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

Purposes of using personal information

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

If the purposes for which personal information will be used are separately specified to an individual at the time his/her personal information or other customer information is collected such as the purposes of use are set out in the relevant terms of service, those purposes are included.

In addition, personal information may be used together with other customer information.

1）Information about individual customers

• To carry out procedures related to registration for the use of services offered by the Group and identity verification;
• 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, partnered service providers or any other service providers), introduce other services, assess usage;
• 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 the Group.
• 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 the Group by telephone, online conferencing systems or any other means.
• To use information for analysis to develop and improve the services ordered by a customer and any other services, analysis of service registration channels, statistical processing, machine learning, and deep learning including large language model;
• 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 the Group.
• To request a customer’s cooperation in participating in surveys and other events related to the Group’s business activities;
• 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 solicit persons to be interviewed for creating articles;
• 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; and
• To conduct other services related or incidental to the foregoing services.

※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 the Group.
• 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, partnered service providers or any other service providers), introduce other services, assess usage;
• 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 the Group, 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, deep learning including large language model 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;
• 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 solicit persons to be interviewed for creating articles;
• 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; and
• To conduct other services related or incidental to the foregoing services.

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

3）Information about other parties involved

(i) 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 to develop and improve services, statistical processing, and machine learning, and deep learning including large language model.

(ii) Information obtained as a result of outsourcing business to the Group

• To carry out the outsourced business

(iii) 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, partnered service providers and other service providers;
• To accurately record and review the content of calls (including online calls) and to improve the quality of customer service; and
• We may record or videotape calls from customers or the Group by telephone, online conferencing systems or any other means.
• To understand service usage, and to aggregate and analyze data, and prepare statistical materials for quality improvement.

(iv) 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.

(v) 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.

(vi) Information about office visitors

• To ensure security control for crime prevention or other purposes; and
• To manage appointments and records of visitors to the Group’s facilities or equipment.

(vii) Information about applicants for employment (including internship) with the Group

• To conduct recruitment for the Group (not limited to the companies to which applicants applied);
• To conduct employment screening, make employment decisions, and conduct interviews;
• To manage personnel affairs of applicants after joining;
• To give invitations to and accept applications for explanatory sessions of the Group (not limited to the companies to which applicants applied);
• To give information and send materials regarding the Group (not limited to the companies to which applicants applied);
• To clarify Leverages’ and 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); and
• To conduct other services related or incidental to the foregoing services.

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

Provision and sharing of personal information to and with third parties

1）We may provide and disclose information about individual customers to third parties as set out below:

Recipient: companies, entities, organizations that use the services of the Group or partnered service providers (“Business Partners”)

[Situations in which information will be provided]

• Use of the Group’s services
• The Group will on behalf of customers or by itself provide information about customers to Business Partners that use the services provide by the Group or partnered service providers, or will disclose such information by making available or posting it on websites or applications accessible by such Business Partners, as provision of services including giving information on jobs or positions or scouting for, freelancers, full-time employees, or temporary employees based on request from customers and for the purpose of facilitating consideration, screening, or other activities at the relevant Business Partners. In such provision or disclosure of information, the Group may provide or disclose only certain part of the information about customers held by the Group by making certain part of information unavailable.
  Besides, the foregoing services may be provided in the following situations:
• Provision of information by individual customer including application for a position or 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 individual customer.
• The Group will provide Business Partners with information to the necessary extent as provision of services of temporary staffing, personnel education (school), provision of platform, residence-broker service, owned media, or other Group’s services.

[Details to be provided]

• Information regarding customer’s profile including the customer’s name, contact information (e.g. address, telephone number, email address), qualifications, academic and professional careers, information regarding usage of service including responses to questionnaires and analysis thereof, and other information provided to the Group from the customer or developed from provided information
• Information that individual customers 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 individual customers.

• 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 regarding customer’s profile including the customer’s name, contact information (e.g. address, telephone number, email address), qualifications, academic and professional careers, information regarding usage of service including responses to questionnaires and analysis thereof, and other information provided to the Group from the customer or developed from provided
• Information that individual customers 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 (the information processed based on the service usage and activity history will also be provided)

Recipient: clients of temporary staffing service

[Situations in which information will be provided]

Information may be provided to clients of temporary staffing service pursuant to the Temporary Staffing Act or other laws and regulations, or in order to respond to inquiries regarding qualifications of temporary staff from the clients of temporary staffing service.

[Details to be provided]

Information that temporary staff registered in the Group’s system and information regarding ability to perform jobs (including certificate of qualification such as nurse licensure).

Recipient: partnered service providers (e.g. real estate companies having business with the Group)

[Situations in which information will be provided]

Information may be provided on behalf of the customers to partnered service providers of the Group to introduce services provided by the partnered service providers.

[Details to be provided]

Name, telephone number, address of the customers and other information provided to the Group from the customer (the details required in the situations in which such details are provided will be provided).

Recipient: partnered service providers (service providers engaged to promote the Group’s services).

[Situations in which information will be provided]

Information may be provided to service providers engaged to promote the Group’s services for marketing activities including advertising delivery as well as for measuring the advertising effectiveness, improving advertising, and expanding targets thereof.

[Details to be provided]

Registered information of users, various dates such as date of registration, and other personal information held by the Group (information required for advertising delivery and measurement of advertising effectiveness).

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

※Unless otherwise specified, personal information shall be provided any of the following means: web system secured by encryption or other means; email or other electromagnetic means of communication; FAX; oral communication over the phone or in person; or personal deliver of document.

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

If a user seeks or applies for a job in a foreign company, if an enterprise located in a foreign country undertakes scouting or recruitment through services operated by the Group, or if the Group needs to provide personal information of the user to provide its services, the Group may provider personal information of the user.

