Privacy Policy
Privacy Policy
1. Basic Policy on Protection of Personal Information
Sparkle AI Co., Ltd. (hereinafter referred to as "the Company") fully recognizes the importance of customers' personal information and, in order to build and maintain a lasting relationship of trust with its customers, hereby establishes the following privacy policy (hereinafter referred to as "this Policy") and is committed, as a whole company, to the appropriate protection of customers' personal information.
2. Compliance with Laws and Regulations
Regarding the handling of personal information, the Company shall comply with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"), the Telecommunications Business Act, other related laws, regulations, and guidelines concerning the protection of personal information, and this Policy.
3. Definitions of "Personal Information" and "Personal Data"
(1) "Personal Information" means information about a living individual that falls under any of the following items: ① Information that can identify a specific individual by name, address, date of birth, gender, occupation, telephone number, email address, etc., contained in said information. ② Information that, by itself, cannot identify a specific individual, but can be easily collated with other information, thereby enabling the identification of a specific individual. ③ Information that contains an individual identification code.
(2) "Personal Data" means Personal Information constituting a personal information database, etc.
4. Name, Address, and Representative of the Business Operator Handling Personal Information
Name of Business Operator Handling Personal Information, Address, and Name of Representative: Sparkle AI Co., Ltd. 9th Floor, Akasaka 1-chome Center Building, 1-11-30 Akasaka, Minato-ku, Tokyo Representative Director: Yuta Watanabe
5. Method of Acquiring Personal Information
The Company handles Personal Information and Personal Data acquired through the following lawful and fair means. The Personal Data handled by the Company includes information of contractors, etc., as well as Personal Data of users acquired through the "User Registration System" in various communication services.
(1) Information obtained from customers through application forms (written), web forms, oral communication, etc., for the purpose of providing the Company's services. (2) Information acquired by the Company in connection with customers' use of the Company's services, etc. (3) Information acquired from external sources: ① Information obtained by inquiring with public agencies, such as certificates of residence. ② Information obtained from publicly available sources, such as telephone directories and official gazettes. ③ Information lawfully acquired from affiliated companies, group companies, etc. ④ Information acquired through customer input via terminal operations. ⑤ Information acquired through transmission or provision accompanying customers' use or viewing of services, products, applications, web pages, advertisements, and content. ⑥ Other information lawfully acquired, such as when provided by business partners, group companies, or third parties with the customer's consent.
6. Purposes of Use of Personal Information
When acquiring Personal Information, the Company shall, within this Policy or on the websites or applications for each service, specify and announce the purposes of use in advance as much as possible. Furthermore, the Company shall handle Personal Information in accordance with the announced purposes of use. The purposes of use for Personal Information acquired by the Company are as follows:
(1) Purposes of use for Personal Information of individuals who have used or are interested in the Company's services (hereinafter referred to as "Customers"): ① For billing for the usage fees of each service based on the terms of use and fee schedules, or for the price of goods sold by the Company. ② For application for contracts related to the Company's services, withdrawal from membership, changes to registered information, and guidance and confirmation procedures for contract renewal/continuation. ③ For content confirmation, investigation, or reply concerning inquiries received regarding the Company or each service provided by the Company. ④ For providing information regarding technical support, such as service outage information and maintenance information for each service provided by the Company. ⑤ For providing various service-related proposals, such as announcements, advertisements, promotions, sending direct mail, and introductions via telephone or short message, concerning new services, new products, functional improvements, etc., provided or operated by the Company that are deemed useful to Customers. ⑥ For shipping products, prizes (awards), gifts, etc., and for requesting cooperation in surveys conducted by the Company. ⑦ For aggregating registered Personal Information as statistical information to an extent that does not identify specific individuals, and using it as reference material for developing services useful to Customers. ⑧ For referencing when using functions related to Customers in each service. ⑨ For providing each service offered by the Company and related services, and for managing service users. ⑩ For analyzing acquired Browse history, purchase history, etc., and using it for advertisements related to new products and services according to Hobbies and Preferences. ⑪ For analyzing acquired behavioral history, etc., calculating a credit score, and providing said score to third parties. ⑫ For providing Personal Information to third parties when prior consent has been obtained from the Customer him/herself in providing each service. ⑬ For other purposes of use for which consent has been obtained after announcing the purpose of use in providing each service. *Note: In the event the purposes of use are changed, the changed purposes of use shall be notified to the individual Customers themselves or announced on the Company's website, etc.
(2) Purposes of use for Personal Information of applicants for employment with the Company: ① For confirming application history and for selection based on information provided in resumes, curriculum vitae, etc. ② For contacting applicants regarding interview schedules, hiring decisions (pass/fail), etc. ③ For determining wages and for employment management after hiring. ④ In addition to the above, for purposes of use for which consent has been obtained from the individual.
(3) Purposes of use for Personal Information provided by individual business partners when newly transacting with the Company: ① For registration as a business partner. ② For compliance with laws and regulations.
7. Use within the Scope of Purposes of Use
The Company shall handle Customers' Personal Information only within the scope necessary to achieve the purposes of use specified and announced in advance. However, in cases falling under the following items as stipulated in the "Guidelines for the Protection of Personal Information in the Telecommunications Business" (hereinafter referred to as the "Telecommunications Business Guidelines"), the Company may handle Customers' Personal Information beyond the scope necessary to achieve the purposes of use specified and announced in advance:
(1) Cases based on laws and regulations. (2) Cases where it is necessary for the protection of a person's life, body, or property, and it is difficult to obtain the consent of the individual. (3) Cases where it is particularly necessary for improving public health or promoting the sound upbringing of children, and it is difficult to obtain the consent of the individual. (4) Cases where it is necessary to cooperate with a state organ, a local government, or an individual or entity entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and where obtaining the consent of the individual is likely to impede the execution of said affairs.
8. Retention Period
The Company shall establish a retention period for Customers' Personal Information within the scope necessary for the purposes of use, and shall delete Customers' Personal Information without delay after the retention period has elapsed or the purposes of use have been achieved. However, this shall not apply to cases falling under the following items as stipulated in the provisions of the "Telecommunications Business Guidelines": (1) Cases where retention is required by laws and regulations. (2) Cases where the consent of the individual has been obtained. (3) Cases where a telecommunications carrier retains Personal Information to the extent necessary for the performance of its own business, and there are reasonable grounds for not deleting said Personal Information. (4) In addition to the cases listed in the preceding items, cases where there are special reasons for not deleting said Personal Information.
9. Measures Taken to Securely Manage Personal Data
The Company shall implement access control to Personal Data, restrictions on the means of taking out Personal Data, measures to prevent unauthorized external access, and other necessary and appropriate measures (hereinafter referred to as "Security Management Measures") to prevent the leakage, loss, or damage of Personal Information and Personal Data, and to otherwise securely manage Personal Information and Personal Data.
