Privacy Policy

Scope of This Policy

This NEO CANVAS Privacy Policy (hereinafter referred to as this "Privacy Policy") is issued by AiHUB Corp. ("AiHUB", "we", or "us") and applies to the "NEO CANVAS" service provided by AiHUB (the "Service"). This Privacy Policy explains how AiHUB and its affiliates collect, use, disclose, protect information, and your choices about the collection and use of your information. If a user do not wish their information to be processed in accordance with this Privacy Policy in in general or any part of it, you should not use the Service. This Policy applies to all users of the Service.

1. Information we collect

We collect the following types of information about users:

(a) Information you provide us directly

We may ask for certain information when you register for a AiHUB account or contact us (such as a username, your first and last names, birthdate, phone number, occupation, address, and e-mail address). We also collect any messages users send us through the Service (such as user feedback, search queries and prompts), and may collect information you provide in User Content you post to the Service (such as text and photos you upload to use in your designs). We use this information to operate, maintain, improve, and provide the features and functionality of the Service to you, to correspond with you, and to address any issues you raise about the Service. If you don't provide your personal information to us, you may not be able to access or use our Service or your experience of using our Service may not be as enjoyable.

(b) Information we receive from third-party applications

We may receive information about users from third-party services. For instance, if users log in through Facebook Connect or link accounts, such third parties may share user IDs, access tokens, permissions, and public profile information. We may receive information about you from third parties. For example, if you access the Service through a third-party connection or log-in, such as Facebook Connect, by "following", "liking", linking your account to the AiHUB Service, etc., that third parties may pass certain information about your use of its service to us. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token that is necessary to access that service, any information that you have permitted the third parties to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service. You may also unlink your third-party account from the Service by adjusting your settings on the third-party service. If you unlink your third-party account, we will no longer receive information collected about you in connection with that service. If users interact with us via social media and choose to share generated content, we may receive videos, photos, usernames, and related comments. In addition, if you choose to integrate with a third-party application to incorporate elements into your designs, enhance media, supercharge your workflow or share to social media, we could receive data from such apps (as well as disclose data to such apps). If you communicate with us via social media and choose to share your user generated content with us, we may receive information such as videos you have created, your photos, your account name, and your comments about the Service.

(c) Information we receive from other third parties

We may receive user information from public sources, social media platforms (e.g., Facebook, Instagram, LinkedIn, X), data providers, and business services. We may obtain information about users from third-party sources, such as public sources, social media platforms (such as Facebook, Instagram, LinkedIn, Twitter, and other platforms), third-party data providers, and information services. Examples of the information we may obtain from such third parties include your company, company size, job title and seniority, industry, and other profile information. We may share your email address or other information in order to obtain and combine this information with information that you provide to us or other information that we collect when you use our Service. We do this to better understand your profile and interests so that we can deliver customized offers and other personalized services to you, such as to serve relevant offers to you via email, chatbots, phone, or personalized advertising. You can opt out of AiHUB collecting more data about you from third-party providers to tailor your experience and messages we send you. Some of providers may combine data collected from our Service through cookies, pixels, tags and similar technologies, with emails or mailing addresses to which they have access to help us serve relevant offers to you. We may obtain your contact details from a social media platform, such as LinkedIn, or third-party data providers, so that we can promote our product offerings and subscriptions to you if we think they would be helpful in your role. We also may have obtained your details from another AiHUB users, for example when they have shared a design with you. We may also receive information about you and your engagement with our advertisements from our ad servers, ad networks and social media platforms. This may include websites you visited before coming to our website so that we can determine advertising effectiveness and pay our referral partners. If you prefer not to have your information used for this purpose, you can opt out at any time by contacting us by email.

(d) Information we collect from you automatically

We will directly collect or generate certain information about your use of the Service (such as user activity data, analytics event data, and clickstream data) for data analytics and machine learning, and to help us measure traffic and usage trends for the Service. We may also use third party analytics tools that automatically collect information sent by your browser or mobile device, including the pages you visit and other information, that assists us in improving the Service. For more information, please see the paragraphs below about cookies information, log file information, clear gifs, device identifiers, and location data.

