privacypolicy(en)

In view of the importance of appropriate privacy protection when promoting its business activities, DataLabs, Inc. (“the Company”) complies with the Act on the Protection of Personal Information (“Personal Information Protection Law”) and other related laws and regulations when pursuing its business activities, and the Company and its officers and employees adhere to this Privacy Policy in order to ensure appropriate protection of personal information. In this Privacy Policy, “personal information,” “personal data” and “retained personal data” are defined as per the Personal Information Protection Law.

Handling of Personal Information at the Company

The Company will specify as exactly as possible the purpose of use for personal information and will acquire it by lawful and fair means. Additionally, the use of personal information will be kept within the scope necessary to achieve the specified purpose of use.

(1) Acquisition of Personal Information

Except in certain cases such as when there is a risk of harming the rights and interests of the person in question or a third party, when acquiring personal information, the purpose of use will be specified as exactly as possible and acquired by lawful and fair means. The Company mainly acquires personal information under the following circumstances.

When the information is entered by the customer himself/herself in connection with use of the Company’s services
When the Company collects the information about the customer in connection with use of the Company’s services
When the information is provided directly from the customer or through a written or other medium
When the information is acquired through legal means other than those specified above, such as when the information is provided from a third party with the customer’s consent

(2) Purpose of Use of Personal Information

The use of personal information will be kept within the scope necessary to achieve the following purposes.

(i) Personal information relating to the customer’s administrator or representative

To provide the Company's services and fulfill its contractual rights and obligations
To identify, verify, confirm, etc., customers
To provide after-sales service and support
To perform customer management
To monitor and investigate misuse of the Company's services and any activity which deviates from the Terms of Service or other agreements, as well as to perform reporting and make contact about the same
To ensure the security and quality of the Company’s services
To investigate, report or make contact in the event that a malfunction or accident occurs in connection with the Company’s services
To provide crucial notifications about the operation of the Company’s services, such as maintenance information and other important communications like changes to the Terms of Service
To conduct research or develop statistics and analysis of the usage of the Company’s services
To provide functions and features aimed at improving customer convenience
To facilitate the development of new services and functions and the performance of marketing and other related tasks
To provide information about the Company’s services and other related matters, or to provide customers with notifications and recommendations that the Company considers useful
To make requests of customers regarding interviews, surveys, campaigns, monitoring, etc.
To respond to comments and inquiries regarding the Company or its services
To identify users who have violated the Terms of Service or who are attempting to use the Company’s services for fraudulent or improper purposes, and to refuse such use

(ii) Personal information relating to those who have made inquiries about the Company’s services, such as requests for information, trials, etc.

To respond to inquiries
To provide information about the Company’s services and other related matters, or to provide customers with notifications and recommendations that the Company considers useful
To make requests of customers regarding interviews, surveys, campaigns, monitoring, etc.
To conduct research or develop statistics and analysis of the usage of the Company’s services
To analyze data necessary to improve the Company’s services or media operations
To analyze data in order to understand customer needs
To provide functions and features aimed at improving customer convenience
To facilitate the development of new services and functions and the performance of marketing and other related tasks
To provide information about the Company’s services and other related matters, or to provide customers with notifications and recommendations that the Company considers useful
To improve the quality of the Company’s responses and to more accurately understand the content of inquiries and other received communications
To identify users who have violated the Terms of Service or who are attempting to use the Company’s services for fraudulent or improper purposes, and to refuse such use

(iii) Personal information relating to participants in events, seminars (including those who view videos of events and seminars; the same applies hereafter) or communities hosted by the Company

To manage and run (including providing participant information to co-hosting and supporting companies) events, seminars or communities hosted by the Company
To provide information about the Company’s, and its partner companies’, services, products, events, seminars, communities, etc.
To send or manage surveys, pay rewards, or send goods
To analyze data necessary for the improvement of events, seminars, Company-hosted communities or the Company's services, or for the development of new services
To analyze data in order to understand customer needs and develop new service improvements and functions based on those needs
To identify users who have violated the Terms of Service or who are attempting to use the Company’s services for fraudulent or improper purposes, and to refuse such use

