KOTOBA

KOTOBA App Terms of Service

Last revised: May 10, 2026

These Terms of Service (these "Terms") set forth the conditions for using the

"KOTOBA" application (the "App") provided by Steam Wagon Japan Limited. (the

"Company"), as well as the rights and obligations between the Company and the

user. By using the App, you must read these Terms in full and agree to all of

their provisions.

Article 1 (Definitions)

In these Terms, the following terms have the meanings set forth below.

(1) "User" means any person who uses the App.

(2) "Personal Information" means "personal information" as defined in

Article 2, Paragraph 1 of the Japanese Act on the Protection of Personal

Information ("APPI").

(3) "Personally Referable Information" means "personally referable

information" as defined in Article 2, Paragraph 7 of the APPI.

(4) "Antisocial Forces, etc." means any person falling within or suspected of

falling within any of the following:

(a) The person, its officers (including those who substantially control or

participate in its management), or its employees are members of organized

crime groups, members of organized crime groups within the past five years,

quasi-members of organized crime groups, related companies, racketeers,

social movement extortionists, special-intelligence violence groups, or

any other persons equivalent thereto (collectively, "Antisocial Forces");

(b) The person, its officers, or its employees have a relationship deemed

to involve improper use of Antisocial Forces;

to involve providing funds or facilitations to Antisocial Forces;

(d) The person, its officers, or its employees have a socially

reprehensible relationship with Antisocial Forces; or

(e) The person, its officers, or its employees have engaged or have

previously engaged in threatening, violent, or other improper conduct,

including damage to credit, defamation, or interference with business

against the Company or its affiliates.

(5) "Content" means text, images, videos, audio, and other similar

materials.

(6) "Story" means the progression and structure of novels and similar

content displayed in the App.

(7) "Character" means the distinctive features of any specific person,

animal, robot, or similar entity expressed in novels and similar content

displayed in the App.

(8) "KC" means virtual points consumed by the User to unlock stories,

enhance skills, or use other services within the App (including, where

applicable, prepaid payment instruments under the Japanese Payment Services

Act).

(9) "In-App Purchase" means a transaction in which a User purchases KC or

other paid items through the payment system of Apple Inc. or Google LLC.

(10) "Submitted Content" means all nicknames, dojo names, unregistered word

suggestions, and other text, images, audio, etc., that a User transmits to

or registers in the App.

(11) "AI Features" means features that use generative artificial

intelligence or machine learning models provided by the Company or by

third parties contracted by the Company to classify, summarize, or generate

information for the User's convenience.

Article 2 (Order of Precedence)

The terms of provision of the App displayed by the Company on the App or on

the app store distributing the App ("Displayed Terms") shall constitute part

of these Terms. However, if any Displayed Term conflicts with these Terms,

these Terms shall prevail.

Article 3 (Acquisition of User Information)

1. The Company uses authentication services provided by Google, Apple, and

LINE to maintain Users' game progress and settings in the App. Through this,

the Company does not receive any information from these providers that

constitutes Personal Information under Japanese law.

2. The Company requires Users to set a nickname displayed publicly within

the App. Users may not include their real name or any other Personal

Information in such nickname.

3. When a User creates a "DOJO" (KOTOBA DOJO) within the App, the dojo name

shall comply with the following:

(1) The dojo name shall be no more than 8 characters.

(2) The dojo name shall not include any names, email addresses, phone

numbers, URLs, or other expressions that may identify an individual.

(3) The Company may, at its discretion, change a dojo name or delete a

dojo if it determines a User has violated the foregoing.

4. Details on the categories of information acquired, purposes of use,

retention periods, and provision to third parties are set forth in the

Article 4 (Use by Minors)

1. If a User is a minor, the User shall obtain prior consent of a person

with parental authority or other legal representative for use of the App

and any In-App Purchase.

2. The Company assumes no responsibility for any damages arising from a

User's use of the App or an In-App Purchase made without consent of a legal

representative.

3. If a User is a minor and the amount of the User's In-App Purchases

exceeds an amount the Company reasonably determines, the Company may

require the User to confirm whether the User has obtained consent of a

legal representative.

