Privacy Policy | Aokumo AI

In this Privacy Policy, Aokumo Japan and Aokumo US are collectively referred to as “Aokumo,” “we,” “us,” or “our.” This Privacy Policy (the “Policy”) explains how we collect, use, disclose, store, and otherwise process personal information in connection with Aokumo AI, our websites, and related products, services, communications, and business activities (collectively, the “Services”).

1. Scope and Our Role

1. This Policy applies to personal information relating to: users and authorized users of the Services; visitors to our websites; prospective and existing customers; business contacts; individuals who contact Aokumo or participate in our events, demonstrations, or other business activities; and other individuals whose personal information we process in connection with the Services. 2. When Aokumo processes Customer Data on behalf of an enterprise customer and under that customer’s instructions, Aokumo generally acts as a processor, service provider, contractor, or equivalent role under applicable privacy law. 3. When Aokumo determines the purposes and means of processing personal information, including for account administration, billing, website operation, security, sales, and business communications, the relevant Aokumo entity acts as the controller, business, personal information handling business operator, or equivalent responsible entity under applicable law. 4. Processing of Customer Data may also be governed by the Aokumo AI Terms of Service, an Order Form, a Data Processing Addendum, or another agreement between Aokumo and the relevant customer. If such agreement conflicts with this Policy regarding Customer Data, the applicable agreement will control with respect to that processing.

2. Aokumo Entities

The Aokumo entity responsible for a particular processing activity depends on the relationship with the individual or customer and, where applicable, the entity identified in the applicable Order Form or other agreement. Aokumo Inc. (Japan): Pacific Century Place Marunouchi 13F, 1-11-1 Marunouchi, Chiyoda-ku, Tokyo 100-6208, Japan. Aokumo, Inc. (United States): A Delaware corporation, 1111B S Governors Ave STE 82641, Dover, DE 19904. Where an Order Form identifies a particular Aokumo entity as the contracting party, that entity will generally be responsible for account, contractual, billing, and customer-relationship processing associated with that agreement. Unless otherwise specified in an applicable agreement or notice, Aokumo Japan is responsible for this Policy.

3. Definitions

For purposes of this Policy: 1. “Personal Information” means information relating to an identified or identifiable individual and includes equivalent concepts under applicable privacy laws. 2. “Personal Data” includes personal data as defined under the Act on the Protection of Personal Information of Japan (“APPI”) where applicable. 3. “Retained Personal Data” means retained personal data as defined under APPI where applicable. 4. “Customer Data” means information, content, files, code, configurations, prompts, instructions, records, and other data submitted to, transmitted through, or made available to the Services by or on behalf of a customer, including information obtained from customer-authorized integrations. 5. “Third-Party Service” means a cloud service, document-management service, source-code management service, collaboration platform, monitoring service, security service, AI service, API, or other service provided by a third party.

4. Information We Collect

We may collect the following categories of information. 4.1 Account and Contact Information — name; company or organization; department; job title; email address; telephone number; user ID; and other information provided when an account is created or managed. 4.2 Contract and Transaction Information — subscription or service plan; contract information; Order Form information; billing and invoicing information; payment status; transaction records; and other information relating to the commercial relationship with Aokumo. 4.3 Service Usage and Technical Information — login and authentication activity; activity and operation records; features used; access timestamps; IP address; browser and device information; diagnostic information; audit logs; security logs; and error and performance logs. 4.4 Information Provided to the Services — text; files; documents; source code; configurations; infrastructure information; instructions; prompts; runbooks; scripts; and other content submitted or made available through the Services. 4.5 Information from Connected Third-Party Services — if a customer or user enables an integration with a Third-Party Service, Aokumo may obtain or process information from that service within the permissions authorized by the customer or user. Depending on the integration and permissions granted, this may include files and file contents; metadata; source code; repository information; cloud resource information; infrastructure information; configurations; security findings; monitoring and observability data; logs; messages; and other information available through the connected service. We seek to access and process only the information reasonably necessary to provide the functionality requested by the customer or user. 4.6 Communications and Business Information — support requests; inquiries; meetings; sales discussions; demonstrations; events; surveys; correspondence; and other interactions with Aokumo.