The Company shall appropriately implement Security Management Measures for Personal Data held by the Company as follows, utilizing the frameworks of relevant laws, regulations, and guidelines:
(1) Establishment of a Basic Policy: To ensure the proper handling of Personal Data as an organization, a basic policy has been established (see "1. Basic Policy on Protection of Personal Information," etc.). (2) Establishment of Discipline Regarding the Handling of Personal Data: Handling regulations have been established concerning the methods of handling Personal Data, responsible persons/staff and their duties, etc. (3) Technical and Physical Security Management Measures: Access control to Personal Data, monitoring systems for access status, entry/exit management, etc., shall be implemented. Restrictions on the means of taking out Personal Data (such as prohibiting recording on external recording media without due cause, and monitoring emails between internal and external networks after stipulating such in internal regulations, etc.) shall be implemented. Measures to prevent unauthorized external access (such as installation of firewalls, etc.) shall be implemented. (4) Organizational Security Management Measures: An "Information Security Officer" shall be appointed as the person responsible for managing Personal Information, and the responsibilities and authorities of employees concerning the security management of Personal Information shall be clearly defined. Employees (including temporary staff, part-time staff, and casual staff) shall be supervised, and a system for reporting to the responsible person in the event of a breach or suspected breach of laws or handling regulations shall be established. (5) Human Security Management Measures: Regular educational training concerning the security management of Personal Information shall be provided to employees. (6) Supervision of Contractors: The Company may entrust all or part of the handling of Personal Information to a third party within the scope of the purposes of use. When selecting a contractor, the Company shall confirm that the contractor handles Personal Information properly and shall require the proper handling of Personal Information. Furthermore, the Company shall exercise necessary and appropriate supervision over the contractor, including by incorporating clauses concerning audits of the handling of Personal Information in the contract.
10. Regarding Joint Use of Personal Data Among Group Companies
The Company shall jointly use Personal Data with its group companies as follows:
(1) Items of Personal Data: ① Personal Data of shareholders (name, address, telephone number, email address, gender, date of birth, status of shareholdings in the Company, etc.) ② Personal Data of individuals who have made inquiries or requests to the Company (name, address, telephone number, email address, gender, date of birth, content of inquiries or requests, etc.)
(2) Group companies for joint use: ① Fabrica Holdings Inc. ② MEDIA4U CO., LTD. ③ Fabrica Communications Co., Ltd.
11. Provision of Personal Data to Third Parties
The Company will not provide personal information to third parties without the prior consent of the individual, except in the following cases:
(1) Cases where disclosure or provision is permitted by laws and regulations.
(2) Cases where it is necessary for the protection of the life, body, or property of an individual, and it is difficult to obtain the consent of the individual.
(3) Cases where it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children, and it is difficult to obtain the consent of the individual.
(4) Cases where it is necessary to cooperate with a state organ, a local government, or an individual or entity entrusted by one in executing the affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of the said affairs.
(5) Cases where disclosure of personal information is requested by a court, public prosecutor's office, police, or an organization with equivalent authority.
(6) Cases where the individual explicitly requests disclosure or provision to a third party.
(7) Cases where personal information is provided as a result of the succession of business due to a merger or other reasons.
(8) Cases where the Company entrusts all or part of the handling of personal data to a service provider within the scope necessary for the achievement of the purposes of use, and provides such personal data to said service provider.
(9) Cases where the Company has determined that the individual is causing or is likely to cause harm or disadvantage to a third party.
(10) Cases where personal data is provided to a specific party with whom the data is jointly used, and the individual has been notified in advance, or information has been made readily accessible to the individual, concerning: the fact of joint use; the items of personal data to be jointly used; the scope of the joint users; the purposes of use of the joint users; and the name or appellation and address of the person responsible for the management of the said personal data, and, in the case of a corporation, the name of its representative.
12. Disclaimer Regarding Provision to Third Parties
The Company assumes no responsibility for the acquisition of personal information by a third party in the following cases:
(1) Cases where the individual voluntarily discloses personal information to user companies, etc., through the functions of the Company's services or by other means (for inquiries regarding the handling of personal information by such user companies, etc., please contact them directly).
(2) Cases where the individual is unexpectedly identified through information entered into the Company's services.
(3) Cases where personal information is provided by the individual and used on external sites linked from the Company's services.
(4) Cases where a person other than the individual obtains information that can identify the individual (such as ID, password, etc.).
13. Anonymously Processed Information
Anonymously processed information refers to information relating to an individual that is produced by processing personal information by taking measures prescribed by laws and regulations so that a specific individual cannot be identified, and so that the said personal information cannot be restored.
(1) When creating anonymously processed information:
① The Company will perform proper processing in accordance with the standards prescribed by laws and regulations.
② The Company will take security control measures to prevent the leakage of deleted information and information concerning the processing methods, in accordance with the standards prescribed by laws and regulations.
③ When the Company creates anonymously processed information, it will publish the items of information contained in the created anonymously processed information in this Policy.
④ The Company will not collate anonymously processed information with other information to identify the individual pertaining to the personal information used for its creation.
(2) When providing anonymously processed information to a third party:
① When the Company provides anonymously processed information, it will publish in this Policy the items of information concerning individuals contained in the anonymously processed information to be provided and the method of provision.
② The Company will clearly indicate to the third-party recipient that the information being provided is anonymously processed information.
14. Pseudonymously Processed Information
Pseudonymously processed information refers to information relating to an individual that is produced by processing personal information by taking measures prescribed by laws and regulations so that a specific individual cannot be identified unless collated with other information.
(1) When creating pseudonymously processed information:
① The Company will create it after performing proper processing in accordance with the standards prescribed by laws and regulations.
② The Company will take security control measures to prevent the leakage of information deleted during the creation process and information concerning the processing methods (hereinafter collectively referred to as "Deleted Information, etc."), in accordance with the standards prescribed by laws and regulations.
(2) When acquiring pseudonymously processed information and Deleted Information, etc.:
① The Company will take security control measures to prevent the leakage of Deleted Information, etc., in accordance with the standards prescribed by laws and regulations.
② When the Company acquires pseudonymously processed information, particularly if it constitutes personal information, the Company will promptly publish its purposes of use in this Policy, unless such purposes have been published in advance.
(3) When handling pseudonymously processed information as a database:
① The Company will take necessary and appropriate security control measures to protect it from unauthorized access, alteration, leakage, loss, and damage.
② The Company will not collate it with other information to identify the individual pertaining to the personal information used for its creation.
③ The Company will not use contact details or other information contained in such pseudonymously processed information for the purpose of making telephone calls, sending mail or correspondence mail, delivering telegrams, transmitting by facsimile or electromagnetic means, or visiting residences.
④ Other handling, except where excluded by the provisions concerning the protection of personal information, will be in accordance with the matters to be published under the Act on the Protection of Personal Information.
15. Personally-Referable Information
Personally-referable information refers to information relating to a living individual that does not fall under any of the categories of personal information, anonymously processed information, or pseudonymously processed information.
(1) When acquiring personally-referable information from a third-party provider and handling it as personal data:
① There are cases where personally-referable information provided by a third party is collated with personal information acquired from customers or other individuals, and as a result, the personally-referable information becomes personal data by which an individual can be identified.
② Items of personally-referable information subject to this: All personally-referable information.
③ Purposes of use after acquisition: In accordance with the purposes of use set forth in this Policy.
