This English text is a courtesy translation provided for convenience. The official text of this Policy is the Japanese version; if there is any inconsistency between the two, the Japanese version prevails.

SmartPropFact, operated by Chomchana Trevai (sole proprietor) ("we," "us," or the "Operator") handles users' personal information in connection with the "SmartPropFact" service (the "Service") in compliance with Japan's Act on the Protection of Personal Information ("APPI") and other applicable laws, as set out in this Privacy Policy (this "Policy").

1. Business Operator

2. Information We Collect

1. Account information: email address, authentication credentials (via Google or Apple sign-in, or email authentication), display name, and similar.
2. Uploaded documents and extracted data: the documents you upload (receipts, monthly statements, purchase contracts, insurance policies, property-tax notices, withholding-tax slips (源泉徴収票), prior-year tax returns, and similar) and the structured data AI extracts from them. These may include information about your income, expenses, loans, salary, and taxes, and — by the nature of the documents — information about third parties such as your tenants (see Section 10).
3. Information you enter: property details, salary-band selections, questions entered into the Q&A feature, and other inputs.
4. Payment information: payments for paid plans are processed by Stripe; credit-card numbers do not pass through our servers and are not retained by us. We receive from Stripe the information needed to manage your subscription (plan, payment status, and similar).
5. Usage and device information: usage history, operation logs, device and browser type, IP address, cookies and similar identifiers, analytics data (see Section 11), and technical information collected when errors occur.
6. Mobile-app launch notification info: the email address and preferred platform (iOS / Android) provided by users who wish to be notified when the mobile app launches. Used solely to send the launch notification.

3. Purposes of Use

1. Providing and maintaining the Service (classifying and reading documents, generating and storing extracted data, computing refund and tax projections, producing year-end documents, and answering Q&A);
2. identity verification, account management, and authentication;
3. billing, payment processing, and contract management;
4. responding to inquiries and providing support;
5. improving the Service, investigating and fixing defects, and developing new features (including analysis using aggregated or anonymized information);
6. preventing fraudulent use and maintaining security;
7. sending important notices about the Service; and
8. complying with legal obligations.

4. Provision to Third Parties

1. We do not sell your personal data.
2. We do not provide personal data to third parties without your prior consent, except (i) where required by law; (ii) where necessary to protect a person's life, body, or property and obtaining your consent is difficult; or (iii) in other cases permitted under the APPI.
3. Provision to service providers entrusted with processing (Section 5) does not constitute third-party provision.

5. Service Providers (Subprocessors)

We entrust the handling of personal data to the following providers to the extent necessary to operate the Service. We ensure appropriate security measures at each provider through contracts and exercise necessary and appropriate supervision.

6. Transfers to Third Parties Located Abroad

1. The providers listed above include companies located in the United States. Your data (uploaded documents, extracted data, account information) is stored in Google Cloud's Tokyo region (asia-northeast1). AI analysis uses Google Cloud's global endpoint and may be transiently processed in regions outside Japan; prompts and document contents are not retained after processing.
2. The United States has no comprehensive federal law on personal information protection. Information on the US system is available in the foreign-regime surveys published by Japan's Personal Information Protection Commission (PPC website).
3. We maintain frameworks — including contractual obligations on foreign providers to implement security measures consistent with the APPI — to ensure the continuous implementation of equivalent protective measures.

7. No Training of Third-Party AI Models

We do not use your uploaded documents or extracted data to train third-party AI models. AI reading of documents is performed solely to provide the Service.

8. Security Measures

1. Basic policy: this Policy and compliance with applicable laws and guidelines;
2. Technical measures: encryption of documents and extracted data at rest, encryption in transit (TLS), access control and authentication, and secure management of secrets;
3. Organizational measures: least-privilege access to personal data, and recording and auditing of handling (every extracted figure carries an audit trail back to its source document and field);
4. Personnel measures: supervision and training of persons handling personal data;
5. Awareness of the external environment: understanding the legal regime of the foreign country (the United States) where personal data is stored, and implementing security measures accordingly (see Section 6).

9. Retention and Deletion

1. We retain information only for the period necessary to achieve the purposes of use.
2. When you delete your account, we delete your uploaded documents and extracted data — including tax documents such as the 源泉徴収票 — within 30 days of account deletion, except for information we are required by law to retain (such as accounting books and transaction records), which is retained for the legally required period.

10. Personal Information of Tenants and Other Third Parties

1. Documents you upload (lease agreements, monthly statements, and similar) may contain personal information of third parties such as your tenants (names, contact details, account numbers).
2. You — the property owner — are the party who collects that information, and you must upload only documents you lawfully hold. Obligations to tenants under the APPI (such as specifying and notifying purposes of use) rest with you. We handle such information only on your behalf and only to the extent necessary to provide the Service.
3. On-screen display of tenant-identifying information is controlled by a per-property setting that defaults to off; it is not shown unless you explicitly enable it. Regardless of the display setting, this information is stored encrypted.

11. Cookies and Analytics

1. The Service uses cookies and similar technologies to keep you signed in, maintain security, and improve usability.
2. We use tools that cause information to be transmitted from your device to the following external providers, for usage analysis and service improvement (disclosed pursuant to Article 27-12 of the Telecommunications Business Act):

   Service	Recipient	Information transmitted	Purpose
   Google Analytics 4 (our website, www.smartpropfact.com)	Google LLC	Cookie-type identifiers, pages viewed and referrers, interactions such as button clicks, device/browser type, IP address (used to estimate region)	Analyzing and improving site usage; understanding traffic sources
   Firebase Analytics (the app, app.smartpropfact.com)	Google LLC	App instance identifiers, screen/feature usage, device/browser type, IP address	Analyzing and improving app usage

   For how this information is handled, see Google's Privacy Policy and Firebase Privacy information. You can disable Google Analytics transmission with the Google Analytics Opt-out Add-on.
3. You can disable cookies in your browser settings, but some features of the Service may then be unavailable.

12. Requests Regarding Retained Personal Data

1. You may request, as provided in the APPI, notification of purposes of use, disclosure, correction, addition, or deletion of content, suspension of use or erasure, and suspension of third-party provision of your retained personal data.
2. Please send requests to the contact in Section 14. After verifying your identity (or your agent's authority), we will respond within the period prescribed by law.
3. Fee for disclosure requests: Free

13. Changes to this Policy

We may revise this Policy in response to changes in law or in the Service. For material changes, we will give notice a reasonable period before the effective date by posting within the Service or by other appropriate means.

14. Contact

For inquiries about this Policy or the handling of personal information, and for disclosure requests, please contact:

End of Policy.

SmartPropFact (operated by Chomchana Trevai)