Pale Blue Inc. (hereinafter referred to as the "Company") is committed to ensuring corporate ethics and legal compliance. Recognizing that protecting personal information—an important asset entrusted to us—is a critical social responsibility, the Company has established the following "Privacy Policy."

• 1. Handling of Personal Information

  1) Acquisition of Personal Information

  In the course of its business activities, the Company may acquire personal information within the scope necessary for legitimate business purposes, based on the consent of the individual or a contract with a business partner, etc., when receiving orders for the Company's products or services, technical consultations, repair requests, inquiries regarding the Company's products or services, participation in various questionnaires, campaigns, or events, and other inquiries to the Company.

  When acquiring sensitive personal information (special care-required personal information), the Company shall obtain the prior consent of the individual, except as otherwise provided by law. In addition, the Company shall not acquire personal information by deceit or other improper means.

  2) Purpose of Use of Personal Information

  The Company handles entrusted personal information for the following purposes:

  Personal Information of Clients/Business Partners:

  • (1)Conducting and communicating regarding business negotiations and meetings
  • (2)Providing information and contacting the persons in charge at business partners
  • (3)Executing operations outsourced to business partners
  • (4)Managing entry and exit to the Company's facilities

  Personal Information of Shareholders:

  • (1)Exercising rights and fulfilling obligations by shareholders or the Company under the Companies Act
  • (2)Providing services to shareholders
  • (3)Managing shares and shareholders, such as creating data based on various laws and regulations

  Personal Information of Job Applicants:

  • (1)Providing information to applicants (including internship applicants) and executing tasks related to recruitment activities
  • (2)Managing recruitment operations within the Company

  Regarding the handling of other personal information, the Company will strictly manage it based on related laws and regulations such as the Act on the Protection of Personal Information (APPI), the Company's internal rules for handling personal information, and this Policy.

  In addition, the Company may acquire personally related information—such as attribute information that alone does not fall under personal information (e.g., age, gender, occupation, area of residence), Cookies, IP addresses, advertising identifiers, location information, browsing history, and purchase history—from third parties affiliated with the Company, and use it by linking it with personal information already held by the Company. In such cases, the information will be used in accordance with this Privacy Policy.

  3) Provision of Personal Information to Third Parties

  The Company may provide the provided personal information to its outsourcing contractors within the scope necessary to achieve the above purposes of use. In such cases, the Company will exercise necessary and appropriate supervision over the contractors.

  Except as provided by law, the Company will not provide personal data to third parties without obtaining the prior consent of the individual. When providing personal data to a third party or receiving it from a third party, the Company will confirm necessary matters and create and retain records in accordance with the law.

  4) Retention Period of Personal Information

  The Company will retain personal information for the period necessary to achieve the purpose for which it was acquired. However, if a retention period is stipulated by law, that period shall apply.

  5) Disclosure, etc. of Personal Information

  When the Company receives a request from an individual regarding retained personal data held by the Company for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, suspension of provision to third parties, or disclosure of records of provision to third parties through the Company's prescribed procedures, the Company will respond without delay in accordance with the law.

  However, the Company may not be able to respond to all or part of the request if it is likely to significantly impede the proper execution of the Company's business, if it is likely to harm the life, body, property, or other rights and interests of the individual or a third party, or if a response is not required by other laws and regulations. In such cases, the Company will notify the individual to that effect without delay.

  6) Cross-Border Transfer of Personal Information

  When providing personal data to a third party located in a foreign country, the Company will, in accordance with the law, provide the individual with information regarding the name of the foreign country, the personal information protection system in that country, and the measures for the protection of personal information taken by the third party when obtaining the individual's consent.

  In addition, when providing personal data to a third party in a foreign country that has established a system necessary under the APPI based on the law, the Company will take necessary measures to ensure the continuous implementation of equivalent measures by the said third party.

  7) Handling of Personal Information Regarding Employees, etc.

  • (1)Personal information of the Company's employees, etc. (including temporary employees such as part-timers) is collected based on laws and regulations such as the Labor Standards Act and tax laws, as well as the Company's rules such as the Rules of Employment.
  • (2)Personal information will be handled only by designated executives and employees.
  • (3)Personal information regarding employees, etc. will not be disclosed without the consent of the individual, including in response to external inquiries, except as required by law.
  • (4)Even after retirement, it may be used for information provision and communication, etc.
  • (5)Personal information of employees, etc. is retained for a certain period even after retirement in accordance with the law. After the expiration of the retention period, it shall be promptly erased or deleted in accordance with laws and regulations and the Company's rules.