(2) When providing personally-referable information as a database to a third party:
① The Company may provide personally-referable information to its partners. There are cases where the provided personally-referable information is collated with personal information held by the third party (partner), and as a result, becomes personal data by which an individual can be identified. Currently, the Company has no plans to provide personally-referable information as a database to third parties; therefore, the recipients and the items of personally-referable information subject to such provision are not published.
② The purposes of use by the recipient after acquiring personally-referable information as personal data will be notified or published by the recipient.
16. External Transmission, etc.
The Company utilizes technologies such as cookies and web beacons on its website. These cookies are used to improve the convenience of the site when customers revisit it. They do not infringe upon customer privacy nor adversely affect customers' computers. While cookies do not identify individuals per se, they are managed with the same level of care as personal information. Furthermore, when providing cookie information to third parties, except in cases stipulated in Article 11, it will be provided in a form that cannot identify individuals. However, if identifiers such as cookies or IP addresses are used in combination with information that can identify an individual, or if a recipient can collate them with information that can identify an individual, such identifiers will also be regarded as personal information.
Additionally, cookie information may be used by the Company or its affiliated partners for targeted advertising delivery and site usage analysis. If you wish to stop targeted advertising or the collection of site usage information (opt-out), please do so on the opt-out pages of our affiliated partners, although this may require some effort. Please note that opt-out procedures are required for each browser used. Therefore, if you delete an opt-out cookie issued by the Company, install a new browser, or change your PC/smartphone, you will need to repeat the procedure.
The external transmission destinations used by the Company are as follows:
Google Analytics (Google LLC) Privacy Policy: ( https://policies.google.com/privacy ) Opt-out: ( https://tools.google.com/dlpage/gaoptout?hl=en )
17. Continuous Improvement
The Company will continuously implement improvements to ensure the proper handling of personal information.
18. Disclosure, Correction, Suspension of Use, or Deletion of Personal Data
If an individual wishes to request disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to a third party (hereinafter collectively "Disclosure, etc.") of their personal data held by the Company, please make a direct request to the Company using the method below. Unless special procedures are stipulated by laws and regulations, the Company will conduct the necessary investigation without delay and, only if it is confirmed that the request is from the individual themselves, will carry out the Disclosure, etc., of the individual's personal data in accordance with laws and regulations. Please note that if the requirements for the request method specified below are not met, or if the content of the request is deemed unreasonable based on the investigation results, the Company may not be able to comply with the request.
Method for Requesting Disclosure of Personal Data: Please prepare the following documents and send them to the "Contact Window for Inquiries." Please note that postage fees will be borne by the customer.
(1) Personal Data Disclosure Request Form: Please fill in the necessary items on the form designated by the Company.
(2) Documents to Confirm Identity of the Individual or Agent:
① For the individual: Identification documents (confirmation by copies of the following identification documents)
a) A copy of one of the following government-issued photo identification documents: driver's license, passport, residence card, special permanent resident certificate, Individual Number Card (My Number Card) (the side showing the Individual Number should not be sent), etc.
b) Copies of two of the following government-issued non-photo identification documents: health insurance card, pension book, etc.
② For an agent: (If the person making the request for Disclosure, etc. is a legal representative of a minor, adult ward, etc., or a voluntary agent designated by the individual, the following documents are required in addition to the documents listed in ① above.)
A. Documents to confirm power of attorney:
- For a minor: An abridged copy of the individual's family register or a copy of an insurance card showing dependent family members.
- For an adult ward: Certificate of registered matters as stipulated in the Act on Guardianship Registration, etc.
B. For a voluntary agent: Power of attorney for the request for Disclosure, etc. of retained personal data and a certificate of the individual's seal impression.
(3) Return envelope (self-addressed, stamped).
(4) Fees, etc.: When a request for Disclosure, etc. ("Disclosure Request" and "Request for Notification of Purpose of Use, Correction, etc., Suspension of Use, etc.") is made by the individual, a fee of JPY 1,000 (tax included) per request, covering handling and postage, will be collected in postage stamps. Please note that fees, etc. will not be refunded even if the Company cannot comply with the request for Disclosure, etc. Furthermore, if the postal system changes, the fees, etc. may be subject to change.
19. Contact for Consultations and Complaints Regarding Handling of Personal Information
For various procedures and inquiries regarding the Company's handling of personal data, please contact the following:
Sparkle AI Co., Ltd.
Personal Information Protection Consultation Service
Email Inquiries: info@sparkleai.co.jp
Postal Inquiries: Sparkle AI Co., Ltd. Personal Information Protection Consultation Service Akasaka 1-chome Center Building 9F 1-11-30 Akasaka, Minato-ku, Tokyo 107-0052 Japan
20. Changes to the Privacy Policy
When the Company makes changes to the personal information it acquires, changes to the purposes of use, or other changes to this Privacy Policy, such changes will be announced by revising this page. The revised Privacy Policy will become effective from the time the revision date is displayed on the website.
Supplementary Provisions
Enacted: May 12, 2025
1. Basic Policy on Protection of Personal Information
Sparkle AI Co., Ltd. (hereinafter referred to as "the Company") fully recognizes the importance of customers' personal information and, in order to build and maintain a lasting relationship of trust with its customers, hereby establishes the following privacy policy (hereinafter referred to as "this Policy") and is committed, as a whole company, to the appropriate protection of customers' personal information.
2. Compliance with Laws and Regulations
Regarding the handling of personal information, the Company shall comply with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"), the Telecommunications Business Act, other related laws, regulations, and guidelines concerning the protection of personal information, and this Policy.
3. Definitions of "Personal Information" and "Personal Data"
(1) "Personal Information" means information about a living individual that falls under any of the following items: ① Information that can identify a specific individual by name, address, date of birth, gender, occupation, telephone number, email address, etc., contained in said information. ② Information that, by itself, cannot identify a specific individual, but can be easily collated with other information, thereby enabling the identification of a specific individual. ③ Information that contains an individual identification code.
(2) "Personal Data" means Personal Information constituting a personal information database, etc.
4. Name, Address, and Representative of the Business Operator Handling Personal Information
Name of Business Operator Handling Personal Information, Address, and Name of Representative: Sparkle AI Co., Ltd. 9th Floor, Akasaka 1-chome Center Building, 1-11-30 Akasaka, Minato-ku, Tokyo Representative Director: Yuta Watanabe
5. Method of Acquiring Personal Information
The Company handles Personal Information and Personal Data acquired through the following lawful and fair means. The Personal Data handled by the Company includes information of contractors, etc., as well as Personal Data of users acquired through the "User Registration System" in various communication services.
(1) Information obtained from customers through application forms (written), web forms, oral communication, etc., for the purpose of providing the Company's services. (2) Information acquired by the Company in connection with customers' use of the Company's services, etc. (3) Information acquired from external sources: ① Information obtained by inquiring with public agencies, such as certificates of residence. ② Information obtained from publicly available sources, such as telephone directories and official gazettes. ③ Information lawfully acquired from affiliated companies, group companies, etc. ④ Information acquired through customer input via terminal operations. ⑤ Information acquired through transmission or provision accompanying customers' use or viewing of services, products, applications, web pages, advertisements, and content. ⑥ Other information lawfully acquired, such as when provided by business partners, group companies, or third parties with the customer's consent.