Article 5 (Users Who May Not Use the App)

1. The Company may refuse to allow a User to use the App if the Company

determines (or suspects) that the User falls within any of the following:

(1) Has violated Article 3 (Acquisition of User Information) Paragraph 2

or Article 6 (Prohibited Acts);

(2) Has been subject to the measures set forth in this Paragraph in the

past;

(3) Has a close relationship with a person previously subject to the

measures set forth in this Paragraph; or

(4) Is an Antisocial Force, etc.

2. When refusing the use of the App pursuant to the preceding Paragraph,

the Company may delete game progress, settings, KC balance, and other data

held with respect to such User.

3. The Company assumes no responsibility for any damages incurred by a

User as a result of measures taken under the preceding two Paragraphs.

Article 6 (Prohibited Acts)

A User shall not engage in any of the following acts:

(1) Disclosing solutions to or hints regarding games provided in the App,

in any medium (books, magazines, broadcasts, internet, etc.), unless

expressly permitted by the Company;

(2) Reproducing, imitating, adapting, or publishing all or any part of the

Content provided in the App in any medium, unless expressly permitted by

the Company;

(3) Imitating or adapting Characters to create new content, unless

expressly permitted by the Company;

(4) Infringing the intellectual property rights or other rights of the

Company;

(5) Acting in violation of laws or these Terms in connection with use of

the App;

(6) Acting against public order and morals in connection with use of the

App;

(7) Defaming the Company or other Users;

(8) Impersonating other Users in using the App;

(9) Imposing excessive load on the App or its supporting systems, gaining

unauthorized access, infecting them with malware, or otherwise creating

information security threats;

(10) Interfering with the provision of services in the App or with the

business activities of the Company;

(11) Reverse engineering or otherwise analyzing the App or its supporting

systems;

(12) Using the App for commercial sales activities;

(13) Interfering with In-App Purchases, KC acquisition or consumption,

network battle progress, or ad display through unauthorized tools, modified

clients, automation programs, emulators, etc.;

(14) Intentionally disconnecting communications, conspiring to manipulate

match outcomes, manipulating ratings, or otherwise interfering with fair

competitive progress in matches with other Users;

(15) Without the Company's prior consent, exchanging KC, paid items,

accounts, authentication credentials, or any other rights or data related

to the App for real currency, transferring them to third parties, providing

them as collateral, or attempting any of the foregoing (real money trade);

(16) Reproducing, imitating, or using without permission any content,

nickname, or dojo name posted by other Users; or

(17) Any other act that the Company reasonably determines is inappropriate

for a User of the App.

Article 7 (Damages)

If a User causes damage to the Company by using the App despite a ground

for refusal under Article 5 Paragraph 1, by violating Article 6, or by

otherwise violating these Terms, the User shall be liable to the Company

for the full amount of such damages.

Article 8 (Intellectual Property of the App)

The copyrights and other intellectual property rights to the App and all

Content comprising the App belong to the Company or the rights holders

licensing such rights to the Company. These Terms do not transfer any

intellectual property rights or other rights in the App or Content to Users.

Article 9 (Submitted Content)

1. When transmitting Submitted Content to the App, a User represents and

warrants that the User has the legitimate right to transmit such Submitted

Content and that such Submitted Content does not infringe any third-party

rights.

2. The User grants the Company a royalty-free, geographically unrestricted,

perpetual license to use Submitted Content in any manner, including

reproduction, screening, public transmission, exhibition, distribution,

translation, adaptation, and creation of derivative works. Such license

includes the right to grant sublicenses.

3. The User agrees not to exercise moral rights in Submitted Content

against the Company or its affiliates.

4. If the Company reasonably determines that Submitted Content violates

Article 6 (Prohibited Acts) or infringes third-party rights, the Company

may delete, hide, or modify all or part of such Submitted Content without

prior notice. The Company assumes no responsibility for any damages

incurred by Users as a result.

5. The Company may use all or part of Submitted Content for purposes

including improving the App, expanding dictionary databases, providing

other services offered by the Company, research and development,

preparation of statistical data, and other purposes.

