AI Governance & Creative Integrity Policy

Article 1 (Purpose and the Company’s Role)

1.The Company regards generative AI not merely as a production tool, but as one of the technological foundations for designing, implementing, and evaluating creative systems and processes.

2.This Policy sets out common principles concerning AI governance, creative integrity, rights, data, and accountability when companies, researchers, AI creators, and other participants collaborate through the Service.

3.In addition to operating a service that supports creative collaboration, the Company may, depending on the nature of a project and the form of agreement, act as a contracting party, contractor, production lead, or coordinator. The contractual relationships, roles, and allocation of responsibilities for each project will be defined in the Terms of Use, an Individual Agreement, purchase order, memorandum, or other applicable document.

Article 2 (Scope)

1.This Policy applies to all deliverables, materials, posts, proposals, prototypes, work-in-progress materials, research outputs, input data, output data, and other content provided, published, shared, created, or used on the Service or in projects conducted through the Service, as well as the processes used to create and manage them, whether public or non-public.

2.This Policy applies to the Company, Users of the Service, Registered Members, Clients, creators, researchers, contractors, joint business partners, and other project participants, in accordance with their respective roles and level of involvement.

Article 3 (Specific Uses of Generative AI)

1.The Company may use generative AI and other forms of AI in creative production, business support, publishing and communications, creator profiles and introductions, training, consulting, and other business activities.

3.The extent to which generative AI or other AI is used, and the manner of human involvement, will vary depending on the deliverable, service, intended use, contractual terms, and anticipated risks. The Company will apply review, verification, or approval procedures proportionate to the relevant risks when making material decisions or publishing, providing, or delivering work.

Article 4 (Roles in the AI Value Chain)

For the purposes of this Policy, parties involved with AI may be described from the following perspectives, as appropriate. A single party may perform more than one role.

1.AI Developer
A party that develops or improves an AI model, AI system, or technology forming part of such a model or system

2.AI Provider
A party that provides an AI model or AI system as a service, product, or feature

3.AI User
A party that uses an AI model, AI system, or AI service in business, research, creative production, or another activity

Article 5 (Human-Centered Creative Principles)

1.Regardless of the extent of AI’s role in a creative or research process, the Company’s principle is that people remain responsible for setting objectives, assessing risks, making material decisions, reviewing deliverables, and making final decisions concerning publication or delivery.

2.Where appropriate, the Company emphasizes meaningful human creative or research involvement, including defining concepts and expressive intent; designing worlds and expressive structures; conducting research; designing prompts and generation parameters; selecting, comparing, editing, and restructuring outputs; integrating multiple tools; performing iterative evaluation; making manual revisions; and making final creative decisions.

3.Whether a deliverable created using AI qualifies for copyright protection, whether any rights arise, and the scope of any such protection will be determined on a case-by-case basis under applicable law, taking into account the specific creative process and the content of the deliverable. This Policy does not guarantee the existence, non-infringement, or registrability of any copyright or other right.

Article 6 (Risk-Based Governance)

1.The Company and relevant project participants will apply controls proportionate to risk, taking into account the intended use of AI, affected persons, scope of publication, potential impact, likelihood of errors or infringement, sensitivity of the information involved, and other relevant circumstances.

2.For uses that may affect legally, financially, medically, physically, or socially significant decisions; materially affect an individual’s rights or interests; or otherwise present a high level of risk, the Company and relevant project participants will, as appropriate, designate a responsible person, require advance human review, consult specialists, limit the scope of use, perform additional evaluation, or implement other appropriate measures.

3.Because AI outputs may be inaccurate, incomplete, or biased, the Company and relevant project participants will perform fact-checking, source verification, similarity review, quality assurance, and human review as appropriate to the intended use and level of risk.

Article 7 (Selection of AI Tools, Models, and Input Data)

1.Within a reasonable scope, the Company and relevant project participants will review an AI tool’s or model’s intended purpose, performance, limitations, terms of use, eligibility for commercial use, terms governing rights in outputs, handling of input data, use of data for training, retention periods, security, and other relevant factors, and will select tools or models appropriate for the intended use.

2.Before entering confidential information, personal information, non-public information, third-party content, or other sensitive information into an external AI service, the Company and relevant project participants will verify the purpose of use and contractual authority and, as appropriate, obtain consent from the relevant individual or rights holder; anonymize or pseudonymize the information; restrict inputs; control the scope of sharing; disable the use of data for training where that option is available; or implement other appropriate measures.

