GTGO Privacy Policy

Version: 2.4.0
Effective Date: September 30, 2026

This English version is provided for reference only. The Japanese version is the authoritative text of this Policy; in the event of any discrepancy between the two, the Japanese version prevails.

CarOwnersClub Inc. ("we," "us," or "our") sets out this Privacy Policy (the "Policy") for the handling of Users' Personal Information in the mobile application "GTGO" (the "App").

Article 1 (Personal Information)

In this Policy, "Personal Information" means "personal information" as defined in the Act on the Protection of Personal Information of Japan (the "APPI"): information about a living individual that can identify that individual through the name, date of birth, address, email address, or other descriptions contained in it, and information that contains an individual identification code.

Article 2 (Information We Obtain)

We obtain the following information.

1. Information provided by the User: email address, password, profile (display name, images, self-introduction, etc.), country and prefecture of residence, year of birth, vehicle information (including the matters stated on the vehicle inspection certificate (including the names or trade names and addresses of the owner and the user) and the electronic file of the vehicle inspection certificate), the locations of the User's reference locations such as home or workplace, favorites, and the content of inquiries and reports
2. Information obtained through the use of the App: location data (GPS coordinates, speed, heading, altitude), motion data (summarized values of acceleration and angular velocity), drive records, device information, App usage information, IP address, and the Android advertising ID
3. Information obtained from external services: when the User registers or signs in with a Google account or an Apple ID, the email address and other information provided by that service

Location data and motion data are obtained only while the User is recording a drive. To continue recording, they may also be obtained while the App is in the background.

Providing Personal Information is voluntary; however, if it is not provided, all or part of the App may be unavailable. The year of birth is required in order to verify age.

Article 3 (Purposes of Use)

We use the Personal Information we obtain for the following purposes.

1. To provide and operate the App (including account management, creating and displaying drive records, determining completion of road segments and roads, navigation, publishing Drive Achievements, sharing current position, and operating follow, friend, and Club relationships)
2. To confirm vehicle ownership based on the vehicle inspection certificate
3. To verify age
4. To respond to inquiries and reports
5. To give important notices, including notices of changes to the Terms of Use and this Policy
6. To prevent unauthorized use, respond to violations of the Terms of Use, and ensure security
7. To analyze usage, improve our services, and plan, research, and develop new products and services
8. To provide information about the products and services of us and of businesses we partner with
9. To measure the effectiveness of advertisements we place
10. To create statistical information and anonymously processed information, and to use and provide them (Article 7)
11. To perform legal obligations and manage consent history
12. For any other purpose of which we have notified the User in advance and to which the User has consented

Article 4 (Changes to the Purposes of Use)

We may change the purposes of use within the scope reasonably recognized as relevant to the purposes before the change, in which case we will notify the User of the changed purposes within the App. Any change beyond that scope, and any expansion of the purposes for which location data is used, will be made only after obtaining the User's consent again.

Article 5 (Publication and Sharing with Other Users)

1. The User's profile (display name, images, self-introduction, age bracket, and country and prefecture of residence) is published to other Users and to people without an account. The year of birth itself is not published.
2. While publication is enabled, Drive Achievements such as completing or passing through a road segment and visiting a spot are published in the feed and on the profile together with the display name, the profile image, and the vehicle used, and can also be viewed by people without an account. Publication is enabled by default and can be stopped at any time from the settings screen.
3. The User's current position while driving (including, during navigation, the destination and estimated time of arrival) is shared with people in a follow or friend relationship with the User, within the scope and under the conditions displayed in the App. Sharing is limited to the duration of a drive session and can be stopped at any time, either per person or all at once.
4. If we expand the scope of publication or sharing beyond this Article, we will obtain the User's consent again.

Article 6 (Provision to Third Parties and Entrustment)

Except in the following cases, we will not provide Personal Information to third parties without the User's prior consent.