(iv) Personal information relating to the Company’s business partners

To select business partners, associates, etc.; to enter into contract procedures; and to manage and carry out related business with said business partners, associates, etc.
To provide information about the Company’s services and other related matters, or to provide notifications that the Company believes the recipient will find useful

(v) Personal information relating to visitors to the Company

To contact Company staff and manage facility access

(vi) Personal information relating to individuals who apply for, and participate in, Company recruitment activities (“Applicants”)

To determine, when screening documents and conducting interviews, whether Applicants match the personality, skills, experience, etc., that the Company is looking for
To check Applicants’ history of past application to the Company
To contact Applicants, such as to arrange interview dates
To create statistical data necessary for formulating the Company’s future recruitment policy
To provide Applicants with information about employment opportunities, events, etc. at the Company

(vii) Personal information relating to current and former employees of the Company

To perform business-related communications, create employee rosters, complete legally required procedures (including for after an employee leaves the Company), and to facilitate other labor management
To determine personnel selection, assignment, transfer, and dispatch destinations
To determine and pay remuneration, process taxes, carry out social insurance-related procedures, and provide employee benefits
To promote the Company in its PR or advertising materials, activities, etc.

(viii) Personal information relating to shareholders

To exercise rights and fulfill obligations under the Companies Act
To send business reports and other materials to shareholders
To provide notifications and instruction to, exchange information and conduct surveys with, etc., shareholders
To perform shareholder management in accordance with all relevant laws and regulations

(3) Provision of Personal Information

(i) Provision to third parties

The Company will not provide personal information to third parties without the consent of the person in question, except in the following cases.

When required by law
When necessary for the protection of a person’s life, body or property, and it is determined that it is difficult to obtain the consent of the individual to whom the personal information applies
When specifically necessary for the improvement of public health or the promotion of healthy child development, and it is determined that it is difficult to obtain the consent of the individual to whom the personal information applies
When necessary to cooperate with a national government agency, local government, or a person commissioned by such competent authorities in carrying out duties prescribed by law, and it is determined that obtaining the consent of the individual to whom the personal information applies may impede the performance of said duties

(ii) Supervision of contractors

When the Company contracts out (including, from the customer’s perspective, subcontracting; the same applies hereafter) all or part of the handling of personal information, the Company will provide necessary and appropriate supervision of the entrusted party to ensure the safe management of the entrusted personal information.

(4) Disclaimer Regarding the Acquisition of Information by Third Parties

In the following cases, the Company shall not bear any responsibility regarding the acquisition of personal information by a third party.

When an individual discloses personal information to a third party using the functions or features of the Company’s services
When an individual’s identification information (email address, password, etc.) required to log in to the Company’s services is obtained by someone else by some means
When the acquisition is not the result of intentional action or negligence on the part of the Company

(5) Use of Cookies and Other Technologies, and Acquisition of Usage Status, Attribute Information and Other Data

The Company may use cookies (including similar technologies, hereafter, “Cookies”) and collect information, such as the user's IP address, access count, browser and OS used, and other information about his or her device, for such purposes as increasing convenience for customers, improving the Company’s services, obtaining statistical data, providing appropriate advertisements, and preventing fraudulent activities that interfere with the normal provision of services.

In order to deliver the most appropriate advertisements to customers, the Company uses Cookies and other technologies which enable utilization of the behavioral targeting advertising services of the third-party companies listed below (including those located overseas). Those wishing to disable these services should follow the procedures provided on the third-party companies’ websites below.

