Legal Documents

DARE Privacy Policy

Effective Date: May 29, 2026

SystemMetrix Co., Ltd. (the "Company," "we," "us," or "our") establishes this Privacy Policy (this "Policy") to explain how we collect, use, disclose, transfer, retain, and protect personal data obtained in connection with DARE accounts, DARE Store, DARE-related Windows desktop applications, license management, support, and other related services that we provide in the Covered Territory.

By creating a DARE Account, purchasing a Paid License, or using the Service, you acknowledge that the Company will handle Personal Data in accordance with this Policy. Where consent is required under applicable law, the Company will obtain the necessary consent.

1. Definitions

For purposes of this Policy, the following terms have the meanings set forth below.

• 1. "Application" means the DARE-related Windows desktop application provided by the Company in the Covered Territory.
• 2. "DARE Account" means the account used by the User in connection with the Service or the Application.
• 3. "DARE Store" means the online store provided by the Company through which Users may purchase or manage Paid Licenses for the Application.
• 4. "Paid License" means paid features of the Application, the right to use paid features of the Application, or the paid right to use the Application, purchased by the User through DARE Store.
• 5. "Personal Data" means data, whether true or not, about an individual who can be identified from that data or from that data and other information to which the Company has or is likely to have access.
• 6. "Service" means the DARE Account, DARE Store, purchase and management of Paid Licenses, license management, support, and other related services that the Company provides in connection with DARE in the Covered Territory.
• 7. "Covered Territory" means the country or region designated in this Policy as the territory in which the Service is provided.
  Covered Territory as of the effective date of this Policy: Singapore.

2. Scope of This Policy

This Policy applies to Personal Data that the Company collects, uses, discloses, transfers, retains, or otherwise processes in connection with the Service and the Application.

Services provided by the Company for the Japanese domestic market, including the Japanese domestic DARE Store, DARE BOX, DARE ONE, DARE Legacy, and other related services, are subject to the privacy policy or terms separately established by the Company for Japan-facing services.

If the Company provides services in the future that are outside the scope of this Policy, the Company may establish separate or additional privacy policies for such services.

3. Personal Data We Collect

The Company collects Personal Data and related information, including the information described below, by lawful and fair means.

3.1 Information Provided Directly by the User

When the User creates or uses a DARE Account, contacts the Company, or uses the Service, the Company may collect the following information:

1. email address;
2. password or authentication information when the User registers using an email address and password;
3. name, company name, contact information, and other information provided by the User;
4. inquiry details, support history, and communications with the Company; and
5. files, screenshots, logs, and other materials voluntarily submitted by the User for support or troubleshooting purposes.

Passwords are managed using security measures such as hashing, encryption, or similar safeguards. The Company does not store passwords in plain text and cannot directly view the User's password.

3.2 Information Obtained Through OAuth or External Login Providers

If the User logs in using Google, Microsoft, or another external account supported by the Company, the Company may collect the following information to the extent the User has authorized the external login provider to share such information with the Company:

1. display name or user name;
2. email address;
3. profile image or icon; and
4. other information provided based on the User's settings and consent with the external login provider.

The handling of Personal Data by the external login provider is governed by that provider's privacy policy and terms.

3.3 License Authentication and B-rite-Related Information

In connection with license authentication, license management, security, prevention of unauthorized use, error analysis, and operation of the Application, the Company may collect the following information:

1. device identifiers;
2. Windows user name;
3. email address;
4. DARE Account ID;
5. license token;
6. license status;
7. authentication date and time;
8. license usage logs; and
9. error logs.

The Application is designed, in principle, to process drawings and local files on the User's device. The Company does not normally collect or transmit the contents of drawings or local files processed by the Application. However, if the User voluntarily submits files, screenshots, logs, or other materials for support or troubleshooting purposes, the Company may process those materials for the purposes described in this Policy.

3.4 Purchase, Subscription, and Payment-Related Information

When the User purchases or manages a Paid License through DARE Store, the purchase and payment processing may be handled by Paddle, acting as Merchant of Record.

The Company does not directly collect or store the User's credit card number, card security code (CVV), or other payment card information. Such payment information is processed by Paddle and handled in accordance with Paddle's security standards, including PCI-DSS, where applicable.

The Company may receive the following information from Paddle to the extent necessary for purchase management, license issuance, accounting, support, prevention of unauthorized use, and compliance with applicable laws:

1. purchase history;
2. order ID, transaction ID, or payment ID;
3. subscription status;
4. billing information;
5. information regarding refunds, cancellations, chargebacks, or payment status;
6. information regarding taxes, invoices, and receipts; and
7. other information reasonably necessary to manage purchases or Paid Licenses.

