01Definition of Personal Information

The term “personal information” as used in the Privacy Policy (hereinafter referred to as “the Policy”) shall mean any information about a living individual which falls under any of the following items.
Nevertheless, in the event that the Act on Protection of Personal Information and any of its relevant laws and ordinances are revised, the definition shall follow such revision(s).
1) Information that can identify a specific individual by name, date of birth, or other description contained in the information (this refers to all matters described or recorded in documents, drawings, or electromagnetic records, or expressed using audio, movement, or other methods) (including information that can be easily cross-checked with other information and thereby identify a specific individual)
2) Information that contains personal identification codes

02Purpose of Personal Information Utilisation

The Company uses personal information for the purposes listed below. In cases where changes in the purpose of utilisation are necessary, the Company will issue a notification or make a public announcement regarding such changes in a timely manner.

• Personal information of employees will be used for employment and human resource management.

• Personal Information that we collect from job applicants or employment agencies in relation to employment selection will be used for management of employment selection (including the determination of whether or not to hire, communicating about interviews or joining the Company, and analysis for use in future employment selection) and communication on various information (e.g., seminar, event, company information session and other information on the Company Group).

• Personal information of clients will be used for business contact, smooth execution of business and communication on various information (e.g., seminar, event, company information session and other information on the Company Group).

• Personal information of subscribers to services that the Company operates and provides will be used for specified purposes in accordance with the terms and conditions of each service’s privacy policies.

• The personal information that we collect in relation to the implementation of events will be used for providing information and communicating about the event, providing information about business related to the event or other projects run by the Company Group, analyzing profiles of event participants, and conducting campaign lotteries and sending prizes and products related to the event.

03Provision of Personal Information to a Third Party

The Company does not provide Personal Data (the definition of Personal Data shall be as stipulated in the Act on Protection of Personal Information) to any third parties except in the following cases:

• In cases where prior consent on such action has been obtained (Personal Data collected in relation to the implementation of events may be provided to the co-organizers, speakers, etc. listed on the event information or application pages as recipient or shared recipient of such Personal Data);

• In cases where such action is conducted in accordance with the Act on Protection of Personal Information and other laws and ordinances;

• In cases where such action is necessary in order to protect individuals from life threats, physical injuries, and property damage, and where there is difficulty in obtaining the Subject’s consent;

• In cases where personal information management is outsourced partially or wholly (including server storage) to an external enterprise in accordance with a business outsourcing contract, the Company Group will sign an agreement with the third party concerning personal information management and/or appropriately supervise the third party regarding security management of personal information;

• In cases where business succession as a result of a merger or acquisition, company split, business transfer, etc. has taken place.

04Acquisition and Use of Personally Identifiable Information and Access History

In order to provide a better user experience and serve more relevant advertisements, including the distribution of advertisements from the Company Group, the Company Group may acquire and use information for which specific identity cannot be determined, such as cookies, accessed URLs, and access history. There are also cases where the Company shares such information with advertisers, information suppliers, and service providers for the same purpose.
See here for examples of the main third-party services that are used by the Company’s services:

05Joint Utilisation of Personal Information

In order to provide better services, the Company Group will share and jointly utilise personal information with its affiliates of the Company Group as listed below under strict management and with appropriate security measures.

• Commonly Used Personal Data

  Personal Data that the Company Group acquires, such as name, e-mail address, company, and job title.

• Shared Users

  The Company Group

• Purpose for Shared Use

  The same purpose as stipulated in Section 2 above.

• Responsible Party for Shared Usage of Personal Data

  Uzabase, Inc.
  The representative and address of Uzabase:
  

  https://www.uzabase.com/en/company/

06Provision toThird Parties in Foreign Countries and Storage

In the following cases, the Company may provide or store personal data with third parties in foreign countries (meaning countries or regions outside Japan). A list of the names of the foreign countries to which the Company may provide personal data and information about the rules of those countries is provided in the exhibit.
In addition, the third parties in foreign countries to which the Company provides personal data have taken measures to ensure that personal information is adequately protected, such as by complying with the laws and regulations of the relevant country regarding the protection of personal information.

• In cases where personal information is provided to a third party

  If the recipient of personal data is a third party located in a foreign country, we will use the personal data within the scope of the purposes of use.

• in cases where the processing or storage of personal data is outsourced

  We may provide all or part of the personal data to a subcontractor located in a foreign country, or entrust the storage of the data in the cloud or by other means. In such cases, we will provide the necessary and appropriate supervision of the subcontractor.

• In cases where personal information is shared with the Company Group located in a foreign country

  Some of the Company Group are based overseas, and we will also share personal data with the Company Group in a foreign company within the scope of the purposes stipulated for joint use. A list of locations of the Company Group is available

  here

  .

07Procedures for Consultation and Disclosure Requests Concerning Personal Information Management

If you have complaints and/or requests for disclosure, correction, and termination of use of your personal information, please contact the personal information manager, and the Company will respond to such requests when your identity has been confirmed.

08Procedures for Disclosure Requests

The following Personal Data can be disclosed by the Company upon request (hereinafter referred to as “Personal Data for Disclosure”):

• Personal Data of customers acquired by any of the Company’s business units (excluding Personal Data received from information providers or consignors for business operations outsourced to the Company);

• Personal Data regarding customers/business partners;

• Personal Data pertaining to employee management for all of the Company’s personnel;

• Personal Data pertaining to those who apply for employment at the Company; however, Personal Data acquired from staffing agencies, such as the resumes of applicants, is not included in Personal Data for Disclosure and cannot be requested or disclosed;

• Personal Data pertaining to users who have made enquiries to the Company.

To request Personal Data for Disclosure, please contact the personal information manager at the Company.
The Company will confirm the identity of the person requesting the Personal Data for Disclosure and there may be cases where a copy of an official identification document needs to be mailed to the Company for confirmation.

09Major Changes and Notifications

In case of major changes and notifications regarding personal information protection, the Company will make public announcements through its website and/or via other channels.

10Revisions of this Privacy Policy

In order to constantly improve its personal information management, the Company may change and revise this Privacy Policy, under which circumstances the Company shall release the revised Privacy Policy on the company website that it operates.
When such revision requires customers’ consent under relevant laws and ordinances, the Company shall obtain such consent in a manner designated by the Company.

11Personal Information Protection Manager of the Company Group

Uzabase, Inc.
Executive Officer in charge of personal information
privacy@uzabase.com