PRIVACY POLICY

Privacy Policy

Article 1 General

We will comply with the Act on the Protection of Personal Information and other related laws and regulations, etc. with regard to the handling of personal information and others.

Article 2 The Purpose of Utilization of Personal Information

Our Company will use personal information acquired (meaning the “Personal Information” defined in paragraph (1) of Article 2 of the Act on the Protection of Personal Information, the same applies hereafter) for the following purposes:

Classification	The details of the purpose of utilization
Information of job seekers who use Our Company's service, “Z Career” (including Cookies data)	For providing the information of job offer tailored to the content of member registration For providing member registration information to companies seeking workers and providers of employment placement services which are partnered with Our Company and receiving a headhunt For applying directly to companies seeking workers (including an informal interview) For notifying the change of the terms of service, the notice on the halt, discontinuation, contract cancellation of services or other announcement relating to the Service (including the provision of e-mail newsletters) and the change of “Regarding the Handling of Personal Information” For utilizing it for the information distribution, marketing or other services conducted by the Service, etc. after processing information (statistical/analytical data, etc.) into any form in which any individual cannot be identified For improving the Service to make it fit more for all customers, and offering and examining new services
Information of job seekers who use Our Company's service, “Z Career Agent” (including Cookies data)	For conducting employment placement For referring providers of employment placement services to which we offer services For notifying the change of the terms of service, the notice on the halt, discontinuation, contract cancellation of services or other announcement relating to the Service (including the provision of e-mail newsletters) and the change of “Regarding the Handling of Personal Information” and others For utilizing it for the information distribution, marketing or other services conducted by the Service, etc. after processing information (statistical/analytical data, etc.) into any form in which any individual cannot be identified For improving the Service to make it fit more for all customers, and offering and examining new services
Information of job seekers who use Our Company's service, “Z Career Unemployment Insurance” (including Cookies data)	For proving the Service For notifying the change of the terms of service, the notice on the halt, discontinuation, contract cancellation of services or other announcement relating to the Service (including the provision of e-mail newsletters) and the change of “Regarding the Handling of Personal Information” and others For utilizing it for the information distribution, marketing or other services conducted by the Service, etc. after processing information (statistical/analytical data, etc.) into any form in which any individual cannot be identified For improving the Service to make it fit more for all customers, and offering and examining new services
Information of job seekers who use Our Company's service, “Z Career Platform” (including Cookies data)	For conducting employment placement in the Service For notifying the change of the terms of service, the notice on the halt, discontinuation, contract cancellation of services or other announcement relating to the Service (including the provision of e-mail newsletters) and the change of “Regarding the Handling of Personal Information” and others For utilizing it for the information distribution, marketing or other services conducted by the Service, etc. after processing information (statistical/analytical data, etc.) into any form in which any individual cannot be identified For improving the Service to make it fit more for all customers, and offering and examining new services
Information of job seekers who use Our Company's service, “Z Career Platform + Persol Career” (including Cookies data)	For conducting employment placement in the Service For notifying the change of the terms of service, the notice on the halt, discontinuation, contract cancellation of services or other announcement relating to the Service (including the provision of e-mail newsletters) and the change of “Regarding the Handling of Personal Information” and others
The Personal Information of registered users and registered agents (including the Personal Information of those employees) who use Our Company's service, “agent connect” (including Cookie data)	For conducting employment placement and outplacement services in the Service For notifying the change of the terms of service, the notice on the halt, discontinuation, contract cancellation of services or other announcement relating to the Service (including the provision of e-mail newsletters) and the change of “Regarding the Handling of Personal Information” and others For improving the Service to make it fit more for all customers, and offering and examining new services For replying to inquiries and providing consultation regarding the Service For conducting the management necessary for our operations including one for content posted in the Service For the proof of identity and the personal verification in the Service and other services (the Service, etc.) operated by Our Company For checking usage conditions of the Service, etc. (including hired or not hired) For rejecting service users who violated the terms of the Service, etc. in the past and have a unrightful and unjustifiable purpose For utilizing it for marketing research conducted by Our Company For utilizing it for the information distribution, marketing or other services conducted by the Service, etc. after processing information (statistical/analytical data, etc.) into any form in which any individual cannot be identified For conducting posterior administration after the cancelation of the Service
Information of job transferees and recommenders who use Our Company's service, “back check” (including Cookies data)	For the proof of identity and the prevention of unauthorized usage in Our Company's service, “back check” For collecting the data of work experience, evaluation, etc. in the previous job of job transferees using the background check by Our Company's service, “back check” and providing them to companies seeking workers For providing to companies seeking workers the investigation results of the accuracy of job transfer and personal history and any problematic SNS posting For utilizing it for recruitment of candidates, post-recruitment training or personnel affairs in recruiting companies For informing the terms of service regarding Our Company's service, “back check”, the halt, discontinuation, contract cancellation of or other important announcement relating to such service, and notifying the change, etc. of the Rules For utilizing it for the information distribution, marketing or other services conducted by the Service, etc. after processing information (statistical/analytical data, etc.) into any form in which any individual cannot be identified For improving the Service to make it fit more for all customers, and offering and examining new services
Information of individual clients other than the above	For providing and introducing Our Company's service For conducting questionnaires For sending out a present including any campaign in Our Company's service For the proof of identity and the prevention of unauthorized usage in Our Company's services For smooth provision, maintenance and improvement of Our Company's services including notification, correspondence to and other communication functions with clients For responding to and contacting for inquiries, and providing information from Our Company
Information of charged persons of business acquaintances	For confirming the ordering details related to Our Company's services For responding to and contacting for inquiries, and providing information from Our Company
Information of Our Company's employees	For personnel labor management for Our Company's employees and business management For health management for Our Company's employees For security management within Our Company
Information of applicants for Our Company	For evaluating the competence of a candidate for a recruiting position For providing information regarding job availability to a candidate For contacting to a candidate regarding his/her application and taking care of it If a candidate has been referred to confirm the information retained regarding the candidate who had applied before, for informing the application status and result to the person referring. For contacting to a candidate regarding a similar position after the first application was rejected unless the candidate does not hope for it. For conducting a background check for an appropriate candidate For analyzing technical issues For the management and improvement of recruitment process, in-house planning and reporting, and compliance with laws and regulations or restrictions
Countermeasures against injustice necessary for the safe operation of Our Company's services	Investigation related to the act of application prohibited by Our Company, the registration of false information, fraud, unauthorized access and other fraudulent acts

