Leverages Group(the “Group”) will take the following measures to properly handle the personal information provided by customers, officers, employees and all other stakeholders of the Group.

1.Obtaining, using and providing personal information

We will properly obtain, use and provide personal information to the extent necessary to conduct our business.

We will use the personal information we obtain only for our intended purposes, and will take measures to prevent the unintended use of such information.

Also, in the event that the handling of personal data is outsourced in whole or in part, we will select a company that satisfies sufficient selection criteria.

2.Compliance with laws and regulations, guidelines, and standards regarding personal information

When handling personal information, we will comply with laws and regulations, guidelines established by relevant governmental authorities, and other standards regarding the protection of personal information.

3.Proper management of personal information

We will take appropriate security control measures necessary to prevent any leakage, loss, alteration or other mishandling of personal information.

4.Responding to complaints and inquiries

We will respond promptly to complaints and inquiries regarding personal information.

5.Measures to protect personal information

We will manage the handling of personal information and our personal information protection system for proper implementation, and will continue to review and improve measures to protect personal information.

Handling of Personal Information

Purpose of using personal information

Personal information provided to the Group will be used for the following purposes.

If the purpose for which personal information will be used is separately specified to an individual at the time his/her personal information is collected, the personal information will be used for that purpose.

1）Information about individual customers

To carry out procedures related to registration for the use of services offered by the Group;
To provide information about and offer services that a customer has inquired about or ordered;

If a customer uses multiple services offered by the Group, we may view and use the customer’s personal information across services.

To provide information related to the services ordered by a customer (including other services offered by the companies in the Group or any other service providers);

We may obtain (not only directly from a customer, but also from advertisers and other third parties; the same applies below) usage log information such as cookies, device information, IP addresses, attribute information, location information, advertising identifiers, and action history (i.e., the history of opening emails, clicking links, and browsing websites, etc.) and use such information after checking it against the customer’s registration information and other personal information held by Leverages.
In addition to emails and telephone calls, we may also provide information through the distribution of Internet advertisements (including targeted advertisements).

To accurately record and review the content of calls (including online calls) and to improve the quality of customer service;

We may record or videotape calls from customers or Leverages by telephone, online conferencing systems or any other means.

To use information for analysis, statistical processing, and machine learning to develop and improve the services ordered by a customer and any other services;

Depending on the services used, we may continue to use a customer’s information after the customer’s membership has terminated.
We may obtain usage log information and use such information after checking it against the customer’s registration information and other personal information held by Leverages.

To request a customer’s cooperation in participating in surveys and other events related to the Group’s business activities; and

We may obtain usage log information and use such information after checking it against the customer’s registration information and other personal information held by Leverages, to select an individual to whom we will make such request.

To conduct investigations into any prohibited matters as set forth in the terms and conditions of the services ordered by a customer, and to take action based on such investigations.

※Please note that some of the documents received may not be returned.

2）Information about officers/employees of business partners (including their subcontractors, etc.)

To carry out procedures related to registration for the use of services offered by the Group;
To provide information about and offer services that a customer has inquired about or ordered;

We may obtain (not only directly from a customer, but also from advertisers and other third parties; the same applies below) usage log information such as cookies, device information, IP addresses, attribute information, location information, advertising identifiers, and action history (i.e., the history of opening emails, clicking links, and browsing websites, etc.) and use such information after checking it against the customer’s registration information and other personal information held by Leverages.
If a customer uses multiple services offered by the Group, we may view and use the customer’s personal information across services.

To provide information about services and related information and to hear requests;

In addition to emails, telephone calls and other communications, we may also provide information through the distribution of Internet advertisements (including targeted advertisements).
If a customer uses multiple services offered by Leverages, we may view and use the customer’s personal information across services.

To accurately record and review the content of calls (including online calls) and to improve the quality of customer service;

We may record or videotape calls from customers or the Group by telephone, online conferencing systems or any other means.

To manage business partners;
To use information for analysis, statistical processing, and machine learning to develop and improve the services a customer orders and any other services;

We may obtain usage log information and use such information after checking it against the customer’s registration information and other personal information held by the Group.

To request a customer’s cooperation in participating in surveys and other events related to the Group’s business activities; and

We may obtain usage log information and use such information after checking it against the customer’s registration information and other personal information held by the Group, to select an individual to whom we will make such request.

To conduct investigations into any prohibited matters as set forth in the purpose of use of the services ordered by a customer, and to take action as a result of such investigations.

※Please note that some of the documents received may not be returned.

3）Information about other parties involved

Information obtained from public domain or disclosed specifically

To establish a business relationship;
To provide information and send materials about services offered by the companies in the Group and alliance partners; and
To use information for analysis, statistical processing, and machine learning to develop and improve services.

Information obtained as a result of outsourcing business to the Group

To carry out the outsourced business

Information obtained when receiving inquiries, etc.

