Handling of Personal Information

This “Handling of Personal Information” (hereinafter referred to as these “Rules”) apply to the Service (please see Article 2 for the definition) which Leverages Co., Ltd. and each of Leverages group companies (hereinafter referred to as the “Company”) provides. If a customer has any question, opinion or advice, please contact the contact information set forth in the “Country-by-Country Table” by phone or e-mail according to the Company’s corporation which provides the Service

The Company is committed to making the safety protection of customers’ personal information reliable. Please read these Rules and consent hereto before using the Service.

1. Definition of Personal Information

Personal Information refers to information recorded by electronic or other forms, which can identify the specific individual by name, address, phone number, e-mail address, place of employment, date of birth, sex, birthplace, educational background, skills, qualification, occupational history, nationality, ID number, marital status, health condition, genetic information, biological information or financial information, or various identifiable information about a natural person, and does not include anonymized information. Such information as will allow easy reference to other information and will thereby enable the identification of the specific individual is also included in Personal Information.

2. Handling and Purpose of Personal Information

The Company may handle Personal Information (name, sex, address, phone number, e-mail address, date of birth, experience and background, etc.) in providing the following services (“hereinafter referred to as the “Service”).

• 1. Use of the Company’s service site
  1. a. Registration to the Company’s service site
  2. b. Sending of information and materials of service site offered by the Company
  3. c. Request for cooperation in marketing and reporting of marketing result, announcement of campaign, application for monitoring, etc. or dispatching gift, etc.
  4. d. Utilization as statistical data in the form that cannot identify Personal Information
  5. e. Provision of Personal Information to a company using the Company service (hereinafter referred to as the “User Company”) based on a principal’s consent
  6. f. Any other businesses in connection with or incidental to the foregoing businesses
• 2. Application for case suggestion service
  1. a. Provision of case suggestion service by the Company
  2. b. Provision of Personal Information (skill sheet information, etc.) to the User Company based on a principal’s consent
  3. c. Sending of information and materials of services offered by the Company
  4. d. Request for cooperation in marketing and reporting of marketing result, announcement of campaign, application for monitoring, etc. or dispatching gift, etc.
  5. e. Utilization as statistical data in the form that cannot identify Personal Information
  6. f. Recruiting of persons to be interviewed for creation of the article content
  7. g. Any other businesses in connection with or incidental to the foregoing businesses
• 3. Inquiry
  1. a. Contacting about each inquiry
  2. b. Utilization as statistical data in the form that cannot identify Personal Information

3. Outcome when Personal Information is not provided

If a customer declines to enter necessary items, he/she may not receive the Service in some cases.

4. Third Party Provision of Personal Information

The Company will not, in principle, provide Personal Information it has acquired to a third party without obtaining the principal’s consent. The Company will provide the information only when it has obtained separate consent of the principal in advance after identifying the provision destination and the content to be provided. If a member applied (entry) for the User Company in the Service or the User Company of a site partnering with the Service, the member shall be deemed to have agreed to provide his/her Personal Information to a third party. Items of Personal Information to be provided, means of provision, type of the User Company that will receive information and the status of execution of a contract concerning the handling of Personal Information with the User Company are as follows.

• a. The items of Personal Information to be provided by the Company to the User Company are name, sex, address, phone number, e-mail address, date of birth, experience and background, etc.
• b. Information to be provided in writing, by oral communication using phone, facsimile, delivery of electromagnetic recording medium or by electromagnetic communication means such as e-mail.
• c. The Company has entered into a contract concerning the handling of Personal Information with the User Company.

The Company may provide Personal Information without a principal’s consent in the following cases.

• a. When related to the performance of obligations stipulated by laws and regulations
• b. When directly related to national security and national defense
• c. When directly related to public safety, public health, and important public interest
• d. When directly related to criminal investigation, prosecution, judgment and execution
• e. When protecting important rights and interests such as a life or assets of the subject of Personal Information or other individuals, and when it is difficult to obtain a principal’s consent
• f. When the related Personal Information is released to the public by the subject of Personal Information
• g. When it is needed for execution and performance of a contract upon request of the subject of Personal Information
• h. When Personal Information is collected from information that was lawfully published (e.g.: routes such as lawful news coverage and release of government information)
• i. When it is needed for maintaining safe operation of products or the Service provided (e.g.: discovery and processing of a deficiency in products or the Service)

5. Outsourcing of Personal Information

The Company may occasionally outsources the handling of Personal Information, wholly or in part, within the scope necessary for the achievement of purpose of utilization. When outsourcing the handling of Personal Information, the Company will select an appropriate contractor and exercise the proper supervision so that Personal Information will be safely managed.

6. Joint use of Personal Information with group companies, etc.

The Company jointly uses Personal Information it has acquired with its group companies and business partner set forth below.

