Privacy Policy

Institution for a Global Society Corporation

Privacy Policy

  Institution for a Global Society Corporation (hereinafter referred to as “the Company”) handles
personal information in the course of conducting its business and recognizes that it has a responsibility to
establish a strict and appropriate management system for the protection of personal information. Therefore, the
Company has established the following privacy policy (hereinafter referred to as the “Privacy Policy”). The
Company has therefore established the following privacy policy (hereinafter referred to as the “Privacy
Policy”). In order to ensure that our customers can use our services and products with peace of mind, all
executives and employees of the Company will strive to properly handle, manage, and maintain personal
information in accordance with this policy. In addition, based on changes in the environment surrounding the
Company and the actual situation, the Company will review and improve the operation of personal information
protection in a timely and appropriate manner on an ongoing basis.

Institution for a Global Society Corporation

CEO

Masahiro Fukuhara

1. Name of business, address, and name of representative

     Institution for a Global Society Corporation (the Company)
   
     1-11-2 Ebisu-Minami, Shibuya-ku, Tokyo 150-0022
   
     Masahiro Fukuhara, President and Representative Director

2. Personal Information Management Officer

     Personal Information Management Committee Personal Information Protection Manager

3. Compliance with relevant laws, regulations, and guidelines

     With respect to the handling of personal information, the Company shall comply with the Act on
   the Protection of Personal Information (Act No. 57 of 2003) (hereinafter referred to as the “Personal
   Information Protection The Company shall comply with the Act on the Protection of Personal Information
   (Act No. 57 of 2003) (hereinafter referred to as the “Personal Information Protection Act”), government
   ordinances and regulations related to the Personal Information Protection Act (hereinafter collectively
   referred to as the “Personal Information Protection Law”), and guidelines related to the Personal
   Information Protection Law (hereinafter referred to as the “Guidelines”). ), and guidelines related to the
   Personal Information Protection Law (General Rules, Pseudonymized and anonymized processed information,
   Obligation to confirm and record information when providing to a third party, Provision to a third party
   in a foreign country, Authorized Personal Information Protection Organization, etc.), as well as other
   laws and guidelines related to our business.
   
     In this Privacy Policy, unless otherwise defined, the terminology used in personal information
   protection laws and regulations will be used.

4. Scope of Application

      This Privacy Policy applies to all of our personal information handling practices and applies
   to all of our services and products (collectively, the “Services”). This Privacy Policy applies to all of
   our services and products (collectively, the “Services”). In the event that the privacy policy, terms of
   use, etc. (hereinafter referred to as “individual terms, etc.”) for each of the services or products that
   comprise the Services individually stipulate the handling of personal information, the Company shall
   notify the customer of such individual terms. (“Individual Terms, etc.”) that individually stipulate the
   handling of personal information, the Individual Terms shall take precedence over this Privacy Policy.

5. Acquisition and Use of Personal Information

     The Company will publicly announce the purposes of use of the personal information it handles
   (including public announcements through this Privacy Policy), or notify the public of such purposes. In
   addition, when obtaining personal information directly from the person concerned, we will clearly state
   the purpose of use in advance and notify the person concerned of such purpose. In addition, when acquiring
   personal information directly from the person concerned, we will clearly state the purpose of use in
   advance and acquire personal information in a lawful and fair manner.
   
     When acquiring personal information that requires special consideration, we will obtain the
   consent of the person in advance, except in cases permitted by law.
   
     We will use personal information in an appropriate manner within the scope necessary to
   achieve the purpose of use.

6. Purpose of use of personal information

   1)  Introduction
   
     The Company acquires information that forms the basis of your temperament, behavioral
   characteristics, skills, cognitive tendencies, qualities and abilities, etc., evaluates and analyzes this
   information, and analyzes and evaluates the results (including the information itself that forms the basis
   of such analysis and evaluation.) The same shall apply hereinafter). ) to customers, companies using our
   services (hereinafter referred to as “Service Users”, and in cases where administrative agencies, etc. use
   services other than those for educational institutions, they are also included), and educational agencies
   using our services (hereinafter referred to as “Educational Agencies”). ) and educational institutions
   using our services (hereinafter referred to as “Service-Using Educational Institutions,” and when services
   for educational institutions are used by administrative agencies, etc., administrative agencies, etc. are
   also included. (Together with Service-Using Companies, collectively referred to as “Service-Using
   Corporations, etc.”). The basis of this service is to communicate the results of the analysis and
   evaluation to the Service Users (including the Service Users’ companies).
   