(e) Cookies information and information taken from similar technologies

When you visit the Service, we (and our third-party partners) will send cookies - small text files containing a string of alphanumeric characters - to your computer that uniquely identifies your browser and let us help you to log in faster, enhance your navigation through the site, remember your preferences, and generally improve users' experience. Cookies also convey information to us about how you use the Service (e.g., pages you view, links you click, and other actions you take on the Service) and allow us or our business partners to track your usage of the Service over time. They also allow us to measure traffic and usage trends for the Service, deliver personalized advertisements that may be of interest to you and measure their effectiveness, and find potential new users of the Service. You can control or reset your cookies and similar technologies through your web browser, which will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

(f) Log file information

Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include information such as your web request, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other anonymous information.

(g) Clear gifs/web beacons information

When you use the Service, we may employ clear GIFs (also known as web beacons) which are used to anonymously track online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the Service.

(h) Device identifiers

When you access the Service on a device (including smart-phones or tablets), we may access, collect and/or monitor one or more "device identifiers," such as a universally unique identifier ("UUID"). Device identifiers are small data files that uniquely identify your mobile device. A device identifier may convey information to us about how you use the Service. A device identifier may remain persistently on your device, to help you log in and navigate the Service better. Some features of the Service may not function properly if use of device identifiers is impaired. Device Identifiers used by AiHUB include Android Advertising ID and iOS Advertising Identifier.

(i) Location data

AiHUB collects information in order to understand where users are located for a number of reasons. It helps AiHUB to localize and personalize content, comply with local laws, undertake aggregated analytics, understand if its users use AiHUB for domestic, business or educational use, improve advertising efficiency and estimate the tax liability of AiHUB. AiHUB may collect your precise or approximate location: - from you, when you provide, correct, or confirm your location (e.g., when you purchase products from us); - by inferring your location from your IP address; and - from our partners or your payment provider.

(j) Content within your account

We receive content that you create within your AiHUB account and media you upload for use within it, such as designs, images, documents, videos, and metadata about your content.

2. How we use your information

We use the information we collect about you for the purposes set out below:

- Providing you with the Service: We use information you directly provided us to provide the Service to you. This includes allowing you to log in to AiHUB, operating and maintaining the Service, giving you access to your designs and billing you for transactions that you make via the Service. We also use information we collect about you automatically to remember information about you so that you will not have to re-enter it during your visit or the next time you visit the site.

- For data analytics: We use information about you to help us improve the AiHUB Service and our users' experience, including by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns.

- For analytics and machine learning: We may analyze your activity, content, media uploads and related data in your account to provide and customize the Service, and to train our algorithms, models and AI products and services using machine learning to develop, improve and provide our Service.

- labeling and detecting components in images (e.g., background, eyes) in order to provide and enhance photo editing tools such as background removal, blemish and red eye correction and erasure of components;

- labeling raw individual data (e.g., "man with dog");

- detecting contents that we prohibit for moderation and security purposes (e.g., pornographic or copyright protected material).;

- translating audio soundtracks;

- predicting the most relevant subscription or product offerings for a user to tailor communications and advertising; and

- search terms and corresponding search interaction data to build algorithms that deliver the most relevant design result.

- Customizing the Service for you: We use and combine the information you provide us and information about you that we collect automatically and receive from other sources (including information we receive on and off our Service) and combine it with information about behavior of other users to make sure that your use of the Service is customized to your needs. For example, to recommend templates, ingredients, and fonts that are likely to be useful to you in a design, we may use information derived from your prior behavior on the Service, the use of these elements by other people working on similar designs and other inferred information.

- To communicate with you about the Service: We use your contact information to get in touch with you and to send communications about critical elements of the Service. For example, we may send you emails about technical issues, security alerts, or administrative matters.

- To promote and drive engagement with the Service: We use your contact information to get in touch with you about taking part in our surveys or about features and offers relating to the Service that we think you would be interested in. We also use information we collect about you to make sure that you get the most relevant offers and promotions based on your use of the Service, and your preferences. You can opt-out of these communications as described below.

- To improve the Service: We analyze information about how users use the Service and the information about users' contents to better understand how users interact with the Service, measure the effectiveness of the Services, and improve and develop the Service for users.

