Date of establishment: April 1, 2019

“Privacy Policy for JRCS INFINITY Training”

JRCS Co. Ltd. (“JRCS”) hereby sets forth this Privacy Policy (this “Policy”) with respect to the handling of User Information (as defined below), including personal information of users (“User”), in relation to the Infinity Training (the “Services”) provided by JRCS.

Article 1. User Information to be Collected and Collection Method Thereof

• “User Information” under this Policy means all information related to User which can identify such User, such as information that identifies User, the browsing history of the website for the Services (the “Site”) and other information created or accumulated in User’s devices (e.g., smart phone, personal computer) in relation to such User or User’s devices. Depending on the collection method thereof, the User Information JRCS collects under the Services may include the following:
  1. Information Provided by User
  
  • The information to be provided by User to use the Services, including:
    (1) Name;
    (2) Email address;
    (3) Date of birth;
    (4) Photos;
    (5) Time zone to which User belongs; and
    (6) Other information entered by User into the entry form designated by JRCS.
    
  2. Information Collected by JRCS for User’s Use of the Services
  
  • JRCS may collect information on the status of access to the Services and other information, including:
    (1) Log information;
    (2) Cookie(s);
    (3) Browsing history of the Site;
    (4) Information on the history of training sessions taken and qualifications obtained through the Services; and
    (5) Content of questionnaires, etc. conducted in relation to the Services.
    

Article 2 Purpose of Use

• 1. User Information may be used not only for provision of the Services as set forth in the following paragraph, but also for other purposes as set forth in Articles 2.3 and 2.4.
  2. The specific purposes of use of User Information relating to the provision of the Services shall be as follows:
  
  • (1) To provide, maintain, protect and improve the Services, such as registration acceptance, identity confirmation and calculation of usage fees in relation to the Services;
    (2) To provide guidance, respond to inquiries, etc. related to the Services;
    (3) To handle any breach of JRCS’s terms, policies, and the like (collectively, the “Terms”);
    (4) To provide notification regarding modifications, etc. to the Terms related to the Services;
    (5) To achieve other purposes of use incidental to the foregoing; and
    (6) In addition, to achieve legitimate business profits, such as through market analysis, development and improvement of products and management of the Services.
    
  3. The purposes of use of User Information other than those specified in the preceding paragraph shall be as follows:
  
  • (1) Purpose of Use: To create statistical data related to JRCS’s services and processed in a form that cannot identify an individual Corresponding User Information Items: Log information and cookies
    (2) Purpose of Use: To distribute or display advertisements of JRCS or third parties Corresponding User Information Items: Log information and cookies
    
  4. When handling User Information for any purpose other than the above purposes, User shall be informed of the additional purpose of use and related information (i.e., retention period, User’s rights and other information as stipulated in the applicable personal information protection laws and regulations (the “Applicable Laws”), including the General Data Protection Regulation (the “GDPR”)).
  

Article 3. Rights to Withdraw Consent based on Consent and Necessity to Provide User Information

• 1. By indicating his/her intention to provide consent to this Policy, User shall be deemed to have provided his/her consent to JRCS’s handling of User Information and JRCS shall handle the User Information of such User based on the consent provided by such User; provided, however, that User may withdraw such consent at any time (the foregoing shall not affect the handling of User Information before the consent is withdrawn). JRCS may use User’s User Information in order to perform a contract with such User, achieve legitimate business profits as specified in Article 2.2(6), or comply with laws and regulations. If User is a minor, such User is required to, upon using the Services, obtain consent from his/her guardian for using the Services or provide his/her consent to use the Services after obtaining permission from his/her guardian.
  2. User Information to be provided by User is that required to be provided by such User when JRCS provides the Services to such User. Accordingly, if User fails to provide his/her User Information, he/she may not use the Services.
  3. User may request suspension of the use of the Services by making the prescribed settings to the Services. In this case, JRCS shall promptly suspend the Services in accordance with the provisions set forth by JRCS.
  

