PRIVACY POLICY

1.Compliance with Personal Information Protection Act and Related Laws and Regulations

The Company shall comply with the Personal Information Protection Act and Related Laws and Regulations to ensure the proper handling of personal information.

2.Acquisition of Personal Information

The Company shall acquire personal information through lawful and fair means.

3.Purpose of Use of Personal Information

The Company will use the acquired personal information only within the scope of the following purposes (hereinafter referred to as "Purposes of Use"), except as provided for by the Personal Information Protection Act and Related Laws and Regulations. In cases where the purpose of use is notified or announced individually, such purpose shall apply.

• (1) To provide services such as: (i) Japanese language education for international students, (ii) Japanese language education for foreign residents in Japan, (iii) Japanese
• (2) To improve the quality of the Company’s services.
• (3) For the settlement and billing of service usage fees.
• (4) For identity verification of customers.
• (5) To provide information related to the Company’s services (e-mail magazines, campaign information, various notices, etc.).
• (6) To understand customer opinions and inquiries and provide responses.
• (7) For questionnaire surveys, marketing research, and analysis.
• (8) For recruitment applicants: for selection, information provision, and communication.
• (9) For conversion approval related to performance-based rewards for affiliate advertising.
• (10) For students wishing to study in Japan: to create and submit applications for the Certificate of Eligibility to the Immigration Services Agency of Japan.
• (11) Other purposes incidental or related to the above items.

4.Purpose of Use of Pseudonymized Information

When creating pseudonymized information (referring to information about an individual obtained by processing personal information so that a specific individual cannot be identified unless matched with other information), the Company processes such information in accordance with the standards prescribed by laws and regulations. The Company shall use pseudonymized information for the following purposes:

• (1) Marketing activities and analysis.
• (2) Formulation of curriculum, teacher placement, and evaluation.
• (3) Improvement and development of teaching materials.
• (4) Improvement of service quality.
• (5) Provision of information regarding services provided by the Company and its group companies.
• (6) Other purposes incidental or related to the above items.

5.Provision of Personal Information to Third Parties

The Company will not provide personal information to third parties without obtaining the prior consent of the individual, except in the following cases:

• (1) When based on the Personal Information Protection Act or other related laws and regulations.
• (2) When necessary for the protection of human life, body, or property, and it is difficult to obtain the consent of the individual.
• (3) When particularly necessary for the improvement of public health or the promotion of the sound growth of children, and it is difficult to obtain the consent of the individual.
• (4) When necessary to cooperate with a national agency, a local government, or a person entrusted by them in performing duties prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the performance of such duties.
• (5) When entrusting the handling of personal information, in whole or in part, within the scope necessary to achieve the Purposes of Use.
• (6) When personal information is provided as a result of business succession due to a merger or other reasons.
• (7) When personal information is jointly used in accordance with the provisions of the Personal Information Protection Act (refer to Section 6 below).

6.Joint Use of Personal Information

The Company may jointly use acquired personal information within its group as follows, within the scope of the Purposes of Use described in Section 3 above: Items of personal information to be jointly used: Name, date of birth, gender, address, phone number, e-mail address, service usage history, questionnaire/survey results, inquiry history, and access records to the Company’s website.

• (1) Scope of joint users: Pathmake Group companies (Pathmake Holdings Co., Ltd. and Abitus Inc.).
• (2) Purpose of use by joint users: Same as the "Purposes of Use" described in Section 3 and Section 4 above.
• (3) Party responsible for the management of joint use: Pathmake Holdings Co., Ltd.

7.Joint Use of Pseudonymized Information

The Company may jointly use pseudonymized information created by the Company within its group, within the scope of the Purposes of Use described in Section 4 above:

• (1) Scope of Joint Users: Pathmake Group companies (Pathmake Holdings Co., Ltd. and Abitus Inc.).
• (2) Items of Pseudonymized Information to be Jointly Used: Information processed from the following personal information by deleting descriptions and individual identification codes contained therein so that a specific individual cannot be identified unless matched with other information:
  
  • ・Personal information concerning attributes or contact information, such as name, date of birth, age, gender, nationality, address, phone number, e-mail address, and qualifications obtained.
  • ・Personal information concerning customer activity history, such as service usage history (including past and future records) and access records to the Company’s website.
  • ・All personal information received from customers, including questionnaire results and the details and history of inquiries to the Company.
• (3) Party Responsible for the Management of Joint Use:Pathmake Holdings Co., Ltd. (For more details, please refer to the section on "Pathmake Holdings Co., Ltd.").
  Would you like me to continue with the translation of the remaining sections, such as the safety management measures or the procedures for disclosure?

8.Entrustment of Personal Information Handling

The Company may entrust the handling of personal information, in whole or in part, to third parties within the scope necessary to achieve the Purposes of Use. In such cases, the Company shall select contractors who are recognized to handle personal information appropriately in light of their security control measures. Furthermore, the Company shall appropriately stipulate matters concerning security management, confidentiality, conditions for re-entrustment, and other matters related to the handling of personal information in the entrustment agreement, monitor the status of the handling of personal information by said third parties, and exercise necessary and appropriate supervision.