To respond to inquiries, etc.;
To conduct identity verification;
To provide information and send materials about services offered by the companies in the Group and alliance partners;
To accurately record and review the content of calls (including online calls) and to improve the quality of customer service; and
To understand service usage, and to aggregate and analyze data, and prepare statistical materials for quality improvement.

Information obtained through public relations interviews

To publish information in the public relations and other media of the companies in the Group; and
To announce public relations activities.

Information about survey respondents, campaign and event participants, gift applicants, etc.

To conduct prize drawings and send out prizes;
To contact respondents, participants, and applicants; and
To administer and conduct campaigns and other events for which participants have registered.

Information about office visitors

To ensure security control for crime prevention or other purposes

Information about applicants for employment with the Group

To conduct employment screening and make employment decisions; and
To clarify the Group’s employment criteria, and to conduct analysis in order to improve the efficiency of employment screening (including, among other things, comparison with the data of the Group’s employees at the time of their application and screening).

Provision and sharing of personal information to and with third parties

1）We may provide information about individual customers to third parties for the purpose of providing the services ordered by those customers:

Recipient: job providers

[Situations in which information will be provided]

Use of employment placement services

In the job placement services provided by our employment recruiters, the Group will provide information to job providers on your behalf.

Scouting by job providers for job seekers

If a job provider uses the scouting service, information can be viewed by the job provider.

Provision of information by job seeker including application for a job, etc.

Information will be provided to the job provider by operating the application screen.

When registering for an event

Registration information will be provided to the companies attending the event on behalf of the registrant.

When responding to a questionnaire prepared by job providers

Information may be provided by the Group on behalf of the job seeker.

[Details to be provided]

Information registered by users in Leverages’ system (The details required in the situations in which such details are provided will be provided.)

No user’s name, address (excluding prefecture), date of birth (but age will be disclosed) or contact information will be provided in the scouting service.

Information that users have provided to an employee of the Group (in the case of job placement, the information provided at the time of the job placement)
Service usage and activity history (In the scouting service, the information processed based on the service usage and activity history will also be provided.)

Recipient: job placement agencies

[Situations in which information will be provided]

When other job placement agencies contact job seekers, introduce them to jobs, or invite them to interviews as a result of providing the services ordered by users, information will be provided on behalf of the users.

Contact with job seekers by job placement agencies

Information will be made available to other job placement agencies as a result of providing the services ordered by users.

Request for interviews with job placement agencies

After a job placement agency contacts a job seeker, information will be provided if the job seeker wishes to interview with the job placement agency that has a job opening.

[Details to be provided]

Information registered by users in Leverages’ system (The details required in the situations in which such details are provided will be provided. No user’s name, address (excluding prefecture), date of birth (but age will be disclosed) or contact information will be provided unless the user wishes to contact other job placement agencies.)
Service usage and activity history (The information processed based on the service usage and activity history will also be provided.)

※In addition to the foregoing, we may provide information to third parties if we have obtained the user’s consent.

2）Additional matters regarding the provision of user information to third parties located in foreign countries

If a user applies to a foreign job provider through the services provided by the Group, the personal information provided by Leverages to the job provider will be handled under the system of the country or region where the job provider is located. See below:

Name of the foreign countries (third parties) to which the information will be provided

The country where the job provider is located

Personal information protection system in the foreign countries (third parties) to which the information will be provided

For details on the personal information protection system of the country where the job seeker with whom users have searched or applied for a job is located, please refer to the “Documents Providing Information” in the “Survey of Personal Information Protection Systems in Foreign Countries” section on the Japan Personal Information Protection Commission’s website.
https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku

Personal information protection measures to be taken by persons to whom the information will be provided (third parties)

The agreements entered into with the job providers to whom the information will be provided require the job seekers to comply with the personal information protection system of the country in which the job providers are located.

3）Sharing information about officers and employees of business partners

In order to provide comprehensive services that utilize the expertise of each group company, the Group will share information about officers and employees of its business partners as follows:

Details of personal information to be shared

Name, organization name, department name, address, job title, email address, telephone and facsimile numbers, and past history of transactions, business negotiations and communications

Scope of persons with whom personal information will be shared

Group Companies

Purpose for which persons with whom personal information is shared will use such personal information

To provide information about and offer services to be offered by the Group and related information, and to hear requests

Person responsible for managing personal information to be shared

Leverages Co., Ltd.
Shibuya Scramble Square, 24F, 25F, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6190 Japan
Tomohide Iwatsuki, President and CEO

Method of obtaining personal information

By receiving personal information from customers in the course of, among other things, exchanging business cards, conducting business negotiations, applying for transactions, attending events, and responding to questionnaires;
By collecting information that is generally and widely available to the public; and
As a result of customers opening and reading emails sent by the companies in the Group, and browsing websites.