     While we strive to ensure that the results of such analysis and evaluation are accurate and
   fair, we cannot guarantee 100% accuracy, and as a result, there is a possibility that some of the analysis
   results may be inaccurate. Based on the results of such analysis and evaluation, there is a possibility
   that Service Users may make favorable or unfavorable evaluations or judgments of clients in the areas of
   personnel management such as recruitment or educational policies such as entrance examinations. We ask our
   clients to use the information appropriately based on such analysis and evaluation. Customers agree in
   advance that the Company’s purpose of use of personal information includes such content, and that the
   Company shall not be held responsible for any evaluation or judgment made by Service Users, etc. toward
   customers.
   
     Specifically, the Company will handle personal information within the scope necessary to
   achieve the following purposes of use. In the event that the Company changes the purpose of use, it shall
   do so within the scope that is reasonably deemed to be relevant to the purpose of use before the change.

   2)  Personal information acquired for the provision and development of our products and services

     A) To provide services and products related to labor relations such as recruitment,
   placement, training, and personnel evaluation

   ・To manage and operate systems and applications related to the Service

   ・To analyze and evaluate the Service’s customers’ temperament, behavioral characteristics, skills,
   cognitive tendencies, etc., including those based on AI, and to provide feedback to customers on the
   results of such analysis and evaluation

   ・For the purpose of analysis and evaluation including those by AI based on the data of temperament,
   behavioral characteristics, skills, cognitive tendencies, etc. of customers of the Service, and for the
   purpose of feedback of the results of analysis and evaluation to the customers. The same applies below.)

   ・For the purpose of analysis and evaluation of the abilities, characteristics, etc. of the customer
   (use of personal information for the purpose of this paragraph includes provision to a third party), the
   Service Usage Companies and Service Usage Companies may use personal information for the purpose of
   analysis and evaluation of the customer.

   ・To provide the results of customer analysis and evaluation to Service Users and platform providers
   contracted by Service Users (use of personal information for the purposes described in this section
   includes provision to third parties).

   ・To perform data analysis (Note) based on data entered by the customer, data entered by a third party
   evaluator, analysis and evaluation results regarding the customer’s temperament, behavioral
   characteristics, skills, cognitive tendencies, etc., and personnel information held by the Service Usage
   Company, and to perform consulting services such as advice and evaluation regarding personnel policies
   for the Service Usage Company. To provide consulting services, such as advice and evaluation of
   personnel policies, to Service Users. In addition, in reference to the results of such advice,
   evaluation, and other consulting services, Service Usage Companies may conduct personnel and labor
   management, and implement personnel policies such as recruitment, personnel assignment, and training.
   (The use of personal information for the purposes of this section includes the provision of personal
   information to third parties.)

   ・Matching of customers with companies using the Service, such as for internships, recruitment, and
   events (including matching using AI-based matching engines). (The use of personal information for the
   purposes of this section includes provision to third parties.)

   ・To analyze and evaluate information related to the client’s decision-making on management issues
   (including but not limited to the decision-making process) through the implementation of management
   simulations.

   ・In the case of using the service provided in Japan under the name of ONGAESHI (an integrated training
   and recruiting service that realizes free digital reskilling through NFT), to manage the LMS, Position
   NFT Market, NFT Rental Market, Recruitment Auction Market, and the system for granting solidarity
   contributions(tokens) within the said service.

   ・To conduct data analysis based on information including learning and behavioral history obtained from
   the said services, to convert them into employment matching score and to provide them to hiring
   companies (use of personal information for the purposes described in this section includes provision to
   third parties).

