Privacy Policy

EmoticoreAI Co., Ltd. (hereinafter referred to as the “Company”) establishes this Privacy Policy (hereinafter referred to as this “Policy”) to set forth the handling of user information, including personal information, that the Company acquires. Please refer here for the Company’s address and the name of its representatives. In the event that specific services provided by the Company have separate privacy policies, such policies shall take precedence and apply over this Policy.

1. Definitions

1. Personal Information refers to “personal information” as defined under Article 2, Paragraph 1 of the Act on the Protection of Personal Information of Japan and other applicable laws and regulations.
2. User Information refers to information relating to the identification of users, behavioral history on communication services, and other information generated or accumulated in relation to users or their devices, which the Company collects under this Policy.
3. User means any individual who uses the services provided by the Company.

2. Information Collected and Methods of Collection

1. The Company collects the following categories of user information (hereinafter collectively referred to as the “Services”) through its services and websites, depending on the method of collection:
   1. Information provided from external services
      If a User permits the Company’s Services to be linked or integrated with social networking services, business communication tools, or other services provided by third parties (collectively “External Services”), the Company may collect the following information from such External Services in accordance with the scope of the User’s authorization:
      1. Account names, profile images, and status messages used on the External Services, as well as internal identifiers assigned independently by the operators of such External Services
      2. Any other information disclosed to the Company by the User via privacy settings on such External Services
   2. Information collected when Users use the Services
      The Company may collect information relating to the User’s postings on linked External Services as stated above, content posted by Users on the Company’s feedback pages, and information on access status and usage of the Services. This may include:
      1. Referrer information
      2. IP addresses
      3. Server access log information
      4. Cookies, ADIDs, IDFAs, and other identifiers
   3. Information collected with individual consent
      Where the User has provided individual consent as set forth in Article 4(1), the Company may collect the following information from the User’s device:
      1. Location information
2. Information collected when Users use the Company’s websites
   The Company may collect content posted by Users on the Company’s websites, content submitted through feedback pages, and information on access status and usage of the Services. This may include:
   1. Referrer information
   2. IP addresses
   3. Server access log information
   4. Cookies, ADIDs, IDFAs, and other identifiers
3. Information collected through user inquiries
   In responding to inquiries from Users via telephone or email, the Company may collect information relating to the content of such inquiries. To accurately understand the content of inquiries, the Company may record telephone conversations.

3. Purpose of Use
The specific purposes of use for user information relating to the Services and Company websites, as well as personal information of the Company’s employees, are as follows:

1. User Information
   1. To provide, maintain, protect, and improve the Services (including the generation of content such as messages, images, and audio using artificial intelligence)
   2. To create statistical data processed in a manner that does not identify individuals, in relation to the Company’s services
   3. To respond to inquiries, provide guidance, and conduct communications regarding the Services, the Company’s websites, or the Company’s business
   4. To respond to acts that violate the Company’s terms, policies, and other rules (collectively, “Terms”) regarding the Services
   5. To notify Users of amendments to the Terms or other changes related to the Services
   6. To deliver, display, and measure the effectiveness of advertisements
   7. To conduct recruitment and selection of job applicants
   8. To conduct seminars for which users have registered
   9. To provide information necessary for public relations activities
2. Personal information of business partners, participants of events/seminars organized, co-organized, or attended by the Company, and members of media where the Company places articles or advertisements
   1. For business communications, transactions, contract execution, and related administrative matters
   2. To send information and communications regarding events, seminars, and similar activities
   3. To provide information and proposals regarding the Company’s products and services
3. Personal information obtained in relation to inquiries
   1. To accurately understand, respond to, and send materials related to inquiries, and for other communications
   2. To improve the Company’s responses to inquiries
4. Personal information of officers and employees
   1. For work related to the determination and payment of salaries and other remuneration
   2. For work related to welfare and benefits
   3. For the implementation of HR systems, employment management, talent development, and capacity building
   4. For reviewing and improving working conditions
   5. For administrative procedures and communications required upon hiring and termination, and for other work-related procedures and communications
   6. To manage employees’ use of the Company’s facilities
   7. To conduct other work incidental to the above
5. Personal information of job applicants
   1. To communicate regarding interviews, notify results, and other recruitment-related communications
   2. To carry out the recruitment and selection process

4. Methods of Notification, Publication, Consent, and Requests to Stop Use

1. Prior to collecting the following user information, we shall obtain the user’s consent:
   1. Location Information
2. Users may, through the designated settings of the Service, request the suspension of all or part of their user information. Upon receiving such a request, the Company shall promptly suspend the use of such information in accordance with our procedures. However, for certain types of user information where collection or use is essential for the provision of the Service, suspension of collection or use will only occur if the user stops using the Service in accordance with the external service’s prescribed method or withdraws from the Service pursuant to the Company’s prescribed method.

