ATRUSTIA LLC. (hereinafter referred to as “the Company”) recognizes that personal information constitutes an important element of an individual’s privacy. In the course of conducting its business, the Company will comply with the Act on the Protection of Personal Information of Japan (hereinafter “APPI”) and other relevant laws and regulations when handling personal information. Additionally, the Company has established internal regulations and an organizational structure to ensure appropriate protection of personal information and is committed to continuous improvement.

1. Definition of Personal Information

“Personal Information” refers to information as defined in Article 2, Paragraph 1 of the APPI, which can identify a specific living individual, including but not limited to name, date of birth, or other descriptions, or which contains individual identification codes.

2. Acquisition of Personal Information

The Company acquires personal information through the following methods:

1. Information provided in writing by employees for corporate management purposes
2. Information provided in writing or registered online by applicants in response to job openings
3. Information provided in writing or registered online by users applying to use the Company’s services (hereinafter referred to as “the Services”)
4. Information provided through inquiry forms or emails from individuals contacting the Company

3. Purpose of Use

The Company uses acquired personal information for the following purposes:

1. Employee Information
1. For HR and general affairs management
2. For various communications and notifications to employees
2. Job Applicant Information
1. For recruitment management
2. For various communications and notifications to applicants
3. Service User (Client) Information
1. For appropriate provision of the Services
2. For management related to the Services
3. For various communications and notifications related to the Services
4. For analysis and confirmation of usage conditions including service improvement
5. For billing and payment management
4. Inquiry Information
1. For managing inquiries
2. For communications and notifications related to the Services

4. Changes to the Purpose of Use

1. If the Company changes the purpose of use of personal information, such changes shall be made only within a scope reasonably recognized as relevant to the original purpose.
2. When the purpose of use has been changed in accordance with the above, the Company shall notify users of the Services of the revised Privacy Policy through a method prescribed by the Company, or shall publicly announce it on the Company’s website.

5. Outsourcing of Personal Information Handling

The Company may outsource the handling of personal information, in whole or in part, to third parties. In such cases, the Company will ensure proper safety measures are taken to prevent unauthorized access, leakage, loss, or damage, and will appropriately supervise the third party to ensure similar measures are implemented.

6. Provision of Personal Data to Third Parties

1. The Company will not provide personal data (as defined in Article 16, Paragraph 3 of the Act on the Protection of Personal Information) to any third party except in the following cases:
1. When the individual has given prior consent
2. When disclosed or provided in a statistical format that does not allow identification of the individual
3. When required by laws and regulations
4. When it is necessary for the protection of the life, body, or property of a person and obtaining the individual’s consent is difficult
5. When it is especially necessary for improving public health or promoting the sound growth of children and obtaining the individual’s consent is difficult
6. When it is necessary to cooperate with a national or local government body, or an entity entrusted by such, in the execution of legally prescribed duties, and obtaining the individual’s consent may hinder such execution
2. Notwithstanding the provisions of the preceding paragraph, the following cases shall not be considered as provision to third parties:
1. When the Company outsources all or part of the handling of personal data to the extent necessary to achieve the stated purpose of use
2. When personal data is provided as a result of a business succession due to a merger or other reasons
3. When personal data is jointly used with specific parties, and the individual has been notified in advance or the information is made readily accessible to the individual, including: the fact of joint use, the items of personal data to be jointly used, the scope of the joint users, the purpose of use by those parties, and the name or title of the person responsible for the management of the personal data
3. For the purpose of providing the Services, the Company may provide personal data it holds to service licensors, only after obtaining the individual’s consent.
4. For the purpose of event management, communication, and related notifications, the Company may provide personal data it holds to companies co-hosting events with the Company, only after obtaining the individual’s consent.
5. Through the Company’s website, cookie information may be collected for the purpose of delivering targeted advertisements. If you wish to opt out of such advertising, please disable cookies through the website or app of the advertising provider.
6. Through the Company’s website, personal-related information such as cookies (as defined in Article 2, Paragraph 7 of the Act on the Protection of Personal Information) may be provided to third parties such as advertising providers. In such cases, the Company confirms that the third party has obtained the individual’s consent and will treat the information as personal data accordingly.