1. Where required by laws and regulations
2. Where necessary to protect the life, body, or property of a person and it is difficult to obtain the consent of the individual
3. Where especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the consent of the individual
4. Where necessary to cooperate with a national agency, a local government, or a person entrusted by either of them in performing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the performance of those affairs

Publication and sharing with other Users under Article 5 are provisions based on the User's consent to this Policy and the User's settings.

To the extent necessary to achieve the purposes of use, we entrust the handling of Personal Information to the following businesses and supervise them appropriately. Provision to entrusted businesses and provision in connection with the succession of business due to a merger or other reasons do not constitute provision to third parties.

• Map and route guidance providers
• Cloud infrastructure providers
• Push notification and usage analytics providers
• Support chat provider (Intercom, United States)
• Address search providers
• Advertising measurement provider (Meta Platforms, Inc., United States)

We send the advertising measurement provider device information, the fact that the App was launched and that an account was registered, and the Android advertising ID; we do not send location data, drive records, email addresses, or the like. Because that provider may also use the information it receives for its own advertising services, we also treat this transmission as a provision to a third party based on consent to this Policy, and we do not send it before consent is given. On iOS, we do not obtain the Identifier for Advertisers (IDFA).

Some entrusted businesses are located outside Japan (for example, in the United States). In accordance with the APPI, we entrust handling to them after confirming that appropriate measures are continuously taken by them.

Article 7 (Statistical Information and Anonymously Processed Information)

We may process the information we obtain (including location data, motion data, and drive records) into statistical information that does not identify individuals, or into anonymously processed information as defined in the APPI, and use it ourselves or provide it to third parties (including provision for a fee). When we create or provide anonymously processed information, we will publish, in accordance with laws and regulations, the items of information it contains and the method of provision on our website. Location data around registered reference locations is not included in such information, and we will not provide drive records or similar information in a form that identifies an individual (except where required by laws and regulations).

Article 8 (Retention and Deletion)

We retain Personal Information to the extent necessary to achieve the purposes of use. When the User deletes their account, we delete that User's Personal Information. However, the following may be retained after account deletion:

• Information whose retention is required by laws and regulations
• Consent history, records of reports, and other information necessary to prevent fraud and respond to disputes
• Information contained in other Users' data, such as conversations with other Users and comments on other Users' posts
• Statistical information and anonymously processed information (Article 7)

Information that entrusted businesses hold for usage analytics and similar purposes is deleted in accordance with the retention periods set by each of them.

Article 9 (Requests for Disclosure, etc.)

As provided in the APPI, the User may make the following requests to us:

1. Notification of the purposes of use, and disclosure of Personal Information and of records of provision to third parties
2. Correction, addition, or deletion where the content of Personal Information is not true
3. Suspension of use, erasure, or suspension of provision to third parties where there are grounds provided in the APPI

Requests are accepted at the contact in Article 12 and handled in accordance with laws and regulations after identity verification by the method we designate. Where grounds provided by laws and regulations apply, we may decline all or part of a request.

A fee of 1,000 yen (including tax) per request is charged for requests for notification of the purposes of use and for disclosure.

The User can delete their account from the App's settings screen.

Article 10 (Security Control Measures)

We take necessary and appropriate measures for the security control of Personal Information. We will describe these measures in response to inquiries to the contact in Article 12.

Article 11 (Changes to this Policy)

We may change this Policy. We will give notice of changes within the App, and changes take effect when posted within the App. For an expansion of the purposes of use or any other material change, we will obtain the User's consent again through a consent dialog within the App, and we will not use Personal Information for the changed purpose until that consent is given.

Article 12 (Business Operator and Contact)

• Name of business: CarOwnersClub Inc.
• Address: Miyamasuzaka Building 609, 2-19-15 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan
• Name of representative: Kazuya Fujimoto, Representative Director
• Contact for inquiries and complaints regarding the handling of Personal Information: contact@car-owners-club.net

We are not currently a covered business of any accredited personal information protection organization. If the User is not satisfied with our response, the User may file a complaint with the Personal Information Protection Commission.

End
Established: April 28, 2026
Amended: September 30, 2026