- For advertising purposes: We use information about you, including cookies information and other information we (and our third-party partners) collect from you automatically about your use of the Service, to serve, personalize, and measure the effectiveness of advertising on the Service and third-party sites and platforms. This includes showing you advertising we think you might find interesting as well as displaying advertising to potential new users that have similar interests.

- Customer happiness: We use information about you, information that we collect or from within your account, information that you provide to our customer happiness team, and information about your interactions with the Service to resolve technical issues you experience with the Service, and to ensure that we can repair and improve the Service for all AiHUB users.

- For security measures: We use information about you and your account data to monitor suspicious or potentially fraudulent activities and to identify violations of this Privacy Policy and our Terms of Use.

- For matters that you have specifically consented to: From time-to-time, AiHUB may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose you may withdraw your consent to this use.

- For troubleshooting, error resolution, and service improvement: We may need to review your designs to support your request for help, correct general errors with the Service or improve the Service.

- For matters that we are required to use your information by law: AiHUB will use or disclose your information where we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of the Service; and/or (c) to exercise or protect the rights, property, or personal safety of AiHUB, our users, or others.

3. Sharing your information

(a) How we share your information

We share your information with third-party service providers for the purpose of providing the Service to you, to facilitate AiHUB's legitimate interests or if you consent. These service providers are vetted by us and will only be provided with access to your information as is reasonably necessary for the purpose that AiHUB has engaged the service provider. We require that such third parties comply with applicable laws, and have security, privacy, and data retention policies consistent with our policies to the extent necessary for them to perform a business or technology support function for us. Some of the third parties with whom AiHUB may share your personal information are service providers who assist AiHUB with functions such as: - Billing; - Customer support and customer management; - Email services; - Hosting and storage; - Data analytics and predictive analytics; - Data labelling and machine learning; - Security; - Advertising and marketing services; - Domain name registration; - Delivery of physical products; and - Other service providers.

(b) How you can share your User Content

(i) Public Posts

Any information or content that you voluntarily disclose for posting to the Service, such as public User Content, becomes available to be read, collected, and used by the public. When you set your profile to public, or make User Content public, your information becomes publicly available globally, searchable by other users and can be indexed by search engines. If you or AiHUB remove information that you posted to the Service, copies remain viewable in cached and archived pages of the Service, or if other users have copied or saved that information. You may share your AiHUB designs to your social media accounts, including LinkedIn, Facebook, X, Pinterest, and Tumblr. You should ensure that you familiarize yourself with the privacy policies of each of these services and any privacy settings that may apply to the designs you choose to share on those accounts.

(ii) Teams

If you are part of a Team, then any information or content that you create in that Team or activity you take within the Team may be shared with other Team members and the Team Owner. If requested by the Team Owner, AiHUB may re-assign ownership of any User Content you post in the Team to the Team Owner or to another Team member. The Team Owner or any Team Administrator in your Team may also move, delete, or edit any folders or items you share with them, or the Team. You should ensure that any personal information, confidential information, or User Content that you'd like to keep private is retained in a separate personal account.

(iii) Design Collaboration

If you accept an invitation to view or edit designs you create at AiHUB, then, we may share certain information about your interaction with that design with the design owner and other users who have access to that design, including the followings: - your name and avatar will be visible to anyone else in the design at the same time as you, whether or not they are logged in to AiHUB or anonymous; - your name and login time will be visible to all other person that has editing rights to the designs, even if they do not belong to the Team.

(c) Sharing in connection with a merger, acquisition, or reorganization

AiHUB may also share, sell, or transfer your information to third parties in connection with or contemplation of (including as part of the debt repayment process) any merger, acquisition, reorganization, financing, sale of assets, bankruptcy or insolvency event involving AiHUB or any portion of our assets, services, or businesses. Information such as customer names and email addresses, User Content and other user information related to the Service may be among the items shared, sold, or otherwise transferred in these types of transactions. You will be notified via email and/or a notice on the Service if such a transaction takes place and be given notice of any material changes to the way we handle your data under this policy.

