PRIVACY POLICY

Article 1 (Personal Information)

• “Personal Information” refers to the definition provided in Article 2, Paragraph 1 of the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as the “Personal Information Protection Act”). It means information relating to a living individual that can identify a specific individual by name, date of birth, or other descriptions contained in such information, or that contains personal identification codes.
• “Personal Data” refers to personal information that constitutes part of a personal information database, etc., as defined in Article 16, Paragraph 1 of the Personal Information Protection Act, and is specified in Paragraph 3 of the same article.

Article 2 (Purpose of Use of Personal Information)

• The Company shall acquire and use personal information of users within the scope necessary for the following purposes. In the event that personal information is to be used beyond the scope of the following purposes, the Company shall obtain the user's prior consent by appropriate means.
  • To provide the Company’s services (hereinafter referred to as “the Services”)
  • To improve or enhance the Services, or to develop new services
  • To provide information regarding new features, updates, promotions, and other services offered by the Company (including email newsletters, printed materials, and other direct marketing communications)
  • To contact users when necessary regarding maintenance or other important notices
  • To respond to users’ inquiries, opinions, or feedback regarding the Company and the Services (including identity verification)
  • To report the usage status of the Services to users
  • To request cooperation in surveys, interviews, or participation in various events related to the Services, and to report the results thereof
  • To investigate and analyze usage history of the Services, and to use the results for improvements, development, or targeted advertising
  • To conduct marketing, including recommendations, advertisements, or analysis based on user attributes and service usage history, in accordance with user interests and preferences (including measurement of advertising effectiveness)
  • To identify users who violate the Terms of Use or attempt to use the Services for improper or fraudulent purposes, and to deny their use of the Services
• With respect to individuals who are applying or have applied to become officers or employees of the Company (including full-time employees, contract employees, part-time employees, temporary staff, seconded employees, or dispatched workers; hereinafter referred to as “Recruitment Candidates”), their personal information shall also be used for the following purposes, in addition to those listed in the preceding paragraph:
  • To evaluate and assess the eligibility of Recruitment Candidates (including background checks)
  • To communicate administrative matters and selection results, and to provide information on employment opportunities
  • To review information previously submitted by Recruitment Candidates in past applications
  • To manage and improve the Company’s recruitment processes
  • To carry out tasks related to or incidental to any of the above purposes

Article 3 (Provision of Personal Data to Third Parties)

The Company shall not disclose or provide personal data to any third party without the prior consent of the user, except in the following cases:

• When it is necessary to protect the life, body, or property of an individual and it is difficult to obtain the user's consent
• When it is particularly necessary for the improvement of public health or the sound development of children, and it is difficult to obtain the user's consent
• When it is necessary to cooperate with a national government organization, local government, or a party entrusted by such an entity in executing affairs prescribed by laws and regulations, and obtaining the user's consent may hinder the execution of such affairs
• In other cases permitted by laws and regulations

Article 4 (Outsourcing the Handling of Personal Information)

The Company may entrust all or part of the handling of personal data to a third party within the scope necessary to achieve the purposes of use.
In such cases, the Company shall thoroughly evaluate the eligibility of the subcontractor, stipulate confidentiality obligations and other necessary matters in the contract, and exercise necessary and appropriate supervision over the subcontractor.

Article 5 (Use of Google Analytics)

The Company uses “Google Analytics,” a web analytics tool provided by Google that utilizes cookies (hereinafter referred to as “Google Analytics”). Through Google Analytics, the Company collects information such as users’ browsing history and receives analytical results.
For details on how data is handled by Google Analytics, please refer to Google’s website.
If you wish to stop data collection via Google Analytics, please use the Google Analytics Opt-out Browser Add-on and adjust your browser settings accordingly.
“How Google uses information from sites or apps that use our services”
“Google Privacy Policy”
“Google Analytics Opt-out Browser Add-on”

Article 6 (Disclosure of Retained Personal Data)

• When a request is made by a user (limited to the individual concerned; the same shall apply hereinafter in this Article) for disclosure of retained personal data held by the Company, the Company shall disclose such data to the user without delay.
  However, all or part of the information may not be disclosed if any of the following applies, and in such cases, the Company shall notify the user without delay of the decision not to disclose:
  • If there is a risk of harm to the life, body, property, or other rights and interests of the user or a third party
  • If there is a significant risk of hindrance to the proper execution of the Company’s operations
  • If disclosure would violate any other laws or regulations
• A handling fee of 1,000 yen (excluding consumption tax and other applicable taxes) shall be charged for the disclosure of retained personal data held by the Company.

