TSUNAGU GROUP HOLDINGS Inc.
Mitsuhiro Yoneda, Representative Director and President and Executive Officer
This page explains how we handle personal information of users acquired through the services we provide (Shotworks, Shotworks Convenience Store, Hataraku Job Navigator, Yumex Net, and the smartphone applications provided by each service) (hereinafter, "Our Services").
For our personal information protection policy, please see our " Privacy Policy ."
(1) Purpose of use
Personal information acquired through our services will be used only for the following purposes and will not be used for any other purposes.
a) In order to provide our services, we use all information that users register with our services.
b) To verify your identity, we use your email address and mobile phone number, and in some cases, we may use other personally identifiable information, such as your name, address, date of birth, phone number, and image data of your photo ID.
c) We may use information on user attributes such as gender, age, attributes, nearest station, time of use, method of use, usage environment, services used, pages and advertisements viewed (hereinafter referred to as "information on user attributes") in order to make the content and advertisements of our services more suitable for users, enrich and improve them, consider new services, customize them to improve convenience, and select subjects for surveys.
d) We may use contact information such as email address, telephone number, and address to notify users about our services and to contact them as necessary.
e) We may use your contact information, such as your email address and address, to send you prizes and/or merchandise, or transfer payments.
f) In order to allow users to view or correct their registration information and view their usage status, we may use registration information such as name, address, contact details, and date of birth, as well as information regarding past usage history.
g) In order to respond to inquiries from users, we may use information used to provide the services you inquired about, such as the content of your inquiry, information about your attributes, information about usage fees, and contact information.
h) In order to respond accurately to questions and inquiries from users, we may use information about the user's usage method and environment.
i) We may use personally identifiable information, such as your name, address, date of birth, and telephone number, to refuse service to anyone who violates our terms of use or who is attempting to use our services for fraudulent or improper purposes.
j) In order to analyze and provide what information or services would be effective for related departments, business partners, and advertisers within our company, we may use the information to analyze user attributes and to select subjects for analytical surveys. Please note that no personally identifiable information will be included in the analysis results.
k) We may use email addresses to deliver advertisements appropriate to users in each of the advertising services of Google, Yahoo, Facebook, Twitter, LINE, and Criteo. In such cases, email addresses will be converted into data in an irreversible manner and used as information that cannot identify individuals.
To disable ad delivery using your email address, please contact the “Contact Information Regarding Personal Information” listed on this page (11).
(2) Provision to third parties
We will not disclose or provide users' personal information to third parties, except under the following legitimate reasons:
a) When the user consents to the disclosure, sharing, or provision of information. When it is deemed necessary to disclose or share information in order to provide the service desired by the user.
b) When a user of the job information provision service operated by our company applies for a job posted, the name, age, gender, telephone number, email address, address, work history, and other information entered at the time of application will be provided to the company that posted the job information and to the company's contractors for the purpose of the employment selection process.
c) We may provide job information held by our business partners (hereinafter referred to as "Partners") through our business partners. If you apply for a job provided by a Partner, your name, date of birth, gender, occupation, telephone number, email address, address, and other information entered when applying will be provided to the Partner for the purpose of employment selection.
d) When information is required by a company that performs work on behalf of the Company in order to provide services to the User. (Unless otherwise notified by the Company, such a company may not use the personal information provided by the Company beyond the extent necessary for the above-mentioned purposes.)
e) When we receive a formal legal inquiry from a public institution such as a court or the police.
f) When a user's actions on a website operated by our company violate the terms of use, etc., and it is deemed necessary to protect our rights, property, services, etc., and it is difficult to obtain the consent of the individual.
g) When there is an imminent danger to a person's life, body, property, etc., and there is an urgent need, and it is difficult to obtain the individual's consent.
(3) Provision to third parties in foreign countries
We may provide part of the information to third parties under the preceding paragraph to advertisement distribution companies located in foreign countries.
a) Personal data provided: email address, telephone number and address
b) Foreign entities providing personal data
Google LLC
1600 Amphitheater Pkwy Mountain View, CA, 94043-1351 United States.
c) Country of location of business: California, United States
d) Personal information protection systems in the country where the business operator is located Survey on personal information protection systems in the state of California, USA, on the Personal Information Protection Commission website:
https://www.ppc.go.jp/files/pdf/USA_report.pdf (United States of America),
https://www.ppc.go.jp/files/pdf/california_report.pdf (California)
e) Personal information protection measures taken by the business operator The business operator itself will handle personal information in accordance with its own privacy policy.
(4) Entrustment
We may outsource all or part of our personal information handling operations to contractors that we have assessed as having safety management measures in place that are equivalent to or greater than those of our company. We will be responsible for the handling of personal information by the contractors.
(5) Request for disclosure, etc.
If you wish to request notification of the purpose of use of personal information handled by our company, disclosure, correction, addition or deletion of the content, suspension of use, erasure, or suspension of provision to a third party of personal information subject to disclosure, please contact us at the address listed below.
a) Contact point for disclosure requests, etc. TSUNAGU GROUP HOLDINGS Inc. , Ltd. Complaints and consultation desk Address: 1F, Jinbocho Kita Tokyu Building, 3-1-16 Kanda Misakicho, Chiyoda-ku, Tokyo 105-0061 Contact: privacy@tsunagu-grp.jp
b) Acceptance of requests for disclosure, etc. Please submit requests for disclosure, etc. by mail or email.
c) Method of identity verification We will verify your identity using a driver's license, My Number card (with photo), etc. If you contact us by email, we will contact you again.
d) Fees: Free. However, if there are any changes to the fees, such changes will be announced in advance.
e) Request for disclosure by representative If the person making the request for disclosure is the legal representative of a minor or an adult ward, or a representative delegated by the individual to make the request for disclosure, please enclose the following documents (i or ii).
i) In the case of a legal representative: ・ One document verifying the legal representative's authority (a copy of the family register; in the case of a parent, a copy of the health insurance card with the dependents listed is acceptable) ・ One document verifying the identity of the legal representative (a copy of the legal representative's driver's license or My Number card (with photo))
ii) In the case of a proxy by delegation: ・ One letter of attorney ・ One document verifying the identity of the proxy (a copy of the proxy's driver's license or My Number card (with photo))
(6) Voluntary provision of personal information
It is up to the user whether or not to provide personal information to our services. However, if necessary information is not provided, we may not be able to provide our services in an appropriate manner. Furthermore, if information required for the provision of the services is not provided, we may refuse to allow you to use our services.
