Privacy Policy

1. Obtaining personal information

When obtaining any personal information from Customers, etc., the Company shall clearly state the purpose of its use, assign a manager in charge, and obtain it according to such purpose of use.

[Personal Information we obtain]
In the course of providing the Company’s services, the Company shall obtain the following personal information:

1. Information provided by Customers, etc.

   • Profile information (e.g., name, date of birth, gender, occupation)
   • Contact information (e.g., email address, telephone number, address, place of employment)
   • Payment method information (e.g., bank account information)
   • Other information entered or sent by Customers, etc. through registration forms or other means 　designated by the Company

2. Information obtained for using the service

   • Information on service usage (e.g., usage logs)
   • Information on the environment on which the service is used (including information on networks, terminals, browsers, and applications)

3. Information obtained from third parties

   • Information obtained from other business operators with which the Company partners
   • Any other information uploaded by Customers, etc.

4. Public information

2. Usage of personal information

The Company shall keep personal information accurate and up-to-date to the extent necessary for business operations within the scope of the purpose of use specified at the time of acquisition thereof and delete such information without delay when the use thereof is no longer required, and take reasonable security measures to protect such information from loss, destruction, misuse, falsification, leakage, and so on. If outsourcing the handling of any personal information to third parties, the Company shall conduct a rigorous investigation of such third parties beforehand and supervise them appropriately to ensure the confidentiality is maintained.

[Purpose of use]
The Company uses the personal information of Customers, etc., for the following purposes:

Types of personal information	Purpose of use
1．Personal information of customers	(1) To perform operations related to the sale, delivery, and payment for the Company’s and third parties’ products, rights, services, etc. (including production of the custom-made products)
	(2) To send advertisements or promotional materials (including sending of emails, flyers, and other direct mailings) or email magazines related to the Company’s and third parties’ products and services
	(3) To inform customers of campaigns and questionnaires and to request for feedback for the purpose of service improvement, etc.
	(4) To conduct campaigns etc., contact winners, and send prizes, etc.
	(5) To manage seminars and events
	(6) To provide point services and affiliate services
	(7) To conduct marketing activities and research and statistical analysis of marketing data
	(8) To manage customer information, and other various contacts and communications, etc.
	(9) To provide support for products and services and respond to inquiries, etc.
	(10) To conduct marketing activities, including face-to-face sales
	(11) To conduct research and statistical analysis of marketing data
	(12) To develop and improve the Company’s products and services
	(13) To maintain the system and address any failures if they occur
	(14) To simplify the registration process for members who have registered their personal information with the Company when they use other services provided by the Company or its subsidiaries
	(15) To perform outsourced operations if the handling of personal information is outsourced by our business partner, etc. (including shipment of products on behalf of the business partner and necessary communications associated with the shipment)
	(16) To exercise rights and fulfill obligations under contracts, laws, regulations, etc.
	(17) To confirm postal addresses and cross-check with other companies' sources for marketing and advertising purposes
	(18) For other purposes as individually determined for each service of the Company
	(19) Other various correspondences, communication management, and sending of related materials
	(20) Inquiries by telephone may be recorded for the purposes stated above and for the use for operator training to ensure smooth business operations.
2．Personal information of business partners (including individuals), directors, and employees of other companies	(1) To communicate (including send greeting messages), cooperate, negotiate, perform a contract, demand for performance, etc. as necessary in the course of business
	(2) To manage business partner information and process payments and income
	(3) To provide Customers, etc. with information on products and production areas, etc., and conduct related sales promotion and PR activities
	(4) To publish the information in company brochures, business reports, company chronicles, and other documents
	(5) To provide information on the Company’s services, events, etc.
	(6) To request cooperation in surveys and create other various statistical materials
	(7) To identify persons who are to enter the Company’s facilities from perspectives of protecting and managing the Company’s trade secrets and the like.
	(8) To fulfill obligations stipulated in laws and regulations including the Act for Securing Proper Operation of Worker Dispatching Undertakings and Improved Working Conditions for Dispatched Workers and the Industrial Safety and Health Laws
	(9) To verify the legal compliance status of employees and business partners of the Company
	(10) To prepare payment records of remuneration, fees, contracts, monetary awards, etc., for sole proprietors among our business partners, for specified personal information, etc.
3．Personal information of employees and public officials of government and municipal offices	(1) To contact, report, or make inquiries to the competent authorities as necessary in the course of business
	(2) To verify the legal compliance status of the Company and its employees
4．Personal information that the Company is contracted out by other business operators, etc. to handle	To perform contracts (to carry out outsourced work), etc.
5．Personal information of shareholders	(1) To exercise rights and fulfill obligations under laws and regulations
	(2) To provide various benefits to them in relation to the status as the Company’s shareholder
	(3) To implement various measures to facilitate the relationship between the shareholders and the Company in terms of a corporation and its members
	(4) To manage shareholders in accordance with laws and regulations (e.g., to compile shareholder data)
	(5) Inquiries by telephone may be recorded for the purposes stated above and for operator training to ensure smooth business operations.
6．Personal information of participants of events, etc.	(1) To contact them and provide information related to the event
	(2) To provide information on related products or services and conduct surveys, analysis, publicity, and advertising activities outsourced by business partners
	(3) To introduce events, etc., and conduct related sales promotion and PR activities
	(4) To publish the information in company brochures, business reports, company chronicles, and other documents
	(5) For other purposes as individually determined for each event and the like
7．Personal information of job applicants	(1) To send hiring information and the like and provide information to job applicants (including internship), and screen applicants for hiring
	(2) To manage recruitment activities at the Company
	(3) To improve the Company’s website for job applicants
8．Personal information of employees and directors	To handle the management of employees and directors
	The Company uses specified personal information within the scope of the following purposes individually designated at the time of acquisition and to the extent necessary for the business operations.
	(1) Health insurance-related, employee pension insurance-related, unemployment insurance-related administrative work, and other social security-related application and claim procedures for employees and directors and their dependents
	(2) Withholding tax-related, individual inhabitant tax-related administrative work, and other tax-related filing procedures for employees and directors and their dependents
9．Personal information of persons who have made inquiries to the Company or visited the Company, other than those listed 1 through 7 above	To contact them, manage communication, send related materials, etc.