Article 4. Provision to Third Parties

• Unless required to be disclosed pursuant to laws and regulations, JRCS shall not provide User Information to any third party without obtaining the prior consent of User, except in cases where:
  (1) JRCS entrusts third parties such as cloud service vendors and service management companies with the handling of User Information in whole or in part, to the extent necessary to achieve the purposes of use. In this case, JRCS shall supervise such third parties (i.e., entrustees) to ensure that they take proper and appropriate protection measures in accordance with the provisions of the Applicable Laws;
  (2) User uses the Services under the Terms of Use for Corporations (https://infinity-xip.com/other/terms_c/) and provides his/her User Information to a corporation which has entered into a contract to use the Services upon the request of such corporation;
  (3) JRCS entrusts the lecturers and the entities to which the lecturers belong, including JRCS’s group companies with User Information, to the extent necessary to provide the Services to User.
  (4) User Information is provided in association with a business succession resulting from a merger or other reasons;
  (5) JRCS is required to cooperate with a state organ or local government, or an individual or business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining User’s consent is likely to impede the execution of the affairs concerned; or
  (6) In addition to the foregoing, in cases where JRCS is entitled to provide User Information pursuant to laws and regulations.
  

Article 5. Overseas Transfer of User Information

• JRCS may transfer User Information to countries outside the country in which User is located (the “User’s Country”). User agrees that countries outside the User’s Country may not have personal data protection laws as comprehensive as those that exist in the User’s Country, and further agrees that the same level of protection as the protection measures set forth in the User’s Country may not necessarily be guaranteed (as for transfers of User Information from Europe to Japan, however, such transfer shall be conducted based on an adequacy decision under the GDPR). In this case, JRCS shall implement necessary safety management measures pursuant to the provisions of the Applicable Laws.
  

Article 6. Safety Management of User Information

• 1. JRCS takes safety management measures to appropriately handle User Information and endeavors to prevent the divulgence, destruction, damage, loss, alteration or unauthorized access thereof.
  2. JRCS shall cause its employees to recognize the importance of User Information and the danger in any breach of the rules for handling User Information and shall supervise its employees to ensure that User Information is managed in an appropriate manner.
  

Article 7. User Rights

• 1.User shall have the following rights in relation to the User Information registered for his/her current membership only when such User satisfies the requirements under the Applicable Laws. Any request for each of these rights in relation to the User Information should be submitted to the “Inquiry Desk” specified in Article 9.
  
  • (1) Right to request access (i.e., disclosure of purpose, type, destination, retention period, source of acquisition, etc.);
    (2) Right to request correction;
    (3) Right to request erasure;
    (4) Right to request restriction on handling;
    (5) Right to request transfer or copy (i.e., portability) to enable the User Information to be used in services other than those of JRCS; and
    (6) Right to withdraw consent at any time.
    
  2. In addition to the rights specified in the preceding paragraph, if User satisfies the requirements under the Applicable Laws, such User shall have the right to make an objection to the handling of his/her User Information. Any inquiry on the exercise of this right shall be submitted to the “Inquiry Desk” specified in Article 9.
  3. Even after withdrawal as a member, User shall have, at his/her choice, the same rights as specified in Articles 7.1 and 7.2 by using his/her name and email address until all of his/her User Information is erased.
  4. User has the right to file a complaint regarding the handling of User Information at JRCS with the supervisory authority governing the region where such User is located.
  

Article 8. Retention Period

• JRCS shall retain User Information of User to the extent necessary to provide the Services to such User; provided, however, that, after such User’s withdrawal, JRCS shall promptly erase such User’s User Information upon request from such User.
  

Article 9. Inquiry Desk

• Any suggestions, questions, complaints and other inquiries regarding the handling of User Information should be submitted as follows:
  Address: 1-2-14 Higashiyamato-machi, Shimonoseki, Yamaguchi, 750-8515 Japan
  JRCS Co. Ltd.
  Email: privacy＠jrcs.co.jp
  

Article 10. Procedures to Modify This Policy

• JRCS shall, from time to time, review and endeavor to continuously improve the operational status of the handling of User Information, and may modify this Policy as necessary. Any modification to this Policy shall be posted on the Site; provided, however, that, for any modification requiring consent from Users pursuant to laws and regulations, such User consent shall be obtained pursuant to the procedures designated by JRCS.