PRIVACY POLICY

AI CROSS Inc. (hereinafter referred to as “AI CROSS”) will contribute to society through work productivity apps development and platform services based on our corporate philosophy – “Realizing Smart life, Smart work, together.”
In recent years, the remarkable development of information processing technology has enabled us to easily and quickly process large amounts of data. At the same time, however, there have been incidents such as personal information leakage, requiring more secure and appropriate management of the handling of such information. With the enforcement of the “Act on the Protection of Personal Information,” we have formulated the “AI CROSS Inc. Privacy Policy” to further recognize the importance of the personal information entrusted to us by our customers, and we will strive to manage and maintain such information more appropriately.

(1) Establishment of a personal information protection management system

In our business activities, such as application development and sales and provision of platform services, we will establish a personal information protection management system (a management system that includes policies, organization, plans, implementation, monitoring, and review to protect personal information used for our business) in order to acquire personal information with the explicit purpose of use and to handle it appropriately, including entrustment, provision, and disposal. Personal information shall be handled within the scope necessary to achieve the specified purposes of use and shall not be used for any other purposes beyond the scope of the specified purposes of use, and necessary measures shall be taken to implement such measures.

(2) Compliance with Laws and Regulations

We will comply with all applicable laws and regulations concerning the protection of personal information, establish internal rules, and continuously strive to protect and improve the personal information we possess.

(3) Use, collection and provision of personal information

We clearly define the purposes for which personal information is to be used and inform you of the purposes for which personal information will be used. We will also collect and use personal information through fair and appropriate means to the extent necessary to achieve our objectives and provide our services.

(4) Management of personal information

We will make every effort to maintain our personal information in an accurate and up-to-date manner, prevent unauthorized access to, loss, destruction, falsification, leakage, etc. of personal information, and safely store and maintain such information under strict control.
In addition, we assign a person in charge of personal information protection and management and educate and supervise our employees.

(5) Outsourcing of Personal Information

When outsourcing the processing of personal information, we require contracts and strict management and guidance to ensure that personal information is not leaked or used for any other purpose.

(6) Disclosure, correction, and suspension of the use of personal information

We will respond appropriately to complaints and inquiries regarding the handling of personal information and the personal information protection management system, as well as requests and inquiries from individuals regarding the disclosure, correction, suspension of use, or refusal of the provision of personal information.

(7) Implementation and Continuous Improvement of Personal Information Protection Management System

We will make our directors and employees aware of the importance of personal information and formulate, implement, maintain, and continually improve a personal information protection management system to ensure that personal information is appropriately protected.

(8) Documentation and Dissemination

We will document and inform our employees of our privacy policy and take steps to make it available to our employees and the public.

Established on June 1, 2015
Revised on April 1, 2021
AI CROSS Inc.
President, CEO Noriko Harada

Handling of Personal Information

Recognizing the importance of protecting personal information in an advanced information and telecommunications society, we believe it is an important social responsibility to safely and appropriately handle the personal information of our customers and all other individuals (hereinafter referred to as “the individual”). As a business operator handling personal information, we have established a management system to protect personal information, including a privacy policy, and are building and continuously improving our internal systems. We will handle and protect personal information as follows.

1. Acquisition of Personal Information

We shall acquire personal information within the scope necessary for our business by legal and fair means. Please note that we may record telephone calls when responding to inquiries, comments, requests, and other communications from customers and other parties. Recorded call content will be used only to the extent necessary to achieve the purposes set forth in “2. Purposes of Use of Personal Information.”

2. Purpose of Use of Personal Information

We will use personal information within the scope necessary to achieve the following purposes.

