LC Studio Privacy Policy (for Creators)

• Name: LinClone K.K.
• Address: Soshiso 402, 2-5-10 Yayoi, Bunkyo-ku, Tokyo 113-0032, Japan
• Representative: Kensei Shiraishi

The Company obtains the following information.

1. Registration information: the e-mail address, name (where provided) and account identifier received by linking a Google account or an Apple ID. Where an agency or corporation registers, its name and the name and contact details of the person in charge
2. The Principal's Materials: voice (audio files and recordings of the AI interview), photos and videos, name or stage name, and profile
3. AI Clone settings: persona, NG topics, relationship modes, visibility, permission for social media posts and official clips, and whether consent has been given to new features
4. Records of consents and confirmations: the Principal's date of birth or age bracket, the confirmation (checkbox) of the Principal's consent and of a parent's or guardian's consent and its date and time, and the invitation code
5. Identity verification information: official social media accounts, the content of exchanges for verification, and recordings of the Principal reading on-screen text aloud to confirm who owns the voice
6. Earnings and payment information: the calculation of Earnings, records of the earnings balance and withdrawals, payout destination information (financial institution accounts, remittance service accounts and the like), country of residence, and records of the purchase of the clone creation fee (including app store transaction identifiers). Payment information such as credit card numbers is obtained by the app store; the Company does not obtain it.
7. Tax information: whether the Creator is registered as a qualified invoice issuer and the registration number, payment statements (purchase statements) and records of their confirmation, and My Number (individual number) and other information necessary for tax procedures (My Number and the like only where the Company requests them)
8. Device and log information: device type, OS, app version, IP address, push notification tokens, crash information, and LC Studio usage logs (including records of viewing Follower Information)
9. The content of inquiries, reports and claims of rights infringement

The Company uses the information it obtains for the following purposes.

1. Providing LC Studio and managing accounts
2. Creating and operating AI Clones and Voice Models within the scope of Article 8 of the Creator Terms, and publishing them in the Fan App
3. Reviewing applications, verifying identity, and preventing impersonation and fraud
4. Calculating and paying Earnings and managing the clone creation fee
5. Withholding tax, preparing and submitting statutory reports such as payment records, preparing purchase statements, and other tax procedures
6. Promoting the Service as set out in Article 17 of the Creator Terms
7. Announcements, push notifications and other communications
8. Responding to inquiries, investigating trouble, responding to reports and claims of rights infringement, and responding as required by law
9. Checking whether Materials and AI Clone settings fall under the prohibited acts (including automated assessment by AI)
10. Processing information into statistics that cannot identify individuals, and improving the Service and developing new features (excluding voice Materials, recordings of the AI interview and Voice Models)
11. E-mail delivery of announcements, campaigns and the like relating to the Service

My Number is used only for preparing and submitting statutory reports under item 5. E-mails under item 11 are sent only to those who agreed to receive them at registration. Delivery can be stopped at any time from the link in each e-mail. Even if delivery is stopped, announcements necessary for using the Service, such as changes to the terms or the payment of Earnings, continue to be sent.

1. The Company uses the Principal's voice Materials and Voice Model only within the scope of Article 8 of the Creator Terms. Without the Creator's permission, it does not repurpose, provide or sell them to other services or to third parties, and does not use them to train any AI model other than that AI Clone.
2. Recordings of the AI interview are used to create the Voice Model and the AI Clone's persona (profile), and for nothing else. Recordings of reading aloud to confirm who owns the voice are used only for that confirmation.
3. Where the Company outsources the creation of Voice Models and voice synthesis to outside businesses, it does so under settings and contract terms under which the subcontractor does not use the voice Materials or Voice Models to train its own AI models. Voice Models are not published or provided to the subcontractor's other users either.
4. If the Voice Model is to be used in a new feature, the Company revises this Policy and obtains the Creator's consent for each feature in accordance with Article 9 of the Creator Terms. Consent can be withdrawn at any time.
5. Only staff authorised by the Company can access voice Materials and Voice Models, and access is recorded.
6. Voice Materials and Voice Models are deleted from the Company and its subcontractors within 30 days of the end of the contract (Article 10).

1. The following information is published in the Fan App as the AI Clone's profile. If the visibility is set to a limited URL, it is published to those who know the URL.
   1. Name or stage name, username, profile photo and profile
   2. The AI Clone's speech and voice
   3. Video and audio of LIVE broadcasts
2. The information in the preceding paragraph may also be used in app store screenshots, advertisements, the Company's official social media and official clips in accordance with Article 17 of the Creator Terms.
3. E-mail addresses, the contact details of agency staff and the like, payout destination information, tax information and identity verification information are not published to Followers.

1. The Company does not provide personal data to third parties except in the following cases.
   1. With the person's consent
   2. Where required by law (submission of statutory reports to the tax office, court orders, inquiries from investigative authorities, inquiries from bar associations and the like)
   3. Where necessary to protect a person's life, body or property and it is difficult to obtain the person's consent
   4. In connection with the succession of the business through a merger, business transfer or otherwise
2. At registration, the Creator agrees to the following provision.
   1. To pay Earnings, providing the recipient's name, the payout destination information and the payment amount to the receiving financial institution or remittance service provider
   2. Where the Principal or their representative asks whether consent was given to the creation and publication of the AI Clone, telling the Principal the registrant's name and the date of registration, after confirming that the person asking is the Principal or their representative
3. To deal with disputes over claims of rights infringement, the Company may provide the necessary information to attorneys it engages.
4. Notwithstanding the preceding paragraphs, My Number is not provided to third parties except in the cases set out in Article 19 of the My Number Act.