Paddle's collection and processing of Personal Data are also subject to Paddle's privacy policy, buyer-facing terms, and other applicable terms.

3.5 Technical Information, Device Information, Cookies, and Analytics Information

When the User accesses or uses the Service, DARE Store, the Company's website, or the Application, the Company may collect the following technical and usage information:

1. IP address;
2. cookie identifiers and similar technologies;
3. device information;
4. browser type and version;
5. operating system;
6. language settings;
7. access date and time;
8. pages viewed;
9. actions within the Service;
10. access and usage logs; and
11. diagnostic or error information.

The Company uses Google Analytics to understand how Users access and use the Company's website and the Service. Google Analytics may collect usage information using cookies and similar technologies. When using Google Analytics, the Company takes reasonable measures, where possible, to enable IP anonymization or otherwise process data in a manner that does not identify individuals. Google's applicable policies govern Google's handling of data.

4. Purposes of Use of Personal Data

The Company uses Personal Data for the following purposes:

1. to create, provide, maintain, and manage DARE Accounts;
2. to authenticate Users and manage login sessions;
3. to provide, operate, maintain, and improve the Service and the Application;
4. to issue, activate, authenticate, manage, suspend, or terminate Paid Licenses;
5. to manage purchases, subscriptions, billing, refunds, cancellations, chargebacks, taxes, invoices, and receipts;
6. to communicate or coordinate with Paddle regarding purchases, payments, refunds, chargebacks, subscriptions, or licenses;
7. to respond to inquiries, support requests, complaints, and troubleshooting requests;
8. to analyze errors, diagnose issues, maintain quality, and improve features;
9. to protect the security and integrity of the Service, the Application, DARE Store, and DARE Accounts;
10. to detect, investigate, prevent, or respond to unauthorized access, fraud, misuse, license abuse, violations of terms, or other illegal or inappropriate acts;
11. to send important administrative notices regarding the Service, the Application, purchases, subscriptions, licenses, security, updates, policy changes, and similar matters;
12. to analyze usage of the Service through Google Analytics and similar tools and improve the user experience;
13. to provide information about the Company's products, services, updates, or related services, to the extent permitted by applicable law and subject to any required consent or opt-out opportunity;
14. to comply with legal, regulatory, tax, accounting, export control, sanctions, and other compliance obligations;
15. to establish, exercise, defend, or resolve legal claims or disputes; and
16. for purposes reasonably related to the foregoing purposes or for other purposes notified to the User at the time of collection.

5. Cookies and Google Analytics

The Company may use cookies and similar technologies, including Google Analytics, to analyze usage of the Service, improve functionality, maintain security, and understand how Users interact with the Company's website and the Service.

The User may manage or disable cookies through browser settings, settings provided by Google, or cookie settings provided by the Company. If cookies are disabled, some features of the Service may not function properly.

If the Company introduces additional advertising, remarketing, or tracking technologies in the future, the Company may update this Policy or provide additional notices in accordance with applicable law.

6. Paddle and Payment Processing

Purchases of Paid Licenses through DARE Store may be processed by Paddle, acting as Merchant of Record. Paddle may process sales, payments, billing, taxes, receipts, refunds, chargebacks, and other related purchase procedures.

The Company may disclose information to Paddle or receive information from Paddle to the extent necessary to process and manage purchases, subscriptions, refunds, cancellations, chargebacks, licenses, and related support.

Paddle may independently collect and process Personal Data in accordance with Paddle's own privacy policy, buyer-facing terms, refund policy, and other applicable terms. Users are encouraged to review Paddle's privacy policy and applicable terms when completing a purchase.

7. Service Providers and Disclosure to Third Parties

The Company does not sell Personal Data.

The Company may disclose or make available Personal Data to the following categories of recipients to the extent necessary for the purposes described in this Policy:

1. payment and purchase processing providers, including Paddle;
2. cloud hosting, infrastructure, and system operation providers;
3. authentication, account management, and security service providers;
4. customer support tools and providers, including Zendesk or similar support service providers;
5. analytics service providers, including Google Analytics;
6. email delivery, notification, and communication service providers;
7. lawyers, accountants, tax advisors, auditors, consultants, and other professional advisors;
8. government authorities, regulators, courts, law enforcement agencies, and other third parties where required or permitted by law;
9. successors or potential successors in connection with a merger, acquisition, reorganization, business transfer, financing, or similar transaction; and
10. other third parties based on the User's consent or instructions.