• (1) Leverages Co., Ltd.
  Address: Shibuya Scramble Square 24F, 25F, 2-24-12 Shibuya, Shibuya-ku, Tokyo
  e-mail: privacy@leverages.jp
  Phone: +81(0)357741632
• (2) Levtech Co., Ltd.
  Address: Shibuya Scramble Square 24F, 25F, 2-24-12 Shibuya, Shibuya-ku, Tokyo
  e-mail: privacy_ltc@levtech.jp
  Phone: +81(0)357741762
• (3) Leverages Office Support Co., Ltd.
  Address: Shibuya Scramble Square 24F, 25F, 2-24-12 Shibuya, Shibuya-ku, Tokyo
  e-mail: privacy@leverages.jp
  Phone: +81(0)357741742
• (4) Leverages Career Mexico, S.A de C.V.
  Address: Priv. De los Industriales No.111 Local 601 Col. Jurica, Querétaro, Querétaro C.P. 76100, Mexico
  e-mail: info@lc-mexico.com
  Phone: +524429015376
• (5) Leverages Career Vietnam Co., Ltd.
  Address: 2nd floor, 101 Lang Ha Building, Lang Ha Ward, Dong Da District, Hanoi City, Vietnam
  e-mail: vn-privacy@leverages.com
  Phone: +84 (0)2473033678
• (6) Leverages Career China Co., Ltd.
  Address: Building T2 5F, Rm. R-56, Tianshan Road, Changning District, Shanghai, China
  e-mail: cn-privacy@leverages.com
  Phone: +81(0)357741742
• (7) Leverages Career India Pvt., Ltd.
  Address: A-5, Saket Cultural Centre, Saket District Centre, Next to Select City Walk Mall, New Delhi - 110017, India
  e-mail: info-in@in.leveragescareer.com
  Phone: +81(0)357741742
• (8) Asia Human Resources Support Cooperative Association
  Address: Benten-Matsui Building 4F, 1-2-4 Benten, Chuo-ku, Chiba-shi, Chiba
  Phone: +81(0)43-305-4722

The items of Personal Information to be jointly used are name, sex, address, phone number, e-mail address, date of birth, experience and background, etc. Joint users will use Personal Information within the scope set forth in Paragraph 2. Personal Information will be acquired in writing or by electromagnetic communication means such as e-mail. Personal Information is possible to be transferred to the jurisdictional district other than the country/region where a customer uses the Service, or to be accessed from such jurisdictional district. The Company complies with the requirements stipulated in the relevant laws and regulations pertaining to cross-border provision of Personal Information, and properly protect it. The person responsible for managing Personal Information to be jointly used is Leverages Co., Ltd.

7. Request procedures for Personal Information inquiry, etc.

(1) Request procedures

If the Company receives from a principal or his/her agent regarding Personal Information held by the Company, an inquiry or requests for modification, deletion, withdrawal of the consent, deletion of the user account, or demand for acquisition of a copy of Personal Information (hereinafter referred to as “Requests including Inquiry”), the Company will promptly respond thereto pursuant to its prescribed procedures; provided, however, that if response to Requests including Inquiry results in falling under any of the following, the Company may not be able to respond to Requests including Inquiry after explaining a principal or his/her agent to that effect and reasons therefor.

• a. When directly related to national security and national defense
• b. When directly related to public safety, public health, and important public interest
• c. When directly related to criminal investigation, prosecution, judgment and execution
• d. When it is sufficiently clarified by evidence that the subject of Personal Information has subjective knowledge or there is an abuse of rights
• e. When responding to a request of the subject of Personal Information will cause serious damage to lawful rights and interests of the subject of Personal Information, other individuals or organizations
• f. When it extends to trade secrets

When Personal Information is deleted or its utilization is suspended or otherwise, the Service etc. being currently used may become unavailable. In addition, as for Personal Information that is no longer needed upon termination, etc. of provision of the Service, the Company will dispose of it in accordance with the Company’s regulations.

(2) Certificate, etc. required at the time of request procedures

(1) In case of a principal

If a principal makes Requests including Inquiry, he/she is requested to submit a copy of one of the identity verification documents set forth below. In principle, the document of a. below needs to be provided, and documents of b. or c. may need to be provided as necessary.

• a. Identification certificate
• b. Valid pass certification
• c. Passport

In case of an agent

If an agent makes Requests including Inquiry, he/she is requested to submit the following documents (copies) in addition to the documents in (i) above.

A. Statutory agent

• a. Document to confirm that the agent has power of legal representation (copy of family register, etc.)
• b. Document to confirm that he/she is the statutory agent (copy of identification certificate, etc.)

B. Privately appointed agent

• 1. Power of attorney
• 2. Document to confirm that he/she is the agent (copy of identification certificate, etc.)

Personal Information provided upon Requests including Inquiry will be used within the scope necessary for Requests including Inquiry procedures. The Company will discard the submitted identity verification documents or agent verification documents by proper means immediately after the confirmation has been completed. In addition, if a certain period has elapsed since completion of the procedures, the Company will also discard a request form for relevant Requests including Inquiry by proper means.