Article 10 (In-App Purchases and KC)

1. Users may purchase KC and other paid items available within the App

through the payment systems of Apple or Google. Consideration, payment

methods, issuance of receipts, viewing of purchase history, and other

matters related to In-App Purchases shall be governed by the terms set by

the providers of such payment systems.

2. KC may only be used within the App and cannot be exchanged for, or

redeemed in, real currency, nor transferred to third parties.

3. The validity period of KC acquired by a User shall be 180 days from the

day following the date of the most recent transaction increasing or

decreasing such KC. KC shall expire upon the lapse of such period, and the

Company assumes no responsibility for any damages incurred by Users as a

result.

4. Refunds or returns of KC, paid items, or unlocked content acquired

through In-App Purchase shall be determined by Apple or Google in

accordance with their respective terms; the Company has no independent

authority to make such determinations. However, this does not apply where

the Company is legally obligated to provide a refund.

5. If a User acquires KC or other paid items beyond the proper amount due

to a bug or other reason in the App, the Company may recover such excess

KC or paid items without prior notice to the User.

6. Use of KC may be restricted, or KC may be lost, in connection with

changes to or termination of services provided in the App. Except where

the Company is required to refund under the Japanese Payment Services Act

or other laws, the Company shall not provide compensation for KC unused at

the time of such change or termination.

Article 11 (Display of Advertisements and Reward Ads)

1. Advertisements provided by the Company or third parties may be displayed

in the App. Such advertisements may include behaviorally targeted ads

delivered using Personally Referable Information (including device

identifiers, advertising identifiers, and usage history) acquired from the

Company or third parties by the relevant ad provider.

2. If a User uses an in-app feature to "earn KC, life, or other rewards by

viewing ads" (the "Reward Ad Feature"), the Company makes no warranty

regarding the continued provision of such feature, the granting of rewards,

or the order or frequency of ad displays.

3. The Company assumes no responsibility for the content of advertisements

delivered by ad providers. Users shall use any services or products related

to advertisements at their own discretion and risk.

4. Users may reset the advertising identifier or limit behaviorally targeted

ads via their device settings. Specific procedures shall follow those

prescribed by Apple or Google.

Article 12 (AI Features)

1. The Company may provide AI Features for the User's convenience in

providing the App.

2. AI Features use models provided by third parties contracted by the

Company (including, but not limited to, Anthropic, PBC and other AI

providers). The Company may transmit Submitted Content and other

information to such providers to the extent necessary for providing the AI

Features.

3. AI Features may, by their nature, produce inaccurate, inappropriate, or

unexpected results. The Company makes no warranty regarding the accuracy,

completeness, usefulness, fitness for a particular purpose, or

non-infringement of third-party rights of any output of AI Features.

4. Users shall be solely responsible for any consequences arising from

acting upon the output of AI Features.

Article 13 (Network Battle and Other Online Features)

1. The App includes real-time multiplayer game features ("Network Battle").

The Company makes no warranty regarding communication stability, response

time, fairness of matchmaking, or accuracy of match-result determinations

in Network Battles.

2. The Company assumes no responsibility for damages caused by interruption

of Network Battle progress, unintended match results, or similar issues

caused by communication failures, server failures, the state of the User's

device, or other reasons.

3. The Company may, at its discretion, modify, reset, or delete classes,

ratings, match histories, or other data generated in connection with

Network Battles.

Article 14 (Disclaimer Regarding App Specifications)

1. The App provides a game in which Users are tasked with selecting

displayed letters to form actual words ("Word Game"). Because the Word Game

treats only the words preset by the Company as actual words, a User may

unavoidably be evaluated as having given an incorrect answer even when the

correct letters were selected. The Company makes no warranty to Users that

such results will not occur in the App.

2. While the Company endeavors to ensure that words designated as correct

in the Word Game do not cause discomfort to Users, the Company makes no

warranty that such results will not occur.

3. The App provides a feature that triggers an alarm at a time specified by

the User. While the Company endeavors to prevent malfunctions such as

non-activation at the specified time or activation at incorrect times, the

Company makes no warranty that such results will not occur.