• To provide products and services to customers
• To provide support for our customers such as responding to customer inquiries regarding our products and services
• To provide various information on our products, services, seminars, etc.
• To request a questionnaire survey to improve the quality of the products and services
• For credit management, collection management, and credit management of transactions with us.(only applied for customers who has actual business with us)
• Applicant management for recruitment
• Personnel management of employees or retirees
• Recording by security cameras in our facilities for crime prevention purposes
• Improving the quality of service in call center operations
• In responding to inquiries, comments, requests, and other communications from customers and other parties by telephone, email, or other means: to keep accurate records of such communications, to ensure the safety of our employees, and to respond appropriately to customer harassment (including verifying facts, issuing warnings, considering revisions to contract terms, reporting to the police, consulting with legal counsel, and taking other legal measures)
• Provision of information to third parties to the extent necessary to achieve the purposes of use described above
• To process the information obtained for each of the above purposes using pseudonyms and analyze the trends in the use of services by age and gender

When we ask you to provide us with personal information, we will clearly state the purpose of use as described above in advance and ask you to provide such information only to the extent necessary to achieve the purpose of use after you have given your consent. However, we may omit specifying the purpose of use if the purpose of the use is clear from the acquisition circumstances, such as when we exchange business cards in the course of business practice or when we receive a request for pamphlet delivery by telephone from a customer. Personal information provided by the customer will be used only within the scope of the purpose of use stated in advance and will not be used for any purpose other than that stated without the customer’s consent. If you do not wish to provide your personal information, you may refuse to provide it at your discretion. Please note that in such cases, the stated purpose of use may not be achieved.

3. Provision of Personal Information to Third Parties

We will not provide personal information to third parties without the individual’s prior consent, except in the following cases.

• When required by law
• When it is necessary to protect the life, body, or property of a person and it is difficult to obtain the person’s consent
• When it is indispensable to improve public health or promote children’s sound development, under the situation difficult to obtain the person’s consent.
• When it is necessary for a national institution or a local public body or a person entrusted with it to cooperate in carrying out the process stipulated by laws and regulations, and obtaining the person’s consent will hinder the performance of the process.
• When entrusting personal information to outsourced companies, including distributors, within the scope necessary for our business execution.

4. Security Control Measures for Personal Information

To prevent leakage, loss, or damage of personal information and for other safety management, we will establish a personal information management system and take physical and technical safety management measures. In addition, as personnel safety control measures, we will educate our employees on the proper handling of personal information and conduct periodic internal audits. As described above, we will continuously take necessary and appropriate safety control measures to prevent accidents.

5. Requests for Disclosure of Personal Information, etc.

Please refer to the “Procedures for Requesting usage purpose description, Disclosure, Correction, Suspension of Use of Personal Information” page for the requests for usage purpose description, disclosure, correction, and suspension of Use of Personal Information (hereinafter referred to as the “Request for Disclosure, etc.”). Once it is confirmed that the person making the inquiry is the person in question, we will respond to requests for disclosure, etc., within a reasonable period and range.

6. Website-specific handling of personal information

Prevention of Wiretapping, etc. by Third Parties in the Process of Communication When providing personal information to customers through our website, we will strive to ensure safety by encrypting personal information using SSL (Secure Sockets Layer) or using equivalent security technology preventing unauthorized access by third parties in the process of communication.

7. Cookies and Web beacons

In order to provide you with a more convenient browsing experience when you revisit this website, we may send you a data called a cookie, which identifies your computer and is stored on your hard disk. It is possible to refuse to accept cookies sent from this website by changing the settings of your Internet browser, but please note that this may prevent you from using this website or the services on this website normally. Web beacons are a technology that, when used in conjunction with cookies, enables us to collect access trends from your computer and statistics on the percentage of visitors to a particular web page. Web beacons are used on some of our pages, but they are used under appropriate management.
Protection of Personal Information at Link Destination
We are not responsible for ensuring the security of personal information on websites (hereinafter referred to as “links”) managed by other companies linked from our website. Regarding the protection of the personal information of the link destination, please confirm the privacy policy of the relevant link destination by yourself.