4）Sharing information about individual customers

In order to provide comprehensive services that utilize the expertise of each group company, the Group will share information about individual customers as follows:

Details of personal information to be shared

Name, sex, address, telephone number, email address, date of birth, experience, work history, education, and other information

Scope of persons with whom personal information will be shared

Group Companies

Purpose for which persons with whom personal information is shared will use such personal information

To provide information about and offer services to be offered by the Group and related information, and to hear requests

Person responsible for managing personal information to be shared

Leverages Co., Ltd.
Shibuya Scramble Square, 24F, 25F, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6190 Japan
Tomohide Iwatsuki, President and CEO

Method of obtaining personal information

In writing, by email or other electromagnetic means of communication

5）Provision of personal information to third parties pursuant to laws and regulations

Personal information may be provided to third parties in accordance with laws and regulations, including pursuant to each item of Article 27, Paragraph 1 of the Act on the Protection of Personal Information.

Receipt of personal information from the Group’s business partners, etc.

The Group may receive personal information from job providers or other persons to whom individual customers have submitted applications using services provided by the Group. In such case, the Group will properly receive personal information in writing or by electromagnetic means.

1）Purpose for which Leverages will receive personal information

To confirm chargeable services with job providers or other persons to whom individual customers have submitted applications using Leverages’ services;
To operate Leverages’ services that individual customers will use and to communicate with and provide information to individual customers as a result of such operation; and
To improve and newly develop Leverages’ services and to conduct incidental research, analysis and marketing.

2）Details of personal information to be received

The fact, status and results of using services provided by the Group

Voluntary provision of personal information

The Group asks all stakeholders to provide us with their personal information to the extent necessary for the purposes described herein. The provision of personal information is voluntary, except where required by law (e.g., to verify their identity or foreign resident status, or to provide their individual numbers (e.g., “My Numbers”). However, the Group may not be able to provide its services or fulfill other requests if customers do not comply with the Group’s request or if the information they provide is insufficient.

Handling of sensitive personal information (yōhairyo kojin jōhō)

The Group will not obtain, use or provide to any third party any sensitive personal information (i.e., personal information, etc. containing statements, etc. specified by a Cabinet Order as the information the handling of which requires special care so as not to cause unfair discrimination or prejudice against or other disadvantage to the person concerned, such as race, creed, social status, medical history, criminal record, or the fact of being a crime victim), except in accordance with laws and regulations or where the customer’s consent has been obtained in advance.

Use of statistical data

Based on the personal information provided by customers, the Group may, in accordance with the procedures prescribed by law, create statistical data or anonymized personal information (tokumei kakō jōhō) that has been processed to avoid the identification of those customers. The Group may use the statistical data that cannot identify customers without any restrictions.

Security control measures

The Group implements the following security control measures for retained personal data (hoyuu kojin deta):

[Organizational security control measures]

In order to implement security control measures for personal data, an information manager has been appointed in each department as the person responsible for management.
In the event of an actual or threatened leakage or other accident involving personal data, we will take the necessary measures, such as promptly investigating the facts and determining the cause, on a case-by-case basis in accordance with Leverages’ reporting and communication system.
We have established and implemented internal manuals regarding the handling of personal data, and we regularly review system usage through access logs and other means.

[Personal security control measures]

We regularly train and inform employees about the rules and points to keep in mind when handling personal data, as well as the cases of incidents that have occurred at other companies.
The obligation of employees to maintain the confidentiality of personal data during and after the employment is set forth in the employment rules and other internal regulations.

[Physical security control measures]

We take security measures, such as requiring visitors to carry IC cards or other forms of identification when entering or leaving the Group’s offices.
We restrict the equipment and other devices that can be brought into our offices, and store personal data in a lockable location, on a server or in another environment that requires authentication.
When personal data is destroyed, it is dissolved or shredded so that it cannot be recovered.
When electronic devices or other items are moved or taken away, they are password-locked to prevent leakage of personal data.
We prevent the loss, theft or other incidents involving personal data by storing it on devices or other platforms that are encrypted, on file servers with advanced security measures, or in the cloud or other locations.

[Technical security control measures]

We implement access control by restricting access to personal data by IP addresses when such data is used, requiring IDs and passwords for database access, using two-factor authentication, and limiting the number of employees who can view personal data based on the type of such personal data.
We ensure that security software is installed on devices used by employees.

[Understanding the external environment]

Please contact the support desks to inquire about how we understand the external environment. We will respond to each inquiry according to the Group’s services that the customer uses.

Acquisition of Personal Information by Methods Not Easily Recognizable by the Individual

This website may use cookies, web beacons, and other technologies for the purpose of improving services and obtaining statistical information on access conditions, etc. However, personal information that has not been entered by the data subject will not be obtained through the use of these technologies.