• 2. Compliance with Laws and Regulations Related to the Protection of Personal Information

  The Company complies with laws, regulations, and guidelines related to the protection of personal information, this Policy, and other internal rules of the Company.

• 3. Security Control Measures for Personal Information

  The Company takes necessary and appropriate security control measures to prevent unauthorized access to personal information, its loss, destruction, falsification, leakage, damage, etc., and to ensure the accuracy and safety of personal information. The security control measures taken by the Company include the appointment of a person responsible for handling personal information, the establishment of internal rules, employee training, access control to facilities, management of media and documents, access control to information systems, countermeasures against unauthorized access, and monitoring of information systems.

  When outsourcing the handling of personal information to a third party, the Company selects contractors who appropriately handle personal information, stipulates necessary matters in outsourcing contracts, etc., and exercises necessary and appropriate supervision over the contractors.

  Furthermore, when the Company handles personal data in a foreign country or uses cloud services provided by a business operator located in a foreign country, the Company takes necessary and appropriate security control measures after understanding the personal information protection systems in that foreign country.

  In the event that personal data leakage, loss, or damage occurs, and there is a significant risk of harming the rights and interests of individuals, the Company will, in accordance with the law, report to the Personal Information Protection Commission, notify the affected individuals, and take other necessary measures.

• 4. Continuous Improvement

  The Company will continuously review and improve its efforts to protect personal information.

• 5. Handling of Personal Information on This Website

  When acquiring and using users' personal information on the website operated by the Company, the Company will handle the personal information as follows, in addition to the contents stipulated above.

  1) Personal Information Provided by Users Themselves

  To provide necessary information in response to inquiries from visitors, the Company asks visitors to provide personal information such as their name, address, telephone number, and email address when contacting us via the Company's inquiry form. The purpose of use is as stipulated in "Purpose of Use of Personal Information" above, and may also be described on each website page.

  2) Use of Cookies, Web Beacons, etc.

  On the Company's website, information related to users such as Cookies, Web Beacons, IP addresses, advertising identifiers, browsing history, and other information may be acquired for the purpose of improving convenience, analyzing usage, delivering advertisements, obtaining statistical data, and improving services. While this information alone may not identify a specific individual, if it is used by linking it to personal information held by the Company, it will be appropriately handled as personal information in accordance with this Policy.

  In addition, the Company may use tools provided by third parties such as ad distribution business operators and access analysis operators. In such cases, user device information, browsing information, etc. may be sent to the said third parties. Users can disable Cookies through their browser settings. However, if Cookies are disabled, some functions of the Company's website may become unavailable.

  3) Use of Google Analytics

  The Company may use Google Analytics to understand website usage and to improve convenience and services. Google Analytics collects browsing history, usage status, device information, etc. of the website using Cookies. The information collected by Google Analytics is managed based on the terms and privacy policy of Google LLC. The Company does not use the information acquired through Google Analytics for the purpose of identifying individuals.

  Users can stop the collection of information by Google Analytics by disabling Cookies in their browser settings or by using the opt-out tool provided by Google.

  4) Handling of Personal Information on Linked Sites

  The Company cannot assume responsibility for the handling of personal information on websites other than the Company's website linked from the Company's website.

• 6. Inquiries

  For inquiries regarding this Policy, the Company's handling of personal information, requests for disclosure, etc. of retained personal data, complaints, and consultations, please contact the following desk.

  Pale Blue Inc. Personal Information Protection Manager (Head of Corporate Development) Email Address: privacy@pale-blue.co.jp

  Please note that upon requesting disclosure, etc., you may be asked to submit necessary documents to verify your identity. In addition, a fee may be charged for the notification of the purpose of use or the disclosure of retained personal data.

• 7. Prevailing Language

  This Privacy Policy has been prepared in Japanese and translated into English for reference purposes only. In the event of any discrepancy or conflict between the Japanese version and the English translation, the Japanese version shall prevail.

• 8. Governing Law and Jurisdiction

  This Privacy Policy shall be governed by and construed in accordance with the laws of Japan. Any disputes arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the Tokyo District Court in the first instance.

Personal Information Handling Business Operator: Pale Blue Inc.
Room 101, Mitsui Link Lab Kashiwanoha 1, 6-6-2 Kashiwanoha, Kashiwa City, Chiba
Representative: Jun Asakawa, CEO