Last updated: April 1, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to LootWalk, the software program provided by the Company.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to PONT Co., Ltd., Jingumae 6-23-4 Kuwano Building 2F, Shibuya, Tokyo, Japan.

• Country refers to: Japan

• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

• Personal Data is any information that relates to an identified or identifiable individual.

• Service refers to the Application.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address

• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Information regarding your location

• Information regarding your fitness and health, including daily steps

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

• To provide advertisements and marketing: To display personalized or generic advertisements in the Application based on Your preferences, interests, or usage patterns, with advertising network.

• To analyze ad performance and attribution: To evaluate the effectiveness of advertisements and understand user interactions with ads to improve our marketing strategies.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You. We may use Google Analytics and Mixpanel to collect and process analytics information on our Services.

• With Blockchain: As the blockchain is a public record, the transaction records associated with any transactions you make using the Service will be publicly available on the blockchain.

• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Advertising and Third-Party Ads

We partner with third-party advertising providers to display advertisements in the LootWalk application. These ads may be personalized based on Your preferences, usage patterns, and interests, or generic if You opt out of personalization.

How We Use Your Data for Advertising

To improve the relevance and performance of the ads You see, we may use the following types of data:

• Device Information: Including Your IP address, device type, and unique identifiers.

• Usage Information: Such as app interactions, time spent on features, and preferences.

Sharing with Advertising Partners

We may share limited data with third-party advertising partners to:

• Serve tailored advertisements.

• Measure and analyze ad performance.

• Prevent fraud or misuse in advertising campaigns.

Your Choices

You can manage Your preferences for advertising by:

• Opting out of personalized ads: Use Your device's settings to enable "Limit Ad Tracking" or similar options.

Please note that opting out of personalized ads does not prevent You from seeing ads; it only ensures that the ads You see will not be based on Your preferences or usage data.

Compliance and Transparency

We comply with all applicable advertising and privacy regulations, including Japan's Act on the Protection of Personal Information (APPI), the General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA) where applicable. EU and California residents may have additional rights regarding ad-related data processing.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your prefecture, country or other governmental jurisdiction where the data protection laws may differ from those in Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Geographic Restrictions

LootWalk services may not be available in all countries or regions. Certain features, including in-app purchases and promotional sweepstakes, are restricted in specific jurisdictions where required by local law, including but not limited to Belgium, the Netherlands, and certain jurisdictions where applicable regulations prohibit such features.

By using the Service, you represent that you are not located in a restricted jurisdiction. We reserve the right to limit access to the Service based on your location.

Act on the Protection of Personal Information (APPI)

As a company based in Japan, the Company complies with Japan's Act on the Protection of Personal Information (APPI) and related guidelines issued by the Personal Information Protection Commission (PPC). If you are a user in Japan, you have the following rights:

1. Request disclosure of personal information held about you.

2. Request correction, addition, or deletion of personal information that is inaccurate.

3. Request suspension of use or erasure of personal information if it has been handled in violation of the APPI.

4. Request suspension of provision of your personal information to third parties.

To exercise any of these rights, please contact us using the details provided in the Contact Us section below.

GDPR

If you are an EU-based user, among other rights, You also have the right to:

1. Ask whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

2. Request that we delete the personal information we hold about you in certain limited circumstances.

3. Request that we stop processing the personal information we hold about you.

4. Object to our processing of data about you.

International Transfer of Data

If you are a resident of the EU, you should know that when you access and use the Service, your data, including your personal data, as described in this Privacy Policy will be transferred outside the EU.

Legal Bases of Processing

We may rely on the following legal bases to collect and process the personal information of EU residents: consent, performance of a contract, our legal obligations and legitimate interests.

California Consumer Privacy Act (CCPA)

If You are a California-based User, among other rights, You also have the right to:

1. Obtain disclosure regarding the specific categories and pieces of Personal Information collected in reference to You.

2. Prohibit the selling of Your Personal Information, if such sale is happening.

3. Request that we delete the personal information we hold about you in certain limited circumstances.

Sale of Personal Information

We do not and will never sell or trade any personal information collected from you for monetary value. Therefore, you do not need to opt out in order to prevent the sale or trading of personal data.

"Do Not Track" Requests

Please be advised that currently we do not respond to "Do Not Track" requests.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: info@lootwalk.co