Privacy Policy

HandsOn AI Inc. (hereinafter referred to as the "Company") establishes this Privacy Policy (hereinafter referred to as the "Policy") to set forth the handling of privacy information of users (hereinafter referred to as "Users") of the services and systems provided by the Company, including but not limited to the language learning service "HandsOn AI" (collectively referred to as the "Services"), as well as privacy information registered by Users on the Services. Article 1 (Privacy Information) For the purposes of this Policy, "Personal Information" means "personal information" as defined under the Act on the Protection of Personal Information of Japan, namely information about a living individual that can identify the specific individual by name, date of birth, address, telephone number, contact details, or other descriptions contained therein. "History and Attribute Information" means any information other than the aforementioned Personal Information, including records of services used, pages or advertisements viewed, search keywords entered by Users, date and time of use, method of use, usage environment, postal code, gender, occupation, age, IP address, cookie information, location information, and unique device identifiers. Article 2 (Methods of Collecting Personal Information) The Company collects Personal Information in the following cases. Failure to provide such information may result in inability to use some or all of the Services. 1. Direct Collection by the Company ・When entered by the User through device operations. ・When provided by the User via written documents, other media, or verbally. ・When transmitted or provided in connection with the User's use or viewing of the Company's services, products, applications, web pages, advertisements, or content. 2. Indirect Collection by the Company ・When lawfully provided by a business partner or another third party with the User's consent. ・When received from business partners regarding browsing history, IP addresses, cookies, advertising IDs, device information, and other personal data collected through services operated by such partners. The Company may link such information with privacy information it holds and use it for the purposes stated in Article 3. In such cases, the information will be treated as Personal Information. 3. Information Registered by Corporate Users The Company may obtain information (e.g., name, corporate email address, department) registered by corporate customers under a corporate agreement. Article 3 (Purposes of Use of Personal Information) The Company will use acquired Personal Information for the following purposes and will not use it beyond the scope necessary to achieve such purposes without the User's consent, unless permitted by applicable law. The Company will not use Personal Information in any manner that may promote or induce illegal or improper acts. 1. Information Obtained from Service Users ・For membership authentication, management, administrative communication, and provision of Service functions. ・For identity verification of Users. ・For management and operation of seminars and events organized by the Company. ・For distribution of information regarding the Services. ・For conducting surveys, campaigns, prize draws, and related communications. ・For responding to inquiries or feedback from Users. ・For advertising, marketing, and solicitation of sales of products or services of the Company or third parties. ・For providing information on seminars operated by the Company. ・For maintenance and operation of the Services. ・For improvement and enhancement of the Services. ・For ensuring safe provision of the Services (including detection, investigation, prevention, and response to fraudulent activities, unauthorized access, and violations of the Terms of Use). ・For outsourcing the handling of Personal Information to contractors, partners, or subcontractors with whom the Company has confidentiality agreements. 2. Information Registered by Users on the Services (Same purposes as 1.6 to 1.12 above, applied to registered content.) 3. Information of Business Partners ・For negotiations, communications, consultations, orders, invoicing, payments, and other business-related activities. ・For management of business partner information. ・For handling Personal Information of business partners as necessary for appropriate and smooth provision of the Services. 4. Information of Shareholders ・For exercising rights and fulfilling obligations under the Companies Act of Japan and other applicable laws. ・For preparing records required by law and managing shareholder information. ・For handling Personal Information of shareholders as necessary for appropriate and smooth provision of the Services. 5. Information of Job Applicants ・For providing recruitment information, conducting hiring selection, and verifying application history. ・For communications and responses to inquiries from applicants. ・For providing information on recruitment-related events and seminars. ・For handling Personal Information of applicants as necessary for appropriate and smooth provision of the Services. 6. Information of Officers, Employees, Former Employees, and Their Families ・For business communications and information exchange. ・For employment management, including payroll, HR, labor management, and provision of benefits. ・For health management and ensuring a safe work environment. ・For provision of benefit services and handling insurance and other administrative procedures. ・For filings and reports to government agencies. ・For labor management and handling Personal Information of employees as necessary for appropriate and smooth provision of the Services. 7. To enable corporate administrators to analyze and manage employee usage of the Services. 8. To propose learning improvement measures to corporate clients based on usage trends. Article 4 (Provision of Personal Information to Third Parties) The Company will not provide Personal Information to third parties without prior consent of the User, except in the following cases or as permitted by applicable laws: 1. Required by law. 2. Necessary to protect life, body, or property where consent is difficult to obtain. 3. Especially necessary for improving public health or promoting the sound growth of children where consent is difficult to obtain. 4. Necessary for cooperating with national or local governments or their agents in executing affairs prescribed by law, where obtaining consent could impede such execution. 