Article 7 (Correction, etc. of Retained Personal Data)

• If a user believes that the personal data retained by the Company is inaccurate, the user may request the Company to correct, add to, or delete such personal data (hereinafter referred to as “Correction, etc.”).
• Upon receiving a request as set forth in the preceding paragraph, the Company shall, without delay, conduct the necessary investigation and, if it determines that the request as set forth in the preceding paragraph is justified based on the results of the investigation, shall promptly make the Correction, etc. to the relevant personal data.
• When the Company has made a decision on whether or not to carry out the Correction, etc. pursuant to the preceding paragraph, it shall notify the user of such decision without delay.

Article 8 (Suspension of Use, etc. of Personal Information)

• A user may request the Company to suspend the use, delete, or cease the provision to third parties of retained personal data held by the Company (hereinafter referred to as “Suspension of Use, etc.”).
• Upon receiving a request as set forth in the preceding paragraph, the Company shall, without delay, conduct the necessary investigation and, if it determines that the request as set forth in the preceding paragraph is justified based on the results of the investigation, shall carry out the Suspension of Use, etc. of the relevant personal data.
  However, if the Suspension of Use, etc. would require significant cost or is otherwise difficult to implement, and if alternative measures can be taken to protect the rights and interests of the user, the Company shall take such alternative measures.
• When the Company makes a decision on whether or not to implement the Suspension of Use, etc. pursuant to the preceding paragraph, it shall notify the user of such decision without delay.

Article 9 (Procedures for Requesting Disclosure of Personal Information, etc.)

If a user wishes to make a request as stipulated in Articles 6 to 8, they shall contact the inquiry desk stipulated in Article 15.
After we receive such contact, we will immediately inform them of the necessary documents, etc.

Article 10 (Procedures for Changes to the Privacy Policy)

The Company shall review the contents of this Policy as appropriate and strive to make improvements.
The contents of this Policy may be changed, except as otherwise provided by laws and regulations or in this Policy.
The revised Privacy Policy shall become effective when it is notified to users by a method prescribed by the Company or published on the Company’s website.

Article 11 (Compliance with Laws and Regulations)

The Company shall comply with applicable Japanese laws and other regulations regarding the personal information it holds.

Article 12 (Response to Complaints and Inquiries)

The Company shall accept complaints and inquiries from users regarding the handling of personal information and respond appropriately and promptly.
The Company shall also respond appropriately and promptly to requests from users concerning disclosure, correction, addition, deletion, suspension of use, or refusal of provision of such personal information.

Article 13 (Security Control Measures)

The personal information entrusted to the Company by users shall be protected through organizational, physical, human, and technical measures such as restricting access to personal information files, recording access logs, and implementing security measures to prevent unauthorized access from outside.
These measures are taken to prevent unauthorized access to personal information, as well as loss, destruction, falsification, and leakage of personal information.
In the event that an incident such as a leakage of users' personal information occurs, the Company shall promptly report it to the relevant supervisory authority in accordance with the Act on the Protection of Personal Information and related guidelines, and shall take necessary measures to prevent similar incidents and recurrences, in accordance with the instructions of the supervisory authority.

Article 14 (Company Address and Representative’s Name)

The Company’s address, representative, and the name of the personal information protection manager are as follows:
Address: Shinjuku Nomura Building, 48F,1-26-2 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023, Japan
CEO: Sho Uryu

Article 15 (Contact for Inquiries)

For inquiries regarding the handling of personal information by the Company, please contact us at the following address:
Structure & Strategy Inc. – Customer Support Desk
Email: sas.info@structure-and-strategy.jp

Enacted and Effective as of September 1, 2024