6. Purposes of Use of Personal Information
When acquiring Personal Information, the Company shall, within this Policy or on the websites or applications for each service, specify and announce the purposes of use in advance as much as possible. Furthermore, the Company shall handle Personal Information in accordance with the announced purposes of use. The purposes of use for Personal Information acquired by the Company are as follows:
(1) Purposes of use for Personal Information of individuals who have used or are interested in the Company's services (hereinafter referred to as "Customers"): ① For billing for the usage fees of each service based on the terms of use and fee schedules, or for the price of goods sold by the Company. ② For application for contracts related to the Company's services, withdrawal from membership, changes to registered information, and guidance and confirmation procedures for contract renewal/continuation. ③ For content confirmation, investigation, or reply concerning inquiries received regarding the Company or each service provided by the Company. ④ For providing information regarding technical support, such as service outage information and maintenance information for each service provided by the Company. ⑤ For providing various service-related proposals, such as announcements, advertisements, promotions, sending direct mail, and introductions via telephone or short message, concerning new services, new products, functional improvements, etc., provided or operated by the Company that are deemed useful to Customers. ⑥ For shipping products, prizes (awards), gifts, etc., and for requesting cooperation in surveys conducted by the Company. ⑦ For aggregating registered Personal Information as statistical information to an extent that does not identify specific individuals, and using it as reference material for developing services useful to Customers. ⑧ For referencing when using functions related to Customers in each service. ⑨ For providing each service offered by the Company and related services, and for managing service users. ⑩ For analyzing acquired Browse history, purchase history, etc., and using it for advertisements related to new products and services according to Hobbies and Preferences. ⑪ For analyzing acquired behavioral history, etc., calculating a credit score, and providing said score to third parties. ⑫ For providing Personal Information to third parties when prior consent has been obtained from the Customer him/herself in providing each service. ⑬ For other purposes of use for which consent has been obtained after announcing the purpose of use in providing each service. *Note: In the event the purposes of use are changed, the changed purposes of use shall be notified to the individual Customers themselves or announced on the Company's website, etc.
(2) Purposes of use for Personal Information of applicants for employment with the Company: ① For confirming application history and for selection based on information provided in resumes, curriculum vitae, etc. ② For contacting applicants regarding interview schedules, hiring decisions (pass/fail), etc. ③ For determining wages and for employment management after hiring. ④ In addition to the above, for purposes of use for which consent has been obtained from the individual.
(3) Purposes of use for Personal Information provided by individual business partners when newly transacting with the Company: ① For registration as a business partner. ② For compliance with laws and regulations.
7. Use within the Scope of Purposes of Use
The Company shall handle Customers' Personal Information only within the scope necessary to achieve the purposes of use specified and announced in advance. However, in cases falling under the following items as stipulated in the "Guidelines for the Protection of Personal Information in the Telecommunications Business" (hereinafter referred to as the "Telecommunications Business Guidelines"), the Company may handle Customers' Personal Information beyond the scope necessary to achieve the purposes of use specified and announced in advance:
(1) Cases based on laws and regulations. (2) Cases where it is necessary for the protection of a person's life, body, or property, and it is difficult to obtain the consent of the individual. (3) Cases where it is particularly necessary for improving public health or promoting the sound upbringing of children, and it is difficult to obtain the consent of the individual. (4) Cases where it is necessary to cooperate with a state organ, a local government, or an individual or entity entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and where obtaining the consent of the individual is likely to impede the execution of said affairs.
8. Retention Period
The Company shall establish a retention period for Customers' Personal Information within the scope necessary for the purposes of use, and shall delete Customers' Personal Information without delay after the retention period has elapsed or the purposes of use have been achieved. However, this shall not apply to cases falling under the following items as stipulated in the provisions of the "Telecommunications Business Guidelines": (1) Cases where retention is required by laws and regulations. (2) Cases where the consent of the individual has been obtained. (3) Cases where a telecommunications carrier retains Personal Information to the extent necessary for the performance of its own business, and there are reasonable grounds for not deleting said Personal Information. (4) In addition to the cases listed in the preceding items, cases where there are special reasons for not deleting said Personal Information.
9. Measures Taken to Securely Manage Personal Data
The Company shall implement access control to Personal Data, restrictions on the means of taking out Personal Data, measures to prevent unauthorized external access, and other necessary and appropriate measures (hereinafter referred to as "Security Management Measures") to prevent the leakage, loss, or damage of Personal Information and Personal Data, and to otherwise securely manage Personal Information and Personal Data.
The Company shall appropriately implement Security Management Measures for Personal Data held by the Company as follows, utilizing the frameworks of relevant laws, regulations, and guidelines:
(1) Establishment of a Basic Policy: To ensure the proper handling of Personal Data as an organization, a basic policy has been established (see "1. Basic Policy on Protection of Personal Information," etc.). (2) Establishment of Discipline Regarding the Handling of Personal Data: Handling regulations have been established concerning the methods of handling Personal Data, responsible persons/staff and their duties, etc. (3) Technical and Physical Security Management Measures: Access control to Personal Data, monitoring systems for access status, entry/exit management, etc., shall be implemented. Restrictions on the means of taking out Personal Data (such as prohibiting recording on external recording media without due cause, and monitoring emails between internal and external networks after stipulating such in internal regulations, etc.) shall be implemented. Measures to prevent unauthorized external access (such as installation of firewalls, etc.) shall be implemented. (4) Organizational Security Management Measures: An "Information Security Officer" shall be appointed as the person responsible for managing Personal Information, and the responsibilities and authorities of employees concerning the security management of Personal Information shall be clearly defined. Employees (including temporary staff, part-time staff, and casual staff) shall be supervised, and a system for reporting to the responsible person in the event of a breach or suspected breach of laws or handling regulations shall be established. (5) Human Security Management Measures: Regular educational training concerning the security management of Personal Information shall be provided to employees. (6) Supervision of Contractors: The Company may entrust all or part of the handling of Personal Information to a third party within the scope of the purposes of use. When selecting a contractor, the Company shall confirm that the contractor handles Personal Information properly and shall require the proper handling of Personal Information. Furthermore, the Company shall exercise necessary and appropriate supervision over the contractor, including by incorporating clauses concerning audits of the handling of Personal Information in the contract.
10. Regarding Joint Use of Personal Data Among Group Companies
The Company shall jointly use Personal Data with its group companies as follows:
(1) Items of Personal Data: ① Personal Data of shareholders (name, address, telephone number, email address, gender, date of birth, status of shareholdings in the Company, etc.) ② Personal Data of individuals who have made inquiries or requests to the Company (name, address, telephone number, email address, gender, date of birth, content of inquiries or requests, etc.)
(2) Group companies for joint use: ① Fabrica Holdings Inc. ② MEDIA4U CO., LTD. ③ Fabrica Communications Co., Ltd.
11. Provision of Personal Data to Third Parties
The Company will not provide personal information to third parties without the prior consent of the individual, except in the following cases:
(1) Cases where disclosure or provision is permitted by laws and regulations.
(2) Cases where it is necessary for the protection of the life, body, or property of an individual, and it is difficult to obtain the consent of the individual.
(3) Cases where it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children, and it is difficult to obtain the consent of the individual.
