DISCLAIMER
This document has been translated from Japanese original for reference purposes only. In the event of any discrepancy between this translated document and the Japanese original, the original shall prevail. The Company assumes no responsibility for this translation or for direct, indirect or any other forms of damages arising from the translation.

Privacy Policy

RGF Talent Solutions Japan K.K. (“Company”) has established this Privacy Policy to set forth the purpose and the method of use of users’ personal information when users use the services the Company operates (“Services”). In this Privacy Policy, the term “user” refers to companies, schools, associations, etc. or their representatives or employees.
If a user agrees to this Privacy Policy, the user’s personal information that the Company already possesses will be handled by the Company in accordance with this Privacy Policy.

Depending on the characteristics of each service, the Company may set forth provisions concerning the handling of personal information that are specific to a particular service, and in such case it will be stated to that effect in 11. Special Provisions on Services, so please check those provisions. Lists of Cookies Used on the Websites and Lists of Cookies Used on the Apps are also provided, so please also refer to these as necessary.

CONTENTS

1. Acquisition of personal information
2. Purpose of use of personal information
3. Provision of personal information to third parties
4. Receiving of personal information from companies, schools, associations, etc. that participate in the Services
5. Outsourcing of personal information handling
6. Provision of personal information to third parties in foreign countries
7. Request of disclosure, etc. of personal information
8. Voluntary nature of provision of personal information
9. Persons responsible for the business and manager for the protection of personal information
10. Contact details regarding personal information
11. Special provisions on Services

1. Acquisition of personal information

The Company acquires personal information by the following methods:

• Receiving personal information directly from users;
• Automatically recording personal information when users use the Services;
• Receiving users’ personal information indirectly from third parties; or
• Acquiring personal information publicized in publications or on the Internet.

The Company also acquires from users or third parties information that does not by itself fall under personal information, such as attribute information (e.g., age, sex, occupation, or resident area), Cookies, IP addresses, advertising identifiers (AAID, IDFA), and log information related to Internet usage, such as location information, activity history, and transmission information (including the details and subjects of communications sent to or received by users in connection with the use of the Services, whether received communications have been read, and whether or not any communications are sent or received) (collectively, “Informative Information”). If a user provides personal information to the Company for use of the Services, the Company may link such information with such user’s Informative Information, in which case such Informative Information shall be treated as personal information.

2. Purpose of use of personal information

The Company uses personal information for the following purposes.
Please check here for information on “Group Companies.”

(1) Operation of the Services that users use (including the Services that users are considering using) and communication and provision of information to users pertaining thereto

Examples of use include the following:

• Personal authentication, identification, and screening of the user;
• Checking the details of opinions, inquiries, or any other communications, and responding to those
• Selecting by lottery the winners of campaigns that users participated in and delivery of prizes or rewards; or
• Providing features to exchange messages, images, videos, and other contents with other users.

(2) Countermeasures against fraudulent acts necessary for safe operation of the Services

Examples of use include the following:

• Investigation of applications prohibited by the Company, transfer of rights or obligations, registration of false information, fraud, fraudulent access, and other fraudulent acts.

(3) Improvement and new development of the Services

Examples of use include the following:

• Improvement of the Services and development of new services based on results of analysis of usage of the Services by users; and
• Improvement of quality of responses to inquiries from users.

(4) Suggesting various services, providing information, and distributing advertisements

Examples of use include the following:

• Notice of campaigns held by the Company and the Group Companies;
• Provision of information such as mail magazines, direct mails, messages, or advertisements regarding the Company’s and the Group Companies’ services; and
• Provision of information such as mail magazines, direct mails, messages, or advertisements regarding products and services of companies, schools, associations, etc. that the Company judges appropriate.

*The Company may suggest Services, provide information, or distribute advertisements of various services to users who satisfy certain conditions (including users of Services or of services provided by advertisement-related operators) by linking the users list held by Google, Facebook, LINE, or any other advertisement-related operators to information such as e-mail addresses, telephone numbers, cookies, and other information held by the Company that is necessary to identify users.

(5) Publication in various media such as information magazines, websites, or applications that the Company edits, publishes, or operates

Examples of use include the following:

• Publishing inquiry results of users who have used the Services on the Services or in the Company’s press releases.

(6) Various surveys, analyses, and marketing necessary for each of the purposes of use above

Examples of use include the following:

• Conducting questionnaire surveys and monitoring surveys (including directly contacting respondents to ensure effectiveness); or
• Analysis of attribute information or activity history, etc. that the Company acquired to understand the preferences of users

*When the Company delegates analysis work to advertisement-related operators, it may receive analysis results aggregated into information by which the Company cannot identify particular individuals, by adding personal information held by the Company to the users’ attribute information or log information related to Internet usage, such as location information and activity history owned by such advertisement-related operators.

(7) 3. Provision of personal information to third parties

3. Provision of personal information to third parties

The Company will provide personal information in writing or by electromagnetic means to the following recipients in accordance with the respective paragraphs. The items of personal information that the Company provides may include Informative Information.

(1) Provision of personal information to companies, schools, associations, etc. with which we have a partnership or contractual relationship necessary for us to manage the Services

[Purposes of provision of personal information by the Company]

• Achieving the purposes stated in 2.Purpose of use of personal information to the extent necessary to manage the Services and the services provided by Group Companies.

[Items of personal information to be provided]

• Items of information necessary to achieve the purposes of provision above among the information such as the user’s name and other information regarding the user

(2) Provision of personal information to Group Companies

[Purposes of provision of personal information by the Company]

• Achieving the purposes stated in 2.Purpose of use of personal information to the extent necessary to manage the Services and the services provided by Group Companies.