5. When the recipient is an academic research institution and the provision is necessary for academic research purposes, except where such provision may unduly infringe the rights and interests of individuals. The following cases do not constitute provision to third parties: ・Entrustment of handling of Personal Information within the scope necessary for the purpose of use. ・Provision of Personal Information due to business succession by merger or other means. ・Joint use as permitted under the Act on the Protection of Personal Information. Article 5 (Entrustment of Personal Information) The Company may entrust handling of Personal Information to subcontractors for business purposes, after carefully selecting entities with proper security controls and entering into contracts specifying confidentiality and proper handling measures. In the provision of operational outsourcing services to corporate Users, the Company may entrust handling of Personal Information to designated subcontractors. Article 6 (Disclaimer Regarding Third-Party Provision) The Company assumes no responsibility in the following cases: ・When the User discloses Personal Information to a third party via the Services or other means. ・When a User is identified by information posted by the User in connection with the Services. ・When Personal Information is provided to or used by an external site linked from the Services. ・When a third party obtains information (such as ID or password) enabling identification of a User without provision by the Company. ・When not attributable to the Company. Article 7 (Use of Statistical Data) The Company may create statistical data from provided Personal Information, processed so that individuals cannot be identified. The Company may use such anonymized statistical data without restriction. Article 8 (Acquisition and Use of History and Attribute Information) History and Attribute Information does not include Personal Information. The Company uses such information to protect privacy, improve convenience, deliver advertisements, and obtain statistical data, and may use cookies and similar technologies. Users may refuse cookies via browser settings, but this may limit functionality. Article 9 (Requests for Disclosure, Correction, and Suspension of Use of Personal Information) Users may request disclosure, notification of purpose of use, correction, addition, deletion, suspension of use, erasure, or cessation of provision to third parties, and the Company will respond appropriately in accordance with applicable laws. Certain exceptions apply where legal grounds exist. Article 10 (Security Control Measures) The Company takes necessary and appropriate security control measures to prevent leakage, loss, misuse, or alteration of Personal Information, stores it in secure environments, and maintains an information security management system with regular reviews. Article 11 (Voluntariness of Provision of Personal Information) Provision of Personal Information is voluntary, but failure to provide necessary information may result in inability to use the Services. Article 12 (Amendments to the Privacy Policy) The Company may amend this Policy at its discretion within the scope permitted by law, with changes effective upon posting on the website, unless otherwise specified. Article 13 (Handling of Linked Websites) This Policy does not apply to third-party websites linked from the Company's website. Please refer to the respective privacy policies of such websites. Article 14 (Additional Provisions for Users in the European Economic Area, the United Kingdom, and Switzerland) If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, the following additional provisions apply in accordance with the General Data Protection Regulation (GDPR) and other applicable local data protection laws: 1. Legal Basis for Processing The Company processes your Personal Information only where one or more of the following legal bases apply: 2. Your consent; ・Performance of a contract with you; ・Compliance with a legal obligation; ・Legitimate interests pursued by the Company or a third party, provided such interests are not overridden by your rights and freedoms. 3. Your Rights under GDPR You have the right to: ・Access, correct, update, or request deletion of your Personal Information; ・Object to processing of your Personal Information; ・Request restriction of processing; ・Request portability of your Personal Information; ・Withdraw consent at any time (without affecting the lawfulness of processing prior to withdrawal); ・Lodge a complaint with a supervisory authority in your country of residence. 4. International Transfers Where we transfer Personal Information outside the EEA, UK, or Switzerland, we ensure appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses (SCCs) or other mechanisms permitted under applicable law. Article 15 (Additional Provisions for Residents of California and Other U.S. States) If you are a resident of California or other U.S. states with privacy legislation (such as Virginia, Colorado, Connecticut, or Utah), the following provisions apply in accordance with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable laws: 1. Categories of Personal Information Collected In the past 12 months, we may have collected the following categories of Personal Information: ・Identifiers (such as name, email address, IP address); ・Commercial information (such as records of products or services purchased); ・Internet or other electronic network activity information; ・Geolocation data; ・Professional or employment-related information. 2. Your Rights under CCPA/CPRA Subject to certain exceptions, you have the right to: ・Know what Personal Information we collect, use, disclose, or sell/share; ・Request deletion of your Personal Information; ・Request correction of inaccurate Personal Information; ・Opt out of the sale or sharing of your Personal Information; ・Limit the use and disclosure of sensitive Personal Information; ・Non-discrimination for exercising your privacy rights. 3. Do Not Sell or Share My Personal Information The Company does not "sell" Personal Information as defined under the CCPA/CPRA. If this changes, we will update this Policy and provide mechanisms for you to opt out. 4. Exercising Your Rights To exercise any of the above rights, please contact us at [email protected]. Article 16 (Retention of Personal Information) We retain Personal Information only for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements. Retention periods vary depending on the type of information and the purpose of its use. Article 17 (Children's Privacy) The Services are not directed to individuals under the age of 13 (or the age of digital consent in your jurisdiction). We do not knowingly collect Personal Information from children. If we become aware that a child has provided us with Personal Information without parental consent, we will take steps to delete such information. Article 18 (International Users) By using the Services from outside Japan, you acknowledge and agree that your Personal Information may be transferred to and processed in Japan and other countries where privacy laws may not provide the same level of protection as your home jurisdiction. We will take appropriate steps to ensure an adequate level of protection for your Personal Information in accordance with applicable laws. Article 19 (Contact Information) For inquiries regarding this Policy, please contact: HandsOn AI Inc. Address: 2-3-6-914 Toyo, Koto-ku, Tokyo 135-0016, Japan Email: [email protected] Disclaimer (Translation for Reference Only) This English version of the Terms of Use is provided solely for reference purposes. In the event of any inconsistency or discrepancy between this English translation and the original Japanese version, the Japanese version shall prevail. Only the Japanese version is legally binding, and this English translation has no legal effect. Supplementary Provision Enacted and effective as of January 23, 2025.