(3) Person to whom Requests including Inquiry should be made

Please contact the contact information set forth in the “Country-by-Country Table” according to the Company’s corporation providing the Service and inform that you will make Requests including Inquiry. Then, fill in the necessary matters on the specified form (request form for Requests including Inquiry) sent by the Company and return it together with the identify verification documents shown in (2) above. Of the said requests, no fee, etc. is charged for a notice of purpose of utilization and disclosure of Personal Information.

In response to Requests including Inquiry, the Company will mail a document to the address specified within fourteen (14) days after receipt of a Disclosure Request Form with necessary matters filled in and identify verification documents.

*For Saturday, Sunday, holiday, year-end and new year or other Company’s non-business days, it will be handled on or after the following business day.

8. Acquisition of Personal Information by the methods that cannot easily recognize a principal

On the Site, technologies such as cookie and web beacon is used sometimes for the purpose of improvement of service, acquisition of statistical information or distribution of adverting, however, using such technologies will not lead to an acquisition of Personal Information that has not been entered by a principal.

1. Cookie

(1) What is cookie?

• Cookie is a mechanism to store, when using website, the usage history or entry content, etc. transmitted/received between a browser and a server on a computer as a file. When accessing the same page next time, the website operator can change display by the user using cookie information. When transmission/receipt of cookie is permitted by the browser setting, the website can acquire cookie from the user’s browser. To protect privacy, the user’s browser transmits only cookies transmitted/received to/from a server of the website used.

(2) Setting of cookie

• A user can choose the setting for transmission/receipt of cookie from among “accept all cookies,” “block all cookies” or “notify when receiving cookie,” etc. Since the setting method varies depending on a browser, please check “Help” menu of the browser you are using.
• Please note that when choosing setting to block all cookies, use of various services by a user on Internet may be restricted in some way, such as being unable to receive services that require authentication.

(3) What the Company/Group Company conducts using cookie

The Company uses cookie for the following purposes.

• a. To be able to offer services customized by the user when a user logs in the authentication service in reference to the stored user registration information
• b. To display an optimal advertising on another company’s site based on the content that a user is interested in or usage status on the Site
• c. To research the number of users or traffics of the Site
• d. To improve the Service
• e. For maintenance of security, to promote users to whom a certain time has elapsed since their use to reenter (reauthenticate) password

The Company may store cookie information, including the browsing history of the Site, and refer to it. Furthermore, part of information acquired with use of cookie will be provided to the partnering companies as statistical information in some cases.

(2) Web beacon

Some pages on the Site use web beacon to acquire statistical information concerning the usage status of the Service or to improve services. No information that can identify an individual is included in information acquired with use of web beacon.

(3) Individual identification number of mobile terminal

An individual identification number of mobile terminal is a number to be transmitted to a user’s mobile terminal in order to distinguish the mobile terminal when accessing to the Site by mobile terminal, which is used for access control and so forth. Information relating to users’ privacy such as mobile phone number or e-mail address, name and the like of the user are not included in an individual identification number. Furthermore, it is not possible to identify the user individual only with an individual identification number.

9. Child Personal Information

The Site and the Service, etc. are targeted mainly at adults. In the absence of the consent of parents or guardians, children are prohibited from creating the user account of a subject of Personal Information by themselves. If Personal Information of a child is collected with the consent of parents, only when the consent of parents or a guardian is obtained definitely, or when the child needs to be protected, the Company will use or release such information to the extent permitted by law.

Even when definition of a child based on the local law and that under the custom is inconsistent, the Company regards all of those who are under age defined or interpreted as a “child” pursuant to laws and regulations of the country in which the Company’s corporation providing the Service is located as children. If the Company finds any child Personal Information that was collected under the circumstances in which it is not possible to demonstrate that the parents’ or guardian’s prior consent has been obtained, the Company will immediately delete the related data.

10. Updating

It is possible to amend these Rules. If the amended content would substantially reduce customers’ rights under these Rules, the Company will publish content of the amendment on the Page or notify customers by means of contacting by e-mail before the amendment becomes effective. In such a case, if a customer continues to use the Service, he/she shall be deemed to have agreed to the amended Rules.

11. Governing Law and Jurisdiction

These Rules shall be governed by the laws of Japan; provided, however, that if the Company providing services is a corporation outside Japan, it shall be subject to provisions set forth in the “Country-by-Country Table”. The Company complies with the Personal Information protection law and related laws and regulations in the country in which it provides the Service.

The parties hereto consent to the exclusive jurisdiction of the Tokyo District Court or the Tokyo Summary Court in the first instance for the settlement of any and all disputes arising out of or in connection with these Rules; provided, however, that if the Company providing services is a corporation outside Japan, it shall be subject to provisions set forth in the “Country-by-Country Table”.