   ・To develop and improve our products and services

     B) To provide services and products related to students and students’ abilities and school
   education

   ・To manage and operate systems and applications related to this service

   ・To analyze the temperament, behavioral characteristics, skills, and cognitive tendencies of customers
   of this service including those by AI based on data feedback to customers on the results of analysis and
   evaluation

   ・For the purpose of analysis and evaluation, including by AI, based on data on the temperament,
   behavioral characteristics, skills, cognitive tendencies, etc. of customers of the Service, and for
   third party evaluators to conduct evaluations of customers of the Service and analyze and evaluate the
   abilities, characteristics, etc. of the customers (The use of personal information for the purposes of
   this paragraph includes provision to a third party.)

   ・To provide the results of customer analysis and evaluation to educational institutions using our
   services (use of personal information for the purposes of this paragraph includes provision to third
   parties).

   ・To perform data analysis(*) based on data entered by the customer, data entered by third party
   evaluators, results of analysis and evaluation of the customer’s temperament, behavioral
   characteristics, skills, cognitive tendencies, etc., and student information held by Service-Using
   Educational Institutions, and to provide educational policy advice and evaluation and other consulting
   services to Service-Using Educational Institutions. To provide consulting services, such as advice and
   evaluation of educational policies, to educational institutions using our services. In addition,
   Service-Using Educational Institutions may manage student information and implement educational measures
   such as entrance examinations, career guidance, curriculum design, class organization, and verification
   of the effectiveness of various educational activities based on the results of such advice, evaluation,
   and other consulting services. (The use of personal information for the purposes of this section
   includes provision to third parties.)

   ・To match customers with corporations, etc. using the Service for classes, seminars, courses, holding
   events, etc. (including matching by AI-based matching engines) (The use of personal information for the
   purposes of this paragraph includes provision to third parties.)

   ・Development and improvement of our products and services

     C) Provision of other educational products and services

   ・For educational businesses that distribute educational materials via the Internet

   ・To provide information on curricula and teaching materials related to various types of education using
   video information

   ・To establish and operate correspondence courses for the acquisition and mastery of various
   qualifications and skills, and to instruct and train lecturers in charge of such courses (the use of
   personal information for the purposes of this section includes the provision of such information to
   third parties).

   ・Planning, production and provision of websites utilizing the Internet and provision of information
   services

   ・To provide information on education and public relations, etc.

   ・To develop and improve our products and services

     D) Provision of products and services related to marketing

   (1) Data entered by customers and by third-party evaluators, To conduct data analysis (see Note) based
   on the results of analysis and evaluation of customers’ temperament, behavioral characteristics, skills,
   cognitive tendencies, etc., and information about customers and other individuals held by the Company,
   and to develop products and services, advertise, market, study sales measures and conduct other
   marketing activities of the Company or companies other than the Company, etc. (See the use of personal
   information for the purposes described in this section includes provision to third parties.)

   ・To analyze data based on data entered by customers, data entered by third party evaluators, results of
   analysis and evaluation of customers’ temperament, behavioral characteristics, skills, cognitive
   tendencies, etc., and information on customers and other individuals held by Service Users, etc. (Note),
   and to conduct advertising, publicity, market development, sales policy review and other marketing
   activities for Service Users, etc.

   (2) To perform consulting services such as advertising, market development, sales policy reviews, and
   other marketing-related advice and evaluations for Service Users, etc. (The use of personal information
   for the purposes described in this section includes provision to third parties.)

   ・Marketing information, public relations information, etc.

   ・To develop and improve our products and services

     E) Information managed under contract from other companies

   ・For development, operation, and maintenance of services provided overseas called ONGAESHI entrusted by
   BOUNDLESSEDU PTE. LTD.

     F) Other actions necessary for our business

   ・To authenticate individuals and provide services to customers (The use of personal information for the
   purposes of this section include the provision of personal information to third parties)

   ・To distribute and send communications and various notices, etc. associated with the use of the Service
   (use of personal information for the purposes of this paragraph includes provision to third parties).