Google LLC

https://tools.google.com/dlpage/gaoptout?hl=en

Yahoo! JAPAN Marketing Solutions(LY Corporation)

https://global-marketing.yahoo-net.jp/products/guidelines

Meta Platforms, Inc.

https://www.facebook.com/policies/cookies/

Apple Inc.

https://www.apple.com/legal/privacy/en-ww/

Microsoft Corporation

https://www.microsoft.com/en-us/privacy/privacystatement

LY Corporation

https://www.lycorp.co.jp/en/company/privacypolicy/

X Corp.

https://x.com/en/privacy

GMO NIKKO Inc.

https://www.gmo-am.jp/privacy/

SmartNews, Inc.

https://www.smartnews.com/privacy/

In addition, cookie information and other such information obtained by these third parties will be handled in accordance with said parties’ privacy policies. In addition, those who do not wish for information about themselves to be collected can refuse to accept Cookies by changing the settings on their Internet browsing software (browser). Instructions on how to adjust browser settings can be found under the “Help” menu or equivalent location of the browser. However, users should note that refusal to accept Cookies may restrict their ability to utilize various online services, such as being unable to receive services that require authentication.

Requests for Disclosure or Modification of Personal Information and Inquiries and Complaints about Personal Information

The Company will appropriately accommodate requests for disclosure or modification of personal information, as well as handle inquiries and complaints regarding personal information.

(1) Disclosure or Modification of Personal Information

Pursuant to the provisions of the Personal Information Protection Law, customers may request notification of the purpose of use of their personal information, disclosure, correction, addition or deletion of the content, or suspension of use, erasure, or suspension of provision to a third party of their personal information (hereafter, collectively, “Disclosure or Modification”). If a customer requests such Disclosure or Modification, the Company will confirm that the request is made by the customer himself/herself, promptly conduct an investigation within reasonable limits, and then make the Disclosure or Modification based on the results of that investigation.

However, if the relevant personal information does not exist, or if the Company decides not to disclose it for a legitimate reason, the requesting customer will be notified to that effect. In addition, this does not apply when the Company is not obligated to do so under the Personal Information Protection Law or other laws and regulations, when the same request is made repeatedly without a legitimate reason, or when accommodating the request requires excessive technical work be performed.

Please note that the disclosure of personal information and notification of the purpose of use will incur a fee set by the Company (1,000 yen per request, excluding tax). Specific details about the procedures, processes, etc., involved in requesting Disclosure or Modification can be obtained from the Inquiry Desk which is contactable via the details given under “Inquiry Desk” below. Any personal information acquired by the Company in response to a request for Disclosure or Modification will be handled appropriately and only to the extent necessary for the request.

(2) Inquiries and Complaints about Personal Information

Inquiries and complaints about personal information can be submitted to the Inquiry Desk which is contactable via the details given under “Inquiry Desk” below.

(3) Inquiry Desk

To contact via mail

Customer Information Support Desk, DataLabs, Inc.

H¹O Nihonbashi Kobunacho, 8-6 Nihonbashi Kobunacho, Chuo-ku, Tokyo 103-0024

To contact via the Inquiry Form

Inquiry Desk on the Company’s official website

URL: https://datalabs.jp/en/contact/

Appropriate Management of Personal Information

The Company implements the following safety management measures for personal information and strives to prevent and correct unauthorized access to, or leakage, loss, or damage of, personal information.

Safety management measures

The Company implements strict technical and organizational security measures to prevent unauthorized access to, or leakage, loss, or damage of, personal data, and to otherwise safely manage personal data.

In addition, in order to ensure continuous, improved protection of personal data, the Company reviews and makes improvements to its internal regulations, guidelines, etc., in accordance with changing laws, regulations, and social norms.

Furthermore, personal data is retained only for the period necessary to achieve the purpose of use.

Personal information manager

The Company will appoint a personal information manager to establish a personal information protection management system and will give him or her the responsibility and authority to implement and operate said system.

Compliance with Personal Information-related Laws and Regulations

When handling personal information, the Company complies with all personal information-related laws, regulations, national guidelines and other standards.

Ongoing Improvement

The Company performs ongoing reviews and improvements to its personal information protection management system.

In an effort to make ongoing improvements, the Company conducts appropriate reviews of the status of operations regarding the handling of customer information and may change this Privacy Policy from time to time as necessary.
Any changes to this Privacy Policy will be announced via the Company’s services, via websites operated by the Company, or via some other easy-to-understand manner. However, when making changes that require the customer's consent by law, this consent will be obtained in a manner separately specified by the Company.

Revised September 17, 2025

Daisuke Tajiri, CEO

DataLabs, Inc.