8. Delivery of Advertising by Third-Party Distributors

Our advertisements are posted on various sites on the Internet by Google and other businesses listed below (hereinafter referred to as “third-party distributors”). Third-party distributors use identification information such as cookies to distribute advertisements based on past access information to our website. In addition, the personal information possessed by the company and the personal information held by the third-party advertising distributor may be irreversibly converted into unidentified data, and then matched by the third-party advertising distributor, and advertisements may be distributed based on the results. The third-party distributor shall not use such information for any purpose other than the distribution of advertisements.

• Use of Services Related to Display Advertising Provided by Google. We display Google AdWords ads according to the status of our website. For more information, please refer to the Customer Match (https://support.google.com/google-ads/answer/6379332)).
• Use of behavioral targeting advertising provided by Yahoo! JAPAN. We display advertisements on our Yahoo! JAPAN and Yahoo! JAPAN partner sites, depending on how we use our website. For more information, please refer to Yahoo! JAPAN’s Action Targeting Advertisement (http://btoptout.yahoo.co.jp/optout/ Index.html) and Yahoo! DMP’s Information Linkage (https://btoptout.yahoo.co.jp/optout/dmp.html)).
• Advertising distribution using Facebook custom audience. We use Facebook custom audience to display advertisements based on our service usage. For more information, see the Facebook custom audience (https://ja-jp.facebook.com/bus iness/help/744354708981227). Facebook custom audience-based advertising delivery can be disabled from the Facebook opt-out page (https://www.facebook.com/about/ads)).

9. Contact for inquiries, complaints, and inquiries concerning the handling of personal information

AI CROSS Inc.
Personal Information Protection Manager,CFO, Ken Zushida
Phone number: 050-1745-3021
Hours: Monday – Friday, 10:00 a.m. to 7:00 p.m.
(except Saturdays, Sundays, National holidays and year-end/new-year holidays)
E-mail: privacy@aicross.co.jp

Retained Personal Data Held by the Company

Matters to Be Made Available to the Data Subject (Including Cases Where We Respond Without Delay at the Data Subject’s Request) Pursuant to the Act on the Protection of Personal Information and JIS

1. Name and Address of the Business Operator Handling Personal Information and Name of Its Representative

Name: AI CROSS Inc.
Address: Shiroyama Trust Tower 20F, 4-3-1 Toranomon, Minato-ku, Tokyo
Representative: Noriko Harada

2. Title, Affiliation, and Contact Information of the Personal Information Protection Manager

Personal Information Protection Manager: Ken Zushida (for contact information, see “Personal Information Complaints and Consultation Desk” below)

3. Purposes of Use of All Retained Personal Data

(1) Personal information of customers

• To perform and appropriately manage the terms of contracts

(2) Personal information of business partners

• To appropriately manage the terms of contracts with business partners

(3) Personal information of shareholders

• To exercise rights and perform obligations under the Companies Act and the Commercial Code
• To provide various benefits from the Company
• To implement various measures to facilitate smooth relations between shareholders and the Company
• For shareholder management, including preparing shareholder data in accordance with prescribed standards under applicable laws and regulations

(4) Personal information of persons wishing to join the Company

• To provide recruitment and job opening information to, and communicate with, persons who have expressed interest in the Company as a potential employer or who have applied
• For recruitment and selection

(5) Personal information of Company employees

• For work-related communications, preparation of employee directories, legally required procedures (including after an employee’s resignation), and other employment management
• For personnel selection and for decisions on assignments, secondments, and dispatch destinations
• For determining and paying compensation, tax processing, social insurance procedures, and providing employee benefits
• For security control measures, including video and online monitoring
• For the Company’s PR and promotional activities, including in PR and promotional materials
• For appropriate health management (we do not acquire, use, or provide employees’ health information, such as health checkup results, except as required by law)

(6) Personal information of persons who contact the Company

• To improve the manner and quality of our customer service
• To accurately understand and address inquiries and other communications
• To ensure the safety of our employees
• To verify facts, issue warnings, review contract terms, report to the police, consult with legal counsel, and take other necessary measures regarding customer harassment and other improper or inappropriate conduct

(7) Specific personal information, etc. (including Individual Numbers)

• To properly carry out, in accordance with laws and regulations, the preparation of withholding tax slips and payment records, and filings for health insurance, employees’ pension insurance, and employment insurance

*Where the purposes above state “to appropriately manage the terms of contracts,” this includes use at the pre-contract stage and use after the contract has ended.