3.If an Individual Agreement or other arrangement specifies which AI tools may be used, what information may be entered, or which uses are prohibited for a project, all relevant parties must comply with those requirements.

Article 8 (Clarity of Rights and Contractual Terms)

Depending on the nature of a project, the Company will clarify all or some of the following matters in advance through the Terms of Use, an Individual Agreement, purchase order, memorandum, specification, or other applicable document.

1.Ownership of rights in deliverables and work-in-progress materials, including the treatment of moral rights

2.Permitted purposes, media, duration, territory, modifications, secondary uses, sublicensing, and other conditions of use

3.Credit requirements, publication conditions, confidentiality, and permission to publicize participation or results

4.Treatment of AI tools, input data, generation parameters, output data, and production records

5.Roles and responsibilities for review, approval, publication, delivery, and incident response

Deliverables and other materials may be used only on a lawful basis and within the scope agreed under the Terms of Use, the consent of the relevant individual or rights holder, an Individual Agreement, or another applicable arrangement. They must not be used, modified, reproduced, or redistributed beyond that scope.

Article 9 (Third-Party Rights and Compliance with Law)

1.The Company and relevant project participants will comply with the terms governing the AI tools they use and with applicable laws and regulations. They will not use AI for the purpose of infringing a third party’s copyright, trademark rights, design rights, portrait rights, publicity rights, privacy, trade secrets, or other rights or legitimate interests.

2.If content may be similar to, or mistaken for, a specific existing work, creator, brand, person, or other subject, the Company and relevant project participants will consider appropriate measures based on the intended use and level of risk, including changing generation parameters, reviewing similarity, clearing rights, providing disclosures, or limiting the scope of publication.

3.Recognizing that the legal analysis applicable to AI development and training may differ from that applicable to the generation and use of outputs, the Company will assess each specific use in light of the laws, judicial decisions, regulatory guidance, and contractual terms in effect at the relevant time.

Article 10 (Transparency, Explanation, and Records)

1.Taking into account the purpose and contractual terms of a project, the nature of the deliverable, and the level of risk, the Company will endeavor, within a reasonable scope, to remain able to explain the use and extent of AI, the principal production and evaluation processes, and any material assumptions, capabilities, or limitations of the deliverable.

2.Where appropriate, the Company and relevant project participants will maintain records of the tools or models used; material inputs and generation parameters; the processes used to select, edit, and review outputs; approvers; and other relevant information, using methods and retention periods proportionate to the purpose and level of risk.

3.The preceding two paragraphs do not require the disclosure of information where disclosure would prejudice trade secrets, personal information, security, third-party contractual obligations, or other legitimate interests.

Article 11 (Safety, Fairness, Privacy, and Security)

1.The Company will endeavor to reduce the risks associated with the use of AI, including harm, misinformation, inappropriate outputs, amplification of discrimination or bias, privacy violations, data breaches, misuse, and other adverse consequences.

2.Personal information will be handled in accordance with the Company’s Privacy Policy and applicable laws and regulations. The Company will implement security controls proportionate to the nature and sensitivity of the information and the level of risk, including controls relating to access, retention, transmission, sharing, and deletion.

3.The Company will not rely solely on an AI system or its provider as the final decision-maker and will endeavor to establish reasonable channels for objection, reconsideration, or human review where the Company determines that such measures are appropriate for a material decision.

Article 12 (Synthetic Content and Prevention of Misrepresentation)

1.Where synthetic content realistically depicts an actual person, organization, event, or record and may materially mislead its audience, the Company and relevant project participants will take measures appropriate to the expressive purpose, medium, and context, such as disclosing the use of AI, providing a notice, obtaining consent, or limiting the scope of publication.

2.Synthetic content must not be created or used, without the relevant individual’s consent or another lawful basis, for impersonation; fraud; defamation or reputational harm; unlawful sexual content; improper manipulation of elections or other social decision-making; or any purpose that endangers a person’s safety.

Article 13 (AI Training, Dataset Creation, and Automated Collection)

1.Without the express consent of the relevant individual or rights holder, the Company will not use non-public works, generated content, production data, prompts, materials, posts, messages, or other content provided by a User in connection with the Service or a project to train or retrain third-party machine-learning or AI models or to build datasets for unspecified purposes.

