Privacy Policy

Reflect Inc. (hereinafter referred to as the "Company") establishes this Privacy Policy (the "Policy") regarding the handling of personal information as follows.

Article 1 (Definition of Personal Information)

In this Policy, "Personal Information" means personal information as defined under Article 2, Paragraph 1 of the Act on the Protection of Personal Information of Japan (the "APPI").

Article 2 (Purpose of Use)

1. The Company uses personal information for the following purposes:
   1. To provide and operate the services offered by the Company under the name "Reflect," as well as related training services (collectively, the "Services"), for users
   2. To provide and operate the Services for organizations that are direct contracting parties of the Services, including sharing usage status and related information of users who use the Services under employment or service agreements with such organizations
   3. To provide notifications to users and information regarding the Company's services, including changes to the Terms of Use and service content
   4. To verify and authenticate users' identities
   5. To respond to inquiries
   6. To investigate, compile statistics, and analyze usage trends
   7. To improve the Services and to develop new services and features
   8. To conduct academic research, empirical research, and other forms of research
   9. To maintain and improve systems and to respond to system failures or issues
   10. To provide information related to recruitment activities and to conduct recruitment screening
   11. For employment management and internal procedures (with respect to officers and employees)
   12. For shareholder management and procedures required under the Companies Act and other applicable laws (with respect to shareholders, holders of stock acquisition rights, etc.)
   13. To manage subcontracting and outsourcing relationships (with respect to contractors, their employees, and sub-contractors)
   14. To create statistical data processed into a form that does not identify individuals
   15. For purposes incidental or related to the above purposes
2. The Company may change the purposes of use within a scope reasonably deemed to be related to the original purposes. In such cases, the Company will notify users or publicly announce such changes.

Article 3 (Restriction on Use of Personal Information)

The Company shall not handle personal information beyond the scope necessary to achieve the stated purposes of use without obtaining the prior consent of the individual, except as permitted under the Act on the Protection of Personal Information of Japan or other applicable laws and regulations.Notwithstanding the foregoing, this restriction shall not apply in the following cases:

1. When handling of personal information is required by law
2. When it is necessary to protect the life, body, or property of an individual and it is difficult to obtain the individual's consent
3. When it is particularly necessary for the improvement of public health or the promotion of the sound development of children and it is difficult to obtain the individual's consent
4. When cooperation with a national government body, a local government, or a party entrusted by such body is required to perform duties prescribed by law, and obtaining the individual's consent may impede the performance of such duties

Article 4 (Proper Acquisition of Personal Information)

The Company shall acquire personal information in an appropriate manner and shall not acquire personal information through deception or other wrongful means.

Article 5 (Security Management of Personal Information)

1. The Company shall provide necessary and appropriate supervision to its employees to ensure the secure management of personal information and to prevent risks such as loss, destruction, alteration, or leakage of personal information.In addition, where the Company entrusts all or part of the handling of personal information to a third party, the Company shall exercise necessary and appropriate supervision over such third party to ensure that personal information is securely managed.
2. This website uses "reCAPTCHA v2," a service provided by Google LLC, to protect the site from spam and other abusive submissions made through online forms. The use of reCAPTCHA is subject to Google's Privacy Policy and Terms of Service.The reCAPTCHA API collects hardware and software information (such as device and application data) and transmits such information to Google for analysis. Information collected in connection with the use of this service is used for the purpose of improving reCAPTCHA and for general security purposes.

Article 6 (Provision of Personal Data to Third Parties)

1. Based on consent to this Privacy Policy, the Company may provide users' personal data, to the extent necessary, to organizations that are direct contracting parties of the Services and with which the users have entered into employment or service agreements, in connection with providing and operating the Services.
2. Based on consent to this Privacy Policy, the Company may also provide users' personal data to research institutions or companies partnered with the Company for purposes such as research, improvement of the Services, and development of new services or features. In such cases, information unnecessary for such purposes, including names, shall be excluded to the extent possible.
3. Except as set forth in the preceding paragraphs or as permitted under the Act on the Protection of Personal Information of Japan or other applicable laws and regulations, the Company shall not provide personal data to third parties without obtaining the prior consent of the individual.Notwithstanding the foregoing, the following cases shall not be deemed "provision to third parties":
   1. When the Company entrusts all or part of the handling of personal information to a third party within the scope necessary to achieve the purposes of use
   2. When personal information is provided in connection with a merger or other succession of business
   3. When personal information is jointly used in accordance with applicable laws and regulations
   4. Other cases permitted under the Act on the Protection of Personal Information of Japan or other applicable laws and regulations

Article 7 (Disclosure, Correction, and Deletion of Personal Information)

When an individual requests disclosure, correction, or deletion of personal information in accordance with the Act on the Protection of Personal Information of Japan (collectively, "Disclosure, etc."), the Company shall, after confirming that the request is made by the individual concerned, carry out such Disclosure, etc. without delay. If the requested personal information does not exist, the Company shall notify the individual to that effect.Notwithstanding the foregoing, this Article shall not apply where the Company is not obligated to comply with such a request under the Act on the Protection of Personal Information of Japan or other applicable laws and regulations.Please note that the Company may charge a handling fee for requests for Disclosure, etc., in accordance with applicable laws and regulations.

Article 8 (Suspension of Use or Erasure of Personal Information)

When an individual requests, in accordance with the Act on the Protection of Personal Information of Japan, the suspension of use or erasure of personal information (collectively, "Suspension of Use, etc.") on the grounds that such personal information is being handled beyond the scope of the publicly announced purposes of use or that it was obtained through deception or other wrongful means, and if the Company determines that such request is justified, the Company shall, after confirming that the request is made by the individual concerned, carry out the Suspension of Use, etc. without delay and notify the individual to that effect.Notwithstanding the foregoing, this Article shall not apply where the Company is not obligated to carry out the Suspension of Use, etc. under the Act on the Protection of Personal Information of Japan or other applicable laws and regulations.

Article 9 (Amendments to This Privacy Policy)

The Company shall periodically review its operational practices regarding the handling of personal information and endeavor to continuously improve such practices.The Company may amend this Privacy Policy in whole or in part. In the event of any material changes to this Privacy Policy, the Company will notify users by posting an announcement on its website or by other appropriate means.

Article 10 (Inquiries Regarding the Handling of Personal Information)

Article 11 (Use of Data Obtained from Google APIs)