3.Provision of personal information to third parties

The Company shall not share personal information with third parties without prior consent of the person concerned, except in cases stipulated in this Privacy Policy or by law.

Information provision to third parties	Purpose of use
a: Outsourcing	The Company may disclose personal information of Customers, etc., to our subcontractors to conduct business, but only to the minimum extent that such information is necessary. The Company shall execute contracts for protecting personal information with such subcontractors and shall exercise necessary and appropriate management and supervision to ensure that such subcontractors fulfill their contractual obligations.
b: Sharing among group companies	Personal data items to be shared Information described in "(1) Personal information we obtain” Scope of information sharing The Company and its group companies (subsidiaries or affiliates of the Company defined in the “Regulation on Terminology, Forms, and Preparation Methods of Financial Statements” of Japan) Users’ purpose This shall be the same as the purposes of use described in “(2) Purpose of use,” but as for purpose of use at the parties with which information is shared, “the Company” shall be changed to “group companies,” and “the Company’s services” shall be changed “group companies’ services.” - The name and address of the person responsible for the management of the relevant personal data and the name of its representative in case of a corporation 7F, PMO Uchikanda, 1-14-10, Uchikanda, Chiyoda-ku,Tokyo 101-0047 SuRaLa Net Co., Ltd. Chief Executive Officer Takahiko Yunokawa
c: Business succession	Personal information may be transferred to business successors to the extent permitted by law in case of acquisitions, mergers, changes in business entities, or other intercompany transactions involving the Company’s business covered by this Policy.
d: Compliance and cooperation with public organizations	The Company may disclose personal information to third parties, such as law enforcement agencies, including police or courts, under the law, such as upon receipt of warrants or other requests pursuant to legal procedures for such information.
e: Cooperation with other businesses	The Company may provide personal information of Customers, etc. to other business operators when Customers, etc. use the services of such operators or when the Company conducts marketing and advertising activities through them. In such case, the Company shall provide personal information only to the minimum extent necessary to achieve the purpose of use.

4. Personal Information Management

The Company shall ensure the accuracy of personal information and manage it securely. The Company shall take appropriate precautions against unauthorized access, computer viruses, theft, and dissemination (including means other than electronic media) to prevent loss, destruction, falsification, or leakage of personal information.

