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About the handling of personal information

1．Purpose of use of the personal information we gather

Personal information gathered by our company is used for the following purposes.

(1)Purpose of use of the personal information we gather

    1.Personal information of service users
  • -For service provision, and to contact users and respond to inquiries regarding service provision.
  • -To provide information regarding events, seminars, campaigns, etc., related to our services, and to contact users and respond to inquiries regarding information provision
  • -Surveys and research
  • -New service and new function development, service improvements, and quality improvements
  • -To create statistical data processed in a format that does not enable the identification of individuals and marketing using said information
    2.Personal information related to business partners
  • -Communication and management related to transactions
    3.Personal information related to employment management for all employees
  • -Human resource management, etc.
    4.Personal information related to persons seeking employment
  • -Hiring selections, etc.
    5.Personal information related to shareholders and investors
  • -IR activities, inquiry response, etc.
    6. Personal information related to persons sending inquiries
  • -Inquiry response

(2)Purpose of use of personal information gathered from client companies

    1.Personal information received from client companies
  • -Fulfillment of contracted duties

2.Name of company

Geniee, Inc. Tomoaki Kudo, President and CEO

3.Affiliation, title of personal information protection supervisor

Manager, R&D Division, Management Information Systems Development Dept.

4.Provision of gathered personal information to third parties

We do not provide gathered personal information to any third parties without the consent of the individual. However, in some cases we do provide information to overseas group subsidiaries based on necessity related to administrative processing.

5.Shared use of gathered personal information

We do not allow the shared use of gathered personal information without the consent of the individual.

6.About the consignment of gathered personal information

We conduct necessary and appropriate supervision when consigning gathered personal information.

7.Security management for personal information

We implement necessary security management measures to ensure the protection of gathered personal information. Upon completion of the purpose of use for gathered personal information, we will take responsibility for ensuring the appropriate disposal or deletion of said information.

8.Procedures for requesting disclosure, etc.

The individual who has provided personal information may request notification concerning purpose of use, the disclosure, revision, addition and deletion of personal information provided to us. Furthermore, the individual may request the stoppage of use and the removal from or stoppage of use by third parties in relation to provided personal information. Contact the following Personal Information Help Desk to issue a request.

9.Discretional nature of providing personal information and cases when we cannot receive provision

The individual providing personal information does so at his or her own discretion with acknowledgement of the purpose of use set forth in Paragraph 1. If the personal information we request is not provided, we may not be able to execute the operations stated as the purpose of use for personal information set forth in Paragraph 1.

10.Inquiries, complaints, and consultation regarding the handling of personal information

Inquiries, complaints, and consultation regarding the handling of personal information should be sent to the following Personal Information Help Desk.

Sumitomo Realty & Development Shinjuku Oak Tower 6th Floor, 6-8-1 Nishi Shinjuku, Shinjuku-ku, Tokyo 163-6006
TEL：+81-3-5909-8181 (main) FAX：+81-3-5909-8182

URL：https://en.geniee.co.jp/inquiry/

Privacy Policy of EU Personal Data

(Created on May 28, 2018)

Geniee, Inc. (''Geniee'') defines our privacy policy of EU Personal Data for the operation of services we provide as follows. Furthermore, we may revise all or a part of this Privacy Policy of EU Personal Data. Notifications concerning important changes will be placed on our website.

    1.EU Personal Data

    ‘‘EU Personal Data'' means any information relating to an identified or identifiable natural person (you) within the EEA (European Economic Area) region, such as your name, date of birth, email address, or other data set forth in Article 2 of this Privacy Policy of EU Personal Data.

    2.Information Geniee collects and uses

      （1）Information that you provide to us:

    • When you register for and use our services, we collect the information that you provide to us, such as your name, email address, phone number, date of birth and language.

