Last updated : December 9, 2022
- Software applications made available by us for use on or through computers and mobile devices (the “Apps”);
- Offline business interactions you have with us.
Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services.”
If you are a California resident, please see “17. Supplementary Information Regarding California” for details on how we handle the Personal Information of California residents and how to exercise your rights under the California Consumer Privacy Act.
1.Types of Personal Information Acquired
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
- Contact information (addresses, names, telephone numbers, email addresses, fax numbers, etc.)
- The Services’ account information (user IDs, passwords, etc.)
- Information accompanying personnel hiring (gender, date of birth, work history, academic history, qualifications, etc.)
- Information about employees (organizational information, insurance numbers, health-related information, images, etc.)
- Information about business transactions (business partners’ organizational information, bank account numbers, etc.)
2.Means of collecting Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
Through the Services.
We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, participate in the Company’s personnel recruitment or other projects involving application submission, contact customer service, place an order, or make a purchase by phone or email.
From Other Sources.
- We receive your Personal Information from other sources, for example, from publicly available databases and our joint marketing partners, when they share the information with us.
3.Purposes of Processing Personal Information
We and the providers of the Services process Personal Information for the following purposes:
Providing the functionality of the Services and fulfilling your requests.
- To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
- To complete your transactions, verify your information, and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
- To allow you to send messages to another person through the Services if you choose to do so.
We will engage in these activities to manage our contractual relationship with you and to comply with a legal obligation.
Providing you with our newsletter or other marketing materials.
- To send you marketing related emails, with information about our services, new products and other news about our company.
We will engage in this activity with your consent or where we have a legitimate interest.
Analyzing Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand your interests and preferences, so that we can personalize our interactions with you, provide you with information and offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
Allowing you to participate in contests or other projects involving application submission, including personnel recruitment.
- We may offer you the opportunity to participate in a contest planned by us or other projects involving application submission, including personnel recruitment.
- Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
We use this information to manage our contractual relationship with you.
Aggregating or anonymizing Personal Information.
- We may aggregate or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
Accomplishing our business purposes. (or more specifically, the objectives listed below)
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our Services, so that we can adapt our Services to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and based on our legitimate interest.
4.Recipients of Disclosed Personal Information
4-1 Recipients of Disclosed Personal Information
We disclose Personal Information:
You can consult the list and location of our affiliates here.
To our third party service providers, to facilitate services they provide to us.
These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
By using the Services, you may elect to disclose Personal Information.
On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
4-2 Purposes of Use and Disclosure to Other than Those Listed Above
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
To comply with applicable law and regulations.
This may include laws outside your country of residence.
To cooperate with public and government authorities.
To respond to a request or to provide information we believe is necessary or appropriate. These can include authorities outside your country of residence.
To cooperate with law enforcement.
For example, when we respond to law enforcement requests and orders or provide information we believe is important.
For other legal reasons.
To enforce our terms and conditions and to protect our rights, privacy, safety or property, or that of our affiliates, you or others.
In connection with a sale or business transaction.
We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
5.Other Information (including an explanation regarding cookies)
“Other Information” is any information that does not reveal your specific identity or cannot identify an individual. The Services collect Other Information such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
5-1 Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
Your browser or device
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
5-2 Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “15. Contacting Us” section below.
7.User Options Pertaining to the Use and Disclosure of Personal Information
We give you with options pertaining to the use and disclosure of users’ Personal Information for marketing purposes. To prevent us from carrying out the following processing, you may make a request to us (hereinafter referred to as “opt out”):
（1）Receiving marketing-related emails from us.
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by using the unsubscribe mechanism provided in each of our marketing emails.
We will try to comply with your requests as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
8.Methods for Accessing, Changing and Deleting your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “15. Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please specify what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
For requests for disclosure of Personal Information and notification of the purpose of use by the Company, a fee of eight hundred (800) yen (including tax) will be charged per request.
Please note that we may need to retain certain information for recordkeeping purposes to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
If you are a resident of California, under 18, and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services. Please contact us in accordance with the “15. Contacting Us” section below. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
We retain Personal Information for as long as needed or permitted in light of the purposes for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
10.Services Provided by Third Parties
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
11.Jurisdiction and Cross-border Transactions
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
12.Supplementary Information Regarding to the EEA
Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “15. Contacting Us” section below.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
16.Supplementary Information Regarding the EEA
You may also:
17.Supplementary Information Regarding California
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of Personal Information that we collect, use, and disclose about California residents. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.
17-1 Sources of Personal Information
We collect Personal Information from:
- Our interactions with you, such as when you interact with our websites or other online services we provide, give us feedback, surveys, questionnaires, contests, participation in projects involving application submission, link your social media account to your account with us, or contact customer support; and
- Our group companies, publicly available online sources and joint business partners.
17-2 Collection of Personal Information
We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information as listed in the CCPA:
- “Identifiers.” Identifiers, such as name, contact information, IP address, and other online identifiers;
- “Customer Records Information.” Personal information, as defined in the California customer records law, such as name, contact information, education information, employment information, etc.;
- “Protected Class Information.” Characteristics of protected classifications such as age, gender, etc.;
- “Online Use Information.” Browsing histories and interactions with the Services, etc.;
- “Employment Information.” Professional or employment-related information, such as work history and prior employer; and
- “Education Information.” Education information subject to the federal Family Educational Rights and Privacy Act.
17-3 Purposes of Use for Personal Information
We use these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including using Personal Information to:
- Respond to inquiries from you;
- Plan, improve and maintain our services;
- Conduct research, analytics, and data analysis;
- Establish and maintain user accounts and authenticate user identity;
- Conduct contests, projects involving application submission, research and surveys;
- Maintain our property and our records, and undertake quality and safety assurance measures;
- Conduct risk and security control and monitoring, and detect and prevent fraud;
- Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping;
- Carry out corporate transactions, such as mergers, joint ventures, or acquisitions; and
- Comply with law, legal process, and internal policies, and exercise and defend legal claims.
17-4 Sale of Personal Information
We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months.
We do not sell Personal Information of minors under 16 years of age.
17-5 Rights and Requests of Individuals
If you are a California resident, you may make the following requests:
（1）“Request to Know”
You may request that we disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
（2）“Request to Delete”
You may request that we delete Personal Information we collected from you.
To make a Request to Know or a Request to Delete, please contact us according to “15. Contacting Us”. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as name, email address, mailing address and information regarding your previous interactions with us, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. You may make a request on behalf of a child who is under 13 years old if you are the child’s parent or legal guardian. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.