4. While the Company endeavors to ensure that Content does not cause

discomfort to Users, the Company makes no warranty that such results will

not occur.

5. The Company does not warrant that the App will run properly on every

version of the OS used on a User's device.

6. The Company does not warrant that services provided in the App will be

free from interruption or other failures.

7. While the Company endeavors to prevent bugs and other defects in the

App, it does not warrant that the App is free from any bugs or defects.

8. While the Company exercises care in safely managing game progress,

settings, KC balances, and other data, it does not warrant that loss of

such data due to bugs or other defects in the App will not occur.

Article 15 (Temporary Suspension of the App)

The Company may temporarily suspend use of the App for system updates,

maintenance, or other actions necessary to provide the App on a continuing

basis. The Company assumes no responsibility for any damages incurred by

Users as a result.

Article 16 (Account Deletion)

1. A User may, at any time, request deletion of the User's account through

the settings screen of the App or through a contact point designated by the

Company.

2. Upon receiving such a request, the Company shall, within a reasonable

period, delete or anonymize information about such User in accordance with

the Privacy Policy attached to these Terms. However, this shall not apply

to information required to be retained by law, information necessary for

investigation of fraudulent use, or information anonymized for statistical

purposes.

3. Upon account deletion, KC, paid items, game progress, match history, and

other data acquired by the User shall be deleted. The Company shall not

restore such data and assumes no responsibility for any damages incurred by

Users as a result.

Article 17 (Disclaimer of Liability)

1. The Company assumes no responsibility to a User for any damages caused

in connection with the provision of the App.

2. Notwithstanding the preceding Paragraph, where the Company is liable to

a User for damages under the Consumer Contract Act or other laws, the

amount of damages shall be limited to the higher of (a) the amount paid by

such User to the Company in connection with the App during the most recent

12 months (limited to amounts received by the Company through In-App

Purchases) or (b) JPY 10,000. However, in such cases, the Company shall

compensate the full amount of damages where such damages arise from the

Company's willful misconduct or gross negligence.

Article 18 (Assignment)

1. A User may not assign, provide as collateral, or otherwise dispose of

any rights, obligations, or contractual position arising under these Terms

to a third party, except where the Company has consented in advance in

writing or by electromagnetic record.

2. A User consents in advance that, in the event the Company assigns the

business of providing services in the App to a third party (including

business assignments, corporate splits, and any other transfers of such

business), the rights, obligations, and contractual position under these

Terms with respect to such User shall be transferred to such third party

in connection with such assignment.

Article 19 (Modification or Termination of Services)

1. The Company may, with prior notice to Users, modify or terminate the

contents of services provided in the App. The Company assumes no

responsibility for any damages incurred by Users as a result.

2. The Company may delete game progress, settings, KC balances, and other

data in connection with such modification or termination. The Company

assumes no responsibility for any damages incurred by Users as a result.

Article 20 (Changes to These Terms)

The Company may change these Terms in accordance with Article 548-4 of the

Japanese Civil Code (changes to standard contract terms) where necessary

due to amendments to laws, changes in social conditions, expansion of

services, or other circumstances. In such cases, the Company shall give

prior notice of the change, the contents of the changes, and the effective

date through either the App or the app store distributing the App. The

revised Terms shall apply to Users who began using the App before the

revision.

Article 21 (Severability)

Even if any provision or part of these Terms becomes invalid or

unenforceable under the Consumer Contract Act or other laws, the remaining

provisions and parts of these Terms shall remain in full force and effect.

Article 22 (Governing Law and Jurisdiction)

1. These Terms shall be governed by Japanese law.

2. Any disputes arising out of or relating to these Terms shall be subject

to the exclusive jurisdiction of the Tokyo District Court for the first

instance.

Article 23 (Provisions for Users on Apple OS)

The provisions of this Article apply only when using the App on an OS

provided by Apple Inc.

(1) Acknowledgment: The Company and the User acknowledge that the license

agreement for the App is concluded between the Company and the User, not

between the User and Apple Inc., and that only the Company is responsible

for the App and its Content. Such license agreement does not include any

terms that conflict with Apple's then-current terms as of the effective

date of the Apple Developer Program License Agreement.

