# Privacy policy

This policy describes how Fenrir Inc. (“We”, “Us” or “Our”) through a “Sleipnir” (the “Software”) collect and use personal information.

If you agree, the following terms and conditions apply in addition to Our Privacy policy(https://www.fenrir-inc.com/jp/privacy-en/). This terms and conditions has priority over Our Privacy policy of different or contrary.

## 1) Collection, Purpose of Use, and Grounds for Use of Personal Information

We receive the following information from users (the "Personal Information"). The Personal Information of the user will be used only for the purpose of use notified to the user at the time of provision thereof or within the scope of the purpose of use listed below, and will not be used for any other purpose without the user’s prior consent. In addition, the personal information will be deleted immediately when its use is no longer necessary.

### 1. Information We Collect

Use the search engine managed by our company
  - Access information to the server managed by our company
    - IP address
    - Time stamp information
    - Requested URL
    - User Agent (Browser information)
  - Information required when using search engines managed by our company (search conditions, page numbers)
Automatic update confirmation of software
  - Access information to the server managed by our company
    - IP address
    - Time stamp information
    - Requested URL
    - User Agent (Browser information)
  - Current version information of the software
  - Operating environment (OS type, language used, IE Version)
Use the bookmarks of sites managed by our company
  - Access information to the server managed by our company
    - IP address
    - Time stamp information
    - Requested URL
    - User Agent (Browser information)
View the software update completion page
  - Access information to the server managed by our company
    - IP address
    - Time stamp information
    - Requested URL
    - User Agent (Browser information)
View the Sleipnir Start page from new tab or home
  - Access information to the server managed by our company
    - IP address
    - Time stamp information
    - Requested URL
    - User Agent (Browser information)
Send the feedback (Feedback Agent)
  - Access information to the server managed by our company
    - IP address
    - Time stamp information
    - Requested URL
    - User Agent (Browser information)
  - Feedback information (feedback contents, crash data)
Use the bookmarks sync feature (Fenrir Pass)
  - Access information to the server managed by our company
    - IP address
    - Time stamp information
    - Requested URL
    - User Agent (Browser information)
  - Information required when using bookmarks sync feature (bookmarks to save)
Use the search suggestion feature
  - Access information to the server managed by our company
    - IP address
    - Time stamp information
    - Requested URL
    - User Agent (Browser information)
  - Information required when using search suggestion feature (Words entered in search bar)

### 2. Purpose of use of collected information (the “Purpose of Use”)

Response to inquiries
  Responding to various inquiries
Statutory procedures
  - Investigation and resolution of claims and disputes by Us or users concerning the use of Our services.
  - Provision to national agencies or local governments to which it is permitted by laws and regulations.
Software Provides the feature
  Providing software various features
Software Improvements
  - Fix software vulnerability
  - Improved software quality and functionality

### 3. Grounds for Use of Collected Information

We will use the Personal Information based on one or more of the following grounds.

Consent
  We collect the Personal Information of users based on the consent of the users. You have the right to withdraw your consent at any time.
Responding to user requirements
  We collect the Personal Information of users when handling thereof is necessary in order to perform contracts and in order to perform the procedure in response to the requests of users prior to the conclusion of the contracts. Responding to requests from users includes responding to inquiries from users.
Compliance with legal obligations
  We collect the Personal Information of users in order to comply with the legal obligations that We must comply with.
Protection of important interests of users or third parties
  We collect the Personal Information of users in order to protect the important interests of users and third parties. Important interests of users include the omission of the users’ re-entry effort, the display of the most appropriate contents for the users, and the display of advertisements according to the users’ interests.
Protection of the public interest
  We collect the Personal Information of users to the extent necessary to protect the public interest.
Pursuit of the legitimate interests of us or third parties
  We collect the Personal Information of users in order to pursue the Our legitimate interests or those of third parties. Our legitimate interests include preventing and detecting fraud in Our services and responding to it, providing customer support, conducting investigations and analyses to improve Our services or security.

### 4. About the use of this software

The default bookmarks and search engines of this software include links to other company’s services in addition to links to our services. If you use another company’s service by bookmarking another company’s service or specifying a search engine or URL, the terms exchanged with the company’s service will be applied.

## 2) Provision and Disclosure to Third Parties

1. We will not provide or disclose the Personal Information of users to third parties except in any of the following cases:

- Cases where the user has given his/her consent to the disclosure of his/her Personal Information;
- When providing or disclosing to subcontractors, etc. within the scope necessary for achieving the Purpose of Use;
- When disclosure or provision is permitted by applicable laws; or
- Cases where the Personal Information is disclosed or provided as a result of business succession such as merger, company split or business transfer, etc.

2. When the user uses this software and uses the other companies' services, that act will be based on the agreement of the terms between the user and the other companies' services, and we are not involved in the information generated by that act.

#### Supplementary Provisions

Added to “article 2 Provision and Disclosure to Third Parties”, August 4, 2021.