[Items of personal information to be provided]

• Items of information necessary to achieve the purposes of provision above among the information such as the user’s name and other information regarding the user

(3) Provision of personal information to customers using the Services

[Purposes of provision of personal information by the Company]

• Provision of services to customers to which users applied to or gave consent, etc., performance of agreements with such customers, and communication and provision of information pertaining to such provision of services and performance of agreements (including consideration of whether the Company will provide services or enter into agreements and suggestions regarding services); and

• Hiring and screening activities for customers and communication and provision of information pertaining to those.

[Items of personal information to be provided]

• Items of information necessary to achieve the purposes of provision above among the information such as the user’s name and other information regarding the user

(4) Provision of personal information to companies, schools, associations, etc. to which users belong

[Purposes of provision of personal information by the Company]

• Sharing the usage status and the results of usage of the Services by users belonging to companies, schools, associations, etc. that entered into agreements for such Services.

[Items of personal information to be provided]

• Items of information necessary to achieve the purposes of provision above among the information such as the user’s name and other information regarding the user

Furthermore, other than the above, the Company may provide personal information to third parties to follow laws and regulations (including when responding to investigations of police and orders of courts) or if it separately obtains a user’s consent, specifying the party to whom the information is to be disclosed, the information to be disclosed, purpose of use, and disclosing the means or method.

4. Receiving of personal information from companies, schools, associations, etc. that participate in the Services

The Company properly receives the fact of users’ usage, usage status, or usage results from companies, schools, associations, etc. that a user applied to using the Services. The purposes for receiving personal information are as follows:

[Receiving purpose of the Company]

• Provision of operation of the Services that a user uses and communication and information with user accompanied by the operation; and
• To improve and newly develop the Services, and for research, analysis, and marketing associated therewith.

5. Outsourcing of personal information handling

[If the Company conducts outsourcing]

• The Company may outsource personal information handling operations in part or in whole. In such case, the Company will provide necessary and proper direction to the party to whom such operations are outsourced.

[If the Company is entrusted with handling personal information]

• If the Company is entrusted with personal information handling operations in part or in whole from companies, schools, associations, etc. that participate in the Services, the Company will handle entrusted personal information to perform the entrusted operations.
• If the Company receives commission of analysis business from companies, schools, associations, etc. that participate in the Services, for users designated by such companies, schools, associations, etc., the Company may produce aggregated analysis results by adding to user’s personal information received from such companies, schools, associations, etc., user’s attribute information and log information related to Internet usage such as location information or activity history held by the Company. In this case, it will process such information to ensure that the information alone cannot be used by such companies, schools, associations, etc. to identify particular individuals, by excluding information on names and addresses and replacing them with attribute information on sex or age, etc.

6. Provision of personal information to third parties in foreign countries

We may provide personal information to third parties in foreign countries (meaning countries or areas outside Japan) in the following cases.

[If the Company provides personal information to third parties]

• If the party to whom personal information will be provided is a third party in a foreign country, the Company will use personal information within the scope provided under 3. Provision of personal information to third parties;
• Please see here for the names of countries to which personal information will be provided and personal information protection systems of foreign countries to which personal information will be provided; and
• The third parties to whom personal information will be provided comply with personal information protection systems of the relevant foreign country.

[If the Company outsources personal information handling operations]

• Some of the contractors to which the Company outsources all or part of personal information handling operations may be contractors in foreign countries. In such case, the Company confirms that such contractor has established systems that comply with the standards stipulated in the Act on the Protection of Personal Information.

[If the Company provides personal information due to succession of business by merger or other events]

• A successor to a business due to merger or other reasons may be an entity in a foreign country. In such case, such successor will handle personal information within the scope of purpose of use before succession of such business.

7. Request of disclosure, etc. of personal information

The Company will store and use personal information within the scope and for the period necessary to comply with laws and regulations or to achieve the purposes of use, but the user or agent thereof may, in accordance with the procedures prescribed by the Company, request the Company to disclose, correct, add, or delete content, or discontinue utilizing or erase the personal information that can be used to identify the user. For details on how to make such requests, please contact us as set forth in 10. Contact details regarding personal information. However, the Company might not respond to the request to the extent permitted by law.

Furthermore, in order to prevent false requests due to identity theft, etc. the Company will conduct identification by using reasonable methods such as requesting submission of identification documents at the time of a request. If all items necessary for identification prescribed by the Company are fulfilled, the Company will consider such request is from the user itself and respond to the request, but even if such request is from third parties other than such user who obtained personal information or identification documents of the user, the Company will not be responsible for damages incurred by the user due to responding to such request unless the Company is intentionally grossly negligent or in violation of the Consumer Contract Act by the Company. Please be careful in handling your personal information.

8. Voluntary nature of provision of personal information

Provision of personal information from users is voluntary, but if a user does not enter items necessary for Services, such user may not be able to use Services.

9. Persons responsible for the business and manager for the protection of personal information

RGF Talent Solutions Japan K.K. Representative Director

10. Contact details regarding personal information

Contact us by e-mail: mail.jp@rgf-executive.com

11. Special provisions on Services

Special provisions on Facebook authentication
If a User chooses Facebook authentication to register and login to the Service and clicks “Accept” on the Facebook app consent screen, the Company will acquire and use, among Facebook User ID, e-mail address, name, sex, date of birth, residence, or profile picture registered on the Facebook account, or any other information that the user discloses on Facebook, the information necessary for the Services in accordance with this Privacy Policy.