1. Private Information Protection Plan

1. The term "Personal Information" as used in this Policy shall mean the personal information as defined in the Act on the Protection of Personal Information.
2. The Company safely and appropriately protects Personal Information and employs measures to prevent its leakage and destruction and to recover them.
   The Company uses legitimate and fair methods in consideration of business contents and scope when it collects Personal Information and employs appropriate measures so that it uses Personal Information only within the scope of usage purpose of the Policy. Furthermore, the Company places strict control on Personal Information so that it is not disclosed to any third parties (excluding outsourcing company as stipulated in section 3 below) except that the Company obtains consent to do so from the individual or that applicable law allows the Company to do so. The Company destroys Personal Information it has collected as soon as it deems the information unnecessary.
3. The Company shall comply with laws and regulations, and guidelines and other rules issued by the government with regard to handling of Personal Information.

2. Purpose of Utilization

The Company uses Private Information for the purposes listed below.

1. For user registration, confirmation of user identity, providing responses to customers’ inquiries, billing, examination and analysis of questionnaires with respect to the service provided by the Company, or other purposes for providing, maintaining, protecting and improving the service.
2. For displaying information regarding the Company’s services which the Company believes may be beneficial to the customer on customers' websites or other devices and for introducing the services by sending emails, email magazines, or postal mail.
3. For screening prospective employees.
4. For information analysis and related purposes.

3. Provision to Third Parties

In the process of the smooth execution of projects and general business, in order to provide superior service to customers, the Company may, to a limited extent, partially outsource operations, at which time Private Information may be entrusted to outsourcing company. In such cases, the Company selects its outsourcing company only after making a stringent assessment of the entity’s system for protecting Private Information appropriately and enters into agreement with them based upon the condition that the system is actively in effect. The Company is extremely thorough in ensuring that necessary measures are in place to protect Private Information appropriately and confidentially under contract. If the Company wishes to disclose Private Information to a third party in any instance other than the outsourcing of business services as outlined here, it will obtain the consent of the customer.

4. Disclosure of Private Information

Where the Company is required by the individual to disclose, correct, remove, discontinue, or erase the Private Information held by the Company, it will disclose, etc., the Private Information in a timely manner and within reason after confirming the identity of the individual. However, the Company may not do so if there is risk of damage to another customer’s vital interest such as life, health and property, or if the Company deems that such disclosure, etc., may create obstacles to its business operations. Furthermore, if required by law, etc., the Company will proceed appropriately as dictated by laws.

1. Procedures for Confirmation of Identity
   1. In a way wherein the Company communicates directly with the individual based on information such as telephone number, mail address, address, etc., that have been provided and recorded.
   2. In a way wherein the Company confirms the individual’s name, address, telephone number, date of birth, age, etc., at the time of procedures.
2. Procedures for Disclosure and Other Requests

   Individuals can make requests for the disclosure, correction, or deletion of their Personal Information, or present opinions questions or complaints, etc., to the Company. The Company will provide the individual with a request for disclosure of Personal Information, etc., form, which the individual should fill out and bring or send back to the Company by mail with the identity verification documents of the individual or the agent of the individual to the following contact:

   Address

   3F TenjinCLASS, Imaizumi 1-19-22, Chuo Ward, Fukuoka City, Fukuoka Prefecture, 810-0021 JAPAN

   Company name

   Groovenauts, Inc.

   Personal Information Protection Administrator

   Manager, Corporate Planning Department

   E-mail

   info@groovenauts.jp

5. Amendments to the Policy

The Company uses its discretion to regularly review its handling of Private Information and other user information in an effort for continual improvement and may, if necessary, amend its Privacy Policy. Customers will be notified of any changes to the Policy via a post to this site. However, if required by law to obtain the consent of customers prior to a policy change, the Company will obtain customers’ consents via a method designated by the Company.

Established: April 1, 2012
Revised: November 1, 2019
Eihiro Saishu, President & CEO