4. Contact for Complaints Regarding the Handling of Retained Personal Data

• “Personal Information Complaints and Consultation Desk” (listed at the end of this document)

5. Name of the Accredited Personal Information Protection Organization and Contact for Complaint Resolution

Japan Institute for Promotion of Digital Economy and Community (JIPDEC)
Accredited Personal Information Protection Organization Secretariat
Address: Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
Tel: 03-5860-7565
Toll-free: 0120-700-779 (Hours: weekdays (Mon–Fri) 9:30–12:00, 13:00–16:00)

6. Procedures for Responding to Requests for Disclosure, etc.

(1) Where to submit requests for disclosure, etc.

• “Personal Information Complaints and Consultation Desk” (listed at the end of this document)

(2) Required forms and other methods for requests for disclosure, etc.
Please send the following documents to the Company’s “Personal Information Complaints and Consultation Desk” by registered mail. We will respond promptly and without delay. Please note that we do not accept requests for disclosure, etc. submitted by any other means (such as in person, by email, or by fax).

a) The Company’s designated “Request Form for Disclosure, etc.”
If you do not have this form, please contact us and we will send it to you.

b) Identity verification documents

1.Requests made by the data subject

• A copy of the data subject’s official identification document

2.Requests made by an agent
All of the following that apply:

① Documents confirming the agent’s authority

i. Legal representative: a certified copy of the family register or other document proving such status
ii. Voluntary agent (all of the following):

・A power of attorney in the Company’s designated form, bearing the data subject’s registered seal (if you do not have the designated form, please contact us and we will mail it to you promptly)

・The data subject’s certificate of seal registration

② Identity verification documents for the agent

・A copy of the agent’s official identification document

③ Identity verification documents for the data subject

・A copy of the data subject’s official identification document

*Official identification document means either A or B below:
A. One of the following: driver’s license, certificate of driving history, passport, Individual Number Card (only the side showing name and photograph), residence card, or special permanent resident certificate
B. Two or more of the following: public health insurance card, copy of residence certificate, certificate of matters stated in the residence record, pension handbook, latter-stage elderly medical insurance card, membership card of a mutual aid association for national or local government employees, membership card of the mutual aid system for private school personnel, child-rearing allowance certificate, or special child-rearing allowance certificate

*The identity verification documents you submit will be used as described below. Please submit a request for disclosure, etc. only if you agree to this.

• This personal information will be used to respond to the data subject’s request for disclosure, etc.
• Please black out or otherwise render illegible any special care-required personal information that is not necessary for identity verification.
• Except as required by law, we will not provide this personal information to third parties without the data subject’s consent. We also have no plans to outsource the handling of this personal information.
• If we are unable to verify identity using the submitted documents, we may be unable to respond to the request for disclosure, etc.
• For other information on the Company’s handling of personal information, please see our website below.
  https://aicross.co.jp/policy/

c) Fee
A fee of 750 yen per request applies to requests for notification of the purpose of use or for disclosure. Please enclose a postal money order for 750 yen with the documents above.
If the fee is not enclosed, we will notify you; however, if payment is not received within the specified period, the request will be deemed not to have been made. In principle, submitted documents will not be returned.

Personal Information Complaints and Consultation Desk
AI CROSS Inc.
Shiroyama Trust Tower 20F, 4-3-1 Toranomon, Minato-ku, Tokyo 105-6020
Contact: Personal Information Protection Management Office
Tel: 050-1745-3021
Email: privacy@aicross.co.jp
(Hours: Monday–Friday, 10:00–16:00, excluding public holidays and the year-end/New Year holidays)

7. Measures Taken for the Security Control of Retained Personal Data

(Formulation of a basic policy)
To ensure the proper handling of personal data, we have formulated a basic policy covering matters such as compliance with relevant laws, regulations, and guidelines, and a contact point for questions and complaints.