(4) Cases where it is necessary to cooperate with a state organ, a local government, or an individual or entity entrusted by one in executing the affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of the said affairs.
(5) Cases where disclosure of personal information is requested by a court, public prosecutor's office, police, or an organization with equivalent authority.
(6) Cases where the individual explicitly requests disclosure or provision to a third party.
(7) Cases where personal information is provided as a result of the succession of business due to a merger or other reasons.
(8) Cases where the Company entrusts all or part of the handling of personal data to a service provider within the scope necessary for the achievement of the purposes of use, and provides such personal data to said service provider.
(9) Cases where the Company has determined that the individual is causing or is likely to cause harm or disadvantage to a third party.
(10) Cases where personal data is provided to a specific party with whom the data is jointly used, and the individual has been notified in advance, or information has been made readily accessible to the individual, concerning: the fact of joint use; the items of personal data to be jointly used; the scope of the joint users; the purposes of use of the joint users; and the name or appellation and address of the person responsible for the management of the said personal data, and, in the case of a corporation, the name of its representative.
12. Disclaimer Regarding Provision to Third Parties
The Company assumes no responsibility for the acquisition of personal information by a third party in the following cases:
(1) Cases where the individual voluntarily discloses personal information to user companies, etc., through the functions of the Company's services or by other means (for inquiries regarding the handling of personal information by such user companies, etc., please contact them directly).
(2) Cases where the individual is unexpectedly identified through information entered into the Company's services.
(3) Cases where personal information is provided by the individual and used on external sites linked from the Company's services.
(4) Cases where a person other than the individual obtains information that can identify the individual (such as ID, password, etc.).
13. Anonymously Processed Information
Anonymously processed information refers to information relating to an individual that is produced by processing personal information by taking measures prescribed by laws and regulations so that a specific individual cannot be identified, and so that the said personal information cannot be restored.
(1) When creating anonymously processed information:
① The Company will perform proper processing in accordance with the standards prescribed by laws and regulations.
② The Company will take security control measures to prevent the leakage of deleted information and information concerning the processing methods, in accordance with the standards prescribed by laws and regulations.
③ When the Company creates anonymously processed information, it will publish the items of information contained in the created anonymously processed information in this Policy.
④ The Company will not collate anonymously processed information with other information to identify the individual pertaining to the personal information used for its creation.
(2) When providing anonymously processed information to a third party:
① When the Company provides anonymously processed information, it will publish in this Policy the items of information concerning individuals contained in the anonymously processed information to be provided and the method of provision.
② The Company will clearly indicate to the third-party recipient that the information being provided is anonymously processed information.
14. Pseudonymously Processed Information
Pseudonymously processed information refers to information relating to an individual that is produced by processing personal information by taking measures prescribed by laws and regulations so that a specific individual cannot be identified unless collated with other information.
(1) When creating pseudonymously processed information:
① The Company will create it after performing proper processing in accordance with the standards prescribed by laws and regulations.
② The Company will take security control measures to prevent the leakage of information deleted during the creation process and information concerning the processing methods (hereinafter collectively referred to as "Deleted Information, etc."), in accordance with the standards prescribed by laws and regulations.
(2) When acquiring pseudonymously processed information and Deleted Information, etc.:
① The Company will take security control measures to prevent the leakage of Deleted Information, etc., in accordance with the standards prescribed by laws and regulations.
② When the Company acquires pseudonymously processed information, particularly if it constitutes personal information, the Company will promptly publish its purposes of use in this Policy, unless such purposes have been published in advance.
(3) When handling pseudonymously processed information as a database:
① The Company will take necessary and appropriate security control measures to protect it from unauthorized access, alteration, leakage, loss, and damage.
② The Company will not collate it with other information to identify the individual pertaining to the personal information used for its creation.
③ The Company will not use contact details or other information contained in such pseudonymously processed information for the purpose of making telephone calls, sending mail or correspondence mail, delivering telegrams, transmitting by facsimile or electromagnetic means, or visiting residences.
④ Other handling, except where excluded by the provisions concerning the protection of personal information, will be in accordance with the matters to be published under the Act on the Protection of Personal Information.
15. Personally-Referable Information
Personally-referable information refers to information relating to a living individual that does not fall under any of the categories of personal information, anonymously processed information, or pseudonymously processed information.
(1) When acquiring personally-referable information from a third-party provider and handling it as personal data:
① There are cases where personally-referable information provided by a third party is collated with personal information acquired from customers or other individuals, and as a result, the personally-referable information becomes personal data by which an individual can be identified.
② Items of personally-referable information subject to this: All personally-referable information.
③ Purposes of use after acquisition: In accordance with the purposes of use set forth in this Policy.
(2) When providing personally-referable information as a database to a third party:
① The Company may provide personally-referable information to its partners. There are cases where the provided personally-referable information is collated with personal information held by the third party (partner), and as a result, becomes personal data by which an individual can be identified. Currently, the Company has no plans to provide personally-referable information as a database to third parties; therefore, the recipients and the items of personally-referable information subject to such provision are not published.
② The purposes of use by the recipient after acquiring personally-referable information as personal data will be notified or published by the recipient.
16. External Transmission, etc.
The Company utilizes technologies such as cookies and web beacons on its website. These cookies are used to improve the convenience of the site when customers revisit it. They do not infringe upon customer privacy nor adversely affect customers' computers. While cookies do not identify individuals per se, they are managed with the same level of care as personal information. Furthermore, when providing cookie information to third parties, except in cases stipulated in Article 11, it will be provided in a form that cannot identify individuals. However, if identifiers such as cookies or IP addresses are used in combination with information that can identify an individual, or if a recipient can collate them with information that can identify an individual, such identifiers will also be regarded as personal information.
Additionally, cookie information may be used by the Company or its affiliated partners for targeted advertising delivery and site usage analysis. If you wish to stop targeted advertising or the collection of site usage information (opt-out), please do so on the opt-out pages of our affiliated partners, although this may require some effort. Please note that opt-out procedures are required for each browser used. Therefore, if you delete an opt-out cookie issued by the Company, install a new browser, or change your PC/smartphone, you will need to repeat the procedure.
The external transmission destinations used by the Company are as follows:
Google Analytics (Google LLC) Privacy Policy: ( https://policies.google.com/privacy ) Opt-out: ( https://tools.google.com/dlpage/gaoptout?hl=en )
17. Continuous Improvement
The Company will continuously implement improvements to ensure the proper handling of personal information.
18. Disclosure, Correction, Suspension of Use, or Deletion of Personal Data
If an individual wishes to request disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to a third party (hereinafter collectively "Disclosure, etc.") of their personal data held by the Company, please make a direct request to the Company using the method below. Unless special procedures are stipulated by laws and regulations, the Company will conduct the necessary investigation without delay and, only if it is confirmed that the request is from the individual themselves, will carry out the Disclosure, etc., of the individual's personal data in accordance with laws and regulations. Please note that if the requirements for the request method specified below are not met, or if the content of the request is deemed unreasonable based on the investigation results, the Company may not be able to comply with the request.
Method for Requesting Disclosure of Personal Data: Please prepare the following documents and send them to the "Contact Window for Inquiries." Please note that postage fees will be borne by the customer.
