Article 1 (Personal Information)

The term "personal information" has different meanings based on the respective applicable laws and regulations as follows

1. The Act on the Protection of Personal Information in Japan (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act") (hereinafter referred to as the "Personal Information Protection Act"), and refers to information about a living individual that can identify a specific individual by name, date of birth, or other description contained in the information, or that contains a personal identification code.
2. For users to whom the EU General Data Protection Regulation ("GDPR") applies, this means "personal data" within the meaning of the GDPR. (hereinafter referred to as "GDPR") refers to "personal data" for users to whom the GDPR applies.

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Article 2 (Information Obtained)

The Company may obtain the following information from the Subscriber or the Subscriber's Users through Beatrust. If such information is not provided, the Subscriber may not be able to use Beatrust.

1. Basic User Information (i.e., User's name, face, profile, personality, email address, phone number, and other basic information about the User).
2. Work-related information (i.e., the User's skills, job description, experience, reporting lines pertaining to the User, colleagues, affiliations, projects, positions, teams, offices, and other information related to the User's position within the organization, and other information related to the User's work).
3. Service usage information (information on operation settings, number of information updates, device status at the time of a crash, etc.), search logs, various action logs (e.g., button presses), access logs, the type of terminal application and browser used to view our services and the pages viewed, information on the device used to access our services, hardware model, device IP address, cookies, serial numbers, device operating information, mobile network information, MAC address and other identifiers, OS and its version, and selected language. (i) information on the device used to access our services, hardware model, IP address of the device, cookies, serial number, device operation information, mobile network information, MAC address or other unique identifier, OS and its version, language selection, advertising identifier, and other information regarding the use of our services by the user. (means information related to your use of our Services).

If the Subscriber permits the Company to obtain information about the User through services provided by a third party, the Company may obtain such information. In such cases, we may combine the information we obtain from the Subscriber or User with the information obtained from the third party for the purpose of improving Beatrust or providing advertisements.

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Article 3 (Acquisition and Use of Personal Information)

THE PURPOSES FOR WHICH WE USE THE INFORMATION WE OBTAIN FROM USERS AS SET FORTH IN ARTICLE 2 AND THE BASIS FOR SUCH USE UNDER THE GDPR ARE AS FOLLOWS

Please note that
"Performance of contract" refers to the use of information by the Company to perform the contract with the Subscriber or User.
Legitimate interest" means that we use the information for our legitimate interests, such as maintaining or improving the level of our services and preventing unauthorized use of our services.
Compliance with legal obligations" refers to our use of information to cooperate with courts of law and other public authorities as required by applicable laws and regulations.
When we use the information specified in Article 2 obtained from the user beyond the scope of the following purposes, we will obtain consent from the user in an appropriate manner in advance.

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Article 4 (Anonymous Processing, etc.)

In order to improve Beatrust, we may compile and analyze information related to subscribers' users and create statistical data (excluding correspondence with specific individuals) related to the following items, and use and disclose such data. (1) The Company may use and disclose the following statistical data (excluding correspondence with specific individuals).

1. Number of advice requests, frequency of consultations, frequency of keyword use
2. Information regarding the contents of concluded contracts, billing dates, expiration dates, etc.
3. INFORMATION ABOUT THE TERMINAL USED, OS, BROWSER, ETC.
4. Other information related to the use of Beatrust

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Article 5 (Management and Protection of Personal Information)

Personal information shall be strictly managed and shall not be disclosed or provided to any third party without the consent of the individual, except in the following cases. In addition, in consideration of security, we will take measures to prevent and correct risks such as unauthorized access to personal information, loss, destruction, falsification, and leakage of personal information.

