1. Acquired information

In relation to the acquisition of personal information, the Company will comply with this policy and related laws and ordinances and conduct acquisition by using the proper methods.
The Company will acquire the information below in relation to the customer’s use of this service.

(1) Information that the customer will present (basic information and work-related information)

In such situations as the information registration that the customer will conduct when beginning the use of this service, the Company may receive direct provision of information from the customer. The aforementioned information includes, for example, the information below.

(Examples)

• Information related to the customer, such as name, birthdate, and gender
• Information related to means of contact, such as e-mail address and telephone number
• Information that the customer enters or sends through an input form or another method stipulated by the Company

(2) Information that the Company will automatically acquire in relation to the customer using this service

Information may be automatically sent to the Company through Internet technology when the customer uses or browses this service. The aforementioned information includes, for example, the information below.

(Examples)

• Referrer
• IP address
• Information related to the server access log
• Information related to cookies and similar technologies
• ADID, IDFA, and other advertising identifiers
• Information related to terminal identification of the information communication terminal, such as the terminal ID
• The browser and OS that the customer uses and other information related to the information communication terminal that the customer uses
• Location information
• Browsing history and action history
• Other information related to the status of use of this service (including the status of use and settings for this service, and the browsing history of content)

(3) Personal information that the Company will obtain through consigned work

Personal information that the Company will receive in association with the provision of the service to the customer for the purpose of acceptance of consignment of all or a portion of handling and for conducting the work below for which acceptance of consignment of all or a portion of the handling of personal information will arise in association with the service that the Company provides and for the other performance and management of agreement content.

(Examples of work)

• Entry of different types of data
• Work related to personnel or skill management

2. Purposes of use

In its human resource development support system and related services that are incidental to that system, the Company may receive the personal information of employees who belong to client companies. The purpose of use of that personal information is for executing the work that has been consigned, and the Company will not conduct any use for purposes other than that purpose of use.

The purposes of use of the information stipulated in 1 “Acquired information” that the Company acquires from a user, and the grounds for use based on the GDPR are as stated below.

(1) Personal information, work-related information, and service use information related to a user of service provided by the Company

• For the contact, cooperation, negotiations, and agreement performance related to the Company’s various forms of business
• For the provision of services, improvement of services, development of new services, and identity verification

(Grounds for use) Performance of agreements, compliance with legal obligations, and legitimate interests

(2) Personal information/legitimate interests related to a person who has made an inquiry, requested materials, or applied for seminar participation

• For handling inquiries related to the Company’s various forms of business
• For operation of seminars
• For other various forms of guidance and contact and for distribution of e-mail newsletters

(Grounds for use) Performance of agreements and legitimate interests

(3) Personal information related to employees

• For personnel and labor management

(4) Personal information related to job applicants

• For hiring selection
• For hiring selection procedures and contact related to the results of those procedures
• For conducting pre-employment procedures and contact related to other procedures

3. Provision to third parties

Excluding the cases stipulated below, the Company will not provide personal information to third parties without obtaining agreement in advance.

1. Cases in which the relevant person’s agreement has been obtained in advance for disclosure or provision to third parties
2. Cases based on laws and ordinances
3. Cases in which it is necessary for the purpose of protection of a person’s life, body, or property, and in which obtaining the relevant person’s agreement is difficult
4. Cases in which it is particularly necessary for the purpose of improvement of public health or promotion of sound upbringing of children, and in which obtaining the relevant person’s agreement is difficult
5. Cases in which it is necessary to cooperate with clerical work that is stipulated in a law or ordinance and that a national government organization, a local public entity, or a party that has received consignment by such an organization or entity will conduct, and in which there is a possibility that obtaining the relevant person’s agreement will cause hindrance to performance of that clerical work
6. Cases in which 4 “Consignment of handling of personal information” will be made to a third party within the scope that is necessary for achievement of 2 “Purposes of use,” after an appropriate consignment agreement has been concluded

4. Consignment of handling of personal information

The Company may, within the scope that is necessary for achievement of 2 “Purposes of use,” consign all or a portion of handling of acquired personal information to a third party.
In such a case, in order to ensure that initiatives will be taken for safety management for personal information, the Company will appropriately select the third party that will be the consigned party, and the Company will conclude the necessary agreement, such as a basic agreement related to consignment of personal information, with the third party that will be the consigned party and conduct the necessary and appropriate management and supervision for the third party.

