Privacy Policy

(i)Personal Information Collected Directly by SmartHR

a.Personal information (e.g. name, affiliation, contact information) relating to the administrator or manager of a customer

• for the purpose of executing contractual procedures, customer management, and related operations;
• for the purpose of providing customer support;
• for the purpose of providing information on SmartHR Group’s services and other information it considers useful to its customers;
• for the purpose of providing functions to improve the convenience of its customers (e.g. recommendations based on a customer’s status and activity and log data from within SmartHR’s services);
• for the purpose of analyzing information such as browsing histories and usage logs to provide functions and recommendations to improve the convenience of its customers based on how often and for what purpose they use SmartHR’s services;
• for the purpose of investigating, reporting to, or otherwise contacting customers when necessary to ensure the security of SmartHR’s services or in the event of an incident or accident;
• for the purpose of notifying customers of maintenance-related information, changes to SmartHR’s terms and conditions, and other important information necessary for the operation of its services;
• for use by SmartHR Group companies, including to develop new services and conduct marketing activities;
• for the purpose of analyzing information such as browsing histories and usage logs to develop new services and functions based on how often and for what purpose customers use SmartHR’s services;
• for the purpose of requesting participation in interviews, questionnaires, campaigns, monitoring sessions, and other activities; and
• for the purpose of responding to inquiries and feedback regarding SmartHR or its services.

b.Personal information (e.g. name, affiliation, contact information) relating to individuals who request explanatory materials and those making inquiries regarding the free trial for SmartHR or regarding other SmartHR services;

• for the purpose of responding to such inquiries;
• for the purpose of providing information on SmartHR Group’s services and other information it considers useful to its customers;
• for the purpose of sending out questionnaires;
• for the purpose of providing functions to improve the convenience of its customers (e.g. recommendations based on a customer’s log data)
• for the purpose of analyzing information such as browsing histories and usage logs to provide functions and recommendations to improve the convenience of its customers based on how often and for what purpose they use SmartHR’s services;
• for the purpose of examining or analyzing the data necessary to improve SmartHR services or media management;
• for the purpose of analyzing information such as browsing histories and usage logs to gain an understanding of customer needs according to how often and for what purpose they use SmartHR’s services; and
• for the purpose of improving the quality of SmartHR’s responses to and properly understanding the content of inquiries received.

c.Personal information (e.g. name, affiliation, contact information) relating to individuals participating in events, seminars, and communities hosted by SmartHR (including the viewing of such events, seminars, and community gatherings in video form)

• for the purpose of operating and managing events, seminars, and community gatherings hosted by SmartHR (including the provision of participant information to third-party co-hosts and sponsors);
• for the purpose of providing information on services, products, events, seminars, and community gatherings hosted by SmartHR Group or its partners;
• for the purpose of sending out or administering questionnaires, or sending payments or delivering goods to respondents thereto;
• for the purpose of examining or analyzing the data necessary to improve the events, seminars, and communities hosted by SmartHR, to improve its existing services, and to develop new services; and
• for the purpose of analyzing information such as browsing histories and usage logs to gain an understanding of customer needs according to how often and for what purpose they use SmartHR’s services and to analyze data for the purpose of improving new services and developing new features based on such analyses.

d.Personal information (e.g. name, affiliation, contact information) relating to SmartHR business partners

• for the purpose of selecting business partners, conducting contractual procedures, managing business partners, and performing related tasks;
• for the purpose of providing information on SmartHR’s services and other information it considers useful to its customers;

e.Personal information (e.g. name, affiliation, contact information) of visitors to SmartHR

• for the purpose of facilitating correspondence with SmartHR representatives and to control access within its offices

f.Personal information (e.g. name, affiliation, work history) of individuals (hereinafter referred to as “Candidates”) who participate in or apply to participate in SmartHR’s recruitment activities, including recruitment-related information sharing sessions and career fairs hosted by SmartHR Group without limitation to the recruitment selection process

• for the purpose of determining whether Candidates fit the criteria for attributes such as personality, skills, and experience as required by SmartHR Group in its recruitment selection process (e.g. document screening, interviews, reference checks);
• for the purpose of confirming the stated accomplishments of Candidates who have previously applied to SmartHR Group;
• for the purpose of contacting Candidates for reasons such as scheduling interviews;
• for the purpose of preparing statistical data necessary to formulate future recruitment policies at SmartHR Group; and
• for the purpose of providing Candidates with information about employment opportunities and recruitment-related events at SmartHR Group.

(ii)Personal Information Obtained by SmartHR Through Contracted Services

a.Personal information entrusted to SmartHR as part of providing services to customers, for the purpose of partially or fully managing the handling of such information

• for the purpose of using, within the scope permitted under applicable laws, either partially or fully, the personal information entrusted to SmartHR as part of providing services to customers, including to perform its duties or to execute or manage other contractually obligated matters that may arise.

(i)Provision of Personal Information to Third Parties

Upon obtaining consent from customers, SmartHR may provide personal data belonging to those customers to advertisement distributors (including those located outside Japan) as detailed below for the purpose of delivering more relevant advertising and to facilitate the delivery, measure the effectiveness, and analyze the performance of ads on its platform.

(ii)Joint Utilization of Personal Information

SmartHR may share personal data as defined below with its group affiliates within the scope of the purposes of utilization outlined below. The person responsible for managing this data shall be as stipulated in Section 8 “Personal Information Protection Supervisor" below.

(iii)Supervision of Outsourcing Partners

When partially or completely outsourcing (including instances perceivable as subcontracting from the customer’s perspective with the same interpretation applying hereafter) the handling of personal data to third party outsourcing partners, SmartHR shall exercise all necessary and appropriate supervision over such partners to ensure that any outsourced personal data is managed securely.