Personal Information Protection Policy

Article 1 (Personal Information)

“Personal information” refers to information about a living individual which can identify a specific individual by name, date of birth, or other descriptions contained in the information (including such information as will allow easy reference to other information and will thereby enable the identification of the individual).

Article 2 (Collection and Use of Personal Information)

1. We will acquire personal information necessary for business purposes and use them for the following purposes. When collecting personal information, we will primarily obtain it with the individual’s consent.
   1. For sending direct mail, emails, and newsletters
   2. For delivering materials requested by the individual
   3. For responding to opinions and requests submitted by the individual
   4. For confirming the use of various services requested by the individual
   5. For providing various services requested by the individual
   6. For accurately informing the individual about special services, new products, etc.
   7. For creating statistical data to understand customer characteristics
   8. For identifying applicants and notifying winners in surveys, etc.
   9. For introducing services provided by the Achievement Group
   10. For the handling of personal data jointly used by companies belonging to the Achievement Group

Article 3 (Management and Protection of Personal Information)

We will strictly manage personal information and will not disclose or provide data to third parties except in the following cases. We also take measures to prevent unauthorized access to personal information, as well as the loss, destruction, alteration, or leakage of personal information, considering security.

1. When there is a risk of harming the life, body, property, or other rights and interests of the individual or a third party
2. When there is a risk of significantly hindering the proper execution of our business
3. When required by law or regulations
4. When entrusting all or part of the handling of personal information within the scope necessary for the achievement of the intended purpose of use
5. When disclosing or providing personal information due to the succession of business by mergers or other reasons

Article 4 (Outsourcing of Personal Information Handling)

We may outsource all or part of the handling of personal information within the scope necessary for the achievement of the intended purpose of use. In such cases, we will carefully review the eligibility of the outsourced company as a subcontractor, establish confidentiality agreements when concluding contracts, and provide necessary and appropriate supervision to the subcontractor.

Article 5 (Joint Use of Personal Information)

We jointly use the personal information of users with the following content based on Article 23, Paragraph 5, Item 3 of the Personal Information Protection Law. The handling of jointly used information will be revised and made public as needed.

1. Scope of parties jointly using personal information
   • Achievement HR Solutions Co., Ltd.
   • Achievement Publishing Co., Ltd.
2. Purpose of joint use by parties
   • For sending direct mail, emails, and newsletters
   • For delivering materials requested by the individual
   • For responding to opinions and requests submitted by the individual
   • For confirming the use of various services requested by the individual
   • For providing various services requested by the individual
   • For accurately informing the individual about special services, new products, etc.
   • For creating statistical data to understand customer characteristics
   • For identifying applicants and notifying winners in surveys, etc.
   • For introducing services provided by the Achievement Group
3. Categories of jointly used personal information
   • Name
   • Address
   • Phone number
   • Email address
   • Service usage history
4. Manager responsible for personal information management
   Achievement Corporation

Article 7 (Disclosure, Correction, Deletion, and Suspension of Use of Personal Information)

1. If a user requests the disclosure of personal information, we will promptly disclose it to the user. However, if disclosure falls under any of the following cases, we may partially or completely decline disclosure and will notify the user promptly.
   1. When there is a risk of harming the life, body, property, or other rights and interests of the individual or a third party
   2. When there is a risk of significantly hindering the proper execution of our business
   3. When it violates other laws and regulations
2. If personal information held by us is found to be incorrect, we will correct or delete the information upon the user’s request following the procedures defined by us.
3. If a user requests such action, we will promptly perform the necessary investigation, notify the user of the results, and take corrective action based on the results.
4. If a user requests the suspension of use, deletion, or removal (hereinafter referred to as “suspension of use, etc.”) of personal information, claiming that the information is handled beyond the scope of the intended purpose or obtained through fraudulent means, we will promptly conduct the necessary investigation and notify the user of the results. In cases where suspension of use, etc. involves significant costs or it is difficult to carry out such measures, and it is necessary to take alternative measures to protect the rights and interests of the user, we will take such alternative measures.
5. To make such requests, please contact us at the email address below. After receiving the email, we will provide further guidance.

Mail: privacy@achievement.co.jp

Article 8 (Procedure for Changing the Privacy Policy)

We will review the contents of this Privacy Policy as necessary and strive for improvements. Except as otherwise provided in laws and regulations or this Privacy Policy, we reserve the right to change the contents of this Privacy Policy. After the change, the revised Privacy Policy will be notified to users and will take effect when announced on our website.

Article 9 (Compliance with Laws and Regulations)

We will comply with applicable Japanese laws and regulations regarding personal information we possess.

Article 10 (Response to Complaints and Consultations)

We will accept complaints and consultations from users regarding the handling of personal information and respond to them appropriately and promptly. We will also promptly and appropriately respond to requests from users for disclosure, correction, addition, deletion, refusal to use, or provision of personal information. In cases of joint use of personal information, we will respond based on our own procedures.

Article 11 (Contact)

For inquiries regarding the handling of personal information by our company, please contact us at the address below.
Achievement Corporation
Mail:privacy@achievement.co.jp

Enacted and enforced on April 1, 2022