   ・To conduct surveys and research (such as sending questionnaires) for the development and improvement
   of products and services (use of personal information for the purposes of this paragraph includes
   provision to third parties).

   ・To perform any other business related to the Company

   3)  Personal information acquired in connection with recruitment and employment at the Company

   1. For employment selection
   2. For appropriate employment management
   3. To develop and implement the Company’s human resources policies
   4. To perform other acts necessary for recruitment or employment

   4)  Personal information concerning shareholders

   ・Exercise of rights and performance of obligations under the Companies Act

   ・Management of shareholders including preparation of records in accordance with various laws and
   regulations

   5)  Use for Academic Research

     In the STAR Project, which is a joint research project between the Company and an academic
   research institution, the Company will provide your personal data to the academic research institution
   with the consent of the customer. The academic research institution will ensure the security of the
   customer’s personal data in accordance with its internal regulations and use such personal data for the
   purpose of academic research (this purpose of use includes provision to third parties).

   (Note) “Data Analysis” in this Privacy Policy cannot determine or diagnose the existence of Sensitive
   Personal Information itself. However, it may be possible to infer sensitive personal information and other
   sensitive information, for example, by identifying a characteristic tendency of a customer, which may lead
   to the inference of a tendency to a specific mental disorder, and the “data analysis” results the Company
   provides to Service Users may include such sensitive information. The results of “data analysis” provided
   to Service Users may include information from which such sensitive information can be inferred.
   
     The company may analyze data, prepare reports on the results of analysis and evaluation, and
   provide them to Service Users, as well as provide consulting services such as advice on personnel policies
   and training programs, and evaluations. The results of such analysis/evaluation and consulting services
   may work to the advantage or disadvantage of individual customers. The Company will indicate this Privacy
   Policy to the customer and let the customer decide whether or not to agree to it, and the customer agrees
   that by agreeing to this Privacy Policy, the Company will not be responsible for the implementation of
   such consulting services by the Company or any evaluation or judgment of the customer by the corporation
   using the service, etc.

7. Safety management of personal data, etc.

     The Company shall take organizational, personnel, physical and technical safety management
   measures to prevent leakage, loss or damage of personal data and to manage other personal data. We will
   take organizational, human, physical and technical safety control measures to prevent leakage, loss or
   damage of personal data and to otherwise manage personal data. The Company’s security control measures are
   as follows.

1. Provision of Personal Data, etc. to Third Parties

     In principle, we do not provide personal data to third parties without the consent of the
   individual, except for provision to third parties to which the customer has consented as described in “6.
   However, we may provide personal data to third parties without the consent of the customer to the extent
   that it does not violate related laws and regulations, including in the following cases.

   1) When required by law

   2) When it is necessary for the protection of the life, body, or property of an individual and it is
   difficult to obtain the consent of the individual

   3) When it is especially necessary to improve public health or to promote the sound growth of children,
   and it is difficult to obtain the consent of the person in question.

   4) When it is necessary to cooperate with a national agency, a local government, or an individual or
   entity entrusted by either a national agency or local government to execute affairs prescribed by law, and
   obtaining your consent is likely to impede the execution of those affairs.

   5) Where the third party is an academic research institution, etc., and it is necessary for the third
   party to handle the relevant personal data for academic research purposes (including cases where part of
   the purpose of handling the relevant personal data is for academic research purposes, but excluding cases
   where there is a risk of unjustified infringement on the rights and interests of individuals) (iii) When
   there is a need for the third party to handle the personal data for academic research purposes.

2. Provision of Personal Data to Third Parties in Foreign Countries

     When we provide personal data to third parties in foreign countries, we will take necessary
   measures such as obtaining consent in accordance with laws and regulations.

     We provide personal data related to ONGAESHI provided in Japan to BOUNDLESSEDU PTE. LTD.
   located in Singapore based on joint use and equivalent measures.

     
   ・Disclosure Items Related to Shared Use

   (1) Joint Use of Personal Data

     The Company jointly uses personal data related to ONGAESHI provided in Japan as follows.