(1) Personal Data Disclosure Request Form: Please fill in the necessary items on the form designated by the Company.
(2) Documents to Confirm Identity of the Individual or Agent:
① For the individual: Identification documents (confirmation by copies of the following identification documents)
a) A copy of one of the following government-issued photo identification documents: driver's license, passport, residence card, special permanent resident certificate, Individual Number Card (My Number Card) (the side showing the Individual Number should not be sent), etc.
b) Copies of two of the following government-issued non-photo identification documents: health insurance card, pension book, etc.
② For an agent: (If the person making the request for Disclosure, etc. is a legal representative of a minor, adult ward, etc., or a voluntary agent designated by the individual, the following documents are required in addition to the documents listed in ① above.)
A. Documents to confirm power of attorney:
- For a minor: An abridged copy of the individual's family register or a copy of an insurance card showing dependent family members.
- For an adult ward: Certificate of registered matters as stipulated in the Act on Guardianship Registration, etc.
B. For a voluntary agent: Power of attorney for the request for Disclosure, etc. of retained personal data and a certificate of the individual's seal impression.
(3) Return envelope (self-addressed, stamped).
(4) Fees, etc.: When a request for Disclosure, etc. ("Disclosure Request" and "Request for Notification of Purpose of Use, Correction, etc., Suspension of Use, etc.") is made by the individual, a fee of JPY 1,000 (tax included) per request, covering handling and postage, will be collected in postage stamps. Please note that fees, etc. will not be refunded even if the Company cannot comply with the request for Disclosure, etc. Furthermore, if the postal system changes, the fees, etc. may be subject to change.
19. Contact for Consultations and Complaints Regarding Handling of Personal Information
For various procedures and inquiries regarding the Company's handling of personal data, please contact the following:
Sparkle AI Co., Ltd.
Personal Information Protection Consultation Service
Email Inquiries: info@sparkleai.co.jp
Postal Inquiries: Sparkle AI Co., Ltd. Personal Information Protection Consultation Service Akasaka 1-chome Center Building 9F 1-11-30 Akasaka, Minato-ku, Tokyo 107-0052 Japan
20. Changes to the Privacy Policy
When the Company makes changes to the personal information it acquires, changes to the purposes of use, or other changes to this Privacy Policy, such changes will be announced by revising this page. The revised Privacy Policy will become effective from the time the revision date is displayed on the website.
Supplementary Provisions
Enacted: May 12, 2025
1. Basic Policy on Protection of Personal Information
Sparkle AI Co., Ltd. (hereinafter referred to as "the Company") fully recognizes the importance of customers' personal information and, in order to build and maintain a lasting relationship of trust with its customers, hereby establishes the following privacy policy (hereinafter referred to as "this Policy") and is committed, as a whole company, to the appropriate protection of customers' personal information.
2. Compliance with Laws and Regulations
Regarding the handling of personal information, the Company shall comply with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"), the Telecommunications Business Act, other related laws, regulations, and guidelines concerning the protection of personal information, and this Policy.
3. Definitions of "Personal Information" and "Personal Data"
(1) "Personal Information" means information about a living individual that falls under any of the following items: ① Information that can identify a specific individual by name, address, date of birth, gender, occupation, telephone number, email address, etc., contained in said information. ② Information that, by itself, cannot identify a specific individual, but can be easily collated with other information, thereby enabling the identification of a specific individual. ③ Information that contains an individual identification code.
(2) "Personal Data" means Personal Information constituting a personal information database, etc.
4. Name, Address, and Representative of the Business Operator Handling Personal Information
Name of Business Operator Handling Personal Information, Address, and Name of Representative: Sparkle AI Co., Ltd. 9th Floor, Akasaka 1-chome Center Building, 1-11-30 Akasaka, Minato-ku, Tokyo Representative Director: Yuta Watanabe
5. Method of Acquiring Personal Information
The Company handles Personal Information and Personal Data acquired through the following lawful and fair means. The Personal Data handled by the Company includes information of contractors, etc., as well as Personal Data of users acquired through the "User Registration System" in various communication services.
(1) Information obtained from customers through application forms (written), web forms, oral communication, etc., for the purpose of providing the Company's services. (2) Information acquired by the Company in connection with customers' use of the Company's services, etc. (3) Information acquired from external sources: ① Information obtained by inquiring with public agencies, such as certificates of residence. ② Information obtained from publicly available sources, such as telephone directories and official gazettes. ③ Information lawfully acquired from affiliated companies, group companies, etc. ④ Information acquired through customer input via terminal operations. ⑤ Information acquired through transmission or provision accompanying customers' use or viewing of services, products, applications, web pages, advertisements, and content. ⑥ Other information lawfully acquired, such as when provided by business partners, group companies, or third parties with the customer's consent.
6. Purposes of Use of Personal Information
When acquiring Personal Information, the Company shall, within this Policy or on the websites or applications for each service, specify and announce the purposes of use in advance as much as possible. Furthermore, the Company shall handle Personal Information in accordance with the announced purposes of use. The purposes of use for Personal Information acquired by the Company are as follows:
(1) Purposes of use for Personal Information of individuals who have used or are interested in the Company's services (hereinafter referred to as "Customers"): ① For billing for the usage fees of each service based on the terms of use and fee schedules, or for the price of goods sold by the Company. ② For application for contracts related to the Company's services, withdrawal from membership, changes to registered information, and guidance and confirmation procedures for contract renewal/continuation. ③ For content confirmation, investigation, or reply concerning inquiries received regarding the Company or each service provided by the Company. ④ For providing information regarding technical support, such as service outage information and maintenance information for each service provided by the Company. ⑤ For providing various service-related proposals, such as announcements, advertisements, promotions, sending direct mail, and introductions via telephone or short message, concerning new services, new products, functional improvements, etc., provided or operated by the Company that are deemed useful to Customers. ⑥ For shipping products, prizes (awards), gifts, etc., and for requesting cooperation in surveys conducted by the Company. ⑦ For aggregating registered Personal Information as statistical information to an extent that does not identify specific individuals, and using it as reference material for developing services useful to Customers. ⑧ For referencing when using functions related to Customers in each service. ⑨ For providing each service offered by the Company and related services, and for managing service users. ⑩ For analyzing acquired Browse history, purchase history, etc., and using it for advertisements related to new products and services according to Hobbies and Preferences. ⑪ For analyzing acquired behavioral history, etc., calculating a credit score, and providing said score to third parties. ⑫ For providing Personal Information to third parties when prior consent has been obtained from the Customer him/herself in providing each service. ⑬ For other purposes of use for which consent has been obtained after announcing the purpose of use in providing each service. *Note: In the event the purposes of use are changed, the changed purposes of use shall be notified to the individual Customers themselves or announced on the Company's website, etc.
(2) Purposes of use for Personal Information of applicants for employment with the Company: ① For confirming application history and for selection based on information provided in resumes, curriculum vitae, etc. ② For contacting applicants regarding interview schedules, hiring decisions (pass/fail), etc. ③ For determining wages and for employment management after hiring. ④ In addition to the above, for purposes of use for which consent has been obtained from the individual.