(2) Scope of License: The license granted to the User for the App is a

non-transferable license to use the App on any Apple-branded products that

the User owns or controls, subject to the limitations on access via Family

Sharing, volume purchase, or accounts associated with purchasers using

deceased account contacts, and as otherwise permitted by Apple's terms of

use.

(3) Maintenance and Support: The Company is wholly responsible for

maintenance and support of the App under the license agreement or

applicable laws. The User acknowledges that Apple Inc. has no obligation

to provide such maintenance or support.

(4) Warranty: Apple Inc. is not responsible for any warranty regarding the

App, whether express, statutory, or implied.

(5) Product Claims: Apple Inc. is not responsible for any claims by Users

or third parties relating to the User's possession or use of the App,

regardless of the legal nature of such claims.

(6) Intellectual Property Rights: If a third party claims that the User's

possession or use of the App infringes the third party's intellectual

property rights, the User shall notify the Company. In such cases, Apple

Inc. shall not be responsible.

(7) Compliance with Laws: The User represents and warrants that the User's

location is not in a country subject to a U.S. Government embargo or

designated as a "terrorist supporting" country, and that the User is not

listed on any U.S. Government list of prohibited or restricted parties.

(8) Third-Party Terms: The User shall comply with the terms of any

applicable third-party agreements when using the App.

(9) Third-Party Beneficiary: The User agrees that Apple Inc. and its

subsidiaries are third-party beneficiaries of the license agreement, and

that upon the User's acceptance of the terms of the license agreement,

Apple Inc. shall have the right (and shall be deemed to have accepted such

right) to enforce the license agreement against the User as a third-party

beneficiary.

Article 24 (Disclosure under the Payment Services Act)

For KC issued in the App that constitutes a prepaid payment instrument

under the Japanese Payment Services Act, the Company shall separately

display, on its website, the issuer's name, the name of the payment

instrument, the maximum amount payable, methods of confirming unused

balances, usage notes, and other matters required by Article 4 of the

Enforcement Order of the said Act.

Article 25 (Disclosure under the Specified Commercial Transactions Act)

The seller's name, address, contact information, sales prices, timing and

methods of payment of consideration, timing of delivery, return policy,

and other matters required under Article 11 of the Japanese Specified

Commercial Transactions Act regarding In-App Purchases shall be displayed

within the App or on the Company's website.

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Last revised: May 10, 2026

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1. Information Acquired

The Company acquires the following information from Users in providing the

App.

(1) Information voluntarily registered by Users

- Nickname

- Age (age range)

- Dojo name, dojo profile, avatar selection

- Suggestions for unregistered words and other Submitted Content sent

within the App

(2) Information acquired through authentication

- Google authentication credentials, Apple authentication credentials,

and LINE authentication credentials (identifiers granted to the

Company by authentication providers)

- Email addresses registered with the foregoing providers (referenced

only when responding to inquiries)

(3) Information acquired automatically through use of the App

- Game progress, match history, KC and other paid item acquisition/

consumption history, settings

- Device type, OS type and version, App version, language settings,

time zone, IP address

- Advertising identifiers (IDFA / Google Advertising ID)

- Device-specific instance IDs, Firebase Installation ID

- Crash and error logs, screen transition logs, operation logs

(4) Information acquired in connection with In-App Purchases

- Purchase history, receipt information, purchase amounts, and payment

currency provided by Apple's or Google's payment systems

Among the foregoing (1) and (2), information that cannot identify a

specific individual generally does not constitute "Personal Information"

under Japanese law. However, with respect to Personally Referable

Information such as IP addresses and advertising identifiers, when

provision to a third party constitutes a third-party provision of personal

data under the APPI, the Company shall obtain User consent before such

provision.