(d) Your employer

If you sign up for the Service using an email address issued by your employer or another organizations (whether business operators, non-profit organizations, or educational institutions) and the employer has established (or is considering establishing) an account with AiHUB, it is acknowledged that AiHUB may share your name, email address, and account activity information with your employer. If you do not use AiHUB in connection with your employment relationship and do not want this information to be shared with your employer, you may opt out at any time by contacting us by email.

(e) Sharing with other third parties

AiHUB will also share your information with third parties in certain circumstances, such as where you consent to our sharing it with a third party for a particular purpose. You or your account administrator may also choose to work with third-party products integrated into AiHUB or third-party applications from within AiHUB so that you can incorporate elements into your designs (e.g., YouTube, an application that uses the YouTube API Services and users agree to be bound by the YouTube and Google, Google Drive, etc.), enhance your media (e.g., with duotone and shadows) or supercharge your workflow (e.g., with LinkedIn or Slack). For example, you may install a third-party document sharing app in order to store, share, and edit contents through the Service. Using third party-products or integrating with third party applications could involve importing data from that third-party to AiHUB and/or exporting data from AiHUB to that third-party. If this requires connecting your AiHUB account to your account on the third-party application, you will be asked for permission. These third-party products and apps are not controlled by us, and this Privacy Policy does not cover how third-party apps use your information. You should review the terms and conditions of any third-party apps before connecting them to the Service. If you object to information about you being shared with these third parties, please do not use the products, or install the apps. For the YouTube application, you can revoke AiHUB's YouTube application's access to your data via the Google security settings page.

(f) Sharing aggregate data

We may also aggregate or otherwise stripe data of all personally identifying characteristics and may share that aggregated such anonymized data with third parties

(g) Sharing with authorities

We access, preserve and share your information with regulators, law enforcement, police, intelligence sharing and obtain various services and other records. This is done where we have a good-faith belief that it is necessary to detect, prevent or address fraud, breaches of our Terms of Use, harmful or illegal activity, to protect AiHUB (our rights, property or intellectual property), as well as you or others, including as part of investigations or regulatory enquiries or to prevent death or imminent bodily harm.

4. Advertising

We partner with third party ad servers, ad networks and social media platforms (like Facebook, Google, LiveRamp, Outbrain, Taboola, and Appsflyer) to deliver personalized advertisements ("ads") on our Service and other sites that may be of interest to you and/or to measure their effectiveness, and/or to identify potential new users of our Service. AiHUB may share certain information with our third party advertising partners, such as your email address, location, cookie information, and information relating to your use of our Service, and allow partners to perform a match of your information against information from other third party networks or sites to serve ads either on the Service or on third party sites (including, but not limited to Facebook, Google and Samsung televisions) and to measure the effectiveness of these ads. We also share certain information with social media platforms, such as Facebook and Tiktok, to display advertising to potential new users whose demographics and behaviour look like those of our existing users. You can opt out of having your email matched by Liveramp by contacting us by email. In addition, these third-party ad servers or ad networks may use technology to send, directly to your browser or mobile device, these personalized ads and ad links directly to your browser or mobile device and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs) to compile information about your browser's or device's visits and usage patterns on the Service, and to measure the effectiveness of their ads and to personalize the advertising content. AiHUB does not sell or rent the information we collect directly from you or the information about you from third parties with these third-party ad servers or ad networks for such parties' own marketing purposes. Please note that an advertiser may ask AiHUB to show an ad on the Service to a certain audience of users (e.g., based on demographics or other interests). In that situation, AiHUB determines the target audience and AiHUB serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. The AiHUB Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

5. How we transfer, store, and protect your data

Your information collected through the Service will be stored and processed in Japan, the United States, Australia, Singapore, European Union, United Kingdom, Philippines and New Zealand and any other country in which AiHUB or its subsidiaries, affiliates or service providers maintain facilities or employ staff or contractors. AiHUB transfers information that we collect about you, including personal information, to affiliated entities, and to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. As a result, we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. However, we always take steps to ensure that your information remains protected wherever it is stored and processed in accordance with applicable laws. Where required under applicable laws, you consent to the transfer of information to the U.S. or any other country in which AiHUB or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

6. Keeping your information safe

AiHUB cares about the security of your information and uses appropriate safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are always responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from AiHUB. However, AiHUB cannot ensure or warrant the security of any information you transmit to AiHUB or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third-party sites and services that you add to the AiHUB Service, such as social networks. AiHUB is not responsible for the functionality or security measures of any third parties.