9.Security Control Measures for Personal Information

The Company shall strive to maintain the accuracy of personal information within the scope necessary to achieve the Purposes of Use. Furthermore, to prevent unauthorized access to, or the alteration, leakage, loss, or damage of personal information, the Company shall implement the following security control measures:

(Organizational Security Control Measures)
• • Appointment of a person responsible for the handling of personal information, clarification of employees who handle personal information and the scope of personal information handled by said employees, and establishment of a reporting and communication system to the responsible person in the event that facts or signs of a violation of laws or handling regulations are detected.
• • Establishment of internal rules and regulations related to the handling of personal information.
• • Implementation of periodic self-inspections regarding the status of the handling of personal information.

(Personnel Security Control Measures)
• • Implementation of regular training for employees regarding points of caution in the handling of personal information.
• • Implementation of disciplinary actions against employees who violate laws or handling regulations related to the handling of personal information.

(Physical Security Control Measures)
• • Implementation of access controls to limit the persons in charge and the scope of personal information they handle.
• • Implementation of mechanisms to protect information systems that handle personal information from unauthorized external access or malicious software.

(Technical Security Control Measures)
• • Implementation of access controls to limit the persons in charge and the scope of personal information they handle.
• • Implementation of mechanisms to protect information systems that handle personal information from unauthorized external access or malicious software.

(Understanding the External Environment)
• • When handling personal information in a foreign country, the Company shall implement appropriate measures based on an understanding of the systems for the protection of personal information in said foreign country.

10.Disclosure, Correction, etc. of Personal Information

When the Company receives a request from an individual for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, disclosure of records on provision to third parties, or suspension of provision to third parties (hereinafter referred to as "Requests for Disclosure, etc.") regarding personal information held by the Company, the Company shall, after verifying the identity of the individual, conduct the necessary investigation without delay in accordance with related laws and regulations, and respond appropriately based on the results. Customers who wish to make a Request for Disclosure, etc. are asked to contact the inquiry desk listed below, where we will guide you through the necessary procedures. If we are unable to comply with your request, we will notify you of the reason. Please note that a fee of 1,000 yen (including consumption tax, etc.) will be charged for each request regarding notification of the purpose of use and disclosure.

11.Handling of Anonymously Processed Information

• (1) When the Company creates anonymously processed information (referring to information about an individual obtained by processing personal information so that a specific individual cannot be identified and the personal information cannot be restored, by taking measures prescribed by laws and regulations; the same shall apply hereinafter), the Company shall take the following actions:
  
  • • Perform appropriate processing in accordance with standards prescribed by laws and regulations.
  • • Implement security control measures to prevent the leakage of deleted information or information regarding processing methods in accordance with standards prescribed by laws and regulations.
  • • Publicly announce the items of information included in the created anonymously processed information.
  • • Refrain from performing any act to identify the individual whose personal information was the basis for the creation.
• (2) When providing anonymously processed information to a third party, the Company shall publicly announce the items of information about individuals included in the anonymously processed information to be provided and the method of provision, and clearly indicate to the third party that the information provided is anonymously processed information.
• (3) Regarding the following personal information held by the Company, the Company will continuously create anonymously processed information after taking appropriate measures so that a specific individual cannot be identified and the personal information cannot be restored.
  (Items of information about individuals included in anonymously processed information)
  Gender, age, industry, and occupation
• (4) Regarding anonymously processed information created or held by the Company, the Company will continuously provide such information to third parties after clearly indicating that the information provided is anonymously processed information.
  
  • (Items of information about individuals included in anonymously processed information)
    Gender, age, industry, and occupation
  • (Method of Provision)
    • Uploading password-managed files to a server with managed access rights.
    • Sending password-protected electronic files via external storage media or e-mail.
    • Providing via cloud services protected by high-level security.

12.Inquiry Desk for Personal Information

For any inquiries, complaints, or consultations regarding our handling of personal information and pseudonymized information, please contact us at the following:
Pathmake Holdings Co., Ltd. 15F Shinjuku Maynds Tower, 2-1-1 Yoyogi, Shibuya-ku, Tokyo 151-0053, Japan
[Inquiry Desk for Personal Information] Email: privacy@pathmake.co.jp

13.Amendment Procedures

The Company may amend this Privacy Policy as necessary. However, in the event of an amendment that requires the consent of the individual under the Act on the Protection of Personal Information or other applicable laws and regulations, the amended Privacy Policy shall apply only to those who have consented to such changes. When amending this Privacy Policy, the Company will announce the effective date and the contents of the amended Privacy Policy by posting it on the Company’s website or by notifying the individuals concerned directly.

14.Use of Cookies and Similar Technologies

The Company may collect certain information through the use of cookies and similar technologies. For further details, please refer to the link below:
[Link to our Cookie Policy]

TCJ Global Inc. Takumi Nakazawa, Representative Director 34 Shinanomachi, Shinjuku-ku, Tokyo