In case that Our Company acquires the Personal Information in writing or by any other means for any purpose other than those stipulated in the preceding paragraph, Our Company shall state the purpose of utilization clearly to an identifiable person in advance of the acquisition.

If it becomes necessary to use the Personal Information exceeding the scope necessary for the achievement of the purpose of utilization stipulated in paragraph 1, Our Company will use it after giving a notice to an identifiable person in advance and receiving the consent.

Our Company may make recordings of sounds or visuals of the telephone conversation or the content of business meetings with clients and business acquaintances. The recorded data will be used “to improve the quality of clients handling and confirm the telephone conversation or the content of business meetings with clients”. The Personal Information recorded will be deleted immediately upon becoming no need to use.

We may make recording of visuals by security cameras for crime prevention in the facilities that Our Company manages. Please be forewarned. The Personal Information recorded will be stored for a certain period and then deleted immediately.

The Personal Information above falls under the retained personal data and will be managed under the safety management system set forth in Article 8.

Article 3 (Proper Acquisition of Information)

Our Company will acquire the Personal Information by lawful and fair means, not by deception or other wrongful means.

Article 4 (Provision to Third Parties)

Our Company will not provide the Personal Information to any third party except:

cases based on laws and regulations;

cases in which there is a need to protect the life, wellbeing or property of an individual, and it is difficult to obtain the consent of the identifiable person;

cases in which there is a special need to improve public wellbeing or promote healthy child development, and it is difficult to obtain the consent of the identifiable person;

cases in which there is a special need to improve public wellbeing or promote healthy child development, and it is difficult to obtain the consent of the identifiable person;

cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining the consent of the identifiable person is likely to interfere with the performance of those functions;

cases in which business succession including the Personal Information is conducted due to a merger, a company split, a business transfer or other such circumstances;

we may provide the Personal Information of persons who registered as a job seeker on or after November 1, 2023, to domestic and overseas advertisement delivery operators in accordance with the Act on the Protection of Personal Information for the purpose of information distribution/marketing;

In Our Company's services, “Z Career”, “Z Career Agent” and “Z Career Platform”, the Personal Information of job seekers will be provided to companies of which a job seeker hopes to take the employment screening through the Service.