(7) When personal information is acquired in a manner that cannot be easily recognized by the individual
We use cookies and localStorage to protect user privacy, improve convenience, deliver advertisements, and obtain statistical data. In addition, we may use technologies such as cookies, localStorage, and JavaScript to obtain attribute information that cannot identify individuals, such as age, gender, occupation, and residential area (limited to information that cannot identify individuals even when combined), device information, user behavior history within our service site (accessed URLs, content, order of browsing, etc.), and location information based on the user's consent or application when using a smartphone, etc. However, cookies, localStorage, behavior history, etc. do not contain any personal information.
a) Use of access analysis tools
We use the following tools as access analysis tools that use cookies.
i) Google Analytics
Google Analytics uses cookies to collect traffic data.
This traffic data is collected anonymously and does not identify individuals. You can refuse collection of this function by disabling cookies.
For more information about Google Analytics, please see Google's Google Analytics Terms of Use and Privacy Policy .
ii) Microsoft Clarity
Microsoft Clarity uses cookies to collect usage data.
This data is collected anonymously and does not identify you personally.
For more information about Microsoft Clarity, please see Microsoft's Microsoft Clarity Terms of Use and Microsoft's Privacy Statement .
(8) About behavioral targeting advertising
Our service uses behavioral targeting advertising services to deliver appropriate advertisements to users. Companies that display advertisements on sites operated by our company may set and access cookies and localStorage on our service. In this case, the advertiser's use of cookies and localStorage will be in accordance with the advertiser's own privacy policy. Advertisers and other companies cannot access cookies and localStorage on our service.
Cookies and localStorage are information recorded on a computer's hard disk and can usually be disabled through the user's browser settings. If you reject all cookies and localStorage, you may not be able to use some of our services. In addition, cookies, localStorage, and behavioral history do not contain any personal information.
We also use the extended conversion feature of Google Ads to measure advertisements. We measure advertisements based on encrypted email addresses, phone numbers, etc. provided by our customers, and information that is matched with Google users.
(9) Existence of external transmission, third-party provision, and information collection modules
The Company collects the user information described in the previous article through the following information collection module built into the web pages and applications of the Company's services. An information collection module is a program provided by a third party that has the function of collecting and analyzing user information. The Company may combine the user information collected through the information collection module with an ID that identifies the individual user, add the user's attribute information, and use the information.
a) Name of information collection module: KARTE
Information collection module provider: PLAID Inc. User information acquired: User identifier, email address, date of birth, nearest station, mobile phone number, highest level of education, work history
(10) Procedures for changing this document (Application Privacy Policy)
This document (Application Privacy Policy) may be revised. If there are changes or additions to the items of user information acquired, changes to the purpose of use, changes to third-party provision, etc., these may be made without individual agreement with customers if any of the following conditions are met. In such cases, the Company will notify customers in advance by posting on its website or other appropriate means.
a) When it is in the general interest of users.
b) When the change does not conflict with the purpose set out in the service terms and conditions and is reasonable in light of the need for the change, the appropriateness of the content after the change, and other circumstances related to the change.
(11) Opting out of behavioral targeting advertising
If you wish to disable behavioral targeting ad delivery using cookies and localStorage information, please visit the opt-out page below and follow the instructions. (The opt-out function may not be available if you are accessing the page from a mobile phone.) *Data acquired through localStorage is not used outside of our services.
a) Treasure Data
https://www.treasuredata.co.jp/privacy/
b) Digital Advertising Consortium Inc.
http://www.dac.co.jp/utility/data-policy
c) Google Inc.
https://policies.google.com/privacy?hl=ja&gl=jp
d) Google Inc. (Google Analytics)
https://www.google.co.jp/analytics/terms/jp.html#6
e) Yahoo Japan Corporation
http://btoptout.yahoo.co.jp/optout/index.html
f) CRITEO Inc.
https://www.criteo.com/jp/privacy/
g) Scigineer Inc.
http://www.scigineer.co.jp/privacy/opt-out/
h) Silver Egg Technology Co., Ltd.
http://www.silveregg.co.jp/privacypolicy/cookie.html
i) FUN Communications Inc. (nend)
http://nend.net/privacy/explainoptout
j) Maverick Corporation
https://www.mvrck.co.jp/reject/
k) Facebook
https://www.facebook.com/legal/terms
l) Twitter
https://support.twitter.com/articles/20171553-
m) Ve
https://www.ve.com/ja/cookies-policy
n) AppsFlyer
https://www.appsflyer.com/optout
o) FreakOut Inc.
https://js.fout.jp/info/privacy.html
p) LINE
https://optout.tr.line.me/
q) TikTok
https://support.tiktok.com/ja/account-and-privacy/personalized-ads-and-data/personalization-and-data
(12) Contact details regarding personal information
Personal Information Protection Manager
privacy@tsunagu-grp.jp