5. How We Use Information

We may use information for the following purposes: 1. to provide, operate, maintain, and support the Services; 2. to create and manage accounts; 3. to authenticate users and manage authorization and access; 4. to connect with Third-Party Services authorized by customers; 5. to retrieve, search, analyze, summarize, correlate, or otherwise process information requested by users; 6. to generate AI-based analyses, recommendations, code, scripts, execution plans, and other outputs; 7. to provide policies, approvals, access controls, audit capabilities, and other governance functionality; 8. to perform actions against Customer Environments within the permissions and configurations authorized by customers; 9. to provide support and respond to questions and requests; 10. to monitor, maintain, troubleshoot, secure, and improve the reliability and performance of the Services; 11. to detect, investigate, prevent, and respond to fraud, misuse, security threats, unauthorized access, vulnerabilities, failures, and other technical issues; 12. to administer contracts, billing, accounts, and transactions; 13. to communicate regarding the Services, including administrative, security, support, and service-related communications; 14. to send information regarding Aokumo products, events, services, or other business matters where permitted by applicable law; 15. to comply with applicable laws, regulations, legal processes, and lawful governmental requests; 16. to establish, exercise, or defend legal rights and claims; 17. to protect the rights, property, safety, and security of Aokumo, our customers, users, and others; and 18. for other purposes disclosed at the time information is collected or otherwise permitted by applicable law. We do not use Customer Data for advertising or marketing.

6. Customer Data and AI Processing

1. As between Aokumo and the customer, the customer or applicable rights holder retains its rights in Customer Data. 2. We process Customer Data only as reasonably necessary to: provide and operate the Services; perform functions requested or configured by the customer; provide customer support; protect the security of the Services and Customer Data; detect and respond to failures, misuse, fraud, or security incidents; and comply with applicable law and lawful legal process. 3. We do not sell Customer Data. 4. We do not use Customer Data for advertising or marketing. 5. We do not use Customer Data or AI Output based on Customer Data to create, train, retrain, fine-tune, or improve general-purpose AI or machine learning models for Aokumo or third parties, except for processing performed solely for the relevant customer in order to provide functionality to that customer. 6. Where necessary to provide the Services, Customer Data or portions of Customer Data may be transmitted to and processed by AI service providers, cloud providers, or other subprocessors used by Aokumo. 7. Aokumo requires service providers processing Customer Data on its behalf to handle such information subject to appropriate contractual, privacy, and security requirements. 8. We may use information that has been aggregated or reasonably de-identified so that it does not identify a customer or individual to operate, secure, analyze, and improve the Services. 9. We do not attempt to re-identify information that has been de-identified for these purposes.

7. Third-Party Integrations

1. Customers may choose to connect the Services with Third-Party Services. 2. When an integration is enabled, Aokumo processes information obtained from the Third-Party Service: within the access permissions authorized by the customer or user; only as reasonably necessary to provide the requested functionality; and in accordance with applicable contractual and legal requirements. 3. Customer Data obtained from Third-Party Services is subject to Section 6 of this Policy. 4. Customer personnel may generally disconnect an integration or revoke Aokumo’s access through the applicable Third-Party Service or through functionality provided by Aokumo, where available. 5. A Third-Party Service’s own processing of information is governed by that provider’s terms, privacy policy, and other applicable conditions.

8. Google Workspace Data

Where the Services access information through Google Workspace APIs: 1. Aokumo’s use and transfer of information received from Google Workspace APIs will comply with the Google API Services User Data Policy, including the Limited Use requirements. 2. Aokumo uses Google Workspace user data only to provide or improve user-facing functionality requested or authorized by the user. 3. Aokumo does not sell Google Workspace user data. 4. Aokumo does not use Google Workspace user data for advertising, personalized advertising, advertising profiling, creditworthiness determinations, or lending purposes. 5. Aokumo does not use Google Workspace user data to create, train, retrain, fine-tune, or improve a general-purpose artificial intelligence or machine learning model beyond processing performed for the specific user’s permitted use case. 6. Aokumo personnel will not access the contents of Google Workspace user data except where: the user has provided explicit consent or affirmative agreement to access specific data; access is necessary for security purposes, including investigation of abuse, vulnerabilities, or technical issues; the information has been aggregated and anonymized and is used for permitted internal operations; access is required to comply with applicable law or legal process; or access is otherwise expressly permitted under applicable Google policies. 7. Aokumo will not transfer Google Workspace user data to third parties except where permitted under Google’s applicable policies. 8. Users may revoke Aokumo’s Google access through their Google account settings or through functionality made available by Google or Aokumo. 9. Users may request deletion of Google Workspace user data retained by Aokumo by contacting us using the information in Section 22, subject to applicable legal, security, backup, and contractual retention requirements. 10. If another provision of this Policy would permit broader use, access, or disclosure of Google Workspace user data than Google’s applicable policies permit, this Section will control with respect to Google Workspace user data.