In Our Company's services, “Z Career”, “Z Career Agent” and “Z Career Unemployment Insurance”, the questionnaire information obtained from job seekers through the official LINE account and other information related to the use of LINE will be provided to LY Corporation.

Article 5 Entrustment of Handling Personal Information

Our Company may entrust a third party with the handling of all or part of the Personal Information acquired (meaning cases to entrust the analysis, management or other operations for information containing the Personal Information). In this case, Our Company enters into a confidential agreement, etc. with such entrusted entity as well as exercising the necessary and adequate supervision over such entity, so as to ensure the safety management of the information there.

Article 6 Regarding External Services

Our Company may provide services in collaboration with external services such as Facebook, the official LINE account, etc. (hereinafter referred to as the “External Services”) and if an identifiable person grants Our Company to use the Personal Information disclosed under the External Services, such Personal Information may also be disclosed under Our Company's services.

If Our Company's services contain a link to the External Services, Our Company is not liable for the handling of the Personal Information under the External Services linked. With regard to the handling of user information under these services, please refer to a privacy policy, etc. separately stipulated by an entity who provides such services.

Article 7 Behavioral Targeting Advertising, etc.

Our Company may, for performing targeting advertising (meaning an advertising method to deliver advertisement tailored to clients' needs or interests), etc. conducted by Our Company or any third party such as advertisement delivery operators, upon providing Our Company's services or collaborating services, collect, use or provide information specified in the following each item (hereinafter collectively referred to as “Log Information, etc.”). In addition, Our Company will retain the Log Information, etc. collected legally and only for the period necessary in the course of business.

Cookie and Anonymous ID
Our Company's services may use the information such as “Cookie”, “IP address”, “User Agent”. Cookie can identify information terminals, but not individuals. Although the function of Cookie can be rendered ineffective by changing the setting in an information terminal, all or part of Our Company's services may become unusable.

Please access to the following opt-out page and take procedures described in the same page, if you do not hope the acquisition and use of the Log Information, etc. specified in paragraph 1:

Name of the service	Provider	Content of user information transmitted	Purpose of utilization in the service	Purpose of utilization for the service provider	Opt-out URL
COMPASS	MicroAd, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ② for placing/delivering an advertisement as its own advertisement business / we have placed an advertisement to ad spot of such target service.	https://www.microad.co.jp/data-info/	https://send.microad.jp/w3c/
Facebook Advertisement / Instagram Advertisement	Meta Platforms, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0	Facebook Advertisement https://www.facebook.com/privacy/explanation Instagram Advertisement https://accountscenter.instagram.com/ad_preferences
Google Ad Manager	Google LLC	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ② for placing/delivering an advertisement as its own advertisement business / we have placed an advertisement to ad spot of such target service.	https://policies.google.com/privacy#infocollect	https://myadcenter.google.com/?hl=ja&sasb=true
Google Analytics	Google LLC	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on.	https://policies.google.com/privacy	https://support.google.com/analytics/answer/7318509?hl=ja
Google Search Console	Google LLC	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on.	https://policies.google.com/privacy?hl=ja	https://support.google.com/analytics/answer/7318509?hl=ja
Logicad for Publishers	SMN Corporation	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ② for placing/delivering an advertisement as its own advertisement business / we have placed an advertisement to ad spot of such target service.	https://www.so-netmedia.jp/cookie/index.html	https://www.so-netmedia.jp/cookie/dsp_optout.html
Yahoo! Advertisement Network	LY Corporation	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ② for placing/delivering an advertisement as its own advertisement business / we have placed an advertisement to ad spot of such target service.	https://btoptout.yahoo.co.jp/optout/index.html	https://btoptout.yahoo.co.jp/optout/index.htm
Google Ads	Google LLC	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://policies.google.com/technologies/ads	https://support.google.com/analytics/answer/7318509?hl=ja
Microsoft Clarity	Microsoft Corporation	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on.	https://privacy.microsoft.com/ja-jp/privacystatement	https://privacy.microsoft.com/ja-jp/privacystatement
AD EBis	YRGLM Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on.	https://www.ebis.ne.jp/privacy/faq/	https://hotei.ebis.ne.jp/policy/optout.php
EC Concier	NTT DOCOMO, INC.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.docomo.ne.jp/utility/privacy/	https://ec-concier.com/optout/
Pardot	Salesforce, Inc	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on.	https://www.salesforce.com/company/privacy/	https://www.salesforce.com/jp/company/privacy/full_privacy/
satori	SATORI, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on.	https://satori.marketing/privacy-policy/	https://satori.marketing/optout/
Marketo	Adobe Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on.	hhttps://www.adobe.com/jp/privacy.html	https://experienceleague.adobe.com/docs/marketo/using/product-docs/administration/settings/understanding-privacy-settings.html?lang=ja
Datadog	Datadog, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	For monitoring the performance of application and infrastructure, collecting the behavior history of service users and detecting the malfunctioning of services, unauthorized access, etc.	https://www.datadoghq.com/ja/legal/privacy/	https://www.datadoghq.com/ja/legal/cookies/
Sentry	Functional Software, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	For detecting the system malfunctioning based on the behavior history of service users	https://sentry.io/privacy/	https://www.sucolab.jp/privacy/
Intercom	Intercom, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	For providing the form for inquiries from service users and responding to such inquiries	https://www.intercom.com/legal/privacy	https://www.intercom.co.jp/privacy/
A8.net	FAN Communications, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.fancs.com/btapolicy	https://nend.net/privacy/explainoptout
Twitter Advertisement	X Corp.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://twitter.com/ja/privacy	https://twitter.com/settings/account/personalization
TikTok Analytics	Bytedance Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.tiktok.com/legal/page/row/privacy-policy/ja
YouTube	Google LLC	Condition of video playback, etc. Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://policies.google.com/privacy?hl=policies&gl=jp
LINE Ads Platform	LY Corporation	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.lycorp.co.jp/ja/company/privacypolicy	https://optout.tr.line.me/
Twitch	Twitch Interactive, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.twitch.tv/p/ja-jp/legal/privacy-notice/	https://dashboard.twitch.tv/monetization/ads#stream-display-ads
17LIVE	17LIVE Inc.	Condition of video playback, etc. Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://jp.17.live/copy-of-jp-privacy1/
Pococha	DeNA Co., Ltd.	Condition of video playback, etc. Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.pococha.com/support/privacy-policy/jp
SHOWROOM	SHOWROOM Inc.	Condition of video playback, etc. Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.showroom-live.com/static/pc/privacypolicy.html
Mirrativ	Mirrativ, Inc.	Condition of video playback, etc. Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.mirrativ.com/page/terms?lang=ja
Criteo	Criteo SA	Information to identify the person who browsed or the equipment	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.criteo.com/jp/privacy/
Kyujin Box	Kakaku.com, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://corporate.kakaku.com/privacy/about
Stanby	Stanby Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://jp.stanby.com/about/privacy
Gunosy Ads	Gunosy Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://gunosy.com/about/privacy	https://ads.gunosy.com/adnw_optout
SmartNews Ads	SmartNews, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://www.smartnews.com/privacy/#jp	https://www.smartnews-ads.com/optout/
Jimoty Ads	Jimoty, Inc.	Browsing history (date of browsing, URL, source URL, etc.) Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(1) Delivery of advertisement and various information ① for delivering an advertisement for the purpose of its own advertising and publicity / we have displayed our own advertisement in such target service or other services.	https://jmty.jp/about/privacy
CHEQ	CHEQ AI Technologies Ltd.	Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on. (3) For confirming that the analysis above is appropriately conducted (safeguard against ad fraud)	https://cheq.ai/ja/privacy/
Spider AF	Spider Labs, Inc.	Location information of equipment used for browsing (IP address) Information to identify the person who browsed or the equipment (user ID, browser identifier, device identifier, etc.)	(2) Analysis ① for analyzing the tendency or history of browsing by users / we collect action history information of users of such target service under the service and analyze the tendency and so on. (3) For confirming that the analysis above is appropriately conducted (safeguard against ad fraud)	https://jp.spideraf.com/privacy