5. Provision to Third Parties
The Company will not provide personal information included in user information or employee personal information to any third party (including parties outside Japan) without the individual’s prior consent, except where disclosure is permitted under the Act on the Protection of Personal Information or other applicable laws and regulations. However, the Company may provide such information to third parties (including parties outside Japan) in the following circumstances:

1. When the Company entrusts all or part of the handling of personal information to a third party to the extent necessary to achieve the purposes of use.
2. When personal information is provided in connection with a business succession due to a merger or other reason.
3. When cooperation is necessary for a national or local government agency, or a party commissioned by them, to carry out duties as prescribed by applicable law, and obtaining consent from the individual may impede the execution of such duties.
4. In other cases as permitted under the Act on the Protection of Personal Information or other applicable laws and regulations.

6. Disclosure of Personal Information
Upon request from an individual, the Company will, after confirming that the request is made by the individual, promptly disclose the requested personal information or records of third-party provision in accordance with the Act on the Protection of Personal Information or other applicable laws and regulations. If no such information or record exists, the Company will notify the individual accordingly. However, the Company is not obliged to disclose information in cases where disclosure is not required under the Act on the Protection of Personal Information or other applicable laws.
A fee of JPY 1,000 per request will be charged for disclosure.

7. Correction and Suspension of Use of Personal Information

1. If an individual requests, in accordance with the Act on the Protection of Personal Information or other applicable laws and regulations, the correction of their personal information or the suspension of its use for any of the reasons specified, the Company shall first verify that the request is made by the individual, promptly conduct the necessary investigation, and, based on the results, correct the personal information or suspend its use. The Company shall notify the individual of the action taken. If the Company decides not to correct or suspend the use of the personal information, the individual shall be informed of this decision.
2. The personal information is inaccurate.
3. The personal information has been used beyond the scope of the previously announced purpose of use.
4. The personal information was collected through false or fraudulent means.
5. The personal information is being used in a manner that may promote or induce illegal or improper acts.
6. The Company will, after confirming the request is made by the individual, promptly conduct the necessary investigation, make corrections or suspend use as appropriate, and notify the individual. If the Company decides not to correct or suspend use, the individual will be notified accordingly.
7. Upon request from an individual for deletion of personal information, the Company will, if deemed necessary to comply with the request, verify that the request is made by the individual and proceed with deletion, notifying the individual once completed.

8. Measures for Security Management
To ensure the security of personal information, the Company implements the following measures:

1. Formulation of Basic Policies:
   The Company formulates and operates this Privacy Policy to ensure proper handling of personal information.
2. Regulations on Handling Personal Data:
   The Company has established internal regulations governing collection, use, storage, provision, deletion, and disposal of personal information, including responsible personnel and their duties.
3. Organizational Measures:
   A person responsible for personal information management (Personal Information Protection Officer) is appointed, and roles and responsibilities for handling personal information are clearly defined.
4. Personnel Measures:
   Employees receive regular training regarding the handling of personal information.
5. Physical Measures:
   Access to areas handling personal information is controlled, and unauthorized access is prevented.
6. Technical Measures:
   Access control measures are implemented to limit personnel and scope of handled personal information.
7. External Environment Measures:
   When storing personal information overseas, the Company implements security measures while considering the personal information protection regulations of the relevant country.

9. Handling of Cookies
The Company uses cookies and similar tracking or analytics technologies (collectively, “Cookies”) on its website to provide users with appropriate services.

1. Overview of Cookies:
   Cookies are small text files containing data that are exchanged between the web server and the user’s browser and stored on the user’s device. Cookies may be used to collect non-identifiable information, including browsing history, service usage history, and location information. Users may configure their browsers to display sites using Cookies, disable Cookies, or delete stored Cookies. Disabling or deleting Cookies may limit website functionality.
2. Google Analytics:
   The Company uses Google Analytics provided by Google. Google collects and analyzes user browsing data based on Cookies set by Google or the Company and provides results to the Company for understanding user behavior and improving services. For details on Google’s handling of data in Google Analytics, please refer to Google’s site: “How Google Uses Information from Sites or Apps that Use Our Services.”

10. Contact Information
For inquiries regarding opinions, questions, complaints, requests based on Sections 6 or 7, or any other matters related to the handling of user information, please contact the following:

Address:
5F, FPG Links Jinnan, 1-11-4 Jinnan, Shibuya-ku, Tokyo 150-0041, Japan
Company: EmoticoreAI Co., Ltd.
E-mail: corporate@emoticore.ai

11. Procedure for Amendments to the Privacy Policy
The Company shall periodically review the handling of user information and endeavor to continuously improve its practices. The Company may amend this Privacy Policy as necessary. However, in cases where amendments require the individual’s consent under applicable laws, such amendments shall apply only to those individuals who have provided their consent through the method prescribed by the Company. In the event of any changes to this Privacy Policy, the Company shall notify individuals of the revised policy and its effective date by displaying it on the Company’s website or through other appropriate means.