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Privacy Policy

Personal Information Protection Policy

SmartHR, Inc. (hereinafter referred to as "SmartHR") and its consolidated subsidiaries and equity-method affiliates (hereinafter collectively referred to as the "SmartHR Group") fully acknowledge the importance and social responsibility of taking appropriate measures to protect privacy, taking care to ensure compliance with the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "APPI") and all other relevant laws and regulations. SmartHR Group and its officers and employees shall adhere to the provisions stipulated herein during the course of their work. For the purposes of the Personal Information Protection Policy and the Privacy Policy below (hereinafter collectively referred to as this “Policy"), use of the terms "personal information", "personal data", and "retained personal data" shall conform to the definitions of such terms in the APPI.

1.Handling of Personal Information

SmartHR Group shall collect personal information in a fair and lawful manner and specify to the extent possible the purpose of its use. Any personal information collected shall only be used to the extent necessary to achieve that specified purpose.

2.Appropriate Management of Personal Information

SmartHR Group shall implement measures to ensure the security of personal information in its possession and shall endeavor to prevent and rectify any unauthorized access or damage to or the leak or loss of such information. For more details, see Section 1, Paragraph 3(1) (“Security Control Measures”) of the Privacy Policy below.

3.Inquiries and Complaints Regarding Personal Information

SmartHR Group shall respond appropriately to any inquiries and complaints arising in connection to the personal information in its possession. Contact details for submitting such inquiries and complaints can be found under Section 3, Paragraph 3 (“Contact Information”) of the Privacy Policy below.

4.Compliance with Laws and Regulations Regarding Personal Information

SmartHR Group shall comply with all laws and regulations, national guidelines, and other norms regarding the handling of personal information.

5.Continuous Improvements

SmartHR Group shall regularly conduct reviews of and make improvements to its personal information protection management system.

Privacy Policy

This Policy explains the following:

  • Section 1: Handling of Personal Information at SmartHR
    How SmartHR collects, uses, securely manages, provides, and deletes personal information.
  • Section 2: Rights of Individuals Regarding Retained Personal Data
    How individuals can manage their own personal information.

Section 1: Handling of Personal Information at SmartHR

1.Collection of Personal Information

SmartHR collects personal information in the following cases:

  1. (i)When SmartHR receives or collects personal information entrusted to it by customers in connection with the provision of all services offered by SmartHR (hereinafter referred to as “SmartHR Services”).
  2. (ii)When provided directly by the individual.
  3. (iii)When SmartHR lawfully obtains personal information from third parties, such as when it is provided by other business operators or collected from publicly available information.

In addition to the personal information collected in the cases above, SmartHR may collect identifiers, cookies, email addresses, usage history, and other information from business partners and other third parties for the purpose of combining such information with personal information held by SmartHR and using it within the scope of the purposes of use described in Paragraph 2, “Use of Personal Information”.

2.Use of Personal Information

(1)Personal information entrusted to SmartHR through the provision of SmartHR services

SmartHR uses personal information within the scope of the following purpose:

  1. (i)Performance of the entrusted services.

(2)Personal information collected directly by SmartHR

SmartHR uses personal information for the following purposes (including methods such as summarization and analysis using AI and other tools):

  1. a.Provision and maintenance of SmartHR Services.
  2. b.Development, improvement, and marketing of SmartHR Services.
  3. c.Security maintenance and prevention of unauthorized use.
  4. d.Recruitment activities of SmartHR.

Specific examples of the purposes of use and the personal information used are as follows:

(a)Provision and maintenance of SmartHR Services

(i)Specific examples of purposes of use:

  • Identity verification and contract management:
    Contract procedures, selection and management of business partners, management of billing information.
  • Customer support:
    Responding to inquiries and consultations, and analysis to improve response quality.
  • Provision of appropriate information:
    Notifications of important information regarding maintenance, terms and conditions changes, security, and other matters.
  • Improvement of convenience:
    Provision of functions to meet needs and recommendations (including based on analysis of browsing and usage history).

(ii)Specific examples of personal information used:

  • Name, affiliation, contact information, and other information of customers' administrators and managers.
  • Name, affiliation, contact information, and other information of our business partners' representatives.

(b)Development, improvement, and marketing of SmartHR Services

(i)Specific examples of purposes of use:

  • Service analysis:
    Improvement of existing services and understanding customer needs through analysis of browsing and usage history on SmartHR websites, survey results, and other information.
  • New service development:
    Planning and development of new services and functions by creating statistical data and conducting marketing analysis.
  • Marketing:
    Provision of information on products, services, events, seminars, and other offerings from the SmartHR Group and its partners, and conducting surveys.