9. Disclosure and Service Providers

We may disclose or make information available as follows. 9.1 Service Providers and Subprocessors — we may use third parties to provide services such as cloud infrastructure; hosting; databases; authentication; artificial intelligence; monitoring; logging; security; communications; customer support; and other infrastructure or operational services. Such providers may process information only as necessary to provide services to Aokumo or as otherwise permitted by applicable agreement and law. 9.2 Aokumo Affiliates — Aokumo Japan and Aokumo US may share information where reasonably necessary to provide and support the Services, subject to applicable law. 9.3 Legal Requirements and Protection of Rights — we may disclose information where reasonably necessary to: comply with applicable law or regulation; respond to valid legal process or lawful governmental requests; investigate or prevent fraud, abuse, security threats, or unlawful conduct; protect the rights, safety, property, or security of Aokumo, our customers, users, or others; or establish, exercise, or defend legal claims. 9.4 Corporate Transactions — information may be disclosed or transferred in connection with an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, subject to applicable law, contractual restrictions, and, for Google Workspace user data, Section 8.

10. International Data Processing and Foreign Transfers

1. Personal Information and Customer Data may be processed in Japan, the United States, and other countries where Aokumo’s service providers operate. 2. In particular, information may be transferred to or processed in the United States where U.S.-based service providers support the Services. 3. Depending on the Third-Party Services used to provide the Services, information may also be processed in other countries or regions. 4. Where Aokumo transfers Personal Data outside Japan or another jurisdiction with applicable international-transfer requirements, Aokumo will take measures required by applicable law. Such measures may include obtaining required consent, using appropriate contractual safeguards, or relying on another transfer mechanism permitted by applicable law. 5. Where required by applicable law, Aokumo will provide information regarding relevant destination countries, recipients, privacy frameworks, or safeguards upon request. 6. Where Personal Data is handled outside Japan, Aokumo takes the applicable foreign legal and regulatory environment into account as part of its security management measures.

11. Legal Bases for Processing

Where applicable law requires a legal basis for processing Personal Information, Aokumo may rely on one or more of the following: 1. Performance of a contract, where processing is necessary to provide the Services or fulfill an agreement; 2. Legitimate interests, including operating and improving the Services, securing our systems, communicating with customers, preventing fraud and abuse, and conducting reasonable business operations, where those interests are not overridden by applicable individual rights; 3. Consent, where we request and receive consent for a particular processing activity; 4. Compliance with legal obligations; and 5. Protection of rights and safety, where processing is necessary to protect legal rights or the safety of Aokumo, our customers, users, or others. Where processing is based on consent, consent may be withdrawn where permitted by applicable law without affecting the lawfulness of processing carried out before withdrawal.

12. Data Retention and Deletion

1. We retain Personal Information only for as long as reasonably necessary for the purposes described in this Policy, including: providing the Services; maintaining customer relationships; fulfilling contractual obligations; maintaining security; resolving disputes; complying with legal requirements; and enforcing agreements. 2. Following termination or expiration of the applicable customer agreement, Aokumo will use commercially reasonable efforts to delete Customer Data from active systems within ninety (90) days unless: a different period is specified in an Order Form or Data Processing Addendum; retention is required by applicable law; retention is reasonably necessary for security, fraud prevention, dispute resolution, or enforcement of an agreement; or otherwise agreed with the customer. 3. Customer Data contained in backups may remain until deleted or overwritten in accordance with Aokumo’s normal backup lifecycle. 4. Disconnecting a Third-Party Service does not necessarily delete information previously stored in the Services. Such information remains subject to the retention and deletion provisions described above.

13. Security

1. Aokumo maintains reasonable and appropriate technical and organizational safeguards designed to protect Personal Information and Customer Data under our control against unauthorized access, disclosure, alteration, loss, destruction, or misuse. 2. Depending on the Services and the nature of the information, these safeguards may include: authentication and authorization; access controls; least-privilege principles; encryption in transit and at rest; logging and monitoring; vulnerability management; backup and recovery controls; security testing; incident-response processes; and organizational security measures. 3. Where Personal Data is handled outside Japan, Aokumo takes into account the applicable foreign legal and regulatory environment as part of its security management measures. 4. No system can be guaranteed to be completely secure. Customers are responsible for maintaining appropriate security controls over Customer Environments, account credentials, permissions, and systems outside Aokumo’s control. 5. Additional information regarding Aokumo’s security practices may be made available through Aokumo’s security documentation or customer agreements.