(Establishment of rules on the handling of personal data)
We have established personal data handling rules that set out, for each stage (acquisition, use, storage, provision, deletion and disposal, etc.), the handling methods, the persons responsible and in charge, and their duties.

(Organizational security control measures)
We have appointed a person responsible for the handling of personal data. We have clarified which employees handle personal data and the scope of personal data they handle. We have also established a system for reporting to the responsible person upon becoming aware of any fact or sign of a violation of laws or of the handling rules.
We conduct regular self-inspections of the handling of personal data, as well as audits by other departments or external parties.

(Human security control measures)
We provide employees with regular training on matters to be noted regarding the handling of personal data.
We have entered into confidentiality agreements with employees concerning personal data.

(Physical security control measures)
In areas where personal data is handled, we control employees’ entry and exit and the equipment they bring in. We also implement measures to prevent unauthorized persons from viewing personal data.
We take measures to prevent the theft or loss of equipment, electronic media, documents, and other items used to handle personal data. When such equipment or electronic media are carried, including within our premises, we take measures so that personal data cannot be easily identified.

(Technical security control measures)
We implement access controls to limit the persons in charge and the scope of personal information databases they handle. We have also introduced mechanisms to protect information systems that handle personal data from unauthorized external access and malicious software.

(Understanding of the external environment)
The Company uses cloud services with servers located outside Japan. However, personal data retained by the Company is stored on servers in Japan and is not stored on servers outside Japan.

Notes

• The Company cannot accept responsibility for documents lost or not delivered due to accidents during mailing or delivery.
• Please complete all required fields. Documents with deficiencies may be returned to you.
• We may be unable to respond to a request for disclosure, etc., such as where an exception under the Act on the Protection of Personal Information applies.
• Depending on the nature of the request, it may take some time to respond.
• Personal information collected in connection with a request for disclosure, etc. will be handled only to the extent necessary for that request. Submitted documents will be disposed of appropriately by the Company.
• Please note that, as a result of correction, etc. or suspension of use, etc., you may no longer be able to use the relevant services.

*”Retained personal data” means personal information that constitutes a collection of information systematically organized so that specific personal information can be searched for using a computer, or systematically organized so that specific personal information can be easily searched for by arranging and classifying it according to certain rules and adding a table of contents, index, symbols, etc., and for which the Company has the authority to respond to all requests from the data subject for disclosure, correction, addition, or deletion of content, suspension of use, erasure, and suspension of provision to third parties. For details, please contact the “Personal Information Complaints and Consultation Desk.”

Guide to Procedures Concerning the Use of Personal Information

If a data subject (including a voluntary agent appointed by the data subject, or a legal representative of a minor or adult ward) wishes to request from the Company notification of the purpose of use, disclosure, correction, etc., or suspension of use, etc. of personal information concerning the data subject (hereinafter, “requests for disclosure, etc.”), please complete the designated “Request Form” and send it by registered mail to the address below, together with identity verification documents (see the list of documents accepted by the Company below) and any other required documents.

The Company will respond to requests without delay. However, please note that we will notify you of the results within a reasonable period (in principle, two weeks; where a response takes longer, such as when there are many requests or a request is complex, we expect to respond within 30 days) and will respond to the extent reasonable.

Because important documents, including identity verification documents, and requests must be exchanged safely and reliably, we recommend sending them by registered mail.
Postage for mailing documents is to be borne by the customer.
For requests to stop receiving our email newsletters, the procedure may be explained in the newsletter itself. In that case, please follow those instructions.