5. Disclosure, correction, deletion, and cessation of use of personal information

1. Place for making requests for disclosure

   For a request for disclosure, if you will make an inquiry to the “Place for making inquiries about personal information” stated below and then request notification of the purposes of use, disclosure, correction of content, addition or deletion, cessation of use, elimination, or cessation of provision to third parties for your own personal information that the Company possesses, the Company will have you enter the necessary matters in the Company’s prescribed document and then submit the document.

2. For a request for disclosure, the Company will conduct identity verification. Depending on the case, the Company may conduct confirmation by having the customer send a copy of an official certificate by postal mail.

   *For a representative, the Company will conduct confirmation by having the customer submit a letter of authorization. When a representative will be used, submission of copies of official certificates for both the Relevant Person and the representative will be necessary. In addition, the Company does not accept any requests for disclosure by telephone, e-mail, or fax, so please submit such requests by a method by which a record of sending can be obtained, such as simple registered mail.
   *In the case of a legal representative of a minor or an adult ward, the Company will use a document that proves legal authority for representation to confirm that the legal representative has authority for representation.

3. For a request for disclosure (a request for notification of purposes of use or disclosure of personal information subject to disclosure), the Company will charge a service charge with a maximum of JPY 1,000. When it is clear that this amount will be exceeded, the Company will contact the customer separately.
4. This will not apply in cases in which, based on personal information protection or another law or ordinance, the Company does not bear an obligation of disclosure.

6. Security

1. The Company will implement reasonable preventive measures for the purpose of protection of acquired personal information and will conduct protection both online and offline. The Company will use technologies, such as firewalls, detection of unauthorized intrusion, and SSL, to strive to take meticulous caution in handling of personal information, and it will make access to personal information possible only for people who have been given the authority that will be necessary for work.
2. For purposes such as improvement of the customer’s convenience, acquisition of statistical data, and provision of appropriate advertisements, the Company may use cookies (including technologies that are similar to cookies; hereinafter referred to as “Cookies”) and collect information, such as the customer’s IP address, the number of times of access, the browser and OS that the customer uses, and other information, such as the terminal that is used. Such information is collected for the relevant purposes, and the Company does not use it for the purpose of identifying an individual.
3. About opting out of (disabling) use of Cookies

   See our Cookie Declaration for information on the cookies we use.

7. Personal information on linked sites

In relation to the provision or collection of personal information that is conducted on a third party’s linked site to which a link is made on the Company’s homepage, personal information will be managed according to the relevant site’s privacy policy. The Company will not, in any case, bear liability for use on the relevant site.

8. Place for making inquiries

If you would like to make an inquiry or complaint related to this policy or the Company’s handling of personal information, please use the Contact information for inquiries below to contact the Company.

[Name of business operator]

• Skillnote Corporation
• KANDA SQUARE 11F , 2-2-1 Kanda-nishikicho, Chiyoda-ku , Tokyo 101-0054, Japan
• Takafumi Yamakawa, CEO

[Contact information for inquiries]

If you would like to make an inquiry, please do so by using the inquiry form on the Company’s official website.

In order to strive to provide even better protection for customers’ personal information and handle changes of laws and ordinances, the Company will appropriately reconsider the content and strive to improve it. Excluding laws, ordinances, and other matters separately stipulated in this policy, it shall be possible to change the content of this policy. The Privacy Policy after a change shall be announced by making a post on the Company’s website or by a method separately stipulated by the Company.

1. Acquired information

In relation to the acquisition of personal information, the Company will comply with this policy and related laws and ordinances and conduct acquisition by using the proper methods.
The Company will acquire the information below in relation to the customer’s use of this service.

(1) Information that the customer will present (basic information and work-related information)

In such situations as the information registration that the customer will conduct when beginning the use of this service, the Company may receive direct provision of information from the customer. The aforementioned information includes, for example, the information below.

(Examples)

• Information related to the customer, such as name, birthdate, and gender
• Information related to means of contact, such as e-mail address and telephone number
• Information that the customer enters or sends through an input form or another method stipulated by the Company

(2) Information that the Company will automatically acquire in relation to the customer using this service

Information may be automatically sent to the Company through Internet technology when the customer uses or browses this service. The aforementioned information includes, for example, the information below.

