1. Business Operator Handling Personal Information

2. Scope

This Privacy Policy applies to User Information collected by the Company through its corporate website, “ARATAMA璞 Co., Ltd.” (https://aratama.tech/, the “Site”), as well as through inquiries, transactions, recruitment activities, events, public relations, and other corporate activities.

If a separate privacy policy applies to a specific service, website, platform, or other business operated by the Company, that separate policy will govern the handling of User Information in connection with that service or business.

The handling of User Information by external services linked from the Site is governed by the privacy policies and other terms of those external services.

3. Information We Collect

In connection with its business activities and operation of the Site, the Company may collect the following information.

Information Provided Through Inquiries and Other Communications

• Name
• Company or organization name, department, job title, and other affiliation information
• Postal address and country or region of residence
• Email address
• Telephone number
• Subject and content of inquiries, consultations, and requests
• How the user learned about the Company or the Site
• Other information provided by the user

Transaction and Project Information

• Information concerning quotations, orders, agreements, delivery, acceptance, invoices, and payments
• Information concerning clients, contacts, and other related parties
• Information concerning projects, deliverables, licenses, and rights clearance
• Information concerning meetings, conferences, events, other communications, and participation
• Other information necessary for transactions or the performance of agreements

Recruitment Information

• Name, address, contact details, date of birth, and other applicant information
• Résumés, CVs, employment history, background, achievements, qualifications, skills, and preferred terms
• Portfolios, websites, social media profiles, GitHub, LinkedIn, and other professional or creative activity information
• Information concerning interviews, selection, evaluation, and communications
• Other information provided by applicants in connection with recruitment activities

Information Collected Automatically When Using the Site

• IP address
• Cookies and other identifiers
• Device, browser, operating system, and language-setting information
• Pages viewed, access date and time, session duration, and interaction history
• Referring URLs, search information, and other access data
• Information necessary to operate and secure the Site and prevent unauthorized or fraudulent use

Other Information

The Company may obtain information from clients, service providers, business partners, event organizers, publicly available information, and other lawful sources to the extent necessary for its business activities, performance of agreements, communications, identity verification, or prevention of unauthorized or fraudulent activity.

The Company acquires User Information properly and not by deception or other wrongful means.

4. Purposes of Use

The Company uses the User Information it collects for the following purposes.

• To respond to inquiries, consultations, and requests
• To propose, consider, and communicate regarding the Company’s businesses, services, projects, and potential collaborations
• To prepare quotations and orders; enter into and perform agreements; deliver and accept work; process invoices and payments; and clear rights
• To communicate and coordinate with clients, collaborators, creators, specialists, and other related parties
• To plan, operate, and provide information regarding events, seminars, competitions, joint ventures, and other initiatives
• To provide information about the Company’s businesses, services, work, events, and other activities
• To accept recruitment applications, verify identity, conduct screening and interviews, make hiring decisions, and communicate with applicants
• To complete contracting, onboarding, and personnel administration procedures following recruitment
• To operate, maintain, improve, and analyze use of the Site
• To improve the Company’s businesses, services, content, and communications
• To prevent and respond to unauthorized access, nuisance conduct, violations of terms or agreements, and other problems
• To protect the rights, property, safety, and reputation of the Company, users, and third parties
• To respond to requests from courts, administrative authorities, and other public bodies pursuant to applicable laws and regulations
• To address disputes, complaints, incidents, data breaches, and other problems
• To carry out accounting, tax, audit, and other procedures required by law or necessary for business operations
• For purposes incidental to those listed above

If the Company needs to use User Information beyond a scope reasonably related to the purposes described above, it will obtain the individual’s prior consent unless otherwise permitted by law.

5. Cookies and Analytics

The Company may use cookies and similar technologies to improve the convenience of the Site, understand usage, improve content, maintain security, and prevent unauthorized or fraudulent use.

For these purposes, the Company may use analytics and other external services provided by third parties. Providers of these services may collect information about use of the Site through cookies and similar technologies.

