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Lark Privacy Policy Last Updated: June 1, 2026 Thank you for using Lark products and services. Lark offers an online, multi-tool business management, efficiency, and communications platform and standalone applications including but not limited to instant messaging services, content creation and collaboration, cloud storage, calendar services, audio and video calls, email services, and other functions, as well as services that interoperate with other software (collectively, the “Platform”). The Platform and its related services, products, sub-applications within the Platform, standalone applications associated with the Platform, software program and content are collectively referred to herein as the “Services.” Each instance of the Services set up is referred to as a “Workplace”. The Services are provided or controlled by Lark Technologies Pte. Ltd. (located at 1 Raffles Quay, #26-10, South Tower, Singapore 048583) ( “we” or “us”). This privacy policy (“Policy”) sets out how your data may be collected and otherwise processed by us when you access or use our Services offered to non-US customers, including any other services that link to or reference this Policy. For further information about the applicability of the Policy, please see the “How Does This Policy Apply” section. If you are using Lark offered to a US customer, please see here instead. Please read the following carefully to understand our approach and practices regarding the processing of your information. For the purposes of this Policy, we use “information”, “personal information” and “personal data” to refer to information relating to an identified or identifiable natural person. We also use the term “Business Workplace Owner” to refer to Workplaces owned by (i) a corporate entity or (ii) an individual who uses it for non-personal purposes. How Does This Policy Apply Under certain data protection laws, a party is either a controller or a processor of data. In general, we are the controller of the information described in the “Types of Information We Collect and Use” section. However, in certain situations, we act as a processor. For example, if a Business Workplace Owner invites you to create an account (“Authorized Business User Account”) for its business purposes and you use the Services as an authorized user of its Workplace , we are a processor and the Business Workplace Owner is the controller of “Workplace Data” you generate when you are signed into your Authorized Business User Account. This data and any other data the Business Workplace Owner may control are referred to herein as “Business Owner Controlled Data.” Please note that this Policy does not cover the processing of Business Owner Controlled Data unless such data is shared with us by the Business Workplace Owner as the data controller. Such processing is primarily covered by the Business Workplace Owner’s privacy policy or notice, a separate agreement between the Business Workplace Owner and Lark which governs delivery, access and use of the Services and applicable employment agreement (or any agreement in lieu of the employment agreement) between you and the Business Workplace Owner. Please note that Business Owner Controlled Data does not include Workplace Data that you generate when you are signed into your personal account, even when you interact with Workplaces associated with Business Workplace Owners. Additionally, upon termination of your Authorized Business User Account by a Business Workplace Owner, Lark will automatically convert your Authorized Business User Account to a personal account. If you continue to use the Services when signed into a personal account, we will then be the controller of the data associated with that personal account, including Workplace Data. Types of Information We Collect and Use We may collect and use the following types of information when you access the Platform or use the Services: Account Data. To create an account, you or a Business Workplace Owner may provide us with your name, photo, phone number, email address, password information, and/or similar account details. Purchase Information. If you use a paid version of the Services or certain portions of our Services that enable purchases (e.g., food or car services purchases), we will collect billing details from you or a Business Workplace Owner, including credit card information, banking information and/or billing address. We will also collect purchase and transaction information. Workplace Data. We collect and process the content you generate on the Platform and with the Services, including: any messages, files, photos, documents, or other content that you upload, view, edit, share or comment on; your uploaded address book and contacts, if you choose to provide it; calendar entries you create, edit or to which you are invited; voice and video data, including when you use voice messaging and conference services, and any associated transcripts; and search queries and commands. Technical and Usage Data. We also collect and process data to administer, provide, optimize, and market the Services. Some of this data is collected automatically, including by our service providers and third-party vendors. Technical and Usage Data includes: metadata and inference information related to your use of the Services, such as your online status, when your messages were sent, the recipient(s) of your messages, the features and embedded content you interact with, the types of files you share, and what, if any, third-party integrations you use; Technical and network information such as your web request, IP address, browser type and settings, exit pages and URLs, number of clicks, date and time stamp information, language preferences, and other such information; data about your online activity on websites and connected devices over time and across third-party websites, such as where you click, how long you visit a page, your scrolling, mouse hovers, and other data to help us better understand your experience and provide you with the best user experience; data collected through cookies and similar tracking technologies to