   (2) Items of personal data to be shared

     Name, nickname, e-mail address, telephone number, gender, date of birth, hometown/place of
   residence, desired and current annual income, personal PR (including education and employment history),
   qualifications and skills possessed, learning history and grades of courses taken within the ONGAESHI
   system

   (3) Scope of joint use

     The Company and BOUNDLESSEDU PTE.

   (4) Purpose of use by those who jointly use the information

     ・For the management and operation of the LMS, Position NFT Market, NFT Rental Market,
   Recruitment Auction Market, and Solidarity Contribution (Token) granting system within the services
   provided in Japan under the name of ONGAESHI (the use of personal information for the purpose of this
   paragraph includes the provision to third parties).

     ・To analyze data based on information including learning and behavioral history obtained on
   the services provided in Japan under the name of ONGAESHI for students and adults who wish to find
   employment or change jobs, convert the data into employment matching scores, and provide the scores to
   hiring companies (use of personal information for the purposes described in this section includes
   provision to a third party).

     ・To develop and improve our products and services

   (5) Name and address of the person responsible for the management of personal data and name of the
   representative of the corporation

     Institution for a Global Society, Inc.

     1-11-2 Ebisu-Minami, Shibuya-ku, Tokyo 150-0022, Japan

     Masahiro Fukuhara, President and Representative Director

     

     ・Regarding the Company and equivalent measures

     The company continuously take measures equivalent to those required to be taken by business
   operators handling personal data (hereinafter referred to as “equivalent measures”) with respect to the
   handling of personal data for BOUNDLESSEDU PTE. LTD. on an ongoing basis. The individual may request
   information on the Reasonable Measures from the Company in accordance with Article 28, Paragraph 3 of the
   Personal Information Protection Law. In addition, in order to implement the Corresponding Measures, the
   Company will make the following public announcement on behalf of BOUNDLESSEDU PTE. LTD. based on the
   agreement with BOUNDLESSEDU PTE. LTD.

   (1) Purpose of use by BOUNDLESSEDU PTE. LTD.

     Same as the description in (4) of the disclosure regarding joint use.

   (2) Response to leakage, etc.

     In the unlikely event of a leakage, etc. of personal data at BOUNDLESSEDU PTE, the Company
   will take responsibility for reporting and notifying the individual concerned.

   (3) Public Announcement, etc.

     BOUNDLESSEDU PTE. LTD. will make the following public announcements regarding the transferred
   retained personal data in accordance with Article 32 of the Personal Information Protection Law:

     ①Name and address of the business operator concerned, and in the case of a corporation, the
   name of its representative BOUNDLESSEDU PTE.

     78 Shenton Way, #20-03, Singapore 079120

     Director：Narumi Nakahara

     ②（Purpose of use of all retained personal data (related to joint use)

      The same as the description in (4) of the disclosure items regarding joint use.

     ③Procedures for responding to requests or demands from the individual

      Same as the Company (refer to 11)

     ④Measures taken for the secure management of retained personal data

      BOUNDLESSEDU PTE. LTD. complies with the Singapore Personal Data Protection Act 2012 (PDPA)
   and other personal data protection laws and guidelines that are relevant or applicable to BOUNDLESSEDU
   PTE. LTD. BOUNDLESSEDU PTE. LTD. will take organizational, personnel, physical, and technical security
   control measures to prevent leakage, loss, or damage of personal data and to manage other personal data
   securely. BOUNDLESSEDU PTE. LTD. uses appropriate passwords, criteria for data disclosure, data
   encryption, data anonymization, periodic security reviews and testing, and other authentication and
   authentication measures.

     ⑤Contact for complaints regarding the handling of retained personal data

     The company will respond on behalf of BOUNDLESSEDU PTE. LTD. (refer 14)

   (4) Disclosure, correction, etc., suspension of use, etc., explanation of reasons, procedures for
   responding to requests for disclosure, etc., and measures related to fees, etc.