1）Cookies

What is a cookie?

A cookie is a mechanism that stores in your computer as a file the usage history, input contents, and other information sent and received between your browser and the server when you browse a website. The next time you access the same page, the website operator can use the information in the cookie to change the display for each user. If the browser settings allow cookies to be sent and received, the website can retrieve cookies from the user's browser. For privacy protection, the user's browser will only transmit cookies sent and received by the server of the website browsed.

About cookie settings

You can choose to “Allow all cookies,” “Reject all cookies,” or “Notify me when cookies are received” for settings related to the sending and receiving of cookies. The setting method varies depending on your browser, so please check the “Help” menu of your browser. Please note that if you choose to reject all cookies, you may not be able to use services that require authentication, or you may be restricted from using various services on the Internet.

2）Web beacons

Some pages on our website use web beacons for the purpose of obtaining statistical information on the usage of our services and improving our services. Information obtained through the use of web beacons does not contain any information that may identify individuals.

3）International mobile equipment identifier of mobile terminals

The international mobile equipment identifier of a mobile terminal is a number sent by a user's mobile terminal to distinguish the mobile terminal when the user accesses this site with the mobile terminal, and is used for access management and other purposes. The international mobile equipment identifier does not include the user's cell phone number, e-mail address, name, or any other information related to the user's privacy. International mobile equipment identifiers alone cannot be used to identify individual registered users.

Please refer to "About Infomative Data" for the purpose of use, provision to third parties and other conditions relating to information listed at 1) to 3) above.

Request for disclosure, etc. of personal information

1）Request procedure

With regard to the disclosable personal information (kaiji taishou kojin jouhou) held by the Group, requests for notification of the purpose of use, disclosure, correction, addition or deletion of content, suspension of use, erasure, and suspension of provision to a third party, as well as disclosure of records of provision to a third party (the “Request for Disclosure, etc.”) from the individual or his/her representative will be handled promptly in accordance with the procedures prescribed by the Group.

However, if responding to the Request for Disclosure, etc. results in any of the following, we may not do so and will explain to the individual or his/her representative that we are unable to respond to the request and the reason therefor:

if responding to the Request for Disclosure, etc. is likely to harm the life, body, property, or other rights or interests of the individual or a third party;
if responding to the Request for Disclosure, etc. is likely to seriously impede the proper conduct of the Group’s business; or
if responding to the Request for Disclosure, etc. results in a violation of any law or regulation.

If we delete or suspend the use of personal information, the individual may not be able to use our services that he/she is currently using.

We will also dispose of personal information that is no longer needed as a result of the termination of the Group’s services in accordance with the Group’s rules.

2）Certificates and other documents required in the request procedure

In the case of the individual himself/herself:

Please enclose a copy of one of the following identification documents when making the Request for Disclosure, etc. If the address is not “the same as” the registered domicile (honsekichi), please blacken or otherwise delete the registered domicile.

driver’s license;
health insurance card;
my-number card;
pension book;
residence card; or
passport.

In the case of a representative:

If a representative is making the Request for Disclosure, etc., please submit the following identification documents (copy) in addition to the document listed above. Please make sure that the current address is verifiable and that the “registered domicile” section is blacked out.

For a legal representative:

A document confirming that the legal representative has the right of legal representation (a copy of the family register (koseki touhon) or, in the case of a person with parental authority, a copy of the health insurance card, etc. with the dependent(s) filled in); and
A document verifying the identity of the legal representative (a copy of the driver’s license or health insurance card of the legal representative).

For a representative appointed by power of attorney:

A power of attorney; and
A document for verifying the identity of the representative (a copy of the driver’s license or health insurance card of the representative).

We will use the personal information provided in the Request for Disclosure, etc. to the extent necessary to process the Request for Disclosure, etc. The identification documents or documents confirming the representative received will be disposed of by appropriate means immediately after verification. The disclosure request form for which a certain period of time has elapsed after the completion of the procedures will also be disposed of by appropriate means.

Where to make the Request for Disclosure, etc.

Please contact the Group’s inquiry counter below to make the Request for Disclosure, etc. Then, please complete the form provided by Leverages by mail (disclosure request form), and return it to us along with the identification documents listed in paragraph 2 above. We do not charge any fee for providing notice of the purpose of use or disclosure of personal information.

A response to the Request for Disclosure, etc. will be sent by email or in writing to the address provided within fourteen (14) business days of receipt of the completed disclosure request form and identification documents.

[Inquiries]

Shibuya Scramble Square, 24F, 25F, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6190 Japan

Customer Service of the Leverages Group Companies

Email address: privacy@leverages.jp
TEL: +81 (0)3-5774-1632

※ Inquiries received on Saturdays, Sundays, holidays, year-end and new-year holidays, and other non-business days of the Group will be answered on the next business day or later.