operate the Platform and provide the Service, which may include purposes like security and providing you with the features you request and remembering your language and other preferences (for further information please see our Cookies Policy); and data about the device you are using to access the Services and related device activity, such as mobile carrier, device IDs, and operating system version. Communication Data. We collect data regarding your communications with us, for example, when you provide us with feedback or contact us with a question or comment through our chat or call services (including on social media). Location Data. We collect information about your location including general location information (e.g., city, state, country and/or zip code) based on your SIM card, IP address, or other device information. With your permission, we may also collect your precise location, including Global Positioning System (GPS) data. You may disable location services in your system settings. Third-Party Data. Lark permits the integration of other services and applications with our Services. If you are using an integrated third-party service, we may receive and process data from that third party (and will also share certain data with that third party, including data described in the above) in order to provide the integrated service. This Policy does not apply to the processing of your information by third-parties through your use of any third-party integrations available via our services. When using integrated apps and services on Lark, please always review the relevant third-party provider’s legal documents including but not limited to their terms of service and privacy policy. Additional Business Owner Controlled Data. We may receive information (including data from the categories described above) that we only collect and process when a Business Workplace Owner chooses to use certain features available to those accounts and upon the Business Workplace Owner’s instruction. For example, a Business Workplace Owner may enable features related to (i) attendance, approval, health report, buzz, and log functions; (ii) business directory services; (iii) third-party integrations; or (iv) precise geolocation services, including via cell tower triangulation. As set forth in the “How Does This Policy Apply” section, we are a processor of this Business Owner Controlled Data and the Business Workplace Owner—not Lark—must ensure that they are collecting, using, and disclosing such data in compliance with applicable laws. Identity Verification Data. Depending on the applicable jurisdiction, to facilitate account recovery, we may collect data such as your legal name, organization's name, national identification number, facial image, last login date and location, and details of your commonly-used device. How We Use Information In addition to the purposes already set out above, we may use, process or disclose your information for the following purposes including to: Administer, operate, and provide the Services (including diagnostics, monitoring, troubleshooting, data analysis, testing, system maintenance, repair and support, reporting and hosting of data); Provide user support and respond to, handle, and process queries, requests, applications, complaints, and feedback from you; Investigate and help prevent security issues and abuse, help improve the security of our Services, including use of automated systems to analyze content such as documents, instant messages and emails to detect abuse, such as spam, malware, and illegal content; Better understand your interests and needs, and personalize your experience on the Services; Analyze and research how you interact with our websites and applications; Continually improve the Services and our technologies and products, including adding new features or capabilities; Provide and improve features that may use artificial intelligence, machine learning, or other similar technology; Comply with applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental or regulatory authority in accordance with or required by applicable law, regulation or legal process; Communicate with you, including to notify you with service messages about changes to our Platform or Services; Send marketing and promotional materials from us or on behalf of others; Measure and understand our marketing campaigns and the effectiveness of such campaigns; Enforce our terms, conditions and policies; Fulfill any other purposes for which you have provided the data; and Fulfill other business purposes related to or in connection with the above. Combined Information Unless otherwise prohibited by law, we may combine the information that we collect through your use of our Services with information that we receive from other sources, both online and offline, and use that combined information as set forth above. Aggregated and De-identified Information We may aggregate or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). Subject to applicable laws, we may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties at our discretion. Legal Bases If you are an individual from the European Economic Area (“EEA”), the UK, Switzerland or any country which requires notification of the legal bases for processing, our legal bases under the General Data Protection Regulation (“GDPR”) and applicable data protection laws of each such country, for collecting and using your information described above will depend on the particular type of information and the specific context in which we collect it. However, some examples of legal bases for processing that we rely on: Where we have your consent to do so; Where use of your information is necessary to perform our obligations under a contract with you (e.g., to comply with the Customer Terms of Service or User Terms of Service and deliver the Services); Where use of your information is necessary for our legitimate interests or the legitimate interest of others (e.g., to operate our Services; provide security for our Services; prevent fraud; analyze use of and improve our Services; and for similar purposes); and Where use of your information is necessary to comply