Details to be provided are as set out in the preceding paragraph,

For details of recipient, see below:

3) 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.

4) Sharing information about individual customers, officers and employees of business partners, and other stakeholders

In order to provide comprehensive services that utilize the expertise of each Group Company, the Group will share information about individual customers, officers and employees of its business partners, and other stakeholders as follows:

• (i)Details of personal information to be shared
• Information regarding profile including name, contact information (e.g. address, telephone number, email address), organization name, department name, address, job title, email address, telephone and facsimile numbers, and past history of transactions, business negotiations and communications, qualifications, academic and professional careers, and other information required for provision of the Group’s services.
• (ii)Scope of persons with whom personal information will be shared
• Group Companies (including Group Companies located in foreign countries)
  https://leverages.jp/en/company/
  ※ If personal information is shared with a Group Company located in a foreign country, the Group will ensure that the Group Company located in the foreign country has in place a system compliant with standards.
• (iii)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;
• To make contact about job offers or position offers, or jobs from the Group;
• To provide services related to job offers or position offers from the Group;
• To conduct recruitment for the Group (not limited to the companies to which applicants applied);
• To manage personnel or labor affairs in the Group or restructure the organization in the Group; and
• To hear requests or otherwise for the purpose of use set out in “1. Purpose of using personal information.”
• (iv)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

Disclaimers regarding provision of personal information to third parties

The Group will not be liable in any way for acquisition of personal information by a third party in any of the following cases:

1) A user discloses his/her own personal information by himself/herself to a job provider or other third parties using a function of Group’s services or other means;

※ For example, such event may occur from registration of the following information when the user registers his/her profile or skill sheet with the Group’s services:

• Detailed description of work experience with proper nouns that may easily envisage the user;
• Photographs that can clearly identify the user;
• Records of writing including books and research paper; and
• IDs, account names or links of public web services such as social media.

2)The third party identifies the user by information posted on public web services such as social media by the user in relation to the use of the Group’s services;

3)A person other than the user obtains information that can identify the user; and

4)There is no reason attributable to the Group.

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.

Purpose for which the Group will receive personal information

• To confirm chargeable services with job providers or other persons to whom individual customers have submitted applications using the Group’s services;
• To operate the Group’s 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 the Group’s services and to conduct incidental research, analysis and marketing.

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 may obtain 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) in accordance with laws and regulations or based on the customer’s consent or request, and may provide the same to third parties within the extent permitted by the laws and regulations, or consent or request.

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 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.

Anonymized personal information (tokumei kakō jōhō)

The Group will continuously create anonymized personal information that is made impossible to identify an individual person or restore personal information pursuant to an appropriate processing method under laws and regulations, and will provide such anonymized personal information to the extent specified in paragraph 2.

Anonymized personal information to be created or provided will include information on personal attributes of customers such as their name, sex, date of birth, experience and history. The information will be provided in writing, orally over the phone, by FAX, delivery of electromagnetic recording media, or electromagnetic communication means such as email.

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 the Group’s 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]

• If the Group keeps personal data abroad, it will take security control measures with understanding of the personal information protection laws in the country in which the Group keeps the personal data.
• 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

• a.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.
• b.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 the Group’s website use web beacons for the purpose of obtaining statistical information on the usage of the Group’s services and improving the Group’s 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.

Amendments to this Privacy Policy

The Group may amend this Privacy Policy at its discretion to the extent that does not violate laws and regulations.

Request for disclosure, etc. of personal information

1）Notice of purpose of use, or disclosure of personal information or records of provision to a third party

With regard to the disclosable personal information (kaiji taishou kojin jouhou) held by the Group, requests for notification of the purpose of use, or disclosure of such information or disclosure of records of provision to a third party from the individual or his/her representative will be handled promptly in accordance with the procedures prescribed by the Group.

However, if responding to such request 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:

• (i)if responding to the request is likely to harm the life, body, property, or other rights or interests of the individual or a third party;
• (ii)if responding to the request is likely to seriously impede the proper conduct of the Group’s business; or
• (iii)if responding to the request results in a violation of any law or regulation.

2) Correction, addition, deletion

With regard to the disclosable personal information held by the Group, requests for correction, addition, or deletion from the individual or his/her representative will be handled promptly in accordance with the procedures prescribed by the Group, and such information will be corrected, added, or deleted to the extent permitted under the Personal Information Protection Act.

Please note that if we delete personal information, the individual may not be able to use our services that he/she is currently using.

3) Suspension of use or erasure, or suspension of provision to a third party

With regard to the disclosable personal information held by the Group, requests for suspension of use or erasure, or suspension of provision to a third party from the individual or his/her representative will be handled promptly in accordance with the procedures prescribed by the Group and handled appropriately in accordance with the Personal Protection Information Act.

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

4）Request procedure, etc.

If you would like to make any of the requests set out in 1) to 3) above (a “Request for Disclosure, etc.”), please complete the form specified by the Group (application form for disclosure, etc.), and return it to us along with the identification documents listed in paragraph a or b below. We do not charge any fee for providing notice of the purpose of use or disclosure of personal information.

A response to a 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 application form for disclosure, etc. and identification documents.

a. In the case of the individual himself/herself:

Please enclose a copy of one of the following identification documents when making a 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.

b. 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 application form for disclosure, etc. for which a certain period of time has elapsed after the completion of the procedures will also be disposed of by appropriate means.

[Inquiries]

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

Customer Service of the Leverages Group Companies

• Inquiry form
• 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.

※ We will not accept a Request for Disclosure, etc. via telephone or inquiry form. We will accept such Request only through the procedures under paragraph 12,2) and 4) above.