7. Disclosure of Retained Personal Data

1. Upon receiving a request from an individual for the disclosure of their retained personal data, the Company shall promptly disclose such data. However, all or part of the data may not be disclosed if any of the following conditions apply. If a decision is made not to disclose the data, the Company shall promptly notify the individual of the reason. Please note that a fee prescribed by the Company will be charged for such disclosure.
1. If there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party
2. If there is a significant risk of interference with the proper execution of the Company’s operations, or if it would result in a violation of laws or regulations
2. Notwithstanding the above, information other than personal data—such as usage history—will not be disclosed in principle.

8. Correction of Retained Personal Data

1. If the retained personal data held by the Company is found to contain inaccuracies, the individual may request correction, addition, or deletion (hereinafter referred to as “Correction, etc.”) in accordance with the procedures prescribed by the Company.
2. If the Company determines that the request from the individual has merit and that it is necessary to comply, the Company shall promptly carry out the Correction, etc. of the relevant retained personal data.
3. If the Company performs the Correction, etc. as prescribed in the preceding paragraph, or decides not to do so, the Company shall promptly notify the individual of the decision.

9. Suspension of Use, etc. of Retained Personal Data

1. If an individual requests the suspension of use or deletion (hereinafter referred to as “Suspension, etc.”) of their retained personal data on the grounds that any of the following conditions apply, the Company shall promptly conduct the necessary investigation:
1. The data is being handled beyond the scope of the stated purpose of use
2. The retained personal data was obtained through fraudulent or improper means
3. The data is being used in a way that may promote or induce illegal or unjust acts
4. The Company no longer needs to use the retained personal data
5. There has been, or is likely to be, a leakage, loss, or damage (hereinafter “Leakage, etc.”) of retained personal data that includes sensitive personal information
6. Leakage, etc. of retained personal data has occurred or is likely to occur, which may result in financial harm due to unauthorized use
7. Leakage, etc. of retained personal data has occurred or is likely to occur due to suspected malicious intent
8. Leakage, etc. involving more than 1,000 individuals has occurred or is likely to occur
9. The handling of the retained personal data is likely to infringe on the rights or legitimate interests of the individual
2. Based on the results of the investigation under the preceding paragraph, if the Company determines that the request should be granted, it shall promptly implement the Suspension, etc. of the relevant retained personal data.
3. When the Company has implemented Suspension, etc. in accordance with the preceding paragraph, or has decided not to do so, it shall promptly notify the individual of its decision.
4. Notwithstanding the preceding two paragraphs, if the Suspension, etc. would require excessive costs or is otherwise difficult to implement, and alternative measures can be taken to protect the rights and interests of the individual, the Company shall take such alternative measures.

10. Security Measures for Retained Personal Data

The Company implements the following safety measures:

1. Designation of a Personal Information Manager
2. Training sessions on APPI and related laws for employees
3. Internal rules on handling personal information
4. Security systems to prevent unauthorized access
5. Monitoring compliance at data server operators
6. Any other measures deemed necessary by the Company

11. Changes to the Privacy Policy

1. The Company may revise the contents of this Privacy Policy, except as otherwise stipulated by laws, regulations, or the Privacy Policy itself, in order to respond promptly to amendments to the Act on the Protection of Personal Information or other relevant laws and to enhance the protection of personal information.
2. Unless otherwise specified by the Company, the revised Privacy Policy shall take effect from the date it is published on the Company’s website.

12. Compliance with Laws and Regulations

The Company complies with the APPI, other relevant Japanese laws, and internal rules regarding the handling of personal information.

13. Contact Us

ATRUSTIA LLC.
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Last modified
Feb 9, 2026