5. Retention Period and Disposal of Personal Information

The Company shall adequately store personal information during the service period and for one year after the service completion and properly dispose of or delete the personal information after the expiration of the period.

6. Handling of Anonymously Processed Information

The Company may provide personal information to third parties after processing the information so that it cannot be used to identify specific individuals.

1. (1) Items of information on individuals included in the anonymized information to be created or provided to third parties
   
   • Performance data
   • Behavior logs (e.g., when customers studied, dates and times of access to various apps by customers, parents, teachers, etc.)
   • Learning logs (which questions were answered)
   • Homework logs (what kind of homework was assigned)
   • Information on the attributes of the school of choice (deviation values, school type (national, public, private), etc.)
   • Information on the attributes of the enrolled school (deviation values, school type (national, public, private), etc.)
2. (2) Method of provision to third parties
   
   • Send password-protected electronic files via email, etc.
3. (3) Purpose of providing data
   
   • Anonymized information will be provided to content holders such as publishers to enable each content holder to use it for research, development, planning, and study of better learning materials and improvement of their service quality.

7. Organization and structure

The Company shall appoint a Personal Information Management Officer to ensure the appropriate personal information management. The Company shall provide training on protecting and properly managing personal information to its directors, employees, temporary staff, and part-timers to ensure the information is handled appropriately in their daily work. The Company will continuously enhance its compliance program for protecting personal information.

8. Use of Cookies

• Some of the pages on the Company’s website use cookies.
  The website may contain advertisements distributed by third parties, including Yahoo Japan Corporation. In this regard, such third parties may obtain and use cookies or other information of customers who visited our website.
• Information such as cookies obtained by third parties will be handled under their privacy policy.
• Cookie is a mechanism to store usage history and input contents transmitted between browsers and servers and stored as files on customers’ computers when they use web pages. If accessing the same page again, the page operator can use the cookies to change the display for each customer. If customers have set their browsers to allow cookies to be sent and received, the website can retrieve cookies from the browsers. The browsers only send cookies sent and received by the website’s server to protect privacy.
• Customers can choose to “Allow all cookies,” “Reject all cookies,” or “Notify the user when receiving a cookie,” among other settings regarding sending and receiving cookies. The setting method varies depending on the browser. Refer to your browser’s “Help” menu to learn how to set up cookies.
• Note that if you select a setting to reject all cookies, you may not be able to use services requiring authentication or may experience other restrictions in using various services on the internet.

9. Use of Analytics

This site uses Google Analytics to record access status to the extent that individuals are not identified.
We handle the recorded status data carefully and use it to enhance service content and make plans to benefit our customers.

10. Compliance with Laws and Regulations

The Company shall comply with laws, regulations, and other rules related to personal information.

11. Revision of the Policy

The Company shall review the operational status of handling user information from time to time to improve it continuously and may change this policy as necessary without prior notice. Any changes will be notified through postings on this site.
If changes to the content require customers' consent under laws and regulations, the Company shall obtain customers' permission in a manner prescribed by the Company.

1-1. Company Name

7F, PMO Uchikanda, 1-14-10, Uchikanda, Chiyoda-ku,Tokyo 101-0047
SuRaLa Net Co., Ltd. Chief Executive Officer Takahiko Yunokawa

1-2. rocedures for responding to “Requests for Disclosure, etc.”

1-2-1. Disclosure

(1) Application for disclosure (content or purpose of use of personal information)
Contact the Personal Information Management Division and “Surala Customer Center” (hereinafter “the Contact Point”) to obtain an "Application Form for Disclosure/Modification/Suspension of Use/Deletion of Customer Personal information,” fill out the form, and send the following three items by registered mail to the Contact Point.

1. 1) Application Form for Disclosure/Modification/ Suspension of Use/Deletion of Customer Personal information
2. 2) 600 yen worth of postal stamps for handling fee
3. 3) Copies of official certificates for identification of the applicant (or proxy)

Two of the following, one of which must contain the customer's current address

• Copy of valid driver’s license
  (International driver's license is not acceptable / If the address has been changed, a copy of both sides of the license is required)
• Copy of valid health insurance card
  (a copy of sections of the person’s name and address is required)
• Copy of certificate of residence
  within six months of issuance (no need for domicile of origin column)
• Copy of personal seal registration-card
  within six months of issuance
• Others
  Copy of alien registration certificate, copy of passport, copy of basic residents' register, copy of pension book

Note 1: If any of the above official certificates for identity verification contain sensitive customer information, such as legal domicile or family name, the customer is requested to voluntarily black out the information so it cannot be discerned.

