Privacy Policy

Last Updated: January 10, 2026

Pierini (“we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services.

Please read this Privacy Policy carefully. By using our website, you consent to the practices described in this policy.

Table of Contents Information We Collect How We Use Your Information Legal Basis for Processing (GDPR) How We Share Your Information International Data Transfers Data Retention Your Privacy Rights Cookies and Tracking Technologies Security of Your Information Children’s Privacy Third-Party Websites Changes to This Privacy Policy Japanese Legal Compliance Contact Information

1. Information We Collect We collect information about you in various ways when you use our website and services.

1.1 Personal Information You Provide to Us We may collect personal information that you voluntarily provide to us, including:

Contact Information: Name, email address, phone number, mailing address Account Information: Username, password, profile information Communication Data: Information you provide when contacting us (emails, messages, feedback) Transaction Information: Payment details, billing information, purchase history (if applicable) Professional Information: Company name, job title, business information (if relevant to our services) 1.2 Information Automatically Collected When you visit our website, we automatically collect certain information about your device and browsing behavior:

Device Information: IP address, browser type and version, operating system, device identifiers Usage Data: Pages viewed, time spent on pages, links clicked, referring website, access times Location Data: General geographic location based on IP address Cookies and Tracking Data: Information collected through cookies and similar technologies (see our Cookie Policy) 1.3 Information from Third Parties We may receive information about you from third-party sources, including:

Analytics Providers: Google Analytics and similar services Social Media Platforms: If you interact with us through social media Business Partners: If you are referred to us by a partner or affiliate Public Sources: Publicly available information that may be relevant to our business relationship 2. How We Use Your Information We use the information we collect for the following purposes:

2.1 Providing and Improving Our Services Deliver, operate, and maintain our website and services Process transactions and send related information Respond to your inquiries and provide customer support Improve user experience and website functionality Develop new features and services 2.2 Communication Send administrative information, updates, and security alerts Respond to your comments, questions, and requests Send marketing and promotional communications (with your consent) Conduct surveys and gather feedback 2.3 Analytics and Performance Analyze website usage and trends Monitor and analyze the effectiveness of our services Generate statistical data and reports Perform research and data analysis 2.4 Legal and Security Purposes Comply with legal obligations and regulatory requirements Protect against fraud, unauthorized access, and other illegal activities Enforce our terms of service and other agreements Protect the rights, property, and safety of our users and third parties 2.5 Marketing (with consent where required) Provide personalized content and recommendations Deliver targeted advertisements Measure the effectiveness of our marketing campaigns 3. Legal Basis for Processing (GDPR) If you are located in the European Economic Area (EEA) or other jurisdictions with similar regulations, we process your personal information based on the following legal grounds:

Consent: When you have given explicit consent for specific processing activities Contract Performance: When processing is necessary to fulfill our contractual obligations to you Legal Obligation: When we must process your data to comply with legal requirements Legitimate Interests: When processing is necessary for our legitimate business interests, provided these do not override your rights and freedoms You have the right to withdraw consent at any time where we rely on consent as the legal basis for processing.

4. How We Share Your Information We do not sell, rent, or trade your personal information to third parties. However, we may share your information in the following circumstances:

4.1 Service Providers We may share information with third-party service providers who perform services on our behalf, including:

Web hosting and cloud storage providers Payment processors Email service providers Analytics providers (e.g., Google Analytics) Customer support services Marketing and advertising partners These service providers are contractually obligated to use your information only for the purposes we specify and to protect your data.

4.2 Business Transfers If we are involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

4.3 Legal Requirements We may disclose your information when required to do so by law or in response to:

Court orders, subpoenas, or other legal processes Government or regulatory requests Protection of our rights, property, or safety Investigation of fraud or security issues Enforcement of our terms and policies 4.4 With Your Consent We may share your information with third parties when you have given us explicit consent to do so.

5. International Data Transfers Our website is operated from [your location/country]. If you are accessing our services from outside Japan, please be aware that your information may be transferred to, stored, and processed in Japan or other countries where we or our service providers operate.

For users in the EEA, we ensure that any international data transfers comply with GDPR requirements through appropriate safeguards such as:

Standard Contractual Clauses (SCCs) Adequacy decisions by the European Commission Other legally recognized transfer mechanisms By using our services, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection laws.

6. Data Retention We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention Periods: Account Information: Retained while your account is active, plus 3 years after account closure Transaction Records: Retained for 7 years for accounting and legal compliance purposes Communication Records: Retained for 3 years from the last interaction Analytics Data: Typically retained for 24 months Marketing Data: Retained until you opt out or withdraw consent, plus 1 year When we no longer need your information, we will securely delete or anonymize it so that it cannot be attributed to you.

