Privacy Policy

Privacy Policy

This policy sets out how OpenPolicy, Inc. handles the personal information of users.

OpenPolicy, Inc. (the “Company”) establishes this Privacy Policy (the “Policy”) regarding the handling of personal information of users (the “Users”) of its services (the “Services”).

Article 1 (Personal information)

  1. “Personal information” means personal information as defined in Article 2, paragraph 1 of the Act on the Protection of Personal Information (Act No. 57 of 2003; the “Act”). It refers to information about a living individual that can identify a specific individual through a name, date of birth, or other description contained in the information, or that contains an individual identification code.
  2. “Personal data” means personal information that constitutes a personal information database or similar collection (Article 16, paragraph 1 of the Act), as defined in Article 16, paragraph 3 of the Act.

Article 2 (Purposes of use)

The Company acquires and uses Users’ personal information to the extent necessary for the following purposes. Before using personal information for any purpose beyond these, the Company obtains the User’s prior consent by an appropriate method.

  1. To provide the Company’s services.
  2. To improve the Services or develop new services.
  3. To provide information about new features, updates, campaigns, and other services offered by the Company, including by email, leaflets, and other direct mail.
  4. To communicate as necessary about maintenance, important notices, and other matters.
  5. To respond to opinions, inquiries, and other communications from Users about the Services, including verifying the User’s identity.
  6. To report to Users on their use of the Services.
  7. To request cooperation with surveys and interviews or participation in events related to the Services, and to report on their results.
  8. To identify Users who violate the terms of use or attempt to use the Services for fraudulent or improper purposes, and to refuse their use of the Services.
  9. To provide personal data to third parties in accordance with this Policy.

Article 3 (Provision of personal data to third parties)

The Company does not disclose or provide personal data to third parties without the consent of the individual concerned, except in the following cases:

  1. Where necessary to protect a person’s life, body, or property and it is difficult to obtain the individual’s consent.
  2. Where particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the individual’s consent.
  3. Where necessary to cooperate with a national government body, a local government, or a party entrusted by either in performing duties prescribed by law, and obtaining the individual’s consent could impede the performance of those duties.
  4. In other cases permitted by law.

Article 4 (Outsourcing of the handling of personal information)

The Company may outsource all or part of the handling of personal data to the extent necessary to achieve the purposes of use. In such cases, the Company thoroughly examines the suitability of the contractor, sets out confidentiality obligations and related matters in the contract, and exercises necessary and appropriate supervision over the contractor.

Article 5 (Disclosure of retained personal data)

When a User (limited to the individual concerned; the same applies throughout this Article) requests disclosure of the personal data the Company holds about them, the Company discloses it without delay. The Company may withhold all or part of the data where disclosure would fall under any of the following, and notifies the User without delay when it decides not to disclose. A fee of JPY 1,000 (excluding consumption tax and other applicable taxes) is charged per disclosure request.

  1. Where disclosure could harm the life, body, property, or other rights or interests of the User or a third party.
  2. Where disclosure could significantly impede the proper conduct of the Company’s business.
  3. Where disclosure would otherwise violate laws or regulations.

Article 6 (Correction of retained personal data)

  1. If personal data held by the Company is incorrect, the User may request that the Company correct, add to, or delete the data (“Correction”) through the procedures specified by the Company.
  2. On receiving such a request, the Company conducts the necessary investigation without delay and, if it finds the request justified, makes the Correction without delay.
  3. The Company notifies the User without delay when it has made a Correction under the preceding paragraph or has decided not to do so.

Article 7 (Suspension of use of retained personal data)

  1. The User may request that the Company suspend the use of, erase, or suspend the provision to third parties of the personal data the Company holds about them (“Suspension of Use”).
  2. On receiving such a request, the Company conducts the necessary investigation without delay and, if it finds the request justified, implements the Suspension of Use. Where the Suspension of Use would involve substantial expense or would otherwise be difficult, and alternative measures can be taken to protect the User’s rights and interests, the Company takes those alternative measures instead.
  3. The Company notifies the User without delay when it has implemented a Suspension of Use under the preceding paragraph or has decided not to do so.

Article 8 (Changes to this Policy)

The Company reviews this Policy as appropriate and endeavors to improve it. The Company may change the contents of this Policy, except for matters otherwise provided by law or by this Policy. A revised Policy takes effect when the Company notifies Users by its prescribed method or posts it on its website.

Article 9 (Compliance with laws and standards)

The Company complies with Japanese laws and other standards applicable to the personal information it holds.

Article 10 (Complaints and inquiries)

The Company accepts complaints and inquiries from Users about its handling of personal information and responds appropriately and promptly. It also responds promptly and appropriately to requests from Users for the disclosure, correction, addition, or deletion of their personal information, or for refusal of its use or provision.

Article 11 (Security measures)

The Company takes organizational, physical, personnel, and technical measures to prevent unauthorized access to, and the loss, destruction, alteration, or leakage of, the personal information entrusted to it by Users. In the event of an incident such as a leak of Users’ personal information, the Company promptly reports to the supervisory authority in accordance with the Act and related guidelines, follows the authority’s instructions, and takes the necessary steps to prevent similar incidents and any recurrence.

Article 12 (Analytics)

The Company’s website uses Google Analytics to analyze and improve how the site is used. Through cookies and similar technologies, information including cookie identifiers, IP addresses, pages viewed, referral sources, and browser and device information is transmitted to Google LLC and its affiliates. For information about how Google uses this information, see Google’s explanation.

Established and effective June 1, 2023.

Revised September 26, 2026.