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PRIVACY POLICY

Privacy Policy

GROUND Inc. (the "Company") has a basic policy of properly protecting customers' personal information and complying with the Act on the Protection of Personal Information and other related laws and regulations.

This Privacy Policy explains what personal information the Company collects and how it uses and manages that information.

01DEFINITION & SCOPE

Definition and Scope of Personal Information

What Is Personal Information?

In this Privacy Policy, "personal information" means information about a living individual that can identify a specific individual by the name, date of birth, address, telephone number, email address, or other details it contains, or that can easily be matched with other information and thereby identify a specific individual (Article 2, Paragraph 1 of the Act on the Protection of Personal Information), and also includes information about individuals other than personally identifying information.

Scope of Personal Information We Collect

The Company collects personal information in situations such as the following:

  • Entries in the inquiry form
  • Applications for services and contract procedures
  • Submission of job application documents
  • Registration for events and seminars
  • Newsletter subscriptions
  • Access logs and cookies collected by automated systems

Specifically, this includes names, addresses, telephone numbers, email addresses, work histories, company information, IP addresses, browser types, and access times.

Note: The Company may use and analyze anonymously processed information that is not classified as personal information (information processed so that individuals cannot be identified) without customers' consent.

02USAGE PURPOSE

Purposes of Use of Personal Information

The Company uses the personal information it collects only within the scope of the following purposes. Thank you for your understanding.

Main Purposes of Use

  • Providing services: Providing, maintaining, and improving the Company's solutions (GWES, PEER, consulting, and others), and related customer support
  • Responding to inquiries: Replying to and handling questions, consultations, and requests
  • Sales and marketing: Information on new solutions, and information on seminars and events (you can opt out)
  • Recruitment: Managing applicants' application information, carrying out the selection process, and contacting applicants
  • Contract management: Preparing contracts, issuing invoices, managing payments, and performing contracts
  • Legal compliance and protection of rights: Complying with legal obligations, protecting the Company's rights and property, and resolving disputes
  • Statistical analysis: Access statistics and usage pattern analysis (carried out in a processed form that cannot identify individuals)

International Data Transfers

Where the Company's services have international functions, some personal information may be transferred to the Company's affiliates or trusted service providers outside Japan to achieve these purposes. In that case, the Company maintains an appropriate level of security.

Legal Basis

The Company handles personal information under Japan's Act on the Protection of Personal Information (in force since 2005, amended in 2022) and its related rules. For international services, the Company is also preparing to comply with the EU's GDPR (General Data Protection Regulation) and works to protect the rights of residents of Europe.

03THIRD-PARTY SHARING

Provision to Third Parties

Policy on Provision to Third Parties

The Company does not provide personal information to third parties without customers' consent. However, the following cases are exceptions:

Cases Where Information May Be Provided to Third Parties Without Consent

  • As required by law: When based on laws, court orders, or requests from government agencies
  • Protection of life and body: When it is necessary to protect the life, body, or property of the person in an emergency
  • Outsourcing: Provision to contractors to the minimum extent necessary to provide services (contractors are bound by confidentiality obligations)
  • Mergers and business succession: Transfer of information in connection with an acquisition, merger, business transfer, or similar transaction (with prior public notice)

Management of Contractors

When the Company entrusts personal information to a contractor, it concludes a contract on the protection of personal information with the contractor and has the contractor ensure appropriate security management. Examples of contractors include cloud service providers, payment processors, and delivery companies.

Notice on joint use: In some cases, it may become necessary to share certain information with affiliated companies. In that case, the Company states this in advance and obtains your consent where necessary.

04SECURITY MEASURES

Security Control Measures

Security Measures

To manage customers' personal information securely, the Company takes the following security measures:

Technical Controls

  • Encryption of communications (SSL/TLS)
  • Database encryption
  • Firewalls and intrusion detection systems (IDS)
  • Regular security assessments and vulnerability scans
  • Multi-factor authentication (MFA)
  • Log monitoring and anomaly detection systems

Organizational Controls

  • Least-privilege, tiered access rights management
  • Regular personal information protection training for employees
  • Confidentiality agreements
  • Management and auditing of access records
  • Establishing and regularly updating an information security policy

Physical Controls

  • Housing servers and data centers in locked facilities
  • Entry logs and security cameras
  • Shredding of important documents

Incident Response

In the unlikely event of a leak, loss, or unauthorized access involving personal information, the Company takes the following actions:

  • Promptly assessing and investigating the damage
  • Notifying affected individuals (and reporting to the Personal Information Protection Commission as necessary)
  • Identifying the cause and taking measures to prevent recurrence
  • Audits by external security experts

Important: Communication over the internet is not guaranteed to be completely secure. Please manage your passwords strictly and stay alert to suspicious emails. The Company also takes the best security measures it can.

06CONTACT & RIGHTS

Contact Desk

Inquiries About Personal Information

If you have any questions, concerns, or requests about the handling of personal information, please contact the desk below.

GROUND Inc., Personal Information Protection Manager

Bizflex Kanda 10F, 1-3-33 Kanda-Sudacho, Chiyoda-ku, Tokyo 101-0041, Japan

Email: info@groundinc.co.jp

Requests for Disclosure, Correction, or Deletion of Personal Information

Under the Act on the Protection of Personal Information, you have the following rights:

RightDescription
DisclosureYou can request disclosure of your own personal information held by the Company
CorrectionIf the personal information held contains errors, you can request its correction
DeletionYou can request deletion of personal information (where there is no legal obligation to retain it)
Suspension of useYou can request that the use of personal information be stopped
ObjectionYou can object to inappropriate purposes of use or provision to third parties

Compliance With International Data Protection Regulations

The Company is preparing to comply with the EU's GDPR (General Data Protection Regulation) for the personal information of residents of the European Economic Area (EEA). If you have rights under the GDPR (such as the right to data portability or the right to object), please contact us.

Complaints

If you have a complaint about the Company's handling of personal information, please first contact the Company's desk. If you are not satisfied with the Company's response, you can file a complaint with Japan's Personal Information Protection Commission.

Personal Information Protection Commission (PPC)

Website: https://www.ppc.go.jp/

Revisions to This Policy

This Privacy Policy may be revised without notice in response to amendments to the Act on the Protection of Personal Information or other laws, or changes to the Company's services or security systems. A revised version takes effect when it is posted on the Company's website. For major revisions, the Company will make efforts to notify you in advance by email or other means.

Last Revised

This Privacy Policy was created on March 1, 2026.