(Examples)

• Referrer
• IP address
• Information related to the server access log
• Information related to cookies and similar technologies
• ADID, IDFA, and other advertising identifiers
• Information related to terminal identification of the information communication terminal, such as the terminal ID
• The browser and OS that the customer uses and other information related to the information communication terminal that the customer uses
• Location information
• Browsing history and action history
• Other information related to the status of use of this service (including the status of use and settings for this service, and the browsing history of content)

(3) Personal information that the Company will obtain through consigned work

Personal information that the Company will receive in association with the provision of the service to the customer for the purpose of acceptance of consignment of all or a portion of handling and for conducting the work below for which acceptance of consignment of all or a portion of the handling of personal information will arise in association with the service that the Company provides and for the other performance and management of agreement content.

2. Purposes of use

In its human resource development support system and related services that are incidental to that system, the Company may receive the personal information of employees who belong to client companies. The purpose of use of that personal information is for executing the work that has been consigned, and the Company will not conduct any use for purposes other than that purpose of use.

The purposes of use of the information stipulated in 1 “Acquired information” that the Company acquires from a user, and the grounds for use based on the GDPR are as stated below.

(1) Personal information, work-related information, and service use information related to a user of service provided by the Company

• For the contact, cooperation, negotiations, and agreement performance related to the Company’s various forms of business
• For the provision of services, improvement of services, development of new services, and identity verification

(Grounds for use) Performance of agreements, compliance with legal obligations, and legitimate interests

(2) Personal information/legitimate interests related to a person who has made an inquiry, requested materials, or applied for seminar participation

• For handling inquiries related to the Company’s various forms of business
• For operation of seminars
• For other various forms of guidance and contact and for distribution of e-mail newsletters

(Grounds for use) Performance of agreements and legitimate interests

3. Provision to third parties

Excluding the cases stipulated below, the Company will not provide personal information to third parties without obtaining agreement in advance.

1. Cases in which the relevant person’s agreement has been obtained in advance for disclosure or provision to third parties
2. Cases based on laws and ordinances
3. Cases in which it is necessary for the purpose of protection of a person’s life, body, or property, and in which obtaining the relevant person’s agreement is difficult
4. Cases in which it is particularly necessary for the purpose of improvement of public health or promotion of sound upbringing of children, and in which obtaining the relevant person’s agreement is difficult
5. Cases in which it is necessary to cooperate with clerical work that is stipulated in a law or ordinance and that a national government organization, a local public entity, or a party that has received consignment by such an organization or entity will conduct, and in which there is a possibility that obtaining the relevant person’s agreement will cause hindrance to performance of that clerical work
6. Cases in which 4 “Consignment of handling of personal information” will be made to a third party within the scope that is necessary for achievement of 2 “Purposes of use,” after an appropriate consignment agreement has been concluded

4. Consignment of handling of personal information

The Company may, within the scope that is necessary for achievement of 2 “Purposes of use,” consign all or a portion of handling of acquired personal information to a third party.
In such a case, in order to ensure that initiatives will be taken for safety management for personal information, the Company will appropriately select the third party that will be the consigned party, and the Company will conclude the necessary agreement, such as a basic agreement related to consignment of personal information, with the third party that will be the consigned party and conduct the necessary and appropriate management and supervision for the third party.

5. About transfer to countries outside the EEA

1. The Company may transfer Personal Data to a country outside the EEA. The places for such a transfer include third parties (parties that will conduct data processing), such as cloud service vendors. The Company will supervise those third parties that will handle Personal Data so that proper and appropriate protection measures will be implemented in conformance with the GDPR and in accordance with the transfer situation.
2. As a result of the Relevant Person using the Company’s service, the Company will deem that the Relevant Person consented to the matters below.
• In countries outside the EEA, there are cases in which laws and ordinances for protection of Personal Data are not sufficient, and it is not necessarily guaranteed that protection is of the same level as the protection measures stipulated by the GDPR.
• There are cases in which, for achievement of the purposes of use, Personal Data will be transferred to third parties (parties that will conduct data processing), including the Company Group and consigned parties, such as cloud service vendors, that are located in countries outside the EEA.

6. Security

1. The Company will implement reasonable preventive measures for the purpose of protection of acquired personal information and will conduct protection both online and offline. The Company will use technologies, such as firewalls, detection of unauthorized intrusion, and SSL, to strive to take meticulous caution in handling of personal information, and it will make access to personal information possible only for people who have been given the authority that will be necessary for work.
2. For purposes such as improvement of the customer’s convenience, acquisition of statistical data, and provision of appropriate advertisements, the Company may use cookies (including technologies that are similar to cookies; hereinafter referred to as “Cookies”) and collect information, such as the customer’s IP address, the number of times of access, the browser and OS that the customer uses, and other information, such as the terminal that is used. Such information is collected for the relevant purposes, and the Company does not use it for the purpose of identifying an individual.
3. About opting out of (disabling) use of Cookies

   See our Cookie Declaration for information on the cookies we use.

