PRIVACY POLICY

1.Privacy Policy

Nowhere Inc. (hereinafter referred to as “the Company”) recognizes that personal information is an important asset of individuals and that the protection of such information is an important responsibility of the Company, and in accordance with laws and other regulations, the Company will clearly state the purposes of use of personal information, acquire, use, and provide personal information appropriately, establish a management system and structure to protect personal information, and continuously improve such systems.
Basic Principles of Personal Information Protection:

We will comply with laws, national guidelines, and other regulations concerning the protection of personal information. We will clearly state the purposes for which personal information is to be used, and collect, use, and provide personal information in an appropriate manner. We will use acquired personal information only within the scope of the stated purpose of use, unless otherwise stipulated by law.
Personal information obtained will not be provided to third parties without the consent of the individual, except as required by law.
We will take appropriate organizational, physical, personnel, and technical measures to protect personal information and implement security control measures.
We will establish and disseminate rules for the protection of personal information, and educate and enlighten employees on the proper handling of personal information.
We will conduct inspections of the handling of personal information, management systems, and initiatives, and continuously improve and review them.
When outsourcing the handling of personal information, we will fully screen the contractor for eligibility and instruct and supervise the contractor to ensure thorough information management.
We will disclose, correct, add, delete, or notify the purpose of use of personal information at the request of the person in question in accordance with laws and regulations, and respond appropriately to comments and inquiries.

2.Purpose of Use of Personal Information

We will use the personal information we collect within the scope of the following purposes of use or other purposes that may be notified to you. Please be aware that if you do not provide us with your personal information, we may not be able to provide you with certain services, including responses to your inquiries.
We may also use personal information when we deem it necessary to protect our rights or to comply with legal proceedings, court orders, or legal process.

(1) Personal information about Customers & Users

To manage customers and users
To conduct campaigns, sweepstakes, and surveys
Notification (including by e-mail) of matters necessary for the operation of our services or website
To advertise, promote, and solicit sales of our products, etc. (including by e-mail)
Sending e-mail magazines
Packing and shipping of products
Calculation of charges and billing
Provision of point services
Posting of information submitted by members and users
Responding to various inquiries and after-sales service
Research and analysis of marketing data and development of new services – Preparation of statistical data to be provided to business partners
Investigation of technical problems and improvement of service quality
Exercise of rights and fulfillment of obligations based on contracts, laws

(2) Personal information concerning applicants for employment

For employment selection and administrative communication
To provide information on recruitment activities

(3) Personal information of employees, retirees and their family members

Human resource management (management of new hires, personnel transfers, evaluation of promotions and advancement, management of leaves of absence and resignations, career paths, secondments, employee training)
Labor management and payroll management (attendance management, salary and bonus payment, personal number-related paperwork)
Business management (risk management, crisis management, privacy management, compliance management, handling of audits and certifications, etc.)
IT management (provision and management of various electronic devices, etc.)
Financial management (financial strategy, expense reimbursement, other financial procedures, etc.)
Benefits (unemployment insurance, health insurance, pension insurance, maintenance management, other benefits)
Health management (periodic health checkups and stress checks, storage and management of results, handling of long-term absences)
Sales and Public Relations (sales activities and public relations activities such as recruitment)
General Affairs (mail management, document management)
Other business activities of the Company (various communications, etc.)
Compliance with legal requirements (withholding tax, year-end adjustment)

(4) Personal information regarding employees of contractors, business partners, and other employees of partner company

To maintain and manage good business relationships
To conduct related transactions and operations
To plan and host events
To make payments associated with transactions and related procedures

(5) Personal information of persons who have made inquiries or requests (hereinafter referred to as “Inquiries, etc.”) to us or our products and services

To respond to inquiries, etc.
To record and manage the content of responses to inquiries, etc.
To improve services in response to inquiries, etc.

(6) Personal information obtained when entrusted by other businesses, etc. to handle personal information

Performing the work entrusted to us

3.Handling of Personal Information

(1) Management of personal information

In order to keep users’ personal information accurate and up-to-date and to prevent unauthorized access, loss, damage, falsification, leakage, etc. of personal information, we take necessary measures such as maintenance of security system, development of management system, and thorough employee training, and implement safety measures to strictly manage personal information.

(2) Provision of Personal Information to Third Parties

We will not provide or disclose personal information collected by us to any third party, except in the following cases.

When the consent of the person in question has been obtained in advance
Cases falling under the exceptions set forth in Article 23, Paragraph 1, Items 1 through 4 of the Act on the Protection of Personal Information
In the case of Article 23(2) (opt-out (except for personal information requiring special consideration)) or Article 23(5)(i) to (iii) (outsourcing, business succession, or joint use) of the Personal Information Protection Law
When the Company deems it necessary to protect the rights of the Company or to comply with legal proceedings, court orders, or legal procedures
When providing basic personal information, such as the name, address, and telephone number of the purchaser’s mailing address, to a business partner that sells products via our platform, etc.
When providing basic personal information such as name, telephone number, job title, etc. to a recruiting agency for the purpose of recruitment activities.

(3) Joint Use of Personal Information

■Personal Information Items

Name, address, date of birth, number of family members, telephone number, e-mail address, occupation and other profile
Other personal information necessary to achieve the purpose of use (including (1) information obtained by the Company, (2) information obtained from outside sources, and (3) information combining (1) and (2))

■Manager
nowhere inc.

(4) Outsourcing of Handling of Personal Information

We may outsource part or all of the handling of personal information we acquire to outside parties for the purposes of use specified in “2.

(5) Handling of Anonymous Processed Information

We may handle anonymized processed information in some of our operations. In handling anonymized processed information, we will take necessary measures to ensure proper handling in consideration of the rights and interests of the individual and in accordance with laws and regulations.

4.Requests for Disclosure, etc., of Retained Personal Information

With respect to ‘Retained Personal Data’ (personal data over which the Company has the right to disclose, correct, add or delete content, suspend use, erase, and suspend provision to third parties) among the personal information acquired by the Company, we will respond to requests for notification of purpose of use, disclosure, correction, addition or deletion of content, suspension of use or erasure, or suspension of provision to third parties (hereinafter referred to as ‘Disclosure, etc.’) in accordance with laws and regulations. (Please note that we may refuse to comply with requests in accordance with laws and regulations.)

Procedures for requesting disclosure of retained personal Information

Please send your request by mail to the address below,
attaching your identification documents (① a copy of your driver’s license, passport, health insurance card, various pension books, basic resident registration card with photo, alien registration certificate, physical disability certificate, or ② the original resident’s card created within 30 days without your personal number listed).
If you are making a request on behalf of someone else, please enclose a document verifying your identity (if you are a legal representative) or a letter of attorney (if you are a proxy by proxy) in addition to your identification documents.

There is no handling fee for requests for disclosure, etc., but the requester must cover the postage costs etc. when making a request to our company. We will check the invoice we receive and respond in accordance with laws, regulations, and our company regulations.

■Address
104, 18th Kyutei Mansion, 28-8 Maruyamacho, Shibuya-ku, Tokyo 150-0044,Japan
nowhere inc.