2.No User or other third party may, without the express authorization of the Company and any other necessary rights holder, use content made available on or through the Service for machine learning; training or retraining AI models; building datasets; generating embeddings; scraping, crawling, or automated collection; automated republication; redistribution for analytical purposes; or any similar purpose.

3.The preceding paragraph does not apply to processing undertaken by the Company as necessary to provide, maintain, search, quality-control, or secure the Service; lawful indexing by general-purpose search engines; use permitted by law; or use expressly authorized by the Company and any other necessary rights holder.

4.Any AI-enabled feature or transmission of data to an external AI service is subject to the Company’s Privacy Policy, the Terms of Use, any applicable Individual Agreement, and the terms of the relevant service provider.

Article 14 (Response to Issues and Incidents)

1.If an infringement, data breach, material misinformation, safety concern, misuse, or other issue relating to the use of AI occurs or is reasonably suspected, the Company will, as appropriate to the circumstances, suspend use or publication; restrict access; preserve relevant materials and logs; establish the facts; identify the scope of impact; notify relevant parties; take corrective action; and implement measures to prevent recurrence.

2.Where a report, notice to an affected individual, or consultation with a relevant authority is required by law, the Company will respond in accordance with the prescribed procedures.

3.If a project participant becomes aware of any fact or indication described in the preceding two paragraphs, the participant must promptly contact the Company or the person designated as responsible for the project and reasonably cooperate with any investigation or response.

Article 15 (Education, AI Literacy, and Continuous Improvement)

1.The Company will endeavor to provide education and improve literacy concerning the technical characteristics of AI, applicable law, rights, ethics, safety, privacy, and security among its officers, employees, contractors, and other relevant parties as appropriate.

2.The Company will review this Policy and related controls periodically or as needed in response to changes in technology, social conditions, applicable law, regulatory guidance, judicial decisions, and the operation of the Service.

3.The Company values participant learning and creative practice, a healthy competitive environment, and the advancement of responsible innovation.

Article 16 (Response to Violations and Misuse)

If the Company identifies a violation of this Policy, the Terms of Use, an Individual Agreement, or applicable law; an infringement of rights; misuse; or another issue, it may take any of the following measures depending on the nature and impact of the matter.

1.Reviewing the circumstances and facts and requesting relevant materials

2.Requesting the removal or suspension of content, suspension of use, restriction of access, or other corrective action

3.Suspending or terminating a contract or registration

4.Contacting relevant parties or authorities, considering legal action, or taking other necessary measures

5.Seeking compensation where the Company or a third party has suffered loss

Article 17 (Relationship to Other Terms and Contact)

1.This Policy establishes common principles for the use of AI and creative collaboration and supplements the Terms of Use, the Privacy Policy, and any Individual Agreement.

2.If this Policy conflicts with an Individual Agreement or other project-specific arrangement, that Individual Agreement or arrangement will prevail for the relevant project. The Privacy Policy will prevail with respect to the handling of personal information, and the Terms of Use will prevail with respect to the general conditions governing use of the Service.

3.As a general rule, questions relating to a contract entered into directly between participants without the Company’s involvement, or to an external AI service, should be directed to the relevant contracting party or service provider.

Article 18 (External Guidance, Governing Law, and Jurisdiction)

1.The Company will operate this Policy with reference to the AI Guidelines for Business issued by Japan’s Ministry of Internal Affairs and Communications and Ministry of Economy, Trade and Industry; the Act on Promotion of Research and Development, and Utilization of AI-related Technology; Japan’s Second Artificial Intelligence Basic Plan; the Agency for Cultural Affairs’ materials on AI and copyright; and other applicable laws, regulations, and government guidance, taking into account the nature of its business and the relevant risks. When any such material is revised, the Company will refer to the version then in effect.

3.This Policy is governed by and construed in accordance with the laws of Japan.

4.The Tokyo District Court or the Tokyo Summary Court has exclusive jurisdiction as the court of first instance over any dispute between the Company and a User arising out of or relating to the Service or this Policy, except where an Individual Agreement provides otherwise.

5.The Company may amend this Policy as necessary in response to changes in applicable law, regulatory guidance, technology, the Service, or other relevant circumstances. If the Company makes a material change, it will provide notice of the change and its effective date by posting the information on the Service or by another appropriate method.