on one or more of the following bases, or another basis permitted by applicable law, depending on the nature of the processing:

(a) the User’s consent;

(b) performance of a contract with the User or steps taken at the User’s request before entering into a contract;

(c) compliance with a legal obligation to which the Operator is subject;

(d) protection of the vital interests of an individual;

(e) performance of a task in the public interest or exercise of official authority, where applicable; or

(f) legitimate interests, including secure provision of the Services, prevention of abuse, troubleshooting, and service improvement, except where the User’s rights and interests override those interests.

  1. Where appropriate, the specific legal basis applicable to particular processing will be described in Product-Specific Information or a notice presented at the time of collection.
  1. Where processing is based on consent, the User may withdraw that consent prospectively in accordance with applicable law. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

8. Third-Party Services and Processors

  1. The Services may use third-party services for operating systems, app stores, cloud storage, network communications, web delivery, file delivery, authentication, payments, crash analysis, or other functionality.
  1. Where the Operator engages a third party to process User Information on its behalf, the Operator will take contractual, selection, supervisory, and other measures required by applicable law.
  1. Where a third party independently collects or processes User Information, that processing may be governed by the third party’s own privacy policy and other terms.
  1. Major third-party services used by a Service and User Information transmitted to them will be identified in Product-Specific Information or another applicable notice where appropriate.
  1. External services such as cloud-storage or VPN providers that Users choose to connect may also be subject to the applicable provider’s terms.
  1. As of the Established and Effective Date, Nagori Soft uses Cloudflare infrastructure to provide its official website, Nagori API, and official Direct Download service at `downloads.nagorisoft.com`. In connection with access to those Services, Cloudflare may process IP addresses, request information, routing information, and technical metadata needed for security and delivery. Additional details concerning a particular product or function will be described in applicable Product-Specific Information or another notice where appropriate.

9. Disclosure to Third Parties

  1. The Operator will not disclose User Information held by the Operator to third parties except:

(a) with the User’s consent;

(b) where processing by a processor, service provider, or other third party is necessary to provide a Service or functionality requested by the User and is carried out under applicable law and appropriate contractual or other legal arrangements;

(c) where disclosure is required or otherwise lawfully permitted in response to a lawful request from a court, governmental body, or other authority with proper jurisdiction;

(d) where necessary to protect life, physical safety, property, or other significant rights or interests and permitted by applicable law;

(e) in connection with a merger, transfer of business, succession, or other organizational or business change in accordance with applicable law; or

(f) as otherwise permitted by applicable law.

  1. Where additional requirements such as consent or an opt-out apply to disclosure, the Operator will comply with those requirements.
  1. Nothing in this Section permits sale of User Information or sharing for behavioral advertising in violation of Sections 2 and 15.

10. International Data Transfers

  1. Depending on the Services or third-party services used by them, User Information may be processed in a country or region other than the User’s country or region of residence.
  1. Where applicable law requires safeguards for an international or cross-jurisdictional transfer, the Operator will use an appropriate transfer mechanism or safeguard recognized under applicable law, such as an adequacy decision, standard contractual clauses, or other lawful contractual or transfer mechanisms.
  1. Where a specific international transfer occurs, an overview will be provided in Product-Specific Information or another notice where appropriate.

11. Retention and Deletion

  1. Where the Operator retains User Information, it is the Operator’s policy not to retain that information longer than reasonably necessary for the purposes for which it was processed, compliance with legal obligations, handling disputes, security, or other legitimate needs.
  1. Retention periods specific to a Service, or the criteria used to determine them, will be described in Product-Specific Information where appropriate.
  1. Information stored only on a User’s device or in storage selected by the User is generally controlled and deleted by the User.
  1. Uninstalling or ceasing use of a Service may not automatically delete files, backups, synchronized copies, logs, or other information separately stored by the User.
  1. Information that must be retained by law, is necessary for the exercise or defense of legal rights, is contained in backups, or cannot immediately be deleted for another legitimate reason may be retained only for the necessary period.

12. Security

  1. The Operator will implement reasonable and appropriate technical and organizational measures, taking into account the nature, volume, purposes, and reasonably foreseeable risks of the User Information handled, to protect against unauthorized access, loss, destruction, damage, disclosure, or other improper handling.
  1. Such measures may include, where appropriate, access controls, authentication, protection of communications or stored data, management of secrets, updates to software and dependencies, signature or integrity verification, vulnerability response, backups, and other safeguards.
  1. Where third-party services or components are used, the Operator will reasonably consider their handling of User Information and relevant security implications.
  1. No technical or organizational measure can guarantee the complete elimination of all information-security risks.

13. User Rights

  1. Depending on applicable law, Users may have rights regarding User Information handled by the Operator, including:

(a) the right to receive information about the purposes and manner of processing;

(b) the right to request access or disclosure;

(c) the right to request correction, supplementation, or updating;

(d) the right to request deletion or erasure;

(e) the right to request suspension or restriction of processing;

(f) the right to object to processing;

(g) the right to withdraw consent;

(h) the right to data portability;

(i) where applicable, the right to opt out of the sale or sharing of personal information or to limit the use or disclosure of sensitive personal information;

(j) rights applicable to automated decision-making;

(k) the right not to receive unlawful or unfair discriminatory treatment for exercising privacy rights; and

(l) any other right provided by applicable law.

