Symphonic Brain (hereinafter referred to as the “Company”) hereby establishes the following Privacy Policy (hereinafter referred to as the “Policy”) regarding the handling of personal information on this website and in the various services provided by the Company (hereinafter referred to as the “Company Services”).
Article 1 (Personal Information)
“Personal Information” as used in this Policy means personal information as defined in the Act on the Protection of Personal Information of Japan, and refers to information relating to a living individual that can identify a specific individual by name, date of birth, address, telephone number, contact information, or other descriptions contained in such information, and also includes data relating to appearance, fingerprints, voiceprints, and information that can identify a specific individual by itself, such as the insurer number of a health insurance card (personal identification information).
Article 2 (Information to Be Acquired and Methods of Acquisition)
The Company acquires personal information such as name, date of birth, address, telephone number, affiliation (including company name, school name, department name, grade/class, etc.), position, and email address when a user registers to use the Company Services or makes an inquiry to the Company, through input or submission by the user, registration by an administrator of the user’s affiliated organization, or automatic recording through use of the services.
The Company also acquires posted content, usage history, access logs, and operation history recorded in the system through use of the services.
In connection with recruitment activities, the Company acquires personal information contained in applicants’ résumés and curriculum vitae.
Article 3 (Purposes of Use)
The Company uses the acquired personal information for the following purposes:
- Provision and operation of the Company Services
- Support of learning activities and improvement of the educational environment
- Improvement of service quality and functionality
- Response to business discussions, meetings, inquiries, and consultations
- Performance of contracts and billing of fees
- Shipment of products, materials, and other items.
- Statistical analysis and research (limited to anonymized information)
- Necessary communications such as support, maintenance, updates, and campaign notifications
- Response to violations of usage rules
- Provision of and communication regarding recruitment information to applicants (including interns)
- Recruitment management operations of the Company
- Other purposes incidental to the foregoing
Article 4 (Personal Information of Minors)
Where a student (a minor) uses the Company Services, such use shall be subject to the consent of a parent or guardian or an affiliated institution.
Where registration is made through such institution pursuant to the preceding paragraph, the consent shall be deemed to have been lawfully obtained by the institution.
Article 5 (Changes to Purposes of Use)
The Company may change the purposes of use of personal information only to the extent reasonably recognized as having relevance to the purposes before such change.
If the purposes of use are changed, the Company shall notify users of the changed purposes by the method prescribed by the Company or publicly announce them on this website.
Article 6 (Provision to Third Parties)
Except in the following cases, the Company shall not provide personal information to any third party without obtaining the prior consent of the user; provided, however, that this shall not apply where such provision is permitted under the Act on the Protection of Personal Information or other applicable laws and regulations:
- When it is necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of the individual
- When it is particularly necessary for improving public health or promoting the sound development of children and it is difficult to obtain the consent of the individual
- When it is necessary to cooperate with a national agency, a local public entity, or a person entrusted thereby in executing affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of such affairs
- When the following matters have been announced or made public in advance and the Company has notified the Personal Information Protection Commission:
- inclusion of provision to third parties in the purposes of use
- items of data to be provided to third parties
- means or methods of provision
- suspension of provision upon request of the individual
- method for accepting such requests
Notwithstanding the preceding paragraph, the recipient of the relevant information shall not be deemed a third party in the following cases:
- When personal information is jointly used with specific persons and the relevant matters have been notified in advance or made readily accessible to the individual
- When the Company entrusts all or part of the handling of personal information to its affiliates or agents within the scope necessary to achieve the purposes of use
- When personal information is provided in connection with business succession due to merger, company split, business transfer, or other reasons
Article 7 (Entrustment and External Services)
The Company may use cloud services for the provision of services. In such cases, the Company may have such service providers handle personal information to the extent necessary.
Article 8 (Use of Data and Research Use)
The Company may use user data for the purpose of improving the services and for educational research.
The data referred to in the preceding paragraph shall be used only after being processed into a form that does not identify any individual.
Research results may be published as statistical information.
Article 9 (Security Management)
The Company shall take appropriate security control measures to prevent leakage, loss, or damage of personal information.
Article 10 (Disclosure, Correction, Deletion)
When the Company is requested by an individual to disclose their personal information, the Company shall disclose such information to the individual without delay. However, if disclosure falls under any of the following cases, the Company may decide not to disclose all or part of such information and shall notify the individual without delay. A handling fee of JPY 1,000 per request shall be charged for disclosure of personal information.
- Where disclosure is likely to harm the life, body, property, or other rights or interests of the individual or a third party
- Where disclosure is likely to cause significant hindrance to the proper execution of the Company’s business
- Where disclosure would otherwise violate laws or regulations
Notwithstanding the preceding paragraph, in principle, the Company shall not disclose information other than personal information, such as history information and characteristic information.
Where a user’s personal information held by the Company is incorrect, the user may request the Company to correct, add, or delete such personal information (hereinafter referred to as “Correction, etc.”) in accordance with the procedures prescribed by the Company.
Where the Company determines that it is necessary to comply with a request from a user under the preceding paragraph, the Company shall make the relevant Correction, etc. to such personal information without delay. Where the Company has made a Correction, etc. pursuant to the preceding paragraph, or has decided not to make such Correction, etc., it shall notify the user thereof without delay.
Article 11 (Suspension of Use)
If the Company is requested by an individual to suspend use of or erase their personal information (hereinafter referred to as “Suspension of Use, etc.”) on the grounds that such personal information is being handled beyond the scope of the purposes of use or was obtained by improper means, the Company shall conduct the necessary investigation without delay.
Based on the results of the investigation set forth in the preceding paragraph, if the Company determines that it is necessary to comply with such request, it shall suspend use of or erase the relevant personal information without delay.
Where the Company has carried out Suspension of Use, etc. pursuant to the preceding paragraph, or has decided not to carry out Suspension of Use, etc., it shall notify the user thereof without delay.
Notwithstanding the preceding two paragraphs, if Suspension of Use, etc. would involve substantial cost or would otherwise be difficult to implement, and if alternative measures necessary to protect the rights and interests of the user can be taken, the Company shall take such alternative measures.
Article 12 (Access Information)
The Company may use access logs including IP address information for service improvement.
Cookies are used, but do not identify individuals and may be disabled via browser settings.
Article 13 (Changes to the Policy)
The Company may change this Policy without notice unless otherwise required by law.
Article 14 (Contact)
Inquiries regarding this Policy as well as requests for disclosure, correction, or deletion of customers’ personal information should be made via the contact form.