8. International Transfers

The Company is located in Japan, and the Company's service providers may operate in Japan, Singapore, and other countries. Accordingly, Personal Data may be transferred to, stored in, or processed outside the User's country or region of residence.

Where required by applicable law, the Company takes reasonable steps, through contractual terms, agreements with service providers, or other mechanisms permitted under applicable law, to ensure that Personal Data transferred internationally receives a standard of protection comparable to that required under the applicable data protection laws of the Covered Territory.

9. Retention Period of Personal Data

The Company retains Personal Data only for as long as reasonably necessary for the purposes described in this Policy or for the period required or permitted by applicable law.

In particular:

1. DARE Account information may be deleted by the User through the DARE Account where that function is available. If the User withdraws from the international version of DARE or deletes the DARE Account, the Company will delete or deactivate Personal Data necessary for the continued use of that account. However, the Company may retain the minimum necessary information for a certain period where necessary for legal, accounting, tax, billing, refund handling, fraud prevention, security, support, dispute resolution, or compliance purposes.
2. Information relating to purchases, billing, invoices, taxes, refunds, and chargebacks may be retained for the period required or permitted by applicable laws and tax and accounting requirements.
3. Support inquiries, support history, and materials voluntarily submitted by the User for support purposes may be retained for the period necessary for inquiry handling, quality improvement, dispute resolution, and related support purposes.

When Personal Data is no longer needed, the Company deletes, anonymizes, or otherwise handles such Personal Data in an appropriate manner in accordance with applicable law and the Company's internal procedures.

10. Security

The Company takes reasonable technical and organizational measures to protect Personal Data against unauthorized access, loss, misuse, disclosure, alteration, or destruction.

Such measures may include access controls, authentication management, encryption or similar safeguards, log management, internal rules, employee access restrictions, and management of service providers.

However, no method of transmission or storage is completely secure. The User is responsible for keeping account authentication information confidential and for implementing appropriate security measures on the User's own device.

11. User Rights and Choices

Subject to applicable law, the User may have the following rights:

1. the right to request access to Personal Data about the User held by the Company;
2. the right to request correction of inaccurate or incomplete Personal Data;
3. where the Company's collection, use, or disclosure of Personal Data is based on consent, the right to withdraw that consent;
4. where applicable, the right to request deletion of, or restriction on processing of, certain Personal Data;
5. where applicable, the right to object to or opt out of certain communications, such as marketing communications; and
6. the right to make inquiries or complaints regarding the Company's handling of Personal Data.

To exercise these rights, the User should contact the Company using the contact details set forth in Section 16.

The Company will respond to requests as soon as reasonably possible and, in principle, within 30 days from receipt of the request, within the period required by applicable law. Complex or numerous requests may require a longer period, in which case the Company will notify the User.

Before responding to a request, the Company may request information reasonably necessary to verify the identity of the User. The Company may refuse to respond to a request or limit the scope of its response where permitted or required by applicable law.

If the User withdraws consent, the Company will, where required by applicable law, notify the User of the likely consequences of the withdrawal. Depending on the nature of the withdrawal, the Company may be unable to continue providing all or part of the Service, the Application, DARE Account, or Paid License features.

If the User is not satisfied with the Company's response to a request or complaint, the User may have the right to lodge a complaint with the data protection authority or relevant authority in the User's country or region of residence.

12. Support Materials and User-Submitted Files

If the User submits files, screenshots, logs, drawings, or other materials to the Company through a support channel, including customer support tools such as Zendesk, the Company may process those materials for the purposes of responding to inquiries, investigating issues, providing support, improving quality, or resolving disputes.

The User must not submit Personal Data, confidential information, or third-party data that is not necessary for the support request. If the User submits such information, the User represents that the User has the necessary authority or consent to do so.

13. Children

The Service and the Application are not intended for children. If the Company becomes aware that it has collected Personal Data from a child below the age of consent under applicable law in circumstances where parental or guardian consent is required under applicable law, the Company will take appropriate measures in accordance with applicable law.

14. Data Breach

If a data breach occurs and notification is required under applicable law, the Company will provide appropriate notice to the relevant authorities and affected individuals within the prescribed period and take necessary measures in accordance with such law.

15. Changes to This Policy

The Company may update this Policy from time to time to reflect changes in laws, regulations, the Service, the Company's business, or data handling practices.

When the Company updates this Policy, the Company will post the updated Policy on the Company's website, DARE Store, or other appropriate location. Unless otherwise specified, the updated Policy will take effect upon posting.

If the Company makes a material change for which the User's consent is required under applicable law, the Company will obtain the User's consent by a method the Company considers appropriate.