1. When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual.
2. When it is especially necessary to improve public health or to promote the sound growth of children and it is difficult to obtain the consent of the individual concerned.
3. Cases in which it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the consent of the individual is likely to impede the execution of the affairs concerned.
4. When all or part of the handling of personal information is outsourced within the scope necessary to achieve the purpose of use in order to facilitate the smooth performance of business operations.
5. When personal information is provided as a result of the succession of a business due to a reason of
6. In cases where personal information is used jointly with a specific person, and where this fact and the items of personal information to be jointly used, the scope of the joint users, the purpose of use by the user, and the name of the person responsible for managing the personal information are notified to the person in advance or are made readily accessible to the person in question. (2) In cases where the personal information is made readily accessible to the individual
7. Other cases permitted by laws and regulations

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Article 6 (Entrustment of Handling of Personal Information)

We may outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use. In such cases, the Company will thoroughly examine the eligibility of the consignee, stipulate confidentiality obligations in the contract, and supervise the consignee in a necessary and appropriate manner.

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Article 7 (Provision to Third Parties)

1. We will not provide personal information acquired by us to third parties, except in the following cases

1. If the user agrees
2. When a user violates our terms and conditions and it is necessary to disclose personal information in order to protect our rights, property, or services.
3. When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual.
4. When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the User's consent is likely to impede the execution of such affairs.
5. When our business, including the provision of personal information, is succeeded due to a merger, corporate separation, transfer of business, or other reasons
6. When permitted by the Personal Information Protection Law and other laws and regulations

2. Notwithstanding the preceding paragraph, we may entrust the handling of users' personal information to third parties in the following foreign countries and provide personal information to them to the extent necessary to achieve the purposes set forth in Article 3. Please refer to the following for the countries where the third parties are located and the personal information protection systems of those countries.

1. Country
   United States of America
2. Personal data protection systems of the foreign country in question
   Please refer to the following Privacy Commissioner's website:
   https://www.ppc.go.jp/files/pdf/USA_report.pdf 
3. Personal data protection measures taken by third parties
   The third parties to whom we provide personal data comply with the laws and regulations of the country concerned regarding the protection of personal data.

3. In addition to the cases set forth in the preceding paragraph, we may provide users' personal data to third parties in foreign countries that have implemented measures in line with the intent of the provisions of Chapter 4, Section 2 of the Personal Information Protection Law and with whom we have ensured the continuous implementation of such measures.

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Article 8 (Cookies)

Beatrust and its ad-serving vendors may use cookies sent to your browser through Beatrust.
You may disable or refuse to accept cookies by changing the settings on your browser. If Users disable or reject cookies, some parts of Beatrust may not function properly.
If acceptance of cookies is not disabled, ad-serving companies may obtain cookie information (such as browsing history) of Users who use Beatrust and our If you do not disable the acceptance of cookies, an ad-serving company may obtain cookie information (such as browsing history) of Beatrust users and serve our advertisements.
The ad-serving entity may deliver advertisements based on the preferences of users by using access data, cookies, our identifiers, and attribute information of users.
Cookie information obtained by the ad-serving provider will be handled in accordance with the privacy policy of the ad-serving provider.
Users may be able to stop the use of cookies and access data by ad-serving providers by accessing the opt-out page of the ad-serving provider and disabling (opting out) the use of cookies and access data by the ad-serving provider. In such cases, the user may no longer receive advertisements based on the user's preferences, or may receive the same advertisements repeatedly.

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Article 9 (Disclosure of Personal Information)

When we receive a request from an individual for disclosure of his/her personal information, we will disclose such information to the individual without delay. However, we may decide not to disclose all or part of the information in the following cases, and if we decide not to disclose the information, we will notify you to that effect without delay.

If there is a risk of harm to the life, body, property, or other rights or interests of the person or a third party
If there is a risk of significant hindrance to the proper conduct of our business
If it would otherwise be in violation of laws and regulations

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Article 10 (Correction and Deletion of Personal Information)

If the personal information in our possession is incorrect, we will correct or delete the personal information upon request from the person in question, in accordance with procedures determined by us.
If we receive a request from the person in question as described in the preceding paragraph and deem it necessary to respond to the request, we will correct or delete the relevant personal information without delay and notify the person in question of such correction or deletion.