(3) Purposes of use for Personal Information provided by individual business partners when newly transacting with the Company: ① For registration as a business partner. ② For compliance with laws and regulations.
7. Use within the Scope of Purposes of Use
The Company shall handle Customers' Personal Information only within the scope necessary to achieve the purposes of use specified and announced in advance. However, in cases falling under the following items as stipulated in the "Guidelines for the Protection of Personal Information in the Telecommunications Business" (hereinafter referred to as the "Telecommunications Business Guidelines"), the Company may handle Customers' Personal Information beyond the scope necessary to achieve the purposes of use specified and announced in advance:
(1) Cases based on laws and regulations. (2) Cases where it is necessary for the protection of a person's life, body, or property, and it is difficult to obtain the consent of the individual. (3) Cases where it is particularly necessary for improving public health or promoting the sound upbringing of children, and it is difficult to obtain the consent of the individual. (4) Cases where it is necessary to cooperate with a state organ, a local government, or an individual or entity entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and where obtaining the consent of the individual is likely to impede the execution of said affairs.
8. Retention Period
The Company shall establish a retention period for Customers' Personal Information within the scope necessary for the purposes of use, and shall delete Customers' Personal Information without delay after the retention period has elapsed or the purposes of use have been achieved. However, this shall not apply to cases falling under the following items as stipulated in the provisions of the "Telecommunications Business Guidelines": (1) Cases where retention is required by laws and regulations. (2) Cases where the consent of the individual has been obtained. (3) Cases where a telecommunications carrier retains Personal Information to the extent necessary for the performance of its own business, and there are reasonable grounds for not deleting said Personal Information. (4) In addition to the cases listed in the preceding items, cases where there are special reasons for not deleting said Personal Information.
9. Measures Taken to Securely Manage Personal Data
The Company shall implement access control to Personal Data, restrictions on the means of taking out Personal Data, measures to prevent unauthorized external access, and other necessary and appropriate measures (hereinafter referred to as "Security Management Measures") to prevent the leakage, loss, or damage of Personal Information and Personal Data, and to otherwise securely manage Personal Information and Personal Data.
The Company shall appropriately implement Security Management Measures for Personal Data held by the Company as follows, utilizing the frameworks of relevant laws, regulations, and guidelines:
(1) Establishment of a Basic Policy: To ensure the proper handling of Personal Data as an organization, a basic policy has been established (see "1. Basic Policy on Protection of Personal Information," etc.). (2) Establishment of Discipline Regarding the Handling of Personal Data: Handling regulations have been established concerning the methods of handling Personal Data, responsible persons/staff and their duties, etc. (3) Technical and Physical Security Management Measures: Access control to Personal Data, monitoring systems for access status, entry/exit management, etc., shall be implemented. Restrictions on the means of taking out Personal Data (such as prohibiting recording on external recording media without due cause, and monitoring emails between internal and external networks after stipulating such in internal regulations, etc.) shall be implemented. Measures to prevent unauthorized external access (such as installation of firewalls, etc.) shall be implemented. (4) Organizational Security Management Measures: An "Information Security Officer" shall be appointed as the person responsible for managing Personal Information, and the responsibilities and authorities of employees concerning the security management of Personal Information shall be clearly defined. Employees (including temporary staff, part-time staff, and casual staff) shall be supervised, and a system for reporting to the responsible person in the event of a breach or suspected breach of laws or handling regulations shall be established. (5) Human Security Management Measures: Regular educational training concerning the security management of Personal Information shall be provided to employees. (6) Supervision of Contractors: The Company may entrust all or part of the handling of Personal Information to a third party within the scope of the purposes of use. When selecting a contractor, the Company shall confirm that the contractor handles Personal Information properly and shall require the proper handling of Personal Information. Furthermore, the Company shall exercise necessary and appropriate supervision over the contractor, including by incorporating clauses concerning audits of the handling of Personal Information in the contract.
10. Regarding Joint Use of Personal Data Among Group Companies
The Company shall jointly use Personal Data with its group companies as follows:
(1) Items of Personal Data: ① Personal Data of shareholders (name, address, telephone number, email address, gender, date of birth, status of shareholdings in the Company, etc.) ② Personal Data of individuals who have made inquiries or requests to the Company (name, address, telephone number, email address, gender, date of birth, content of inquiries or requests, etc.)
(2) Group companies for joint use: ① Fabrica Holdings Inc. ② MEDIA4U CO., LTD. ③ Fabrica Communications Co., Ltd.
11. Provision of Personal Data to Third Parties
The Company will not provide personal information to third parties without the prior consent of the individual, except in the following cases:
(1) Cases where disclosure or provision is permitted by laws and regulations.
(2) Cases where it is necessary for the protection of the life, body, or property of an individual, and it is difficult to obtain the consent of the individual.
(3) Cases where it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children, and it is difficult to obtain the consent of the individual.
(4) Cases where it is necessary to cooperate with a state organ, a local government, or an individual or entity entrusted by one in executing the affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of the said affairs.
(5) Cases where disclosure of personal information is requested by a court, public prosecutor's office, police, or an organization with equivalent authority.
(6) Cases where the individual explicitly requests disclosure or provision to a third party.
(7) Cases where personal information is provided as a result of the succession of business due to a merger or other reasons.
(8) Cases where the Company entrusts all or part of the handling of personal data to a service provider within the scope necessary for the achievement of the purposes of use, and provides such personal data to said service provider.
(9) Cases where the Company has determined that the individual is causing or is likely to cause harm or disadvantage to a third party.
(10) Cases where personal data is provided to a specific party with whom the data is jointly used, and the individual has been notified in advance, or information has been made readily accessible to the individual, concerning: the fact of joint use; the items of personal data to be jointly used; the scope of the joint users; the purposes of use of the joint users; and the name or appellation and address of the person responsible for the management of the said personal data, and, in the case of a corporation, the name of its representative.
12. Disclaimer Regarding Provision to Third Parties
The Company assumes no responsibility for the acquisition of personal information by a third party in the following cases:
(1) Cases where the individual voluntarily discloses personal information to user companies, etc., through the functions of the Company's services or by other means (for inquiries regarding the handling of personal information by such user companies, etc., please contact them directly).
(2) Cases where the individual is unexpectedly identified through information entered into the Company's services.
(3) Cases where personal information is provided by the individual and used on external sites linked from the Company's services.
(4) Cases where a person other than the individual obtains information that can identify the individual (such as ID, password, etc.).
13. Anonymously Processed Information
Anonymously processed information refers to information relating to an individual that is produced by processing personal information by taking measures prescribed by laws and regulations so that a specific individual cannot be identified, and so that the said personal information cannot be restored.
(1) When creating anonymously processed information:
① The Company will perform proper processing in accordance with the standards prescribed by laws and regulations.
② The Company will take security control measures to prevent the leakage of deleted information and information concerning the processing methods, in accordance with the standards prescribed by laws and regulations.
③ When the Company creates anonymously processed information, it will publish the items of information contained in the created anonymously processed information in this Policy.
④ The Company will not collate anonymously processed information with other information to identify the individual pertaining to the personal information used for its creation.
(2) When providing anonymously processed information to a third party:
① When the Company provides anonymously processed information, it will publish in this Policy the items of information concerning individuals contained in the anonymously processed information to be provided and the method of provision.