7. Your choices about your information

(a) You control your account information and settings

We provide choices about how to process your account information. - You can request access, correction, or deletion of the data AiHUB holds on you by contacting us.

(b) Opting out of collection of your information through tracking technologies

Please refer to your mobile device or browser's technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents AiHUB or its business partners from tracking your browser's activities in relation to the Service, and for use in targeted advertising activities by AiHUB, including via third-party websites. However, doing so may disable many of the features available through the Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, please contact us directly.

(c) Opting out of enrichment using third-party data

We may combine information about you with information obtained from third-party sources to better understand your profile and interests so that we can deliver customized offers and other personalized services. You can opt out of AiHUB collecting more data about you from third-party providers to tailor your experience and messages we send you by contacting us by email.

(d) Managing how Canva analyzes your data for analytics and machine learning

You can manage your preferences relating to how AiHUB and the third-party service providers we engage to enable functionality within the Service, may use your data for training AI, including through the use of machine learning technologies.

(e) Rights Under Data Protection Laws

The laws of some countries grant particular rights in respect of personal information. Individuals in certain countries, including the European Union, United Kingdom, and Brazil have the rights to: - Request access to their information; - Request that we correct inaccuracies in their information; - Request that their information be deleted or that we restrict access to it; - Request a structured electronic version of their information; and - Object to our use of their information. Should you wish to make a request in respect of your personal information, please contact us. You also have the right to object to our processing of personal data about you in for marketing purposes and we will stop processing data for that purpose if you exercise that right. In some circumstances, AiHUB will not be able to comply with your request regarding your personal data. If we are unable to remove any of your information, we will explain the reason. For example, we may not be able to provide a copy of your information where it infringes on the rights of another user. In some cases, you may have shared your information with third parties, such as by publishing a design on a third party's website. In that case, AiHUB will not be able to delete the information, and you will need to contact that third party directly. If we are unable to resolve your request, or if you are concerned about a potential violation, you also have the option to report the issue or make a complaint to the data protection authority in your jurisdiction. Where you have provided your consent to certain processing and no longer want us to use your information for that purpose, you may withdraw your consent to this use, although this will not affect the lawfulness of processing based on consent before its withdrawal.

8. How long we keep your information

Following termination or deactivation of your user account, AiHUB will retain your profile information and user contents for a commercially reasonable period, and for as long as we have a valid purpose to do so. In particular, AiHUB will retain your information for the purpose of complying with its legal and audit obligations, and for backup and archival purposes.

9. Children's personal data

In this policy, a child is considered a person under the age of 13 years old (or the minimum legal age in the child's country to be able to provide lawful consent to the processing of their personal data where the age is higher than 13 years old). The Service and our content are not directed at children. Children are not permitted to sign up by themselves for the Service. AiHUB does not knowingly collect or solicit personal information from children. If we learn that we have collected personal information from a child without verification of parental consent where this is required, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child, please contact us.

10. Links to other websites and services

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party's own rules and policies. In addition, you acknowledge that we are not responsible for and we do not exercise control over any third parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook) and you allow such a third party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

11. Additional information for users in Europe

This section of the policy applies to AiHUB users that are located in the European Economic Area (EEA), Switzerland or United Kingdom (UK). AiHUB processes your personal data in accordance with European laws and regulations, such as the General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR).

(a) Controller's details

For the purposes of the GDPR and UK GDPR, AiHUB Corp. is the controller of your personal data. AiHUB Corp.'s registered address is at MA SQUARE AKIHABARA 4F, 2-1-1, Kandasuda-cho, Chiyoda-ku, Tokyo, Japan, and we can be contacted using the details provided in section 14 below. "How to contact us" heading.