To the extent necessary to achieve the purposes of use, the Company may outsource the following work and entrust personal data to outside parties. The Company concludes contracts with subcontractors that include not using the entrusted personal data for anything other than the outsourced work, and supervises them appropriately.

• Storing data on cloud servers
• Creating Voice Models, generating AI Clone replies, and synthesising and recognising speech
• Remitting Earnings
• Tax and accounting processing
• Delivering push notifications and e-mail
• Analysing app crashes
• Developing and maintaining the Service
• Handling inquiries

1. The Company stores the Service's data in the cloud service provided by Amazon Web Services Japan G.K. (Amazon Web Services, "AWS"). The creation of Voice Models and voice synthesis, and the generation of AI Clone replies and speech recognition, are outsourced to and processed by outside AI businesses.

2. Storage on AWS is used under contract terms under which AWS does not handle the content of the stored data, and is managed as part of the Company's own security control measures (Article 11).
3. AI processing is carried out after a system has been established, by contract with the subcontractors, to take measures equivalent to those required by the APPI on a continuing basis. The Company periodically checks how the subcontractors are implementing those measures and, on request, provides Creators and Principals with information about them.
4. Where a foreign financial institution or remittance service is chosen as the payout destination, the name of the business, its country and that country's personal information protection system are shown on LC Studio's payout method selection screen, and the information is provided after consent has been obtained.
5. The United States has no comprehensive federal law equivalent to Japan's APPI; personal information is protected by state laws and sector-specific laws. The EU General Data Protection Regulation (GDPR) applies in the Netherlands, and the Personal Data Protection Act (PDPA) applies in Singapore. Each country's system can be checked in the Personal Information Protection Commission's survey of personal information protection systems in foreign countries.
6. My Number is not provided to third parties in foreign countries.

LC Studio currently contains no tools that send information from Creators' devices to outside businesses for usage analysis or advertising. If such tools are introduced in future, the Company will revise this Policy in advance and publish the information sent, the recipients and the purposes of use.

1. Voice Materials, Voice Models, other Materials, and the persona and other AI Clone settings are deleted from the Company and its subcontractors within 30 days of the end of the contract. Copies remaining in subcontractors' backups are erased within a further 30 days under the subcontractors' own rules. However, records required by law or needed to deal with disputes are retained for as long as needed for that purpose.
2. Registration information, records of consents and confirmations, identity verification information and records of viewing Follower Information are retained for one year after the end of the contract and then deleted. While retained, they are used only to investigate trouble and to comply with laws.
3. Records of Earnings, payments and the clone creation fee are retained for the period required by law.
4. My Number is deleted and disposed of promptly after the period necessary for tax procedures has passed, in accordance with the My Number Act.
5. The history of exchanges between the AI Clone and Followers (including the generation history remaining with the voice synthesis subcontractor) is handled in accordance with the Fan App's privacy policy.
6. Data entrusted to subcontractors is also deleted in accordance with the periods in this Article.

The Company takes the following measures to prevent the leakage and the like of personal data.

1. Basic policy: this Policy has been established and published.
2. Rules: the handling at each stage (acquisition, use, storage, provision and deletion) is set out in internal rules.
3. Organisational measures: a personal information protection manager has been appointed, and a reporting system for incidents such as leakage is in place.
4. Human measures: employees and subcontractors are bound by confidentiality obligations and are trained regularly.
5. Physical measures: measures are taken to prevent the theft and loss of devices that handle personal data.
6. Technical measures: access rights management, encryption of communications and stored data, access records, and monitoring for unauthorised access. The staff who can view voice Materials, Voice Models, payout destination information and tax information are especially limited.
7. Management of My Number: in accordance with the My Number Act, the staff who handle it are limited and it is managed separately from other information.
8. Understanding the external environment: the Company takes the measures in Article 8 after understanding the personal information protection systems of the foreign countries where personal data is handled (the United States, the Netherlands, Singapore and others).

1. Creators and Principals may ask the Company to notify the purposes of use of retained personal data, to disclose it (including disclosure by electronic record), to correct, add to or delete it, to stop using or erase it, to stop providing it to third parties, and to disclose records of its provision to third parties.
2. Even where an agency or corporation registered, the Principal may make the requests in the preceding paragraph about their own voice, appearance, name and other personal information.
3. Requests are accepted at the contact point in Article 15. After verifying identity, the Company responds without delay in accordance with laws.

1. A Principal under 13 cannot be registered. Where the Principal is 13 or over and under 18, the consent of a parent or guardian (legal representative) is confirmed with a checkbox at registration, and its date and time are recorded.
2. The personal information of a Principal under 16 is handled with the consent of a parent or guardian, and the parent or guardian may ask the Company to stop using or to erase that personal information.

The Company revises this Policy in response to changes in laws and in the Service. Important revisions are notified in LC Studio before their effective date. A revision that expands the scope of use of voice data in Article 4 is made with consent for each feature in accordance with Article 9 of the Creator Terms.

Inquiries about the handling of personal information and requests for disclosure and the like are accepted at the following contact points.

• The inquiry form in LC Studio
• By post: Personal Information Inquiries, LinClone K.K., Soshiso 402, 2-5-10 Yayoi, Bunkyo-ku, Tokyo 113-0032, Japan