PRIVACY POLICY

PARONYM Inc. (“we,” “our,” or “us”) recognizes the protection of the Personal Information as our important responsibility. We will endeavor to properly collect, handle and protect the Personal Information acquired under this Privacy Policy (this “Policy”).

1. Our name, address and representative

 PARONYM Inc.
 7F Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo 108-0075 Japan
 Representative Director: Michio Kobayashi

2. About the Personal Information

■ What is the Personal Information?

“Personal Information” means information about a living individual that can identify the specific individual by name, email address, etc. contained in such information (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual).

■ The purpose of use of the Personal information

We will collect and use the Personal information by legal and appropriate means within the scope necessary to achieve the following purposes of use:
(1) The customer’s Personal Information
[1] To provide our services;
[2] To respond to customer inquiries;
[3] To send documents about our services requested by the customer;
[4] To provide the customer with information via e-mail, etc. (such as email newsletters about our services);
[5] To analyze the usage history of our services, improve them and make proposals;
[6] To survey the customer usage and satisfaction with our services;
[7] To respond to the opinions and requests from the customer regarding us or our services;
[8] To carry out maintenance on our services, and
[9] To examine new services.

(2) The shareholder’s (if the shareholder is a corporation, then its officers and employees) Personal Information
[1] To exercise rights and perform obligations under the Companies Act, other laws and regulations, and
[2] To manage shareholders such as creating records, etc. under various laws and regulations.

(3) The job applicants’ Personal Information [1] To carry out recruitment screening,
[2] To notify applicants of the results of the recruitment screening and contact those who have been hired before they join us, and
[3] To use the application information of new hires as our personnel information after they have joined us.

■ Use of the Personal information

If it is necessary for us to use the Personal information for a purpose other than those stated above, then we will inform you of the new purposes in advance and use the Personal Information only after obtaining your consent. However, this will not apply to the followings:
 (1) Cases in which the handling of the Personal Information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person,
 (2) Cases in which the handling of the Personal Information is specially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person; or
 (3) Cases in which the handling of the Personal Information is based on laws and regulations

We may change the purpose of use of the Personal Information within the scope reasonably recognized as being relevant to the above-stated purposes of use. If we change the purpose of use of the Personal information, we will notify you of the revised purpose of use or post it on our website or service page.

3. About the Personal Information, etc. of those who use the our services

■ Compliance with related laws, regulations and guidelines, etc.

We will properly handle non-personally identifiable statistical information and its processing method, etc., in addition to the Personal information in compliance with the Act on the Protection of Personal Information, other laws, the “Guidelines on the Act on the Protection of Personal Information” and other guidelines.

■ Securities

We will use an ISMS (Information Security Management System) to implement necessary and appropriate safety management measures below to manage the Personal Information and prevent its leakage, loss, damage, etc. in compliance with relevant laws and guidelines.
 (1) Organizational security control action
We will appoint the Personal information officers and managers and clarify their roles, establish internal rules on the handling of the Personal information, and create an organizational control system.
 (2) Personnel security control action
We will provide education and training on the protection of the Personal information, etc. to all employees who handle the Personal Information, etc.
 (3) Physical security control action
We will implement measures such as entrance and exit management on the floor where the Personal Information is handled and impose restrictions on taking information and documents out of the office, etc.
 (4) Technical security control action
We will control access to the personal data, take measures to prevent unauthorized access from outside, etc.

4. Request to disclose the personal data, etc.

We will promptly respond to requests to inquiry, revise, cease using, erase, etc. the personal data after confirming your identity through the prescribed procedures. Please contact us listed as “6. Inquiries” below if you have any questions on this Policy or if you wish to exercise your rights under this Policy.

5. Inquiries

If you have any questions or complaints regarding our handling of the personal data, please contact us by email.
 Address: 7F Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo 108-0075 Japan
 PARONYM Inc. Business Management Division
 Email: kanri@paronym.jp
Business hours: Monday to Friday (excluding public holidays, year-end and New Year holidays)

6. Other

■ Change to this Policy

We may change the content of this Policy in whole or in part. We will post the important changes of this Policy on our website.

Revised on August 1, 2022