Privacy Policy

Privacy Policy of Truffle Technologies KK

Updated April 15, 2022

Truffle Technologies Co., Ltd. (hereinafter referred to as "our company") has established the following personal information protection policy for the handling of personal information acquired by our company, established a personal information protection system, and promoted the protection of personal information by making all employees aware of the importance of personal information protection and thoroughly implementing such measures.

Article 1 Personal Information

"Personal information" refers to "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act"), which is information about a living individual that can identify a specific individual by the name, date of birth, or other description contained in the information, or that contains a personal identification code.

Article 2 Purpose of Use of Personal Information

Our company will acquire personal information and use the acquired information to the extent necessary for the following purposes. If we use personal information beyond the scope of the following purposes, we will obtain the individual's consent in an appropriate manner in advance.

a. Personal information of those who use our services (hereinafter referred to as "Users")

1. To provide our services (hereinafter referred to as "This Service")

2. To improve and enhance the content of This Service, or to consider and develop new services, etc.

3. To inform you of new functions, updates, campaigns, etc. of This Service, and other services provided by our company (including sending emails, flyers, and other direct mail)

4. To contact you as necessary, such as for maintenance and important notices

5. To respond to opinions and inquiries from users regarding This Service (including identity verification)

6. To report to users on the usage status of This Service

7. To request cooperation in surveys and interviews regarding This Service, request participation in various events, and report the results, etc.

8. To investigate and analyze the usage history of This Service, etc., and use the results to improve and develop This Service and deliver advertisements

9. To analyze the attributes and preferences of users, etc., and display content or advertisements and deliver emails optimized for those attributes and preferences, etc.

10. Provision of personal information to companies participating in events hosted by our company based on the user's consent/application

11. To identify users who violate the terms of use or who attempt to use this service for fraudulent or unjust purposes, and to refuse their use

b. Personal information of business partners

1. To provide information, reports, and contact to personnel in charge of our business

2. To carry out commissioned business

3. To make payments and send invoices

4. To create and submit various sales documents such as quotations

c. Personal information of employees (including former employees)

• For personnel, labor, health management, and various communications of employees

d. Personal information of job applicants

1. To inform job applicants of interview dates and times, and the results of their employment

2. For security management

3. For employment procedures

Article 3 Information to be acquired and method of acquisition

Information about users collected by our company in this service (hereinafter referred to as "user information") is as follows, depending on the method of collection. If user information can identify an individual by linking it to personal information acquired by our company, the user information will also be treated as personal information.

a. The following information entered by the user using the Service or provided to the Company in a manner specified by the Company

1. Profile information such as name, date of birth, gender, photo, occupation, marital status, etc.

2. Contact information such as email address, telephone number, address, etc.

3. Information on the content, history, and status of the Service used by the user, such as the date and time of use, the number of times of use, behavior when using the Service, website browsing history and behavior history, purchase history, etc.

b. Information provided when the user permits linking with external services (hereinafter referred to as "External Services") such as social networking services (including but not limited to Google, Facebook, and LINE) when using the Service (hereinafter referred to as "External Service Linkage Information")

1. ID used by the user in the relevant External Service

2. Other information that the user has permitted to be disclosed to the linked party due to the privacy settings of the relevant External Service (including each information specified in the preceding paragraph a.)

c. Information collected by the Company when the User uses the Service

1. Terminal information

2. Referrer

3. IP address

4. Information on server access logs

5. Cookies, ADID, IDFA and other identifiers

6. Location information (only if the User individually consents)

Article 4: Linkage with external services

If the User allows linkage with an external service when using the Service, the external service linkage information will be shared with the companies that operate the external service. User information can be used, stored and edited within the application of the external service.

Article 5: Informative information

Among the User information, information that cannot identify an individual but may raise privacy concerns, as well as information that has been statistically compiled and is used in a form that cannot be linked to the identification of an individual (hereinafter referred to as "informative information") may be used by the Company and third parties such as its partners for marketing research, cross-device linking, behavioral targeting advertising services and other services.

Article 6 Management and Protection of Personal Information

Personal information will be managed with strict scrutiny, and will not be disclosed or provided to third parties without the individual's consent, except in the following cases. In addition, with safety in mind, 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 a person's life, body, or property, and it is difficult to obtain the individual's consent

2. When it is particularly necessary for the improvement of public health or the promotion of healthy child development, and it is difficult to obtain the individual's consent

3. When it is necessary to cooperate with a national institution, local government, or a person commissioned by them in carrying out duties prescribed by law, and obtaining the individual's consent is likely to hinder the performance of such duties

4. When all or part of the handling of personal information is entrusted to the extent necessary to achieve the purpose of use in order to smoothly carry out business

5. When personal information is provided in connection with business succession due to a merger or other reason

6. When personal information is used jointly with a specific person, the individual is notified in advance or made easily accessible to the individual of the fact, the items of personal information to be used jointly, the scope of the joint users, the purpose of use of the users, and the name or title of the person responsible for the management of the personal information

7. Other cases permitted by law

Article 7 Entrustment of the handling of personal information

We may entrust all or part of the handling of personal information to the extent necessary to achieve the purpose of use. In this case, we will thoroughly examine the suitability of the contractor, stipulate matters related to confidentiality obligations in the contract, and provide necessary and appropriate supervision of the contractor.