2. Purposes of Use

The Company uses information acquired under the preceding section for the

following purposes:

(1) Providing, maintaining, and improving the App

(2) User authentication, retention of game progress and settings,

management of KC and other paid items

(3) Providing online features such as Network Battle, ranking, and dojo

features

(4) Processing In-App Purchases, issuing receipts, handling refunds, and

other payment-related operations

(5) Delivering advertisements within the App, measuring ad effectiveness,

and preventing fraudulent use of advertisements

(6) Analyzing App usage and calculating KGI/KPI and other management

metrics

(7) Expanding and improving the dictionary database (including

classification of Submitted Content via AI Features)

(8) Detecting and addressing fraudulent acts (real money trade, use of

automation tools, manipulation of match results, etc.)

(9) Responding to inquiries from Users

(10) Investigating and responding to violations of laws, these Terms, or

other rules and guidelines

(11) Other actions necessary to protect the rights, property, or safety

of the Company or third parties

3. Provision to Third Parties and Outsourcing

The Company shall not provide Personal Information acquired from Users to

third parties except in the following cases:

(1) Where User consent has been obtained

(2) Where required by law

(3) Where necessary to protect human life, body, or property and obtaining

User consent is difficult

(4) Where it is necessary to cooperate with national or local government

agencies (or persons commissioned by them) in performing legally

prescribed duties, and obtaining User consent could impede the performance

of such duties

(5) Where, to the extent necessary to achieve the purposes of use, the

Company outsources the handling of information (including to external

cloud service providers, payment agencies, AI providers, ad providers,

and analytics providers)

The principal providers to which the Company outsources information

handling are as follows. Such providers handle information in accordance

with their own privacy policies.

- Google LLC (Firebase, Google Cloud, AdMob, Google Analytics for

Firebase, Google Ads)

- Apple Inc. (App Store, App Store Connect, Sign in with Apple,

StoreKit)

- LY Corporation (LINE Login)

- Anthropic, PBC (AI Features via Claude API)

- RevenueCat, Inc. (In-app purchase management infrastructure)

- Other analytics and delivery providers as needed

4. International Transfer of Information

As set forth in the preceding section, the Company provides information to

third parties located outside Japan (including cloud service providers,

payment agencies, and AI providers located in the United States and other

countries) to the extent necessary for providing the App. When providing

User Personal Information to third parties outside Japan, the Company

takes the measures required by the APPI.

5. Advertising Identifiers and Opting Out of Behaviorally Targeted Ads

To display ads in the App, the Company may provide advertising identifiers

(IDFA / Google Advertising ID) to ad providers. Users may reset

advertising identifiers or limit behaviorally targeted ads through device

settings. Specific procedures shall follow those prescribed by Apple or

Google.

6. Use of Cookies, etc.

The Company may use cookies, local storage, and other similar technologies

in the App and related websites. Information acquired through these

technologies shall be used for the purposes set forth in Section 2 of this

Policy.

7. Retention Period

The Company retains information acquired from Users only for the period

necessary to achieve the purposes of use. Information that has exceeded

such period or for which the purposes have been achieved shall be deleted

or anonymized within a reasonable period. However, information required to

be retained by law and information necessary for investigation of

fraudulent use may be retained until such obligation or investigation

period ends.

8. Security Measures

The Company takes organizational, personnel, physical, and technical

security measures to prevent leakage, loss, or damage of information

acquired from Users and to ensure the safe handling of such information.

9. User Rights

Users may request the Company to notify the purposes of use, disclose,

correct, add, delete, suspend use, suspend provision to third parties, or

disclose third-party provision records of their Personal Information.

Specific procedures are available through the contact point set forth in

Section 11 of this Policy.

10. Account Deletion

Users may request deletion of their account through the settings screen of

the App or through the contact point set forth in Section 11 of this

Policy. Upon receiving such a request, the Company shall respond in

accordance with Article 16 (Account Deletion) of the Terms.

11. Contact Point

For inquiries about the use or disclosure of User information, please

contact:

[Contact] kotoba@steam-wagon.com

[Operator] Steam Wagon Japan Limited

12. Revisions to This Policy

The Company may revise this Policy as necessary in accordance with

amendments to laws, changes in services, or other circumstances. The

Company shall give notice of any revision through the App or by other

appropriate means.