Privacy Policy
Article 1 — General Provisions
ZEALS Co., Ltd. (“ZEALS”, “we”, “us”, or “our”) complies with the Act on the Protection of Personal Information and other applicable laws, regulations, and guidelines. We handle the personal information of individuals (“Customers”) in accordance with this Privacy Policy. Where separate terms of use, privacy policies, or other individual terms apply to a specific service, those terms form part of this Privacy Policy and govern matters not addressed here. Translations in languages other than Japanese are provided for reference only; if there is any inconsistency, the Japanese version prevails.
Article 2 — Information We May Collect
We may collect the following information (collectively, “Personal Information, etc.”) directly from Customers, automatically through use of our services, or by other lawful means. This may include names, addresses or regions of residence, age, date of birth, gender, telephone numbers, email addresses and other contact details; employment, household, credit, financial-product, and other information needed to provide appropriate service guidance; inquiry conversations and video-call images; employee information; and business-partner information. Automatically collected information may include survey responses, device and log information, browser type, IP address, cookies and other device identifiers, service-use history, activity information, purchase and payment history, advertising-contact records, and location information. We may also receive information disclosed through external-service privacy settings with consent, information shared for outsourcing or joint use, publicly available information, and information specified in individual terms.
Article 3 — Purposes of Use
We use Personal Information, etc. only to the extent necessary for the following purposes: to authenticate accounts, provide, maintain, and bill for our services; respond to inquiries; deliver campaign prizes; and provide notices about changes to our terms or services. We may use it to recommend products and content suited to Customers, measure advertising and behavior, and deliver personalized advertising. We may analyze service-use information to develop and improve our services, content, design, and flows, and conduct evaluation surveys. We also use information to prevent fraud and unauthorized access, improve security, manage business-partner information and contractual performance, carry out recruitment and employment procedures, and perform other purposes specified in individual terms.
Article 4 — Use of Cookies and Similar Technologies
We may use cookies and other information-collection modules to obtain access and browsing information for analytics and similar purposes. Information collected through these technologies does not, by itself, identify an individual Customer. Customers can control or disable cookies through their browser settings; however, disabling them may reduce convenience or limit available service functionality. We use cookie information to operate, maintain, and improve our services, develop and improve products and services, and provide advertising tailored to Customer usage.
Article 5 — Management and Protection of Personal Information
We manage Personal Information strictly and do not disclose or provide it to third parties without Customer consent, except where necessary to protect life, body, or property; where necessary for public health or the sound development of children; where cooperation with a government body is required by law; or where otherwise permitted by applicable law. We take preventive and corrective measures against unauthorized access, loss, destruction, alteration, leakage, and other risks.
Article 6 — Outsourcing of Personal Information Handling
We may outsource all or part of the handling of Personal Information to the extent necessary to achieve the purposes of use. In such cases, we carefully assess the suitability of the contractor, establish confidentiality and other required provisions by contract, and provide necessary and appropriate supervision.
Article 7 — Joint Use of Personal Information
For certain services, we may jointly use Personal Information, etc. with other business operators. Before such joint use begins, we will announce, through the applicable individual terms, privacy notice, or another method prescribed by us, the categories of information jointly used, the scope of joint users, purposes of use, and other matters required by law to be disclosed or made readily available to Customers.
Article 8 — Provision of Personal Information to Third Parties
Except as permitted by the Act on the Protection of Personal Information or other applicable laws, we will not provide Personal Information to third parties without obtaining Customer consent in advance.
Article 9 — Disclosure of Personal Information
Customers may request notice of the purposes of use and disclosure of Personal Information we hold, including records of third-party provision, by following the procedure in Article 12. We will disclose the information without delay by a method we reasonably determine. We may withhold all or part of the information if disclosure is likely to harm the life, body, property, or other rights or interests of a Customer or third party; seriously impede our proper business operations; or violate applicable law. If we decide not to disclose information, we will notify the Customer without delay.
Article 10 — Correction, Addition, or Deletion
If Personal Information we hold is incorrect, Customers may request its correction, addition, or deletion by following the procedure in Article 12. Upon receiving a request, we will conduct the necessary investigation without delay and, if we determine that the request is justified, correct, add to, or delete the relevant information without delay. We will promptly notify the Customer of our decision.
Article 11 — Suspension of Use, Erasure, and Suspension of Third-Party Provision
Customers may request suspension of use, erasure, or suspension of third-party provision of Personal Information we hold by following the procedure in Article 12. Upon receiving a request, we will conduct the necessary investigation and, if we determine that the request is justified, take the requested measures without delay. If taking such measures would require substantial cost or is otherwise difficult, but an alternative measure necessary to protect Customer rights and interests is available, we will take that alternative measure. We will promptly notify the Customer of our decision.
Article 12 — Procedures for Requests Concerning Personal Information
To make a request under this Policy, please complete our prescribed request form, attach the identity-verification documents described below, and send them to the contact address below. The fee for notification of purposes of use or disclosure requests is JPY 1,100, including tax, per request. Please contact the inquiry desk for the prescribed form. For requests made by the Customer, submit a copy of one of the following: driver’s license, passport, My Number Card, or qualification confirmation certificate. For requests made by an agent, submit identification for both the Customer and the agent, together with a power of attorney. Send requests to: ZEALS Co., Ltd., Personal Information Inquiry Desk, 6F ARCO Tower, 1-8-1 Shimomeguro, Meguro-ku, Tokyo 153-0064, Japan.
Article 13 — Complaints and Consultations
We accept complaints and consultations from Customers regarding our handling of Personal Information and respond appropriately and promptly. We also respond promptly and appropriately to requests concerning disclosure, correction, addition, deletion, refusal of use, or refusal of provision of Personal Information.
Article 14 — Security Control Measures
To safely manage personal data, including Personal Information we have obtained or intend to obtain and handle as personal data, we maintain this Privacy Policy as our basic policy and establish internal rules for acquisition, use, storage, provision, deletion, and disposal. We appoint managers responsible for personal-data handling, clarify the persons and data within scope, regularly review access authority, maintain reporting and incident-response systems, and conduct periodic audits. We provide regular training on personal-data handling and information security, require confidentiality commitments, control access to work areas, protect equipment, media, and documents from theft or loss, limit personnel and data accessible through systems, monitor access logs, protect systems from unauthorized access and malicious software, and evaluate security risks. When handling personal data in a foreign country, we understand the applicable data-protection framework and take necessary and appropriate safeguards.
Article 15 — Changes to This Privacy Policy
We review this Policy from time to time and endeavor to improve it. We may amend this Policy except where otherwise provided by law or by this Policy. Any amended policy becomes effective when we notify Customers by our prescribed method or post it on our website.
Article 16 — Contact Information
For comments, questions, requests for disclosure of Personal Information, or other inquiries about our handling of Personal Information, please contact: ZEALS Co., Ltd., Personal Information Inquiry Desk, 6F ARCO Tower, 1-8-1 Shimomeguro, Meguro-ku, Tokyo, Japan. Email: info@zeals.co.jp. Telephone: +81-3-5719-2133. Hours: 10:00–19:00, excluding Saturdays, Sundays, and public holidays.
Article 17 — Governing Law and Jurisdiction
This Policy is governed by and construed in accordance with the laws of Japan. The Tokyo District Court has exclusive agreed jurisdiction as the court of first instance for all disputes arising from or relating to this Policy or services provided by us.
Article 18 — Company Address and Representative
Company: ZEALS Co., Ltd. Address: 6F ARCO Tower, 1-8-1 Shimomeguro, Meguro-ku, Tokyo 153-0064, Japan. Representative Director: Masahiro Shimizu.