Privacy policy.

1. Personal information handler

KiShisanMyaku K.K., 1-1-1 Otemachi, Chiyoda-ku, Tokyo 100-0004, Japan. A registered personal-information-handling business under Japan's Personal Information Protection Commission (PPC).

2. Personal information we collect

• Account data: name, date of birth, My Number, identity documents, residential address, citizenship.
• Contact data: email, phone, emergency contact.
• Financial data: bank details, tax status, trade history, positions, risk profile.
• Technical data: IP address, device identifier, browser fingerprint, login timestamps.

3. Purpose of use

• Providing the service (account administration, order execution, settlement, tax reporting)
• Regulatory reporting to the FSA and NTA, AML/CFT compliance
• Security, fraud prevention, system integrity
• Related communications where you have expressly consented

4. Retention

Account and transaction data retained for seven years after account closure — the requirement under Japan's Financial Instruments and Exchange Act and tax law. Technical logs kept 18 months. Marketing consents valid until withdrawn.

5. Sharing with third parties

We share personal information only with:

• Our FSA-registered execution partners (for trade execution)
• Our trust bank and settlement venues (for fund segregation and settlement)
• Regulators and tax authorities (as legally required)
• Contracted technical providers (data center, email, 2FA), all under contract

We do not sell personal information. We do not share data for third-party advertising.

6. Cross-border transfer

Some data may involve limited, contractually protected transfer to technical providers in the U.S. and Europe. All transfers occur under Japan's APPI and the corresponding laws of the recipient jurisdictions.

7. Your rights

Under APPI, you have the right to:

• Request disclosure of the personal information we hold
• Request correction of inaccurate data
• Request cessation of unauthorized use or collection
• Complain to the Personal Information Protection Commission (PPC)

Requests to: [email protected]

8. Complaints

First contact our privacy officer at [email protected]. If unsatisfied, you have the right to complain to Japan's Personal Information Protection Commission (https://www.ppc.go.jp/).