     The company will respond on behalf of BOUNDLESSEDU PTE. LTD. （refer 11）

   (5) Complaint handling

     The company will respond on behalf of BOUNDLESSEDU PTE. LTD. (refer 14)

3. Outsourcing the Handling of Personal Data

     When outsourcing the handling of a person’s personal data to a subcontractor, such as a
   subcontractor, within the scope of the purposes of use described in 6, we will select an appropriate
   subcontractor, exchange a contract regarding the outsourced operations, and implement appropriate
   supervision, such as ascertaining the status of the handling of personal data at the subcontractor. In
   this case, the Company will select an appropriate subcontractor.

4. Disclosure, etc. of Personal Information

     If we receive a request from a customer for disclosure, etc. of personal information for which
   we are authorized to respond to notification of purpose of use, disclosure, correction, addition or
   deletion of content, suspension of use, deletion, suspension of provision to a third party, or disclosure
   of records of provision to a third party (hereinafter referred to as “Request for Disclosure, etc.”), we
   will respond as follows. If we receive a request for disclosure, etc. from a customer regarding personal
   information for which we have the authority to respond to the customer’s request, we will respond as
   follows

   1) To prevent leakage of personal information, we will verify your identity when we receive your request
   for disclosure, etc. If we are unable to confirm your identity, we may not be able to respond to your
   request.

   2) Requests for disclosure must be made in accordance with the prescribed procedures.

   3) If we are unable to respond to your request for Disclosure, etc., we will reply to your request,
   clarifying the reason in accordance with laws and regulations.

   4) A fee of 1,000 yen (excluding tax) will be charged for each request for notification or disclosure of
   the purpose of use of personal information among the requests for disclosure, etc.

   
   ※ Please click here to download the request form for disclosure, etc. and submit your request. (Only in
   Japanese)
   

5. Use of Cookies and Google Analytics

     Cookie technology allows a website to exchange information between the website and the site
   user’s computer, making it possible to obtain a record of the site user’s visits and to change the display
   for each site. This is a service that is not available on the Company’s Web site. Our website and this
   service use cookies to understand the usage of the website and this service (number of visits, etc.), but
   we do not collect personal information using cookies (including the collection of cookie information using
   Google Analytics, which is described below). However, the Company does not collect personal information
   through the use of cookies (including the collection of cookie information through Google Analytics as
   described below). 
   
     We also use Google Analytics to understand the use of the above website and the Services.
   Google Analytics uses cookies to collect information about users. For an explanation of the Terms of Use
   (https://www.google.com/analytics/terms/jp.html) and Privacy Policy
   (https://www.google.com/intl/ja/policies/privacy/) of Google Analytics, please visit Google’s website at
   Google Analytics. The Company shall not be liable for any damages resulting from the use of Google
   Analytics services.
   
     In addition, the Company may place banner advertisements, etc. on websites other than the
   Company’s, in which case the Company will follow the cookie rules of the website on which the
   advertisement is posted. You can change your browser settings to disable the acceptance of cookies or
   delete stored cookies.

6. Personal Information to be Received

     Whether or not to submit personal information is at the discretion of the customer. However,
   if you do not register the necessary information for the Service, we may not be able to provide all or
   part of the Service. In addition, if you set your browser not to accept cookies, some of the functions of
   the Service may be limited or you may not be able to use the Service depending on the contents of the
   Service.

1. Inquiries

1. 
   Name of the “authorized personal information protection organization” to which the Company belongs and
   contact for complaints
   

     The organization accepts complaints and consultations regarding the Company’s handling of
   personal information.

   1. Name of authorized personal information protection organization Japan Information Processing
   Development

   2. Inquiries Regarding Complaint Resolution Secretariat of the Authorized Personal Information
   Protection Organization Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032 Telephone
   03-5860-7565 / 0120-700-779 (Note) This is not a contact for inquiries regarding our products or
   services.
   

   
   Our website is protected by SSL (Secure Socket Layer) encrypted communication to prevent personal
   information from being leaked to outside parties.