Article 8 Safety Management System

Our Company will take security measures against the possibility of the leakage, destruction or damage, etc. of the Personal Information as follows:

Organizational security control measures;

• Creating rules regarding the handling of the Personal Information on the handling methods, the responsible person/person in charge and their duties for each stage of acquisition, use, storage, deletion/disposal, etc.
• Auditing periodically the handling conditions of the Personal Information

Human security control measures;

• Giving training regarding the handling of the Personal Information to employees periodically

Physical security control measures;

• Taking measures including the employees' room entry and exit control and the restriction of equipment to be carried in, etc. as well as the prevention of browsing of the Personal Information by unauthorized persons
• Taking measures for preventing the theft or lost, etc. of equipment, electronic media and documents, etc. in which the Personal Information is handled as well as conducting encryption or password-protection of the equipment, if such equipment, electronic media, etc. are carried including moving in the office

Technical security control measures;

• Limiting the scope of charged persons and the Personal Information database handled, etc. by conducting access control; and
• Bringing in a system to protect the information system which handles the Personal Information against unauthorized access or rogue software from the outside

Article 9 Sensitive Personal Information

Our Company shall, upon acquiring the Sensitive Personal Information (pursuant to the provision of paragraph 3 of Article 2 of the Act on the Protection of Personal Information), do so after receiving a consent of the identifiable person unless it is allowed by the Act on the Protection of Personal Information or other laws and regulations. In addition, Our Company will, if receiving the Sensitive Personal Information from users, handle such information in accordance with this privacy policy only within the scope of the purpose of utilization.

Article 10 Informing the Matters on the Personal Information We Hold

Regarding disclosure, collection, deletion (hereinafter referred to as the “Disclosure, etc.”) of the Personal Information we hold which has been registered to Our Company's services, our handling structure is as follows: Please refer to here for the specific procedures regarding requests for the Disclosure, etc.

Name of Entity

ROXX, Inc.

Protection Administrator of the Personal Information

Name of Administrator: Miura, Fumiya

Department: Corporate IT

Name of a certified personal information protection organization

Japan Institute for Promotion of Digital Economy and Community

Personal Information Protection Complaints Desk

Roppongi First Bldg., 1-9-9 Roppongi,
Minato-ku, Tokyo 106-0032

Tel: +81 3-5860-7565 0120-700-779
* This is not our contact point for Our Company's products/services.

Please contact us through the following form for your opinion, question regarding Our Company’s handling of the Personal Information or other inquiries regarding the handling of the Personal Information.
Please make inquiries concerning complaint resolution at a certified personal information protection organization mentioned above. (Inquiries are accepted from 9:00 to 19:00 on weekdays.)
ROXX, Inc., Contact for the Personal Information: Shinjuku Eastside Square 8F, 6-27-30 Shinjuku, Shinjuku-ku, Tokyo 160-0022
+81 3-6777-7070 Inquiry is here.

Article 11 Change of Rules

Our Company shall review the operational status regarding the handling of the Personal Information from time to time and endeavor for the continuous improvement and may change the Rules as needed. The rules after the change will be notified by posting a notice on Our Company’s services or the website that Our Company operates or through other tangible ways. Provided, however, that, upon change of content requiring a consent of an identifiable person, the consent of the identifiable person will be acquired by any means specified by Our Company separately.

• [Established on February 28, 2016]
• [Revised on July 1, 2019]
• [Revised on January 24, 2020]
• [Revised on August 4, 2020]
• [Revised on August 26, 2020]
• [Revised on December 10, 2021]
• [Revised on June 22, 2022]
• [Revised on August 30, 2022]
• [Revised on March 28, 2023]
• [Revised on October 20, 2023]
• [Revised on October 20, 2023]
• [Revised on February 1, 2024]
• [Revised on February 13, 2024]
• [Revised on May 15, 2024]
• [Revised on July 1, 2024]