  1. Where applicable, Users may have the right to lodge a complaint with a data-protection or other supervisory authority.
  1. Requests to exercise these rights may be directed to the contact information in Section 19.
  1. The Operator may request identity verification or other information reasonably necessary to process a request.
  1. Where applicable law permits a request to be refused, delayed, or restricted, the Operator will act in accordance with that law.
  1. Where information remains only on a User’s device and has not been transmitted to the Operator, the Operator may not possess the information and may be technically unable to respond to a request for access, correction, or deletion of that information.

14. Children and Minors

  1. Depending on the nature of a Service, the Service may be used by minors.
  1. Where applicable law requires age verification, parental notice, parental consent, or other special measures for processing information relating to minors, the Operator will comply with those requirements.
  1. A Service primarily directed to children or minors, or a Service that collects User Information from individuals of an age for which special legal protection applies, will provide additional Product-Specific Information, parental notices, consent procedures, or other measures where appropriate.
  1. If the Operator becomes aware that protected information relating to a minor has been collected without satisfying consent or other requirements imposed by applicable law, the Operator will take deletion or other actions required under applicable law.

15. Sale, Advertising, and Tracking

  1. Nagori Soft does not sell User Information to third parties as a “sale” or equivalent transaction under applicable privacy law.
  1. Nagori Soft does not share or disclose User Information to third parties for cross-context behavioral advertising or similar third-party behavioral or targeted advertising.
  1. Nagori Soft does not process User Information for the purpose of tracking Users across different Nagori Soft products or third-party services in order to use such information for third-party behavioral advertising.
  1. This Section does not prohibit communications necessary to provide the Services, security or troubleshooting activities, integrations with third-party services requested by Users, or general information about Nagori Soft’s own products or services, provided that such activities comply with this Policy and applicable law.
  1. If Nagori Soft materially changes the principles stated in this Section in the future, the Operator will revise this Policy in accordance with Section 18 and provide any notice, choice, opt-out, consent, or other measure required by applicable law.

16. Automated Decision-Making and Profiling

  1. If a Service uses automated decision-making or profiling that produces legal or similarly significant effects on Users, the Operator will provide information required by applicable law regarding the existence, principal operation, purposes, and reasonably foreseeable effects of such processing through Product-Specific Information or another appropriate method.
  1. Where applicable law provides a right to human review, objection, or other safeguards in relation to such processing, the Operator will provide a reasonable means to exercise those rights.

17. Data Breaches and Other Security Incidents

  1. If a breach, loss, destruction, unauthorized access, or other security incident affects User Information held or controlled by the Operator, the Operator will take reasonable steps appropriate to the nature and risk of the incident, including assessment, containment, investigation, and measures designed to reduce the risk of recurrence.
  1. Where required by applicable law, the Operator will report the incident to the appropriate supervisory or other authority and notify affected Users within the time and in the manner required by applicable law.

18. Changes to This Policy and Product-Specific Information

  1. The Operator may revise this Policy or Product-Specific Information in response to changes in law, Services, technology, third-party services, data processing, or other circumstances.
  1. If the Operator changes a common principle of this Policy or makes a change that materially affects Users, the Version number of this Policy will be updated and reasonable notice will be provided as appropriate to the nature of the change and applicable law.
  1. Where only processing specific to a particular Service changes, the Operator may update the date or Version of the applicable Product-Specific Information without changing the Version number of this Policy.
  1. If a material change to a purpose or other processing is incompatible with the previous description, the Operator will provide any notice, choices, consent, or other measures required by applicable law.
  1. Product-Specific Information alone will not implicitly modify the common principles in Section 2, Section 15, or elsewhere in this Policy to the detriment of Users.
  1. The current version of this Policy and applicable Product-Specific Information will be made reasonably available to Users.

19. Operator and Contact Information

  1. The Operator responsible for handling User Information in connection with the Services is the legal operator providing the Services under the Nagori Soft name.
  1. Questions regarding privacy, requests to exercise privacy rights, and other communications concerning this Policy may be sent to:

privacy@nagorisoft.com

  1. General inquiries may be sent to:

contact@nagorisoft.com

  1. The Operator’s legal name, address, and other information that applicable law requires to be provided to a User will be displayed directly where applicable law requires direct public disclosure. In other cases, such information will be provided without undue delay, to the extent required by applicable law, upon request sent to the privacy contact above.
  1. Where applicable law requires appointment or disclosure of a data protection officer, representative in the European Union, representative in the United Kingdom, or another representative, the relevant contact information will be provided in this Section or in applicable Product-Specific Information.

20. Applicable Law and Statutory Rights

  1. Processing of User Information under this Policy is subject to the Act on the Protection of Personal Information of Japan and any other law applicable to the relevant processing.
  1. Depending on the User’s location, regions in which the Services are offered, or the manner in which User Information is processed, the EU General Data Protection Regulation (GDPR), United Kingdom data-protection law, United States federal or state privacy law, or other privacy or data-protection law may apply.
  1. Nothing in this Policy excludes, waives, or restricts any right, remedy, or protection that cannot lawfully be excluded, waived, or restricted under mandatory applicable law.
  1. If a provision of this Policy conflicts with mandatory applicable law, that mandatory law will prevail only to the extent of the conflict.

21. Language

  1. Both the Japanese and English versions of this Policy are authoritative versions.
  1. The two language versions are intended to have the same content and legal effect.
  1. If there is any difference in wording or question of interpretation between the Japanese and English versions, they will be read together and interpreted in the manner that best gives effect to their common intent. Where applicable law requires a particular treatment, that law will apply.

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