2. Handling of Personal Data of Customers in Europe

     Additional information regarding the handling of personal data of customers located in the
   European Economic Area (EEA) and the United Kingdom under the EU General Data Protection Regulation (GDPR)
   and the UK Data Protection Act is as follows. This information applies when the Company acts as a data
   controller. When acting as a data processor pursuant to a contract, personal data will be processed based
   on the controller’s instructions and within the scope of the contract.

   1. Data Controller

     As set out in the Company name, address, and representative’s name.

   2. Purpose of Use, Legal Basis, and Retention Period

     The purposes of use, legal bases, and retention periods of relevant personal data are as
   follows.

   
   

   Type of Personal Data	Category	Purpose of Use	Legal Basis	Retention Period
   Personal data obtained for providing/developing Company products/services	Employment-related services (recruitment, placement, training, evaluation, etc.)	For management and operation of systems and applications related to the service	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For analysis, evaluation (including AI-based), and feedback based on temperament, behavioral traits, skills, and cognitive tendencies	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For providing information necessary for third-party evaluators to conduct evaluations of customers and analyze abilities and characteristics	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For providing customers’ analysis/evaluation results to service-using companies and their contracted platform providers	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For providing input data and analysis/evaluation results for data analysis by service-using companies	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For providing customers’ information to service-using companies for internships, recruitment, and event matching (including AI-based matching)	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For the development and improvement of Company products and services	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   Personal data of students	Educational services and products	For management and operation of systems and applications related to the service	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For analysis, evaluation (including AI-based), and feedback	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For providing information necessary for third-party evaluators to evaluate customers’ abilities/characteristics	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For providing customers’ analysis/evaluation results to service-using educational institutions	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For providing input data and evaluation results for data analysis by service-using educational institutions	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For providing customers’ information to service-using institutions for classes, seminars, lectures, and event matching (including AI-based matching)	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until one year after termination of the customer’s service contract
   		For the development and improvement of Company products and services	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   Other educational services	Distribution of educational materials via the internet	For providing educational services using online content	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until termination of the service contract
   		For providing information on curricula/materials via video	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   		For establishing and operating correspondence courses and training instructors (includes provision to partners)	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until termination of the service contract
   		For providing websites and information services	Necessary for the performance of a contract or taking steps prior to entering into a contract (GDPR Art. 6(1)(b))	Until termination of the service contract
   		For planning and producing websites	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   		For distribution of educational/public relations information	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   		For development and improvement of Company products/services	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   Marketing-related personal data	Marketing services and products	For conducting data analysis and marketing activities (including provision to third-party companies)	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   		For consulting services to service-using companies based on data analysis (including provision to institutions)	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   		For distribution of marketing/public relations information	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   		For development and improvement of Company products/services	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   Other necessary business-related actions	Communications and notifications related to service use	For sending communications/notifications regarding service use	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn
   		For surveys/research (e.g., questionnaires) for product/service development and improvement	Consent of the customer (GDPR Art. 6(1)(a))	Until consent is withdrawn

   3. Legal Rights of Customers and How to Exercise Them

     Customers have the right to request disclosure, correction, deletion, and restriction of
   processing of their personal data, the right to object to processing, the right to data portability, the
   right to withdraw consent, the right not to be subject to automated decision-making, and the right to
   receive information regarding processing. If you wish to exercise these rights, please contact
   pim@i-globalsociety.com. Responses will be free of charge.

   For the prevention of personal data leakage, identity verification will be required when responding to
   such requests. If verification cannot be made, the request may not be fulfilled.

   If a request cannot be fulfilled, reasons will be provided in accordance with applicable laws.

   4. Complaints to Supervisory Authorities

     Customers may lodge complaints regarding the handling of their personal data with the
   supervisory authority having jurisdiction over their place of residence.

     For details, please refer to the following websites.
   
     EU/EEA:https://edpb.europa.eu/about-edpb/board/members_en
     UK:https://ico.org.uk/

   5. Right to Seek Judicial Remedy

     If customers consider that their rights have been infringed as a result of the Company’s
   processing of their personal data, they have the right to seek judicial remedy before a court.

(Supplementary Provisions)

Date enacted May 18, 2010

Date last amended October 1, 2025