Article 1 (Personal Information)

“Personal Information” herein refers to “personal information” as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, this Act will be hereinafter referred to as “APPI”), which means information about a living individual (i) that can be used to identify a specific individual by a name, date of birth, or other identifier contained in such information or (ii) that contains an individual identification code.

Article 2 (Acquisition and Use of Personal Information)

The Company will acquire and use Users’ Personal Information within the scope necessary for the following purposes. If such Personal Information is to be used beyond such scope, the Company will obtain the Users’ consent in advance through appropriate means. Also, the Company may designate additional purposes for each of services and surveys.

1. To provide the Company’s services (the “Services”)
2. To promote the sale of the Services, conduct surveys on the Services, and send gifts and other items via various media including telephone, email, and postal mail
3. To improve and enhance the content of the Services or to develop new services
4. To inform Users of new features, updates, campaigns, and other information about the Services, as well as to introduce other services provided by the Company (including sending emails, flyers, and other direct mail)
5. To provide information about the Company’s or third parties’ services via telephone, email, or other direct mail from the Company
6. To contact Users as necessary for maintenance, important notices, and other relevant matters
7. To respond to inquiries or consultations from Users regarding the Services (including identity verification)
8. To report to Users on their usage of the Services
9. To request cooperation in surveys and interviews regarding the Services, and to invite participation in various events, as well as to report the results
10. To investigate and analyze the usage history of the Services and use the results to improve and develop the Services or for advertising distribution
11. To identify Users who breach the Terms of Use or attempt to use the Services for fraudulent or improper purposes, and to refuse their use of the Services

Article 3 (Management and Protection of Personal Information)

The Company shall manage Personal Information strictly and will not disclose or provide data to third parties without the User’s consent, except in the following cases. Additionally, considering safety, the Company will take preventive and corrective measures against risks such as unauthorized access to Personal Information, and loss, destruction, alteration, and leakage of Personal Information.

1. If such disclosure or provision is necessary to protect a person’s life, body, or property and it is difficult to obtain the User’s consent.
2. If such disclosure or provision is especially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the User’s consent.
3. If it is necessary to cooperate with a national institution, local public body, or an individual or entity commissioned by them to execute affairs prescribed by law, and obtaining the User’s consent is likely to impede such execution of affairs.
4. If the handling of Personal Information is commissioned in whole or in part within the scope necessary for achieving the purpose of use to ensure the smooth execution of operations.
5. If Personal Information is provided as a result of the succession of business due to a merger or other reasons.
6. If Personal Information is shared with specific individuals; provided that the User is notified in advance of, or the User can easily access, information regarding the shared use, the items of Personal Information to be shared, the scope of joint users, the purpose of use by the joint users, and the name or title of the person responsible for the management of the Personal Information.
7. Other cases as permitted by law.

Article 4 (Commissioning of Handling Personal Information)

The Company may commission the handling of Personal Information in whole or in part within the scope necessary for achieving the purposes of use. In such cases, the Company will thoroughly examine the eligibility of the commissioned party and stipulate confidentiality obligations and other relevant matters in the contract, ensuring necessary and appropriate supervision over the commissioned party. Additionally, the Company may share all or part of acquired Personal Information in accordance with the provisions of APPI. For the joint use of applicants’ Personal Information obtained in relation to recruitment activities involving the Company and/or its consolidated subsidiaries, please refer to the separately established “Privacy Policy for Recruitment Activities”.

Article 5 (Disclosure of Personal Information)

If the Company is requested by a User to disclose his/her Personal Information, the Company will promptly disclose it to the User. However, if the disclosure falls under any of the following cases, the Company may choose not to disclose all or part of the information. If a decision is made not to disclose the information, the Company will promptly notify the User of the decision.

1. there is a risk of harm to the life, body, property, or other rights or interests of a User or a third party.
2. there is a risk of significant hindrance to the proper execution of the Company’s business.
3. Other cases where such disclosure will result in a violation of other laws and regulations.

Article 6 (Correction and Deletion of Personal Information)

1. If any piece of Personal Information held by the Company is incorrect, the Company will correct or delete such piece in accordance with the procedures specified by the Company upon request of the relevant User.
2. If the Company determines that it is necessary to respond to the request from the User as stipulated in the immediately preceding paragraph, the Company will promptly correct or delete the relevant piece of Personal Information and notify the User of such action.

Article 7 (Suspension of Personal Information)

If a User requests the suspension or deletion (“Suspension”) of his/her Personal Information on the grounds that it is being handled beyond the scope of the intended purpose of use, or that it has been obtained by improper means, then the Company will promptly conduct the necessary investigation and, based on the results, will implement Suspension of the use of the Personal Information and notify the User of such action. However, if the Suspension of Personal Information entails significant costs or if it is otherwise difficult to perform the Suspension, and if alternative measures can be taken to protect the rights and interests of the User, then the Company will take such alternative measures.

Article 8 (Procedure for Changing Privacy Policy)

The Company will review and strive to improve the content of this policy as appropriate. The content of this policy can be changed, except for matters otherwise provided by law or in this policy. The revised privacy policy will take effect from the time it is notified to Users or posted on the Company’s website by a method prescribed by the Company.

Article 9 (Compliance with Laws and Rules)

The Company will comply with the Japanese laws and other rules applicable to Personal Information held by the Company.

Article 10 (Handling Complaints and Inquiries)

1. The Company will accept and respond appropriately and promptly to complaints and inquiries from Users regarding the handling of Personal Information. The Company will also respond promptly and appropriately to requests from Users for disclosure, correction, addition, deletion, refusal of use, or refusal of provision concerning their Personal Information.
2. A handling fee of 1,000 yen (tax included) per request will be charged for responses to requests for disclosure of Personal Information or disclosure of the purpose of use. However, if additional costs are required due to special disclosure or notification methods requested, an additional fee reflecting those costs might be charged.

Article 11 (Security Management Measures)

Regarding Personal Information that the Company receives from Users, the Company will prevent unauthorized access to, loss, destruction, alteration, leakage, and other problems of Personal Information by taking organizational, physical, human, and technical measures, including implementing access restrictions to Personal Information files, recording access logs, and implementing security measures to prevent unauthorized access from external sources. In the event of an incident such as a leakage of Personal Information of Users, the Company will promptly report it to the supervisory authority in accordance with APPI and relevant guidelines, and will take necessary measures such as measures to prevent the occurrence of similar incidents and recurrence prevention measures in accordance with the instructions of the supervisory authority.

Article 12 (Contact Information)

For inquiries regarding the handling of Personal Information by the Company, please contact the following:
Customer Support
Phone number: 03-5579-8029
(Monday to Friday, excluding public holidays, year-end and New Year holidays, and other Company holidays, 10:00 to 18:00)

Article 13 (Address and Representative's Name of the Company)

The address and the representative’s name of the Company are shown in the linked page below:
https://www.serverworks.co.jp/en/about.html

Revised on December 1, 2023.