(ii)Specific examples of personal information used:

  • Name, affiliation, contact information, and other information of individuals who have requested materials, trials, or made other inquiries regarding SmartHR Services.
  • Name, affiliation, contact information, and other information of participants in events, seminars, or communities hosted by SmartHR.
  • Browsing and usage history (including cookies and similar technologies) on SmartHR websites; information entered into various forms; survey responses; and other similar information.

(c)Security maintenance and prevention of unauthorized use

(i)Specific examples of purposes of use:

  • Ensuring safety:
    Prevention of unauthorized access; investigation, reporting, and contact in the event of an incident or accident.
  • Facility management:
    Managing entry to and exit from SmartHR offices and implementing crime prevention measures.
  • Detection of violations:
    Investigation and analysis of violations of terms of use, illegal acts, and other misconduct.

(ii)Specific examples of personal information used:

  • Access logs for SmartHR Services, device information, and other related information.
  • Name, affiliation, contact information, entry and exit records, and other information of visitors.

(d)Recruitment activities of SmartHR

(i)Specific examples of purposes of use:

  • Performance of recruitment activities:
    Identity verification of applicants, conducting selection processes, and contacting applicants regarding selection.
  • Consideration of recruitment initiatives:
    Formulation and improvement of recruitment policies for SmartHR Group's recruitment activities using past recruitment results and statistical information.
  • Provision of information on recruitment activities:
    Provision of information on employment opportunities, recruitment events, and other recruitment-related matters within SmartHR Group.

(ii)Specific examples of personal information used:

  • Information contained in documents submitted at the time of application, such as resumes, CVs, application forms, and other documents, including names, contact information, educational background, work history, qualifications, and other information.
  • Content of communication during the selection process, selection results, and other related information.
  • Names, contact information, career histories, and other information of individuals who have applied for or participated in recruitment-related information sessions, events, and other activities hosted or attended by SmartHR Group.

3.Management of Personal Information

(1)Security Control Measures

SmartHR implements rigorous technical and organizational security measures to prevent unauthorized access to personal data, or the leakage, loss, or damage of personal data, and to otherwise ensure the secure management of personal data.

To continually enhance the protection of personal data, SmartHR reviews and updates its internal rules and other regulations in response to changes in laws, regulations, and social norms.

SmartHR discloses its "Data Handling Principles" as an explanation of the specific security control measures it has implemented and other matters related to SmartHR’s handling of data.

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

(2)Personal Information Protection Supervisor

Personal information collected is managed under the responsibility of the following person:

Personal Information Protection Supervisor, SmartHR, Inc.

4.Provision of Personal Information

(1)Provision to Third Parties

To deliver more relevant advertising and to conduct advertisement distribution, effect measurement, and analysis, SmartHR may provide personal data (excluding personal data entrusted by customers) to advertisement distributors (including those located outside Japan) as detailed below, upon obtaining the individual’s consent.

  1. 1.Advertisement distributors that data is provided to (list is subject to change):
  2. 2.Personal data provided:
    Hashed email addresses and similar information (processed into a format that cannot be converted back into the original email address or other original information).

SmartHR will not provide any other personal data than listed above to third parties without the consent of the individual (including cases where the individual has entered personal data into SmartHR Services with public settings), unless permitted by applicable law.

(2)Joint Utilization

SmartHR may share the personal data listed below with its group companies within the scope of the purposes of use described in Section 1, Paragraph 2(2) (“Personal information collected directly by SmartHR”), Items (a), (b), and (d).

Regarding the purposes of use by joint users, "SmartHR" shall be read as “SmartHR's group companies", and "SmartHR Services" shall be read as "services provided by SmartHR's group companies".

The supervisor for managing jointly used personal data is as stipulated in Section 1, Paragraph 3(2) (“Personal Information Protection Supervisor").

  1. 1.Personal information regarding customers' administrators and managers

    Personal data categories: Name, affiliation, contact information, and other relevant information.

  2. 2.Personal information regarding individuals who have requested materials, trials, or made other inquiries regarding SmartHR Services

    Personal data categories: Name, affiliation, contact information, and other relevant information.

  3. 3.Personal information regarding participants in events, seminars, or communities hosted by SmartHR

    Personal data categories: Name, affiliation, contact information, and other relevant information.

  4. 4.Personal information regarding SmartHR’s business partners' representatives

    Personal data categories: Name, affiliation, contact information, and other relevant information.

  5. 5.Personal information regarding recruitment candidates

    Personal data categories: Name, contact information, career history, and other relevant information.

