Privacy Policy

Atrae, Inc. (hereinafter referred to as the “Company”) is developing its business mainly in the field of People Tech and, under the philosophy that the Company is in the position of being a role model for proper handling of personal information, as the Company recognizes the importance of proper handling of personal information, the Company has determined this Privacy Policy, and its executives and employees will make concerted efforts to observe this Privacy Policy. Moreover, the Company will make the utmost efforts to protect personal information and individual rights and interests thereby.

1. Acquisition

   1. Upon acquisition of personal information, the Company will specify the purpose of use of the information to the extent possible, and acquire the personal information to the extent necessary for achievement of the relevant purpose. The Company will take necessary measures therefor.

   2. When acquiring personal information in writing directly from the principal, the Company will acquire the personal information to the extent necessary after notifying the principal of the name of the Company, the name of the Personal Information Protection Manager and contact address thereof, and purpose of use of the information, etc.

2. Use

   Personal information will be used within the scope of the purpose of use. Moreover, the Company will establish procedures to take necessary measures to avoid out-of-purpose use of personal information, and put those into practice.

3. Management

   The Company will manage the personal information in its possession by proper methods, and will not provide it to a third party* without the consent of the principal. *Same as the third parties indicated in Article 23 of the Act on the Protection of Personal Information

4. Security Control Action

   The Company will manage the personal information in its possession accurately and in the most current state within the scope necessary, depending on the purpose of use, and take reasonable safety measures for risks of leaks, destruction/loss or damage of personal information etc. striving to lessen risks and correct the measures.

5. Consignment of handling

   If the Company outsources handling of personal information, the Company will obligate contractors in agreements not to leak or provide personal information to a third party, etc., and carry out the proper management of contractors.

6. Anonymously processed information

   1. If the Company creates anonymously processed information, the Company will process it appropriately in accordance with the law and at the same time take appropriate security control actions.

   2. If the Company provides anonymously processed information, the Company will release the information in a timely and appropriate manner as required by law.

   3. For more information on the above, please clickhere

7. Pseudonymously Processed Information

   The Company creates pseudonymously processed information (information about an individual that has been processed in such a way that the individual cannot be identified unless cross-checked with other information). In accordance with laws and regulations, the Company will process information appropriately and take security management measures when creating pseudonymously processed information. As for the purposes of use, the Company will use pre-processed personal information for the purposes listed in the "Handling of Personal Information" below. In addition, the Company will use pseudonymously processed information for the purposes of (1) research and development of new businesses, services, or products, and (2) analysis and integration of data across services.

8. Response to inquiries

   The Company will respond to complaints and consultations regarding personal information in its possession by being notified at the inquiry contact window of the Company.

9. Legal compliance

   The Company will comply with the laws and regulations, guidelines and other codes provided by the government with respect to handling of personal information.

10. Review of management system development and operation

    The Company will provide a personal information protection management system, reexamine it regularly, and improve it on a continuous basis.

On Requests Relating to Disclosure, Deletion, etc. of Personal Information

1. When a principal requests notification or disclosure of purpose of use of the principal’s personal information, correction, addition or deletion of contents thereof, suspension of use thereof, deletion and suspension of provision thereof to a third party (hereinafter collectively referred to as “disclosure, deletion, etc.”), the Company will conduct an internal investigation on the personal information and reply without delay. *However, the Company may not respond with disclosure, deletion, etc., depending on the details of the request. In such instance the Company will reply about the reason as well.

2. When making a request for disclosure, deletion, etc., please do so by postal mail, according to the following procedures. The Company may not accept your request if there is anything left out or incomplete, etc. as to the contents of the request. Moreover, for requests for disclosure of personal information or notification of purpose of use, the requestor shall pay 1,000 yen per request via registered mail in cash as an administrative charge.

3. The Company will use the personal information provided in “Personal Information Disclosure, Deletion, etc. Request Form” only for handling of inquiries, and will not use it for other purposes.

*For details of disclosure, deletion, etc., please inquire at the contact Personal Information Consultation Window.

Personal Information Consultation Window

【Name of accredited personal information protection organization with which the Company is affiliated, and where to lodge a petition of complaint】

* In accordance with the Act on the Protection of Personal Information and the Cabinet Order to Enforce the Act on the Protection of Personal Information, the name of the affiliated accredited personal information protection organization and where to lodge a petition for resolving a complaint are stated.