with applicable legal obligations. How We Share Your Information We may share, at our sole discretion or per your Business Workplace Owner's instructions (if any), your information (including, for example, data which you choose to share with us through third-party integrations with Lark Email, such as Gmail) with the following third parties, including, without limitation, to those who may be processing your information on our behalf for one or more of the purposes stated above and herein: Service Providers and Business Partners We may disclose your information to service providers who support our business, such as cloud service providers and other technology third-party vendors. These service providers and business partners help us provide, administer and support the Services, including but not limited to research, payment processing and transaction fulfillment, information system maintenance, data processing and storage, analytics, measurement, and disaster recovery. Business Workplace Owners and their Designated Third Parties We will share certain information about you with Business Workplace Owners or any third parties designated by Business Workplace Owners only if you are an Authorized User of such Business Workplace Owner. Third-Party Integrations We may share certain data with third-party integrations providers if you give them access to your account and information, including any content you choose to use in connection with those third-party integrations. Our Corporate Group We may also share your information with other members, subsidiaries, or affiliates of Lark’s corporate group, in order to provide, maintain and improve the Services. For example, to help recover your account, we may share your Identity Verification Data with an affiliate to help verify your identity. Corporate Transactions We may share your information in connection with or during negotiations of a corporate transaction, such as a merger, acquisition in full or in part, reorganization, asset sale, or in the unlikely event of bankruptcy. Law Enforcement We may disclose your information as we believe to be necessary or appropriate to: comply with applicable law and legal processes; respond to requests from public and government authorities; enforce Customer Terms of Service or User Terms of Service; protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; or allow us to pursue available remedies or limit the damages that we may sustain. With Your Consent We may share your information for other purposes pursuant to your consent or at your direction. International Data Transfers International data transfers are necessary for us to provide the Services and fulfill our contractual obligations to you relating to the Services. We share your personal data globally with companies of our business group to carry out the activities specified in this Policy. We may also subcontract the processing of data involved in the Services or share your personal data with third parties located in other countries. We rely on permitted legal bases and exceptions and will comply with requirements under applicable laws, in relation to such transfers. We maintain servers located in US, Singapore and Japan and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this Policy. When required by applicable law, we will provide an adequate level of protection for your personal data using various means, including where appropriate, relying on a formal decision that a certain country ensures an adequate level of protection for personal data, or complying with Model Contractual Clauses. In the case where you are an authorized user of a Business Workplace Owner, your Business Workplace Owner will determine which servers will process and store your information. Your Business Workplace Owner may also choose to share your information with parties that are located outside of the country where you live. Your Business Workplace Owner will protect your personal data and comply with requirements under applicable laws in relation to such transfers. Security of Your Information We attach great importance to the security of your information and have in place technical, managerial and physical safeguards, including an internal policy for data protection, limiting access to personal data on a need-to-know basis and controlling access to facilities where personal data is processed, in order to prevent any unauthorized access to or unauthorized alteration, disclosure or destruction of personal data we hold. However, like all information transferred over the internet, please note that information you send to us electronically may not be secure. Despite our best efforts, you understand that due to technical limitations , no security measures are perfect or impenetrable and it is impossible to ensure permanent and absolute security. Therefore, we strongly suggest you take active measures, including but not limited to using a complicated password, regularly changing your password, and avoiding disclosure of your account password or other information relating to logging in to your account, so as to protect the security of your information. We also recommend that you do not use unsecure channels to communicate information or other sensitive or confidential information to us. For detailed information, please visit Lark Trust Center. Data Retention We will retain your personal data for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required, for example to comply with legal obligations or requests or for the establishment, exercise or defense of legal claims, or for legitimate business purposes, or as provided by law. For example, if you request to recover your account, any facial image that may be processed as part of identity verification depending on the jurisdiction will be deleted after identity verification is completed. Information Relating to Children and Minors The Services are intended for and should only be used by, adults (persons who meet the legal consent age in each applicable jurisdiction) and not children or minors. We do not seek or knowingly collect any personal data about children under the age of 18. If you learn that anyone younger