(3)Supervision of Outsourcing Partners

When SmartHR outsources all or part of the handling of personal data to a third party, (including cases where personal data entrusted to SmartHR by a customer is handled by another service provider or further subcontracted), SmartHR provides necessary and appropriate supervision to ensure that the personal data is managed securely.

(4)Cross-Border Transfer

SmartHR may provide personal data to third parties such as outsourcing partners or group companies outside of Japan. When providing personal data entrusted by customers for handling, SmartHR shall confirm that the recipient has a system that complies with the standards stipulated in Article 28, Paragraph 1 of the APPI.

The countries or regions where the recipients are located are as follows. SmartHR has confirmed that these recipients have taken all measures corresponding to the Eight Principles of the OECD Privacy Guidelines.

(5)Deletion of Personal Data

When personal data collected is no longer needed for use, SmartHR shall delete the personal data without delay in accordance with legal requirements.

Section 2: Rights of Individuals Regarding Retained Personal Data

1.Disclosure and Other Requests Concerning Retained Personal Data

  1. 1.Pursuant to the provisions of the APPI, individuals may request notification of the purpose of use of their retained personal data; disclosure of such data; correction, addition, or deletion of its content; suspension of use; erasure; or suspension of provision to third parties. These requests are collectively referred to as “Disclosure and Other Requests”.
    When SmartHR receives a Disclosure or Other Request concerning retained personal data pursuant to the APPI, SmartHR will confirm that the request was made by the individual who is the subject of the data, carry out the request without delay, and notify the individual accordingly. If the relevant retained personal data does not exist, or if SmartHR decides not to carry out the request for a legitimate reason, SmartHR will notify the individual accordingly.
    However, for personal data that SmartHR handles on behalf of customers of SmartHR Services, SmartHR will not respond to Disclosure and Other Requests from individuals at its own discretion. SmartHR will do so only when authorized by the relevant customer.
  2. 2.Notwithstanding the preceding paragraph, depending on the category of retained personal data, its collection or use may be a prerequisite for the provision of SmartHR’s services. In such cases, SmartHR will suspend the collection or use of such data only when the individual terminates the use of SmartHR’s services in accordance with the procedures prescribed by SmartHR.
  3. 3.SmartHR charges a fee of JPY 1,000 per request for disclosure of retained personal data or notification of the purpose of use.
  4. 4.Requests for Disclosure and Other Requests concerning retained personal data must be made using the form prescribed by SmartHR. Requests made using any other form will not be accepted. To request the prescribed form, please contact SmartHR as described in Section 3, Paragraph 3 (“Contact Information”) below.
  5. 5.Personal information collected in connection with a Disclosure or Other Request will be handled appropriately and only to the extent necessary to respond to the request.

Section 3: Other Important Matters

1.External Transmission of User Information

SmartHR externally transmits user information for purposes such as advertising, marketing, and access analysis by using cookies, tags, information collection modules, and similar technologies. For details on the kinds of user information transmitted externally, refer to “About Externally Transmitted Information (Japanese only)”.

2.Revisions to This Policy

SmartHR may revise this Policy at any time without prior notice in response to changes in laws and regulations, or as otherwise necessary. In such cases, SmartHR will publish the latest version of this Policy on the SmartHR website.

SmartHR will handle information in accordance with the latest version of this Policy, except where the individual’s consent or other procedures are required by law for changes made through a revision.

3.Contact Information

SmartHR, Inc.
Sumitomo Fudosan Roppongi Grand Tower
3-2-1 Roppongi, Minato-ku, Tokyo 106-6217, JAPAN

Please send any inquiries in accordance with instructions on the Contact Us pageOpens external site in a new window or tab. of the English version of SmartHR’s official website.

4.Governing Language

This Policy is prepared in the Japanese language and translated into the English language. The Japanese version shall be the original and authoritative text, and the English version is prepared for reference purposes only. In the event of any conflict, discrepancy, or inconsistency between the Japanese version and the English version, the Japanese version shall prevail.

Revision History

  1. March 01, 2015: Established
  2. November 16, 2015: Revised
  3. January 07, 2016: Revised
  4. April 03, 2017: Revised
  5. March 01, 2018: Revised
  6. April 01, 2020: Revised
    (Summary of changes)
  7. April 01, 2022: Revised
    (Summary of changes)
  8. June 16, 2023: Revised
    (Summary of changes)
  9. June 17, 2024: Revised
    (Summary of changes)
  10. May 26, 2026: Revised
    (Summary of changes)

Masato Serizawa
SmartHR CEO