      • （2）Information we collect or receive:

    • When you use our services or our third-party partners’ services, we may collect the following information of you.
    1. Information about your browser
    2. Cookies
    3. Information about your device, including operating system, model, device indentifiers such as your IDFA or AAID
    4. Your geographic location
    5. IP address
    6. Information about your activity on web pages or apps visited or used. We do not passively track your activity but only receive information about your activity in connection with requests specifically made to our system to serve you an ad, measure your interaction with an ad or to place you into an interest-based category for future use by a client to help make the ads they show to you more relevant.
    7. Information about ads served, viewed or clicked on, including the type of ad, where the ad was served, whether you clicked on it and whether you visited the advertiser's website or downloaded the advertiser's app.
    8. Information about you or inferences about your interests that a third-party partner has collected about you and shared with us such as information about your interests or demographic information (your age or gender) or to help make the ads served to you more relevant. For clarity, we do not independently collect information about your interests or demographic information for use within our system, but we do allow our third-party partners to utilize their own data or third-party data they have access to in connection with the services.
    9. Information about your internet service including information about which Internet Service Provider (ISP) is used by you.

    3.Purpose and legal basis of using EU Personal Data

    （1） We use the information you provided to us for the following purposes:

    1. To provide, maintain and improve various services operated by us and to provide information related to said services.
    2. To prevent the use of services operated by us in ways that violate the terms of use.

    （2） We may use the information we collected for the following purposes:

    1. We may use cookies or other technologies on some of the features of our services. Cookies help us to ensure the safety and smooth functioning of certain features of our services and they also help us to collect information about your user preferences. We sometimes use information collected from cookies to improve your user experience and the quality of our services. For example, by saving your user preferences, we may be able to customize our services in ways that you prefer. You may be able to disable cookies in your browser settings or set your browser to alert you when cookies are being used. If you disable cookies, you may not be able to use all of the features of our services.
      The legal basis for the processing pursuant to this item is Art. 6 para. 1 (b) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – “GDPR”).
    2. We also may permit our third-party partners to set cookies and use web beacons and similar technologies within our services to help us perform various internal functions necessary to operate our business and to collect information about your use of our and others’ services across your devices. We and these third parties may use that information to provide you advertisements, across the Internet and mobile applications and devices, about goods and services that may be of interest to you.The legal basis for the processing pursuant to this item is Art. 6 para. 1 (f) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – “GDPR”).
      You may have the right to object, on grounds relating to your particular situation, at any time to the processing pursuant to this item. To exercise this right you may at any time contact us as provided for in Section 8 below.

    4.How your information is shared

    （1）We may share information with other Geniee affiliated companies to process for purposes that are consistent with those disclosed in this Privacy Policy.
    The legal basis for sharing your information with our affiliated companies is Art. 6 para. 1

    (f) GDPR.
    you may have the right to object, on grounds relating to your particular situation, at any time to such sharing. To exercise this right you may at any time contact our European representative as provided for in Section 8 below.

    （2） We may provide the information you provided to us to our third-party partners as follows:

    1. advertisers
    2. advertisement distribution company
    3. research company

    The legal basis for sharing your information with our affiliated companies is Art. 6 para. 1

    (f) GDPR.
    you may have the right to object, on grounds relating to your particular situation, at any time to such sharing. To exercise this right you may at any time contact our European representative as provided for in Section 8 below.

    5.Original source of EU Personal Data

    When we do not obtain your EU Personal Data directly from you, we obtain such data from the Internet publishers which you accessed to.

    6.Period for which EU Personal Data Stored

    （1）We will store the information you provided to us until you contact us to erase your information.
    （2）We will store the information we collect or receive until the default setting term of the browser you are using.

    7.Your rights

    You have the right related to your EU Personal Data as follows, and may use your right by contacting us by the method set forth on Article 8 of this Privacy Policy of EU Personal Data.

    a. to request from us access to and rectification or erasure of EU Personal Data,
    b. to request the restriction of processing concerning the data subject,
    c. to object to processing as well as the right to data portability,
    d. to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal,
    e. to lodge a complaint with a supervisory authority.

    8.Inquiries

    Inquiries concerning this Privacy Policy of EU Personal Data, complaints, notification of the purpose of use of personal information, disclosure, revision, addition or deletion, stoppage of use, removal from or stoppage of use of personal information by third parties.

    CONTACT US

    URL:EURepresentative.Geniee@ashurst.com
    https://en.geniee.co.jp/inquiry/
    TEL：+81-3-5909-8181

    Data protection officer: Manager, R&D Division, Management Information Systems Development Dept, Geniee, Inc.
    Email: contact@geniee.co.jp

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