than legal age of consent has provided us with their personal data in relation to the Services, please contact us and we will make commercially reasonable efforts to delete such information from our database. Your Rights and Choices Email marketing If you do not wish to receive marketing information from us, you may follow the unsubscribe instructions included in the emails you receive or contact us as described below. We will continue to send you non-promotional, service emails in regard to your account, such as for billing and payment information, and other emails relating to your account or Workplace, and/or your use of the Services. Cookies and Similar Technologies Please review our Cookies Policy for more information about how you can control our use of cookies and similar technologies. Requests Regarding your Information Depending on the laws of your jurisdiction, we may provide you with the ability to exercise certain controls and choices regarding our collection, use, and sharing of your personal information. For example, you may have the right to: obtain confirmation of whether data are being processed and access, or a copy of, your information, and in some cases, receive it in a structured, commonly used and machine-readable format, or have it be transmitted to a third party in such form; update, correct or delete the information; object to the use, sale, or disclosure of the information, to the extent permitted by the applicable law; withdraw consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information); information about the possibility to refuse providing personal data and the respective consequences, when applicable; anonymization, blocking or erasure of data; portability of personal data to a third party; information of public and private entities with which we shared data; and request a review of decisions made solely based on automated processing of personal data affecting your interests, including decisions made to define your personal, professional, consumer or credit profile, or aspects of your personality. For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request. In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request. If you would like to exercise your rights under applicable law, you can submit your request to the email set forth in the "Contact Us" section. with your name, account and a description of your request. Where permissible by law, we may verify your identity. Please allow us a reasonable time to respond to your inquiries and requests. Please see “Additional Information for Certain Jurisdictions” to learn more about the rights provided in specific jurisdictions. For enquiries relating to Workplace Data, please contact your Business Workplace Owner. Complaints In the event that you wish to make a complaint about how we process your information, please contact us in the first instance using the details set forth in the “Contact Us” section and we will endeavor to deal with your request as soon as possible. Contact Us If you wish to talk with us about how we process your personal data, please contact us at privacy@larksuite.com and we will endeavor to deal with your request as soon as possible. Changes This Policy may be updated by us from time to time to reflect changes to applicable laws, regulations, standards, industry codes or other instruments of a similar nature, or to reflect changes, updates or new features to the Services. When we update the Policy, we will notify you by updating the “Last Updated” date at the top of this Policy and posting the new Policy and providing any other notice required by applicable law. Your continued access to or use of the Services after the date of the updated Policy constitutes your acknowledgment and agreement that you have read, understood and accepted the terms of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Platform or the Services and delete your account. Prevailing Language This Policy is prepared in English and may be translated into multiple languages other than English. If there is any inconsistency between the English language text and any translation, to the maximum extent permitted under applicable law the English language text shall prevail, unless otherwise expressly stated in the applicable translation. SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC TERMS If you access or use the Services in any of the jurisdictions listed below, the supplemental terms relevant to that jurisdiction will apply. In the event of a conflict between those jurisdiction-specific terms and the main body of this Privacy Policy, the relevant jurisdiction’s supplemental terms will supersede and control. European Economic Area (“EEA”), Switzerland, and United Kingdom (“UK”) If you are a user of the Services in the EEA, Switzerland and UK, you have the below rights in relation to your personal data. Where we act as a controller for your personal data, you should contact us to exercise any of your rights. Where we act as a processor, you should contact the Business Workplace Owner to exercise any of your rights. You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with. You also have the right to ask us to correct your personal data where it is inaccurate or incomplete. In certain circumstances, you have the right to ask us to delete the personal data we hold about you: where you believe that it is no longer necessary for us to hold your personal data (for example, if you decide that you no longer wish to use the Services); where we are processing your personal data based on legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; or where you believe the personal data we hold about you is being unlawfully processed by us. In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data: where you believe the personal data we hold about you is inaccurate and while we verify accuracy; where we want to erase your personal data as the processing is unlawful, but you want us to continue to store it; where we no longer need your personal data for the purposes of our processing, but you require us to retain the data for the establishment, exercise or defense of legal claims; or