Article 8: Joint use of personal information

We may jointly use user information to the extent necessary to achieve the purpose of use.

1. Items of user information to be jointly used
   User information specified in Article 3 a. and b.

2. Scope of joint users
   Business owners who have entered into a service contract for this service

3. Purpose of use of joint users
   For the purpose of use specified in Article 2 a.

4. Administrator for joint use
   Truffle Technologies Inc.
   7-5-901 Ebisu Minami 3-chome, Shibuya-ku, Tokyo 150-0022
   CEO, Yusuke Takahashi

Article 9: Safety management measures

We will establish regulations within our company and strive to take safety measures to prevent and correct unauthorized access to personal information, leakage, loss, or damage of personal information. In order to achieve the above purpose, we have taken the following measures.

1. Establishment of basic policies for implementing each response stipulated by laws and guidelines for the proper handling of personal information

2. Establishment of various regulations that define each response such as acquisition, use, storage, provision, deletion, disposal, etc., as well as the person in charge and their role

3. Organizational safety control measures such as appointing a person in charge, clarifying the scope of employees who handle personal information and the personal data handled, establishing a reporting and contact system to the person in charge when facts or signs of violation of laws or regulations are identified, and regular inspections of the handling status

4. Personal safety control measures such as including matters regarding confidentiality of personal data in the work rules and conducting regular training on points to note regarding the handling of personal data

5. Physical safety control measures such as management of employee entry and exit, restrictions on devices brought in, and restrictions and management of devices and electronic media/documents that handle personal data to prevent theft and loss, etc.

6. Technical safety control measures such as introducing a system to protect information systems that handle personal data from unauthorized access from outside or malicious software

Article 10 Anonymously Processed Information

1. We may create anonymously processed information (defined in Article 2, Paragraph 6 of the Personal Information Protection Act as information about an individual obtained by processing personal information so that a specific individual cannot be identified, and the personal information cannot be restored; hereinafter the same), and use it ourselves or provide it to a third party.

2. When creating anonymously processed information, we will provide it after appropriately processing it in accordance with the standards set forth in the Personal Information Protection Commission rules.

3. The items of information contained in anonymously processed information are gender, age, website browsing history and behavior history, purchase history, etc.

Article 11 Disclosure of personal information, etc.

When the Company is requested by an individual to disclose personal information or a record of third-party provision, the Company will disclose it to the individual without delay after confirming that the request is made by the individual. However, if the Company is not obligated to disclose it under the Personal Information Protection Act or other laws and regulations, the Company may not disclose all or part of it, and if a decision is made not to disclose it, the Company will notify the individual without delay.

Article 12 Correction and Suspension of Use of Personal Information, etc.

1. If the Company is requested by the individual to correct, delete or erase (hereinafter referred to as "correction, etc.") the contents of personal information based on the provisions of the Personal Information Protection Act because the personal information is not true, the Company will confirm that the request is from the individual, conduct the necessary investigation without delay, correct the personal information based on the results, and notify the individual to that effect. In addition, if it is decided not to make corrections, etc. based on reasonable grounds, the Company will notify the individual to that effect. In addition, if it is difficult to suspend the use of personal information or if it would cost a large amount of money to do so or if it is difficult to suspend the use, etc., and alternative measures necessary to protect the rights and interests of the individual can be taken, the Company will take these alternative measures.

2. If the Company is not obligated to make corrections, etc. under the Personal Information Protection Act or other laws and regulations, the provisions of the preceding paragraph will not apply.

Article 13 Procedure for changing the privacy policy

The Company will review the contents of this policy as appropriate and strive to improve it. The contents of this policy may be changed, except for matters otherwise specified by laws and regulations or otherwise in this policy. The revised privacy policy will take effect when it is notified to the individual or posted on our website in the manner specified by our company.

Article 14: Compliance with Laws, Regulations, and Standards

Our company will comply with Japanese laws and regulations and other standards that apply to the personal information we hold.

Article 15: Handling Complaints and Inquiries

Our company will accept complaints and inquiries from individuals regarding the handling of their personal information and will respond appropriately and promptly. In addition, we will not accept requests from individuals to disclose, correct, add, or delete such personal information. We will also promptly and appropriately respond to requests for removal, refusal to use or provide personal information, etc.

Article 16 Contact Point

For inquiries regarding our handling of personal information, please contact us by email at the address below.

Truffle Technologies Inc.
Privacy Policy Administrator
7-5-901 Ebisu Minami 3-chome, Shibuya-ku, Tokyo 150-0022
Mail: hello@truffletechnologies.co.jp (We accept emails 24 hours a day.)

Article 17 Company Name and Representative Name

Truffle Technologies Inc.
Representative Director Yusuke Takahashi
Address is as stated in the previous article.

Enacted and effective April 15, 2022