② The Company will clearly indicate to the third-party recipient that the information being provided is anonymously processed information.
14. Pseudonymously Processed Information
Pseudonymously processed information refers to information relating to an individual that is produced by processing personal information by taking measures prescribed by laws and regulations so that a specific individual cannot be identified unless collated with other information.
(1) When creating pseudonymously processed information:
① The Company will create it after performing proper processing in accordance with the standards prescribed by laws and regulations.
② The Company will take security control measures to prevent the leakage of information deleted during the creation process and information concerning the processing methods (hereinafter collectively referred to as "Deleted Information, etc."), in accordance with the standards prescribed by laws and regulations.
(2) When acquiring pseudonymously processed information and Deleted Information, etc.:
① The Company will take security control measures to prevent the leakage of Deleted Information, etc., in accordance with the standards prescribed by laws and regulations.
② When the Company acquires pseudonymously processed information, particularly if it constitutes personal information, the Company will promptly publish its purposes of use in this Policy, unless such purposes have been published in advance.
(3) When handling pseudonymously processed information as a database:
① The Company will take necessary and appropriate security control measures to protect it from unauthorized access, alteration, leakage, loss, and damage.
② The Company will not collate it with other information to identify the individual pertaining to the personal information used for its creation.
③ The Company will not use contact details or other information contained in such pseudonymously processed information for the purpose of making telephone calls, sending mail or correspondence mail, delivering telegrams, transmitting by facsimile or electromagnetic means, or visiting residences.
④ Other handling, except where excluded by the provisions concerning the protection of personal information, will be in accordance with the matters to be published under the Act on the Protection of Personal Information.
15. Personally-Referable Information
Personally-referable information refers to information relating to a living individual that does not fall under any of the categories of personal information, anonymously processed information, or pseudonymously processed information.
(1) When acquiring personally-referable information from a third-party provider and handling it as personal data:
① There are cases where personally-referable information provided by a third party is collated with personal information acquired from customers or other individuals, and as a result, the personally-referable information becomes personal data by which an individual can be identified.
② Items of personally-referable information subject to this: All personally-referable information.
③ Purposes of use after acquisition: In accordance with the purposes of use set forth in this Policy.
(2) When providing personally-referable information as a database to a third party:
① The Company may provide personally-referable information to its partners. There are cases where the provided personally-referable information is collated with personal information held by the third party (partner), and as a result, becomes personal data by which an individual can be identified. Currently, the Company has no plans to provide personally-referable information as a database to third parties; therefore, the recipients and the items of personally-referable information subject to such provision are not published.
② The purposes of use by the recipient after acquiring personally-referable information as personal data will be notified or published by the recipient.
16. External Transmission, etc.
The Company utilizes technologies such as cookies and web beacons on its website. These cookies are used to improve the convenience of the site when customers revisit it. They do not infringe upon customer privacy nor adversely affect customers' computers. While cookies do not identify individuals per se, they are managed with the same level of care as personal information. Furthermore, when providing cookie information to third parties, except in cases stipulated in Article 11, it will be provided in a form that cannot identify individuals. However, if identifiers such as cookies or IP addresses are used in combination with information that can identify an individual, or if a recipient can collate them with information that can identify an individual, such identifiers will also be regarded as personal information.
Additionally, cookie information may be used by the Company or its affiliated partners for targeted advertising delivery and site usage analysis. If you wish to stop targeted advertising or the collection of site usage information (opt-out), please do so on the opt-out pages of our affiliated partners, although this may require some effort. Please note that opt-out procedures are required for each browser used. Therefore, if you delete an opt-out cookie issued by the Company, install a new browser, or change your PC/smartphone, you will need to repeat the procedure.
The external transmission destinations used by the Company are as follows:
Google Analytics (Google LLC) Privacy Policy: ( https://policies.google.com/privacy ) Opt-out: ( https://tools.google.com/dlpage/gaoptout?hl=en )
17. Continuous Improvement
The Company will continuously implement improvements to ensure the proper handling of personal information.
18. Disclosure, Correction, Suspension of Use, or Deletion of Personal Data
If an individual wishes to request disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to a third party (hereinafter collectively "Disclosure, etc.") of their personal data held by the Company, please make a direct request to the Company using the method below. Unless special procedures are stipulated by laws and regulations, the Company will conduct the necessary investigation without delay and, only if it is confirmed that the request is from the individual themselves, will carry out the Disclosure, etc., of the individual's personal data in accordance with laws and regulations. Please note that if the requirements for the request method specified below are not met, or if the content of the request is deemed unreasonable based on the investigation results, the Company may not be able to comply with the request.
Method for Requesting Disclosure of Personal Data: Please prepare the following documents and send them to the "Contact Window for Inquiries." Please note that postage fees will be borne by the customer.
(1) Personal Data Disclosure Request Form: Please fill in the necessary items on the form designated by the Company.
(2) Documents to Confirm Identity of the Individual or Agent:
① For the individual: Identification documents (confirmation by copies of the following identification documents)
a) A copy of one of the following government-issued photo identification documents: driver's license, passport, residence card, special permanent resident certificate, Individual Number Card (My Number Card) (the side showing the Individual Number should not be sent), etc.
b) Copies of two of the following government-issued non-photo identification documents: health insurance card, pension book, etc.
② For an agent: (If the person making the request for Disclosure, etc. is a legal representative of a minor, adult ward, etc., or a voluntary agent designated by the individual, the following documents are required in addition to the documents listed in ① above.)
A. Documents to confirm power of attorney:
- For a minor: An abridged copy of the individual's family register or a copy of an insurance card showing dependent family members.
- For an adult ward: Certificate of registered matters as stipulated in the Act on Guardianship Registration, etc.
B. For a voluntary agent: Power of attorney for the request for Disclosure, etc. of retained personal data and a certificate of the individual's seal impression.
(3) Return envelope (self-addressed, stamped).
(4) Fees, etc.: When a request for Disclosure, etc. ("Disclosure Request" and "Request for Notification of Purpose of Use, Correction, etc., Suspension of Use, etc.") is made by the individual, a fee of JPY 1,000 (tax included) per request, covering handling and postage, will be collected in postage stamps. Please note that fees, etc. will not be refunded even if the Company cannot comply with the request for Disclosure, etc. Furthermore, if the postal system changes, the fees, etc. may be subject to change.
19. Contact for Consultations and Complaints Regarding Handling of Personal Information
For various procedures and inquiries regarding the Company's handling of personal data, please contact the following:
Sparkle AI Co., Ltd.
Personal Information Protection Consultation Service
Email Inquiries: info@sparkleai.co.jp
Postal Inquiries: Sparkle AI Co., Ltd. Personal Information Protection Consultation Service Akasaka 1-chome Center Building 9F 1-11-30 Akasaka, Minato-ku, Tokyo 107-0052 Japan
20. Changes to the Privacy Policy
When the Company makes changes to the personal information it acquires, changes to the purposes of use, or other changes to this Privacy Policy, such changes will be announced by revising this page. The revised Privacy Policy will become effective from the time the revision date is displayed on the website.
Supplementary Provisions
Enacted: May 12, 2025