(b) Legal bases for processing

If you are located in the EEA, Switzerland or UK, we need a lawful basis to collect, use, and disclose your personal data as a controller. Our lawful basis will depend on the information concerned and the context in which it is processed. Generally, AiHUB will collect and use your information as follows: - Contractual necessity: We need it to provide the Service to you and fulfil our obligations to you under our Terms and Use. For example, this includes creating and maintaining your account, resolving issues you may experience with the Service, obtaining payment for our Services and providing you with access to your designs. - Legitimate interests: It is necessary for our legitimate interests for example, providing a useful and customized Service, sending you relevant marketing messages, displaying advertising and tracking its effectiveness, using information we collect about you (like your spending, platform usage, occupation and employer) so that we can make more informed predictions, decisions and offers for our users, helping users connect with team members and their employer's subscription on AiHUB and enhancing our Service via research and development, data analytics, data labelling, machine learning and predictive analytics relating to your usage data. We do not rely on this lawful basis where our legitimate interests are overridden by your rights and interests. - Consent: You consent to us and our third-party partners using your information in a certain way – for example, to hear about new features or offers, and for machine learning and predictive analysis relating to your User Content. - Legal obligations: It is necessary for compliance with our legal obligations – for example, to disclose your information in response to law enforcement requests and to retain your information for our record keeping purposes. If you consented to our use of your information, you can withdraw that consent at any time. Depending on the situation you can either withdraw your consent by sending an email to neo-canvas@aihub.tokyo.

(c) Cross-border transfers of information

By signing up, you understand and agree that AiHUB Corp. will receive and process your personal data. We may transfer your personal data to other countries where our affiliates and service providers are located. Please note that some of these countries may have data protection laws that are different from your country (and, in some cases, may not be as protective). For AiHUB users in the EEA, Switzerland or UK, where we transfer your information to third-party service providers that are not located in Europe, and iare not in a country that benefits from an adequacy decision by the European Commission, UK or Swiss authorities, we will require those third party providers to enter into an agreement that provides appropriate safeguards for your information, including by using the EU Model Clauses and the UK International Data Transfer Addendum.

12. Additional information for users in the United States

This section of the policy applies to AiHUB users that are located in the United States. In certain U.S. states, AiHUB users have additional rights afforded to them under applicable state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act and the Virginia Consumer Data Protection Act.

(a) Categories of personal information collected by AiHUB

For more details about the personal information AiHUB has collected in the past year, please see section 1 "Information we collect". For details on how we use that information, who we share it with, and how long we keep it, please see section 2 "How we use your information", section 3 "Sharing your information", and section 8 "How long we keep your information."

(b) Rights in respect of your personal information

These state privacy laws give resident users various rights with respect to the personal information we collect, including the right to (subject to applicable law and certain limitations): - Request access to the personal information AiHUB has collected about you; - Request that AiHUB delete your personal information; - Request that AiHUB correct inaccurate personal information; - Opt out from the "sale" of your personal information; - Opt out of the "sharing" of your personal information for cross-context behavioral advertising; - Appeal decisions where we deny your rights request.

(c) Exercising your rights

You may make a request by contacting us at neo-canvas@aihub.tokyo. We will authenticate your request using the email address associated with your AiHUB account and if necessary, proof of residency. Depending on applicable state law, you may also appeal a refusal to take an action on a request by contacting us at neo-canvas@aihub.tokyo. You may opt out of the "selling or sharing" of your personal information, which may include us sharing your information with third party advertising partners as described in section 4 "Advertising" or providing your employer with information confirming whether or not you use AiHUB using their email domain, as described in section 3(d) "Your employer". You can opt out by following the instructions on the "Do not sell or share my personal information" banner, or by sending an email to neo-canvas@aihub.tokyo.

13. Changes to this Policy

We may update this policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this policy, we will revise the "Last Updated" date at the top of this policy. If we make any material changes to the way we collect, use, store and/or share your personal information, we will notify you on our website or by sending an email to the email address associated with your AiHUB account. We recommend that you check this page from time to time to inform yourself of any changes.

14. How to contact us

If you have any questions about this Privacy Policy or the Service, or wish to make a complaint, please contact us at: Email: neo-canvas@aihub.tokyo Address: AiHUB Corp. 4th Floor, MA SQUARE AKIHABARA, 2-1-1 Kanda-Sudacho, Chiyoda-ku, Tokyo 101-0041, Japan

Effective Date: May 1, 2025
AiHUB Corp.