7. Disclosure, correction, deletion, and cessation of use of personal information

1. Place for making requests for disclosure

For a request for disclosure, if you will make an inquiry to the “Place for making inquiries about personal information” stated below and then request notification of the purposes of use, disclosure, correction of content, addition or deletion, cessation of use, elimination, or cessation of provision to third parties for your own personal information that the Company possesses, the Company will have you enter the necessary matters in the Company’s prescribed document and then submit the document.

2. For a request for disclosure, the Company will conduct identity verification. Depending on the case, the Company may conduct confirmation by having the customer send a copy of an official certificate by postal mail.

*For a representative, the Company will conduct confirmation by having the customer submit a letter of authorization. When a representative will be used, submission of copies of official certificates for both the Relevant Person and the representative will be necessary. In addition, the Company does not accept any requests for disclosure by telephone, e-mail, or fax, so please submit such requests by a method by which a record of sending can be obtained, such as simple registered mail.

*In the case of a legal representative of a minor or an adult ward, the Company will use a document that proves legal authority for representation to confirm that the legal representative has authority for representation.

3. For a request for disclosure (a request for notification of purposes of use or disclosure of personal information subject to disclosure), the Company will charge a service charge with a maximum of JPY 1,000. When it is clear that this amount will be exceeded, the Company will contact the customer separately.
4. This will not apply in cases in which, based on personal information protection or another law or ordinance, the Company does not bear an obligation of disclosure.

8. Clear indication of the data subject’s rights (the rights of users who reside in the EU)

Users who are EU residents have the rights below.

• Information acquisition and access to personal information

  The user can conduct the procedures that the Company will separately stipulate and thereby request an explanation related to the user’s personal information that the Company possesses and an explanation related to the purposes of use and methods of use of that information, and the user has the right to access the user’s personal information and certain related information.

• Correction or deletion

  The user can request correction of inaccurate personal information related to the user or a change of incomplete personal information into complete personal information. In addition, when certain requirements are fulfilled, the user can request deletion of personal information that the Company handles in relation to the user (provided, however, that when the personal information is necessary in order to comply with a legal obligation, when there is a business-related legitimate purpose, and when the personal information is necessary for proof, exercising, or defense in relation to a legal claim are excluded).

• Restriction of processing, and objections

  When certain requirements are fulfilled, the user can request restriction of processing of personal information. The user can also make objections and complaints to the supervisory agencies of individual countries within the EEA or to the Company.

• Data portability

  When certain requirements are fulfilled, the user has the right to receive personal information related to the user in a structured, commonly used, and machine-readable format, and the right to transfer that data to another manager without being hindered by the Company.

9. Saving period for information

The Company will retain and possess the user’s personal information for the period that is necessary for performance of the aforementioned 2 “Acquired information” and 3 “Purposes of use” or for the period stipulated by applicable laws and ordinances.

The specific retention and saving period will be decided by considering the purposes of acquiring and processing personal information, the nature of the personal information, and the legal or work-related necessity of retaining and saving personal information.

In addition, this will not apply when the user has exercised a right related to privacy.

10. Compliance with laws, ordinances, and standards

The Company will comply with Japan’s laws and ordinances that will be applied in relation to possessed personal information and with other applicable laws and ordinances.

11. Place for making inquiries

If you would like to make an inquiry or complaint related to this policy or the Company’s handling of personal information, please use the [Contact information for inquiries] below to contact the Company.

[Name of business operator]

• Skillnote Corporation
• KANDA SQUARE 11F , 2-2-1 Kanda-nishikicho, Chiyoda-ku , Tokyo 101-0054, Japan
• Takafumi Yamakawa, CEO

[Contact information for inquiries]

If you would like to make an inquiry, please do so by using the inquiry form on the Company’s official website.

In order to strive to provide even better protection for customers’ personal information and handle changes of laws and ordinances, the Company will appropriately reconsider the content and strive to improve it. Excluding laws, ordinances, and other matters separately stipulated in this policy, it shall be possible to change the content of this policy. The Privacy Policy after a change shall be announced by making a post on the Company’s website or by a method separately stipulated by the Company.