Note 2: If a proxy makes the application, please attach a letter of proxy from the applicant. Indicate that a proxy is making the application and provide contact information, names, and seals of the applicant and the proxy on the letter.

Note 3: The response to the application will be made approximately two weeks after the Contact Point receives the above-mentioned required documents. Copies of official certificates we received will be returned to the customer by registered mail at the time of response.

(2) Send back the completed [Application Form for Disclosure/Modification/Suspension of Use/Deletion of Customer Personal information] along with the required documents to the Contact Point from which you obtained the application form.

(3) Notes
The Company properly manages personal information contained on the [Application Form for Disclosure/ Modification/Suspension of Use/Deletion of Customer Personal Information] in accordance with the Privacy Policy and the Intent of the Privacy Statement of the Company. Note that we may not be able to fulfill the request if any of the following apply.

• In case we cannot confirm the identity of the applicant or their proxy (letter of proxy)
• In case two copies of official certificates for identification of the applicant (or proxy) are not enclosed
• In case of failure to send by “registered mail” to the Company

1-2-2. Modification/Suspension of Use/Deletion

(1) Application for modification/suspension of use/deletion of personal information
Contact the Personal Information Management Division and “Surala Customer Center” (hereinafter “the Contact Point”) to obtain an "Application Form for Disclosure/Modification/Suspension of Use/Deletion of Customer Personal information,” fill out the form, and send the following three items by registered mail to the Contact Point.

1. 1) Application Form for Modification/ Suspension of Use/Deletion of Customer Personal information
2. 2) Copies of official certificates for identification of the applicant (or proxy)

Two of the following, one of which must contain the customer's current address

• Copy of driver’s license
  International driver's license is not acceptable / within the validity period / if the address has been changed, a copy of both sides of the license is required
• Copy of valid health insurance card
  (a copy of sections of the person’s name and address is required)
• Copy of certificate of residence (no need for domicile of origin column)
  Within six months of issuance
• Copy of personal seal registration-card
  Within six months of issuance
• Others
  Copy of alien registration certificate, copy of passport, copy of basic residents' register, copy of pension book

Note 1: If any of the above official certificates for identity verification contain sensitive customer information, such as legal domicile or family name, the customer is requested to voluntarily black out the information so it cannot be discerned.

Note 2: If a proxy makes the application, please attach a letter of proxy from the applicant. Indicate that a proxy is making the application and provide contact information, names, and seals of the applicant and the proxy on the letter.

Note 3: The response to the application will be made approximately two weeks after the Customer Information Consultation Service receives the above required documents. Copies of official certificates we received will be returned to the customer by registered mail at the time of response.

(2) Send the completed [Application Form for Disclosure/Modification/Suspension of Use/Deletion of Customer Personal information] with the required documents to the Contact Point from which you obtained the application form.

(3) Notes
The Company properly manages personal information contained on the [Application Form for Disclosure/ Modification/Suspension of Use/Deletion of Customer Personal Information] in accordance with the Privacy Policy. Note that we may not be able to fulfill the request if any of the following apply.

• In case we cannot confirm the identity of the applicant or their proxy (letter of proxy)
• In case two copies of official certificates for identification of applicant (or proxy) are not enclosed
• In case of failure to send by “registered mail” to the Company

1-3. For any complaint and consultation regarding the management of personal data held by the Company, please contact the Personal Information Management Division and the "Surala Customer Center."

▼SuRaLa Customer Center

https://sateraito-apps-kform2.appspot.com/surala.jp/default/public/newdocpopup2/template-20150414090000DTNMIqVVOSTUwfhM?hl=ja&submit=yes

1-4. Handling Fee

A fee of 600 yen per application for Disclosure, etc., is charged. Enclose 600 yen worth of postal stamps with the application form and required documents. Note that the amount of the handling fee is subject to change without notice. Note that the fee (postal stamps) will be used to send the response letter and will not be returned.