where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection. Right to Object To the extent that Lark’s processing of your personal data is subject to the General Data Protection Regulation, we rely on our legitimate interests, described above, to process your data. You can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground. Right to Withdraw Consent You have the right to withdraw your consent to our processing of data about you for marketing purposes at any time, and we will stop processing data about you for that purpose. To exercise any of these rights above, please contact us using the details set forth in the "Contact Us" section. In addition, you have the right to complain to the applicable data protection supervisory authority. You also may access, correct or request deletion of personal data we have about you by logging into your account. You may also request cancellation of your account by contacting us using the details set forth in the "Contact Us" section. We’ll take steps to delete your information within a reasonable timeframe, but some information may remain in archived/backup copies for our records or as otherwise required by law. Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data. GDPR Representative If you are based in the United Kingdom, our designated GDPR representative is: Cosmo Technology Private Limited Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP If you are based in the European Region (other than the United Kingdom), our designated GDPR representative is: Mikros Information Technology Ireland Limited 6th Floor South Bank House Barrow Street Dublin 4 Ireland D04 TR29 Participation in the Data Privacy Framework Lark , through its affiliated company, Lark Enterprise Applications Inc., complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Lark has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF. Lark has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Lark commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF should first contact Lark using the details set forth in the “Contact Us” section. If we plan to use your personal information for a new purpose that differs significantly from the one originally disclosed, or share it with a third party that is not processing it on behalf of us, we will provide you the option to decide if you wish to proceed with this use or disclosure. For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction. In the context of onward transfers, Lark is accountable for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third-party acting as its agent. Lark remains liable under the EU-U.S. DPF Principles, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles if Lark’s agent processes personal information in a manner inconsistent with the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles, unless Lark proves that it is not responsible for the event giving rise to damage. With respect to personal data received or transferred pursuant to the Data Privacy Framework, Lark is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Lark may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Lark commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe - an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.trustarc.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you. South Korea Security of your Information. We work hard to protect the Services and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policies for data protection, limitation of access to personal data on a need-to-know basis and control of access to the facilities where personal data is processed. Data Retention. We destroy personal data for which the purposes of collection as consented to by you have been achieved, or for which the periods of use as consented to by you or as provided in this Policy have expired; provided, however, we will continue to store your personal data for any statutorily-prescribed periods, where applicable, including but not limited to: Act on Consumer Protection in Electronic Commerce: Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years Records on the handling of consumer complaints or disputes: 3 years Records on advertisements and labels: 6 months Protection of Communications Secrets Act Records on your visits to our Platform: 3 months Entrustment and/or International Transfer of Personal data. We entrust your data to our affiliates and service providers, some of whom are located outside of Korea (see here for a list), subject to your consents or notifications to you, if applicable. The entities receiving and processing your data are committed to using and storing personal data in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal data. Destruction of personal data. We destroy your personal data in a manner that renders it unrestorable by the relevant department. Contact us. If you have questions about this Policy, please contact us using the details set forth in the "Contact Us" section. Japan How Does This Policy Apply? Under Japanese data protection laws, there is no distinction between a controller or a processor of data. As a business who handles personal information, we are subject to the data protection laws, including in respect of the information described in the “Types of Information We Collect and Use” section and in respect of Business Owner Controlled Data as it is defined in this Policy. However, we note that this Policy does not cover the processing of Business Owner Controlled Data unless such data is shared with us by the Business Workplace Owner. Making information about the handling of Business Owner Controlled Data accessible to you is the responsibility of Business Workplace Owners, since it constitutes "retained personal data" (保有個人データ) over which they have authority under Japan's Act on the Protection of Personal Information. Such processing is primarily covered by the Business Workplace Owner’s privacy policy, a separate agreement between the Business Workplace Owner and Lark which governs delivery, access and use of the Services and/or the employment agreement (or any agreement in lieu of the employment agreement) between you and the Business Workplace Owner. rangeDom