Privacy Policy

Administrative Scrivener KT International Office (hereinafter referred to as “the Company”) recognizes the importance of protecting personal information and complies with the Act on the Protection of Personal Information of Japan (hereinafter referred to as “the Personal Information Protection Act”).
The Company handles and protects personal information appropriately in accordance with the following Privacy Policy (hereinafter referred to as “this Policy”).
Unless otherwise specified in this Policy, the definitions of terms shall follow those set forth in the Personal Information Protection Act.

1. Definition of Personal Information

In this Policy, “personal information” shall mean personal information as defined in Article 2, Paragraph 1 of the Personal Information Protection Act.

2. Purpose of Use of Personal Information

The Company uses personal information for the following purposes:

• To provide the Company’s services and products (“the Services”).
• To respond to inquiries and provide guidance regarding the Services.
• To notify and provide information about the Services.
• To address any violations of the Company’s terms, policies, or other agreements (“the Terms”).
• To inform users of changes to the Terms and other important notifications.
• To improve existing Services and develop new services or products.
• To analyze browsing, behavioral, and purchasing histories to improve functionality, develop new offerings, and provide tailored advertisements.
• For employment management and internal administrative procedures (for officers and employees).
• For shareholder management and legal procedures in accordance with the Companies Act and other laws (for shareholders, stock option holders, etc.).
• To create statistical data that cannot identify individuals in connection with the Services.
• To provide information, including advertisements, from the Company.
• For other purposes related or incidental to the above.

3. Changes to the Purpose of Use

The Company may change the purpose of use of personal information within a reasonable and relevant scope and will notify or publicly announce such changes to the individual concerned.

4. Restriction on Use of Personal Information

Except as permitted by the Personal Information Protection Act or other laws and regulations, the Company will not handle personal information beyond the necessary scope without the consent of the individual, except in the following cases:

1. When required by law.
2. When necessary to protect a person’s life, body, or property and it is difficult to obtain the individual’s consent.
3. When particularly necessary for improving public health or promoting the sound growth of children and obtaining consent is difficult.
4. When necessary to cooperate with national or local government organizations in performing legally prescribed duties, and obtaining consent may hinder such performance.
5. When providing data to academic research institutions for academic purposes, provided such handling does not unjustly infringe on individuals’ rights or interests.

5. Proper Acquisition of Personal Information

5.1 The Company will obtain personal information appropriately and not through deceitful or other improper means.
5.2 The Company will not acquire sensitive personal information (as defined in Article 2, Paragraph 3 of the Personal Information Protection Act) without prior consent, except in the following cases:

• When falling under any of the cases listed in Section 4 above.
• When acquired from academic institutions for legitimate academic research purposes.
• When the information has been made public by the individual, a government agency, or other authorized body.
• When such sensitive information is visually or photographically observable.
• When provided in a manner not deemed a third-party provision under Section 7.1.

6. Security Management of Personal Information

The Company takes necessary and appropriate measures to prevent loss, destruction, alteration, or leakage of personal information, and supervises employees and contractors handling such information appropriately.
Key security management measures include:

• Compliance with the Personal Information Protection Act and related guidelines.
• Establishment of handling rules, responsible personnel, and reporting structures.
• Regular inspections by the responsible officer.
• Employee training and confidentiality clauses in employment rules.
• Secure storage of data and devices to prevent theft or loss.
• Access restrictions and system protections against unauthorized access and malware.
• Secure deletion and disposal of personal data and storage media.

7. Provision to Third Parties

7.1 The Company will not provide personal information to third parties without prior consent, except as permitted by law. The following cases do not constitute third-party provision:

• Outsourcing within the necessary scope to achieve the purpose of use.
• Business succession due to merger or similar events.
• Joint use under the Personal Information Protection Act.

7.2 When providing personal information to a third party in a foreign country (excluding countries designated by the Personal Information Protection Commission), the Company will obtain prior consent or take other legally required measures.

7.3 The Company will create and retain records when providing personal information to a third party in accordance with Article 29 of the Act.

7.4 When receiving personal information from a third party, the Company will verify and record necessary information in accordance with Article 30 of the Act.

7.5 The Company may provide user information to partner companies based on the Terms of Use or special agreements.

8. Personally Related Information

When obtaining personally related information (as defined in the Act) from third parties and using it as personal data, the Company will obtain prior consent and use it only within the purposes stated in Section 2.
When providing personally related information to a third party expected to use it as personal data, the Company will confirm that the individual’s consent has been obtained.

9. Disclosure of Personal Information

Upon request from an individual, the Company will promptly disclose retained personal data or third-party provision records after verifying the requester’s identity, unless exempted under law.

10. Correction of Personal Information

If an individual requests correction, addition, or deletion (“Correction, etc.”) of their personal information on the grounds of inaccuracy, the Company will promptly investigate and, if necessary, correct or notify the individual accordingly, unless exempted by law.

11. Suspension of Use or Provision of Personal Information

If an individual requests suspension or deletion (“Suspension, etc.”) or discontinuation of provision (“Cessation of Provision”) of their personal information on legitimate grounds such as unauthorized use or acquisition, the Company will promptly comply and notify the individual, unless exempted under law.

12. Handling of Anonymized Information

12.1 When creating anonymized information, the Company will process data in accordance with standards set by the Personal Information Protection Commission.
12.2 The Company will implement necessary security measures.
12.3 The Company will publicly announce the categories of information contained in anonymized data.
12.4 When providing anonymized data to third parties, the Company will disclose the items and methods of provision in advance and indicate that the information is anonymized.
12.5 The Company will not re-identify individuals by collating anonymized data with other information.
12.6 The Company will endeavor to take necessary measures for secure handling and public disclosure of such measures.

13. Use of Cookies and Similar Technologies

The Company’s services may use cookies or similar technologies to understand usage and improve service quality.
Users can disable cookies via browser settings; however, some features may not function properly if cookies are disabled.

14. Use of External Services

The Company uses external services for analytics, including:

• Google Analytics and Google Analytics Advertising Features for understanding user behavior.
  Google Analytics Remarketing
  Google Display Network Impression Reporting
  Google Analytics Demographics and Interest Reporting

Users may disable cookies or opt out via the following links:

• Google Privacy Policy
• Google Analytics Opt-out Add-on

15. Name, Address, and Representative of the Personal Information Handling Business Operator

Administrative Scrivener KT International Office
Address: Kasuya-machi, Kasuya-gun, Fukuoka, Japan
Representative: Keiko Takayanagi

16. Inquiries

For requests for disclosure, opinions, inquiries, or complaints regarding personal information handling, please contact:

Personal Information Inquiry Desk
Phone: 080-3184-4607
(Available from 9:00 AM to 6:00 PM, Japan Time)

17. Continuous Improvement

The Company regularly reviews and improves its handling of personal information and may revise this Policy as necessary.

Enacted on September 30, 2025