FullDepth, Co., Ltd. (hereinafter referred to as the “Company”) has established the following Policy of Personal Information Protection (hereinafter referred to as the “Policy”) for the provision of the Company’s services or the Company’s products (hereinafter collectively referred to as the “Company’s Services, etc.”), and the Company protects and manages appropriately the Personal Information.

1. Definition of the Personal Information

In the Policy, the Personal Information is defined as the information on the customers (including those who inquire about the Company’s business, services or products, the users of the Company’s services or products, and individuals who are in charge of the contact point for the Company’s services or products, hereinafter referred to as the “Customers”), the entrusted parties of the Company, the parties to the business alliance with the Company or any other counterparties (including individuals who are in charge of the contact point for the Company, hereinafter referred to as the “Counterparties”), and those who have applied for employment with the Company (hereinafter referred to as the “Applicants for Employment”) that can identify specific individuals, such as name, e-mail address, ID, address, etc., (including any information that can be easily collated with other information and thereby used to identify that specific individual) or any other information as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information (hereinafter referred to as the “PIPA”).

2. Management of Personal Information

The Company shall take the necessary and appropriate measures for managing the security of the Personal Information and implement safety measures to strictly manage the Personal Information. If you wish to make any inquiries regarding the necessary and appropriate measures of the Personal Information, please inquire at the contact point in Section 10.

3. Purpose of Use of the Personal Information

The Company may use the Personal Information for the following purposes. In cases where there are grounds permitted under the PIPA or any other laws and regulations, where the Identifiable Person (meaning the “Identifiable Person” as defined in Article 2, Paragraph 4 of the PIPA; the same applies hereinafter)gave consent, or the Company has separately notified or disclosed the purpose of use, the Company does not use the Personal Information for any purposes other than the following purpose;
If the purpose of use of the Personal Information is separately stipulated in the terms of use of the Company’s Services, etc., such purpose of use shall also be included.

【Information on the Customers】
To identity verification on the Company’s Services, etc.;
To provide the Company’s Services, etc.; To provide information regarding the Company’s Services, etc.;
To provide information regarding events and seminars related to the Company’s Services, etc.;
To conduct questionnaires or any other investigation regarding the Company’s Services, etc.;
To operate and manage the Company’s Services, etc.;
To create statistical data or any other data that does not identify individuals;
To analyze and classify the Customer’s information to improve the Company’s Services, etc. (including monitoring and countermeasures against illegal activities);
To analyze the attributes and tastes, etc. of the Customer’s information, and to display contents, advertisements, etc. of the Company’s Services, etc. or third-party services optimized for such attributes and tastes, etc., or to send messages by e-mail, SMS, online chat, notification on a browser, etc.;
To perform prize competitions, campaigns, etc.;
To research and develop new services or products of the Company;
To assist the Customers in resolving issues related to the Company’s Services, etc. in making use of the Company’s Services, etc., and to perform any other customer success and customer support;
To accurately ascertain the inquiries on the contents and send answers and information about the inquires, etc.;
To investigate and respond to conduct prohibited by contracts, terms of use, etc.; and
To use for purposes incidental to the above purposes.

【Information on Counterparties】
To contact Counterparties regarding transactions;
To perform obligations and exercise rights regarding transactions;
To accurately ascertain the inquiries of contents and send answers and information about the inquires, etc.;
To provide information on the use, quality, safety, effectiveness, etc. of the Company’s Services, etc.;
To introduce, send, provide, and promote the Company’s Services, etc.;
To investigate and respond to conducts prohibited by agreements, contracts, terms of use, etc.; and
To use for purposes incidental to the above purposes.

【Information on applicants for employment】
To conduct employment screening of the Company;
To deal with the affairs of employment screening of the Company, such as communication regarding employment screening of the Company;
To provide information on medical examinations at the time of hiring and on procedures for becoming the member of the Company to those whom the Company has decided to hire; and
To use for purposes incidental to the above purposes.

4. Provision to Third Parties

The Company does not provide the Personal Information to third parties, except as permitted under the PIPA or any other laws and regulations. The Company use Individual Number or Specific Personal Information (meaning the Personal Information that includes Individual Number) only for dealing with affairs permitted by the Act Concerning Use of Numbers to Identify Specific Individuals in Administrative Procedures or any other applicable laws and regulations, and the Company does not provide Individual Number or Specific Personal Information to any third party, except as permitted by such Acts or other applicable laws and regulations.

5. Provision to Third Parties Located in Foreign Countries

In the cases where the Company provides the Personal Information to a third party in a foreign country in accordance with laws and regulations, the Company shall take necessary measures such as the provision of information.

6. Entrusting the Handling of the Personal Information

In the cases where the Company entrusts the handling of the Personal Information to an outside contractor, the Company shall conduct necessary and appropriate supervision by contractually obligating the contractor to ensure appropriate security management.

7. Requests for Disclosure, Correction, etc. of the Personal Information

Please contact the following for any inquiries regarding our handling of personal Information.

8. Use of Cookies, etc.

The Company uses cookies. You can set your browser to limit the use of cookies, but please note that restricting the use of cookies may limit the Company’s Services, etc. and the features available on the Company’s website. In addition, the Company uses tools set forth below to understand how the Company’s website is used. For more information on such tools, including data collection and processing methods, please refer to the following URL.

【Google Analytics】
Tool providers: Google.inc.
Google Analytics Terms of Service: https://marketingplatform.google.com/about/analytics/terms/gb/
Privacy Policy: https://policies.google.com/privacy?hl=en
Privacy & Terms: https://policies.google.com/technologies/partner-sites?hl=en

【Pardot】
Tool providers: Salesforce.com, Inc.
Pardot Terms of Service: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/salesforce_MSA-jp.pdf
Privacy Policy: https://www.salesforce.com/eu/company/privacy/

9. Compliance with and Review of Laws, Regulations and Norms

The Company shall comply with Japanese laws, regulations, and other norms applicable to Personal Information in the Company’s possession and will endeavor to review and improve the contents of the Policy as appropriate.

10. Contact the Company

If you wish to make any inquiries regarding handling of the Personal Information by the Company, please contact the following addresses.

FullDepth Co., Ltd.
Higashi-Nihonbashi 1st Building 2F, 2-8-4 Higashi-Nihonbashi, Chuo-ku, Tokyo
privacy@fulldepth.co.jp

11. Name, address and name of representative of the business operator handling the Personal Information

FullDepth Co., Ltd.
Higashi-Nihonbashi 1st Building 2F, 2-8-4 Higashi-Nihonbashi, Chuo-ku, Tokyo, 103-0004, Japan
Satoshi Yoshiga, Representative Director, and CEO

… and upwards