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MATTERS CONCERNING THE HANDLING OF PERSONAL INFORMATION

Matters concerning
the Handling of Personal Information

Date of enactment: August 8, 2017
Revised : October 1, 2023

Junnosuke Hayashi,
President & CEO,
Zenken Corporation

Zenken Corporation (hereinafter referred to as "the Company") collects necessary personal information for the smooth operation of the Company's services and for the recruitment of employees. When acquiring personal information, the Company will comply with our "Personal Information Protection Policy" and carry out the acquisition as stipulated below.

  1. Business name
    Zenken Corporation
  2. Personal Information Protection Supervisor and Personal Information Protection Manager
    Personal Information Protection Supervisor: Representative Director 
    Personal Information Protection Manager: Board Director, Head of Administrative Headquarters
  3. Acquisition and Use of Personal Information
    In acquiring personal information, we will clarify the purpose of use in advance, collect the information in an appropriate manner, and use the information within the scope necessary to achieve the purpose. Except as stipulated in laws and regulations concerning the protection of personal information, we will not use collected personal information for purposes other than those for which it was collected without the prior consent of the individual concerned, and we will endeavor to delete such personal information promptly after the purpose of use has been achieved.
  4. Voluntary nature of provision of personal information
    The provision of personal information is voluntary. However, if you do not provide us with your personal information, the Company may not be able to provide you with the services you request, respond to your questions, or process your employment application.
  5. Purpose of use of personal information acquired directly by the Company or by a third party

    (1) The Company will use personal information only for the following purposes

    ① To fulfill contractual responsibilities

    ② For administrative procedures such as contract management

    ③ For procedures related to the use of our services and membership management

    ④ To receive and respond to inquiries and requests from customers and business partners

    ⑤ To provide guidance and contact regarding our services and other useful information to our customers.

    ⑥ For analysis and research to improve our services or develop new services

    ⑦ To provide information on products and services of our business partners

    ⑧ To provide information and contact regarding employment selection and to conduct recruitment operations

    ⑨ To manage employee employment and personnel affairs

    ⑩ To manage supplier information and process payments and income

    ⑪ For other purposes that are specifically identified on the website or in writing at the time of acquisition and that are clearly indicated in advance.

    (2) The Company may change the purpose of use of personal information to the extent deemed reasonable. In such cases, the Company will notify or publicly announce the changed purpose of use.

  6. Purpose of use of personal information entrusted to the Company

    ① Information on students taking English conversation, Japanese and other language lessons To fulfill the contracts (delivery of teaching materials, lesson implementation, class roster creation, grade report creation and reporting, etc.) Notification of class cancellations, time changes, etc.

    ② Personal information of employees of group companies To carry out outsourced employment management and personnel management

    ③ Personal information provided by recruitment agencies, etc. For the Company's recruitment and selection process and for the performance of business operations

  7. Safety Management Measures

    (1) In order to prevent leakage, loss, or damage of personal information, we will take safety measures to manage personal information to ensure and improve security, and will establish and continuously improve internal regulations to take reasonable corrective actions against these risks.

    (2) In order to properly protect personal information, we will educate all employees and have them manage personal information in an appropriate manner.

  8. Joint use

    The Company will register the personal information of business card exchanges with our business partners in our business card management system and use it jointly with them.

    ① Items of personal information to be shared
    Name, company name, address, postal code, telephone number, e-mail address, and any additional information

    ② Scope of joint users
    Consolidated subsidiaries and equity method affiliates in Japan of Zenken Corporation.

    ③ Purpose of joint use
    To contact and follow-up on business activities and to provide information on business activities and services

    ④ Party with responsibility for management of jointly used personal information
    Zenken Corporation.

  9. Complaint and Consultation Desk regarding Personal Information

    【Complaint and Consultation Desk regarding Personal Information】

    Tel: 03-3349-1641
    e-mail: privacy@zenken.co.jp
    Personal Information Complaints and Inquiries Desk Manager

  10. Name of the authorized personal information protection organization to which the Company belongs and where complaints may also be submitted for resolution.
    The Company is a covered entity of an authorized personal information protection organization. In addition to the Complaint and Consultation Desk regarding Personal Information, complaints may also be submitted to the following institution.

    Name :Japan Institute for Promotion of Digital Economy and Community(JIPDEC)
    Contact: Personal Information Protection Complaints Office
    Address: Roppongi First Building 12F, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
    Tel: 0120-700-779

  11. Procedures for Responding to Requests for Disclosure, etc.

    When we receive a request from an individual or his/her representative for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, elimination, or suspension of provision to a third party (hereinafter referred to as "disclosure, etc.") of personal information in our possession, we will, in principle, respond to such a request without delay. The purposes of use of retained personal data for which we may respond to requests for disclosure, etc. are as described in 5 above.

