Privacy Policy

A3 Inc. (the “Company”, “we”, “our”, “us”) promotes the protection of personal information by establishing the following privacy policy regarding the handling of personal information of the Users of the Company's services (the “User”) and ensuring that all employees are fully aware of the importance of protecting personal information.

Article 1 (Personal Information)
Personal information means information about a living individual that can identify a specific individual by name, date of birth, or other description, etc., or that contains a personal identification code, as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, the “Personal Information Protection Act”).

Article 2 (Acquisition and Use of Personal Information)
The Company acquires personal information of the User and uses the acquired information to the extent necessary for the following purposes. If the Company intend to use personal information beyond the scope of the following purposes, the Company will obtain prior consent from the User in an appropriate manner.
(1) To provide our services (the “Service”)
(2) To improve and enhance the contents of the Service or develop new services
(3) To provide information on new features, updates, campaigns, etc. of the Service and other services provided by the Company (including sending e-mails, flyers, and other direct mailings)
(4) To contact as necessary for maintenance, important notices, etc.
(5) To respond to opinions, inquiries, etc. from the User regarding the Service (including to confirm the identity of the User)
(6) To report to the User on the use of the Service
(7) To request the User’s cooperation in surveys, interviews, and participation in various events related to the Service, or to report the results of such events, etc.
(8) To research and analyze the usage history of the Service and use the results to improve and develop the Service and to deliver advertisements
(9) Provision of personal information to companies participating in events hosted by the Company based on the User's consent or application
(10) To identify Users who violate the Terms of Use or who attempt to use the Service for fraudulent or unfair purposes, and to refuse their use of the Service.

Article 3 (Management and Protection of Personal Information)
Personal information shall be strictly managed and shall not be disclosed or provided to any third party without the consent of the User, except in the following cases. In addition, in consideration of safety, 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 User's consent.
(2) Cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the User's consent.
(3) Cases in which it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the User's consent is likely to impede the execution of such affairs.
(4) When all or part of the handling of personal information is outsourced within the scope necessary to achieve the purpose of use, in order to facilitate the smooth performance of business operations.
(5) Cases in which personal information is provided as a result of the succession of business due to merger or other reasons.
(6) Cases in which personal information is used jointly with a specific person, and in which this fact, the items of personal information to be jointly used, the scope of the joint Users, the purpose of use by the User, and the name of the person responsible for the management of the personal information is notified to the User in advance, or is made readily accessible to the User or the name of the person responsible for the management of such personal information is made readily accessible to the User in advance.
(7) Other cases permitted by laws and regulations

Article 4 (Entrustment of Handling of Personal Information)
The Company may outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use. In such cases, the Company will thoroughly examine the eligibility of the consignee, stipulate confidentiality obligations in the contract, and exercise necessary and appropriate supervision over the consignee.

Article 5 (Disclosure of Personal Information)
When the Company is requested by the User (limited to the person himself/herself.) to disclose personal information, the Company shall disclose such information to the User without delay. However, if the Company decides not to disclose the information, it will notify the User to that effect without delay.
(1) When there is a risk of harm to the life, body, property, or other rights or interests of the User or a third party
(2) If there is a risk of significant hindrance to the proper conduct of our business
(3) Other cases that would violate laws and regulations

Article 6 (Correction and Deletion of Personal Information)
1. If the personal information in our possession is incorrect, we will correct or delete the personal information at the request of the User in accordance with the procedures we have established.
2. If we receive a request from the User as described in the preceding paragraph and deem it necessary to respond to the request, we will correct or delete the relevant personal information without delay and notify the User of such correction or deletion.

Article 7 (Suspension of Use of Personal Information)
When the Company receives a request from the User to stop using or delete (“stop using, etc.”) his/her personal information in the following cases, the Company will conduct the necessary investigation without delay and, based on the results, will suspend the use of personal information in accordance with the law and notify the User. However, in cases where it is difficult to suspend the use of personal information due to the large amount of costs involved or other difficulties in doing so, and alternative measures can be taken to protect the rights and interests of the User, we will take such alternative measures.
(1) Cases in which the purpose of use is handled in a manner that exceeds the scope of the intended purpose of use.
(2) If the personal information was obtained by wrongful means.
(3) If the information is used in a manner that may encourage or induce illegal or unjust acts.
(4) When there is no longer use of the User's personal information.
(5) Leakage, loss, or damage (“leakage, etc.”) of personal information that includes personal information requiring special consideration has occurred or is likely to occur.
(6) When there has been or is likely to be a leakage, etc. of personal information that may cause property damage due to unauthorized use.
(7) When there has been or is likely to be a leakage, etc. of personal information that may have been done for a wrongful purpose.
(8) When there has been or is likely to be a leakage, etc., of personal information involving more than 1,000 persons.
(9) When there is a risk that the rights or legitimate interests of the User may be harmed by the handling of said personal information.