1. Documents Required for Requests for Disclosure, etc.

Identity Verification Documents Accepted by the Company

• Copy of driver’s license
• Copy of passport
• Copy of residence card or special permanent resident certificate; or copy of certificate of residence, together with a copy of health insurance card or certificate of seal registration (two documents in total)

Each of the above documents must clearly state the requester’s current address (where any changes have been made, a copy of the reverse side shall also be submitted) and must be within its period of validity or have been issued within six (6) months prior to submission. The Company shall send its notification of the results to the address stated in the Request Form (or, in the case of a request made by an agent, to the agent’s address) after confirming that such address and other particulars are consistent with those stated in the identity verification documents and other required documents submitted. Accordingly, the requester is required to submit documents stating the requester’s current address.

Documents Accepted by the Company to Confirm Parental Authority or Adult Guardianship
Document confirming parental authority: certified copy of family register (koseki tohon) issued within six (6) months prior to submission
Document confirming adult guardianship: certificate of registered matters concerning adult guardianship issued within six (6) months prior to submission

Where any identity verification document states the registered domicile (honseki), Individual Number (My Number), or family information, such information shall be concealed (for example, by blacking it out) prior to submission.

Certain required documents may be downloaded from the links below.
Request Form for Disclosure of Personal Information (PDF)
Request Form for Notification of the Purpose of Use of Personal Information (PDF)
Request Form for Correction, etc. of Personal Information (PDF)
Request Form for Suspension of Use, etc. of Personal Information (PDF)
Power of Attorney (PDF)

2. Fees

A fee of 750 yen shall be charged for each request for notification of the purpose of use of personal information and each request for disclosure. The requester shall enclose postage stamps in the amount of 750 yen with the request.

3. Address for Submission of Documents

Documents required for requests for disclosure, etc. shall be sent by registered mail to the following address:

AI CROSS Inc.
Shiroyama Trust Tower 20F, 4-3-1 Toranomon, Minato-ku, Tokyo 105-6021, Japan

4. Cases in Which the Company Is Unable to Respond to Requests for Disclosure, etc.

The Company shall not respond to a request for disclosure, etc. of personal information where the request is not made in the manner specified by the Company, or where any of the following applies:

• Where the information subject to the request does not exist in the Company’s personal information database
• Where there are deficiencies in the request or the required documents, or where the disclosure fee is not paid
• Where the request is made by an agent and the agent’s authority cannot be confirmed
• Where revealing the existence or non-existence of the personal data is likely to harm the life, body, or property of the data subject or a third party
• Where revealing the existence or non-existence of the personal data is likely to encourage or induce illegal or unjust acts
• Where revealing the existence or non-existence of the personal data is likely to harm national security, damage relationships of trust with foreign countries or international organizations, or cause disadvantage in negotiations with foreign countries or international organizations
• Where revealing the existence or non-existence of the personal data is likely to hinder the prevention, suppression, or investigation of crimes, or the maintenance of public safety and order
• Where responding is likely to significantly interfere with the proper conduct of the Company’s business
• Where responding would result in a violation of other laws and regulations

Where the Company determines that it is unable to respond to a request for disclosure, etc., the Company shall promptly notify the requester of the reasons therefor. Please note that postage stamps submitted shall not be returned even in such cases.

Handling of Personal Information Acquired in Connection with Requests
Personal information acquired by the Company in connection with a request shall be used solely to the extent necessary to respond to such request. Requesters are asked to submit requests only upon consenting to the foregoing purpose of use. Please note that the Company may be unable to respond to a request where any of the cases set forth in “4. Cases in Which the Company Is Unable to Respond to Requests for Disclosure, etc.” applies. The Company shall manage customers’ personal information under appropriate security measures and shall endeavor to prevent leakage and other incidents. The Company shall not disclose or provide such personal information to any third party without the customer’s consent. Identity verification documents shall be disposed of by secure means after the notification of the results has been sent and the documents have been retained for the necessary period.

*No revision of the Power of Attorney included in the Guide to Procedures for Notification of the Purpose of Use, Disclosure, Correction, etc., and Suspension of Use, etc. of Personal Information is required.