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ARTICLE 11 (RIGHTS OF EU RESIDENT USERS)

USERS WHO ARE EU RESIDENTS HAVE THE RIGHT TO

1. Right to access personal information
   The user has the right to request a copy of the user's personal information held by the Company. In such case, we will charge a small fee for this service.
2. Right to Correction or Deletion
   You have the right to request that we correct information that you believe to be inaccurate. You also have the right to request that we make complete any information that you believe to be incomplete.
   You also have the right to request that we delete any personal information that we process about you, provided that certain requirements are met. The User has the right to request the deletion of his or her personal information, except in exceptional cases, such as when necessary to comply with legal obligations and when necessary to prove, exercise, or defend against a legal claim.
3. Right to restriction of processing and objection
   Users may request the restriction of the processing of their personal data if certain requirements are met.
   The user may also file an objection or complaint with the national supervisory authority in each country in the EEA or with us.
4. Right to Data Portability
   You have the right to receive personal data concerning you in a structured, commonly used and machine-readable format and to transfer that data to another controller without hindrance from us, provided that certain requirements are met.

If you request to exercise any of the above rights, we will respond within one month. If you wish to exercise such rights, please contact us at the e-mail address provided at the end of this Privacy Policy.

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Article 12 (Distribution of Advertisements Using Custom Audience and Customer Match)

In order to customize and display advertisements and content related to our products and services for each user, and to improve user convenience, we use "Custom Audience" provided by Meta Platforms Inc. ("Facebook") and "Custom Audience" provided by Google LLC ("Google"). ("Facebook") and "Customer Match" provided by Google LLC ("Google") are used to serve advertisements.

We deliver advertisements based on the encrypted email addresses obtained from users and information matched with Facebook and Google users. However, because the email addresses to be matched are encrypted, they will not be provided to third parties such as Facebook and Google.

If you wish to stop the use of your personal information for "Custom Audience" and "Customer Match", please follow the link below to deactivate your personal information.

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... "About Facebook Ads."

https://www.facebook.com/about/ads 

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Google Policies and Terms

https://policies.google.com/technologies/ads?hl=ja

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Article 13 (Suspension of Use of Personal Information, etc.)

When we receive a request from a person to stop using or delete (hereinafter referred to as "stop using, etc.") his/her personal information on the grounds that it has been handled beyond the scope of the purpose of use or that it has been obtained by wrongful means, we will conduct the necessary investigation without delay, and based on the results, we will stop using, etc. the personal information and notify the person to that effect. In the event that a customer requests the suspension of use or deletion of personal information (hereinafter referred to as "Suspension of Use, etc."), we will conduct the necessary investigation without delay, and based on the results, we will suspend the use of the personal information and notify the customer to that effect. However, in cases where it is difficult to suspend the use of personal information due to the large amount of costs involved or other reasons, and alternative measures necessary to protect the rights and interests of the individual can be taken, these alternative measures will be taken.

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Article 14 (Retention of information, retention period)

We will retain and store users' personal information for the period of time necessary to carry out the purposes of acquisition and use described above, or for the period of time required by applicable laws and regulations. The specific period of retention and storage will be determined by taking into consideration the purpose for which the personal information was acquired and processed, the nature of the personal information, and the legal or business need to retain and store the personal information.

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Article 15 (Procedures for Changing Privacy Policy)

We will review the contents of this policy from time to time and strive to improve it. The contents of this policy may be changed except as otherwise provided in laws and regulations or in this policy. The revised Privacy Policy shall become effective when it is notified to users or posted on the Company's website in a manner prescribed by the Company.

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Article 16 (Compliance with Laws, Regulations and Norms)

We will comply with Japanese laws and regulations and other applicable laws and regulations regarding personal information in our possession.

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Article 17 (Response to complaints and consultations)

The Company will accept complaints and consultations from individuals regarding the handling of their personal information and respond to them appropriately and promptly. We will also respond promptly and appropriately to requests from the person in question to disclose, correct, add to, delete, or deny the use or provision of the relevant personal information.

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Article 18 (Contact for Inquiries)

For inquiries regarding our handling of personal information, please contact the following

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Beatrust Corporation Customer Service Contact:
No. 35 Kowa Building 3F, 1-14-14 Akasaka, Minato-ku, Tokyo 107-0052, Japan 306
Mail: support@beatrust.com

Revised on March 27, 2023

Enacted and effective as of March 1, 2021

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