14. Security Incidents

If Aokumo becomes aware of a security incident affecting Personal Information or Customer Data under our control, we will take measures appropriate to the nature and impact of the incident, which may include investigation, containment, identification of affected systems and information, remediation, recovery, and required notifications. Where applicable law or an applicable agreement requires notification or reporting, Aokumo will notify affected customers, individuals, regulators, or other relevant parties as required.

15. Cookies and External Transmission Technologies

1. Aokumo websites and Services may use cookies, analytics tools, tags, pixels, and similar technologies for purposes including: authentication; security; session management; remembering preferences; understanding website and Service usage; analytics; maintaining performance; and improving the user experience. 2. Where required by applicable law, Aokumo will obtain consent or provide other legally required disclosures before using non-essential technologies. 3. Where required, information regarding material external transmission tools used on Aokumo websites, including the provider, information transmitted, and purpose of transmission, will be provided through a separate Cookie Notice, External Transmission Notice, or equivalent disclosure. 4. Users may be able to manage cookies through browser controls or other settings made available by Aokumo. 5. Disabling certain cookies may affect functionality of the Services.

16. Marketing Communications

1. Aokumo may send product updates, event information, business communications, or other marketing communications where permitted by applicable law. 2. Recipients may unsubscribe from marketing email through the unsubscribe mechanism in the applicable communication or by contacting Aokumo. 3. Opting out of marketing communications does not prevent Aokumo from sending transactional, security, account, legal, or other service-related communications. 4. Customer Data is not used to determine who receives Aokumo marketing communications.

17. Privacy Rights

Depending on your location and applicable law, you may have rights relating to Personal Information, including rights to: request access; obtain information about processing; request correction; request deletion or erasure; request restriction or suspension of processing; object to certain processing; request portability; withdraw consent where applicable; request information concerning third-party disclosures; and lodge a complaint with an applicable supervisory or regulatory authority. These rights may be subject to exceptions and limitations under applicable law. To exercise a privacy right, contact us using the information in Section 22. We may request information reasonably necessary to verify identity and authority. We will not discriminate against an individual for exercising a right protected by applicable law.

18. Customer-Controlled Personal Information

Where Aokumo processes Personal Information contained in Customer Data on behalf of an enterprise customer: 1. the customer may be responsible for responding to requests from individuals regarding that information; 2. individuals should generally direct requests concerning Customer Data to the organization that provided or controls the data; and 3. Aokumo will provide reasonable assistance to the customer as required by applicable law and the applicable agreement.

19. Rights Under Japanese Privacy Law

Where APPI applies, individuals may have rights regarding Retained Personal Data held by Aokumo, including rights to request, where applicable: notification of the purpose of use; disclosure; correction; addition; deletion; suspension of use; erasure; and suspension of provision to third parties. Requests may be made using the contact information in Section 22. Aokumo does not currently charge a fee for reasonable requests made under this Section. If Aokumo introduces a legally permitted fee for particular requests in the future, the applicable amount and procedure will be disclosed in advance.

20. Children’s Privacy

The Services are intended for businesses and professional users and are not directed to children. Aokumo does not knowingly collect Personal Information from children through the Services in circumstances where parental or guardian consent would be legally required. If you believe a child has provided Personal Information to Aokumo inappropriately, please contact us.

21. Changes to this Policy

1. We may update this Policy from time to time to reflect changes in the Services, our processing practices, applicable laws, regulatory requirements, or other operational circumstances. 2. When we update this Policy, we will update the effective date above. 3. If a change materially affects how we process Personal Information, we will provide additional notice where required by applicable law. 4. Where applicable law requires consent to a change, we will obtain such consent.

22. Contact Us

For privacy questions, requests, complaints, or requests for information concerning international data transfers, please contact:

Aokumo Inc. (Japan)

Pacific Century Place Marunouchi 13F, 1-11-1 Marunouchi, Chiyoda-ku, Tokyo 100-6208, Japan

Representative: Younes Hairej

Privacy Contact: privacy@aokumo.io

Aokumo, Inc. (United States)

A Delaware corporation, 1111B S Governors Ave STE 82641, Dover, DE 19904

Privacy Contact: privacy@aokumo.io

We will respond to privacy inquiries and requests in accordance with applicable law.

23. Language

This Policy is drafted in English for global use. Any translation is provided for convenience unless expressly stated otherwise. In the event of any inconsistency between this global English Policy and a translation of this Policy, the English version will prevail. Where an applicable agreement or locally issued privacy notice expressly states that another language version controls for a particular customer, jurisdiction, or processing activity, that specified version will control for that purpose.

Effective September 27, 2026

Aokumo Inc. (Japan) · Aokumo, Inc. (United States)