    《Contact for Requests for Disclosure, etc.》
    Requests for disclosure, etc., should be addressed to the "Complaint and Consultation Desk regarding Personal Information" above, or mailed to the following address.

    〒160-8361
    6-18-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo
    Sumitomo Fudosan Shinjuku Central Park Tower 19th Floor
    Complaints and Inquiries Concerning Personal Information, Zenken Corporation

    *In principle, the request must be made by the person in question or a representative authorized by the person in question.

    (1) Procedures for Requests for Disclosure, etc.

    • After receiving your request, we will mail you the prescribed request form.
    • The Company will reply in writing (by mail).

    (2) Method of confirming that the person making the request for disclosure, etc. is the person in question or his/her agent.

    • Either of the following certificates 2 or 3 must be submitted.
    • Driver's license, passport, disability certificate, residence card, special permanent resident certificate, alien registration certificate, resident basic registry card, My Number card (front side only, please do not submit the back side), and copies of official identification documents with photos issued by government agencies or special corporations. The official identification card must be within its validity period.
    • A copy of two of the following: health insurance card, resident certificate, pension book, driver's record certificate, pension certificate, bill for payment of public charges, or student ID card.
    • Items on the Company's prescribed request form should match the relevant personal information subject to disclosure in the possession of the Company.

    (3) Fees for disclosure procedures

    • Actual expenses (postage, etc.) incurred in the procedures for notification of purpose of use and disclosure will be charged upon prior approval.

    (4) In any of the following cases, the Company may not be able to respond to a request for disclosure, etc.
    ①When the Company cannot confirm the identity of the requestor
    ②When there is a deficiency in the disclosure request documents
    ③The personal information in question does not exist in the data held by the Company
    ④If there is a risk of harm to the life, body, property, or other rights or interests of the requesting party or a third party
    ⑤If there is a risk of significant hindrance to the proper conduct of our business
    ⑥In case of violation of laws and regulations

  12. Provision of acquired personal information to a third party
    The Company will not provide personal information to a third party without prior consent, except in the following cases

    ① When providing personal data to a third party in accordance with other laws and regulations other than the Personal Information Protection Law.

    ② When providing personal data to a third party is necessary for the protection of a person's life, body, or property, and it is difficult to obtain the consent of the person.

    ③ Cases in which the provision of personal data is particularly necessary for improving public health or promoting the sound growth of children, and in which it is difficult to obtain the consent of the individual concerned.

    ④ Cases in which the provision of personal information is necessary for cooperating with a state organ, a local government, or an individual or entity entrusted by either a state organ or local government to execute affairs prescribed by law, and in which obtaining the consent of the individual is likely to impede the execution of the affairs concerned.

  13. Provision of Personal Data to a third party in Foreign Countries

    When the Company provide personal data to a third party (including our subsidiaries) located outside of Japan, the Company will handle it appropriately in accordance with laws and regulations.

  14. Use of Cookie and Web beacon

    We use Cookie and web beacon technology to obtain access information. The purpose is to analyze the access information of our website and provide better information: there is no personal information that identifies you.

  15. Use of Google Analytics

    Our website uses Google Analytics, a service provided by Google, to understand how our customers visit our website. When the Company uses Google Analytics on our site, Google collects, records, and analyzes visits to our site based on cookies issued by us. We receive the results of this analysis from Google so that we can grasp information about visits to our site.

    The information collected, recorded, and analyzed by Google Analytics does not contain any personally identifiable information. Google Analytics does not collect, record, or analyze any personally identifying information about you, and such information is controlled by Google in accordance with Google's privacy policy.

    ※Please refer to the following URL for more information.

    <Google Analytics Terms of Use>
    http://www.google.com/analytics/terms/jp.html

    <Google's Privacy Policy>
    http://www.google.com/intl/ja/policies/privacy/

    ※Customers can also stop the collection of information about themselves through our use of Google Analytics by disabling Google Analytics in their browser's add-on settings.

    <Google Analytics Opt-out Add-on>
    https://tools.google.com/dlpage/gaoptout?hl=ja

  16. Use of Enhanced Conversion

    In order to deliver advertisements that match the interests of our customers and to improve the accuracy of measuring the effectiveness of advertisements, our website may use the Google service called "Enhanced Conversion". When you use Enhanced Conversion, your name, address, e-mail address, and telephone number will be encrypted and used by Google.

    Please refer to Google's opt-out page (https://support.google.com/ads/answer/2662922?hl=jav) for information on disabling the delivery of advertisements using Google Ads Enhanced Conversion.

    <Google Enhanced Conversion Overview>
    https://support.google.com/google-ads/answer/9888656?hl=ja