Article 8 (Procedures for Changing Privacy Policy)
The Company will review the contents of this policy from time to time and strive to improve it. The contents of this policy may be changed except as otherwise provided in laws and regulations or in this policy. The revised Privacy Policy shall become effective when it is notified to the Users or posted on the Company's website in a manner prescribed by the Company.

Article 9 (Compliance with Laws, Regulations and Norms)
The Company will comply with Japanese laws and regulations and other norms applicable to personal information in our possession.

Article 10 (Response to complaints and concerns)
If the Company receives complaints and concerns from the User regarding the handling of personal information, such responses to complaints and concerns shall be done in an appropriate and timely manner. The Company will also respond promptly and appropriately to requests from Users for disclosure, correction, addition, deletion, or refusal of use or provision of said personal information.

Article 11 (Security Control Measures)
The Company takes organizational, physical, personnel, and technical measures to prevent unauthorized access to personal information, loss, destruction, alteration, and leakage of personal information by restricting access to personal information files, recording access logs, and implementing security measures to prevent unauthorized access from outside the company. In the unlikely event of an incident involving the leakage of Users' personal information, the Company shall promptly report the incident to the regulatory authorities in accordance with the Personal Information Protection Act and related guidelines, and take necessary measures to prevent similar incidents from occurring or recurring, in accordance with the instructions of the relevant regulatory authorities. For details, please refer to the attached "Security Control Measures for Personal Information".

Article 12 (Address, Name of Representative, Personal Information Protection Manager)
Our address, the name of the representative and personal information protection manager are as follows;
Address: Yamatane Ikebukuro Building 2F, 1-11-22 Minami Ikebukuro, Toshima-ku, Tokyo
Representative: Takashi Ozawa
Personal Information Protection Manager: Mitsuhisa Toya

Article 13 (Contact for Inquiries)
For inquiries regarding our handling of personal information, please contact the following;
A3 Inc. Customer Service Contact
〒 171-0022
Yamatane Ikebukuro Building 2F, 1-11-22 Minami Ikebukuro, Toshima-ku, Tokyo
TEL: 03-6903-1806
Mail: kanri@athree3.com

Attachment: Security Control Measures for Personal Information

We will endeavor to keep personal information of Users and others accurate and up-to-date, and will take the following necessary and appropriate security control measures by formulating a basic policy and rules for handling personal information.

1. formulation of basic policy
Establishing a basic policy regarding compliance with relevant laws, regulations, guidelines, etc., as well as a contact point for handling questions and complaints for ensuring the proper handling of personal information.

2. Establishment of rules for the handling of personal information
Establishing rules for handling personal information, including handling methods, responsible persons/persons in charge, and their duties at each stage of acquisition, use, storage, provision, deletion, disposal, etc.

3. Organizational safety control measures
・Placing a person responsible for the handling of personal information, clarifying the employees who handle personal information and the scope of personal information handled by such employees, and establishing a system for reporting to the person responsible in the event that a violation of the law or handling rules is detected or any indication of such a violation is detected.
・Conducting periodic self-inspections of the status of personal information handling, and conducting audits by other departments or outside parties.
・Establishing a system to respond to incidents of leakage, etc.

4. Personnel safety control measures
・Ensuring that all employees are aware of the matters to be considered in handling personal information, and providing education and periodic training.
・Prescribing confidentiality of personal information in the rules of employment and the pledge.
・Clarifying the roles and responsibilities of employees regarding protection of personal information.

5. Physical security control measures
・Placing control access to the area where personal information is handled and limiting the equipment and other items that employees may bring into the area.
・Implementing measures to prevent access to personal information by unauthorized persons.
・Implementing measures such as locking and encryption to prevent theft or loss of equipment, electronic media, and documents that handle personal information.

6. Technical security control measures
・Designating the management classification of personal information and placing access privileges.
・Managing the access privileges to personal information databases.
・Implementing measures to prevent leakage, damage, etc. of personal information.
・Implementing systems to protect personal information from unauthorized access from outside or unauthorized software.