7. Your Privacy Rights Depending on your location, you may have the following rights regarding your personal information:

7.1 Rights Under GDPR (EEA Residents) Right of Access: Request a copy of your personal data Right to Rectification: Request correction of inaccurate or incomplete data Right to Erasure: Request deletion of your personal data (“right to be forgotten”) Right to Restrict Processing: Request limitation of how we use your data Right to Data Portability: Receive your data in a structured, machine-readable format Right to Object: Object to processing based on legitimate interests or for direct marketing Right to Withdraw Consent: Withdraw consent at any time (where consent is the legal basis) Right to Lodge a Complaint: File a complaint with your local data protection authority 7.2 Rights Under Japanese Law (個人情報保護法) Under Japan’s Act on the Protection of Personal Information, you have the right to:

Request disclosure of your personal information Request correction, addition, or deletion of your personal information Request suspension of use or deletion of your personal information Request suspension of provision to third parties File a complaint with the Personal Information Protection Commission 7.3 California Residents (CCPA) If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to know what personal information is collected Right to know whether personal information is sold or disclosed Right to opt-out of the sale of personal information Right to deletion of personal information Right to non-discrimination for exercising your rights Note: We do not sell personal information to third parties.

7.4 How to Exercise Your Rights To exercise any of these rights, please contact us at:

Email: pier_alberto@pierini.com Subject Line: “Privacy Rights Request” We will respond to your request within:

30 days (GDPR) 30 days (Japanese law) 45 days (CCPA) We may need to verify your identity before processing your request.

8. Cookies and Tracking Technologies We use cookies and similar tracking technologies to collect information about your browsing activities. For detailed information about our use of cookies, including the types of cookies we use and how to manage them, please see our Cookie Policy.

9. Security of Your Information We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption: SSL/TLS encryption for data transmission Access Controls: Limited access to personal data on a need-to-know basis Secure Storage: Encrypted storage of sensitive information Regular Security Assessments: Periodic reviews of our security practices Employee Training: Staff training on data protection and privacy Incident Response: Procedures for responding to data breaches However, please be aware that no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

Data Breach Notification In the event of a data breach that affects your personal information, we will notify you and relevant authorities as required by applicable law, typically within 72 hours of becoming aware of the breach.

10. Children’s Privacy Our website and services are not intended for children under the age of 13 (or the applicable age of digital consent in your jurisdiction, which may be 16 in some countries).

We do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately at pier_alberto@pierini.com.

If we discover that we have inadvertently collected personal information from a child, we will delete that information as quickly as possible.

11. Third-Party Websites Our website may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to those third-party sites.

We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

The inclusion of any link does not imply our endorsement of the linked site or service.

12. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.

When we make material changes to this Privacy Policy:

We will update the “Last Updated” date at the top of this page We may notify you via email or through a prominent notice on our website For significant changes, we may seek your renewed consent where required by law We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Your continued use of our website after changes are posted constitutes your acceptance of the updated Privacy Policy.

13. Japanese Legal Compliance (日本の法令遵守) 13.1 Act on the Protection of Personal Information (個人情報保護法) We comply with Japan’s Act on the Protection of Personal Information in our collection, use, and management of personal information.

Personal Information Administrator (個人情報管理責任者):

Name: Pierini Email: pier_alberto@pierini.com 13.2 Purpose of Use (利用目的) The purposes for which we use personal information are clearly stated in Section 2 of this Privacy Policy.

13.3 Third-Party Provision (第三者提供) We will not provide personal information to third parties without your consent, except as permitted by law or as described in Section 4 of this Privacy Policy.

13.4 Complaints and Inquiries (苦情及びお問い合わせ) For complaints or inquiries regarding the handling of personal information, please contact us using the information in Section 14.

You may also file a complaint with: Personal Information Protection Commission (個人情報保護委員会)

Website: https://www.ppc.go.jp/en/ Phone: 03-6457-9680 (Japanese language support) 13.5 Recognized Personal Information Protection Organization [If applicable, include information about any recognized personal information protection organization you belong to]

14. Contact Information If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: pier_alberto@pierini.com Name: Pierini Response Time: We aim to respond to all inquiries within 5 business days

For specific privacy-related requests, please include:

“Privacy Inquiry” in your email subject line Your full name and contact information A detailed description of your request Any relevant account information (without including passwords) We are committed to working with you to obtain a fair resolution of any privacy concerns.