Users may disable or delete cookies by changing their browser settings. However, disabling cookies may prevent certain functions of the Site from operating properly.

6. Provision of Personal Data to Third Parties

The Company will not provide personal data to a third party without the individual’s consent, except in any of the following circumstances:

• When required or permitted by law
• When necessary to protect a person’s life, body, or property and it is difficult to obtain the individual’s consent
• When particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the individual’s consent
• When cooperation is necessary for a national government agency, local government, or a person entrusted by either of them to perform duties prescribed by law, and obtaining the individual’s consent is likely to impede the performance of those duties
• When personal data is provided in connection with a succession of business
• When otherwise permitted under the Act on the Protection of Personal Information or other applicable laws and regulations

If information must be shared with clients, collaborators, creators, specialists, business partners, or other relevant parties in connection with a transaction, project, event, or other activity, the Company will provide only the information necessary, based on the individual’s consent, an agreement, or another lawful basis.

7. Provision to Third Parties in Foreign Countries

If the Company provides personal data to a third party located outside Japan, it will, unless otherwise permitted by law, obtain the individual’s prior consent and provide the information required by law, including information concerning the personal information protection system of the relevant foreign country.

8. Outsourcing the Handling of Personal Information

The Company may entrust all or part of the handling of personal information to third-party service providers to the extent necessary to achieve the purposes of use, including for operation of the Site, inquiry handling, contracting procedures, payment processing, accounting, data storage, analytics, and email distribution.

When doing so, the Company will appropriately select service providers, enter into agreements as necessary, and exercise necessary and appropriate supervision to ensure that personal information is properly handled.

9. Use of Generative AI and Other AI Systems

The Company may use generative AI and other AI systems for business operations, research, planning, production, analysis, drafting, translation, inquiry handling, and other activities.

When using AI, the Company will consider the purpose of use, the nature of the information, contractual terms, and foreseeable risks, and will take appropriate measures as necessary, such as deleting or anonymizing information, limiting the scope of information entered, and conducting human review.

Without the individual’s consent or another contractual or legal basis, the Company will not use non-public information that identifies an individual for the purpose of training generative AI models made available to unspecified third parties or building public datasets.

10. Security Control Measures

The Company implements organizational, personnel, physical, and technical security control measures to prevent leakage, loss, damage, unauthorized access, unauthorized use, and other risks relating to the personal data it handles.

The Company also reviews the status of its handling of personal data as appropriate. If an incident occurs, the Company will take the measures required by law, including reporting to relevant authorities, notifying affected individuals, investigating the cause, containing harm, and preventing recurrence.

Upon request from an individual, the Company will provide information about its specific security control measures to a reasonable extent, except where disclosure is restricted by law.

11. Retention and Deletion

The Company retains User Information for the period necessary in light of the purposes of use, performance of agreements, management of transaction records, legal obligations, dispute resolution, and other relevant needs.

When User Information is no longer required, the Company will endeavor to delete or anonymize it within a reasonable period, unless retention is required by law, contract, or a legitimate business reason.

12. Requests for Disclosure, Correction, or Discontinuance of Use

Under the Act on the Protection of Personal Information, individuals may request notification of the purpose of use, disclosure, correction, addition, deletion, discontinuance of use, erasure, or discontinuance of provision to a third party with respect to their retained personal data held by the Company.

To submit a request, please contact us through the inquiry channel below. The Company will respond in accordance with applicable law after verifying the identity of the individual or the authority of an authorized representative.

The Company may decline all or part of a request when it is not legally required to comply; when compliance is likely to harm the rights or interests of the individual or a third party; when compliance is likely to seriously interfere with the proper conduct of the Company’s business; or in other circumstances prescribed by law.

13. Changes to This Policy

The Company may revise this Policy in response to changes in laws and regulations, its business activities, services, information-handling practices, or other circumstances.

If the Company makes a material change, it will provide notice by posting the change on the Site or through another appropriate method. The revised Policy will take effect on the date it is posted on the Site or on another effective date specified by the Company.

14. Contact