Privacy Policy

The Japanese version of this document is the authoritative text. If there is any difference between this translation and the Japanese version, the Japanese version prevails. View the Japanese version

Symbe, inc. (the "Company") recognizes the importance of protecting its customers' personal information. The Company complies with Japan's Act on the Protection of Personal Information (the "APPI") and endeavors to handle and protect personal information appropriately in accordance with the following privacy policy (this "Privacy Policy"). If, for any individual service of the Company, there is a privacy policy or other terms and the like that govern the handling and protection of information of customers (including end users), those terms and the like apply in priority to the provisions of this Privacy Policy.

1. Definition of personal information

In this Privacy Policy, "personal information" means personal information as defined in Article 2, paragraph (1) of the APPI (including information that can identify a specific device or its user by means of a device-specific ID, cookie, or the like contained in that information).

2. Purposes of use of personal information

The Company may use customers' personal information for the following purposes.

(1) To provide the Company's services
(2) To provide information about the Company's services and to respond to inquiries and the like
(3) To provide information about the Company's products, services, and the like
(4) To respond to acts that violate the Company's terms, policies, and the like relating to the Company's services (the "Terms")
(5) To give notice of changes to the Terms relating to the Company's services and similar matters
(6) To analyze information on users' use of the services and the like, and to use it to improve the Company's services, develop new services, and so on
(7) To create, in connection with the Company's services, statistical data processed into a form that cannot identify individuals
(8) To combine information collected from multiple services of the Company and create new data
(9) For employment management and internal procedures (for personal information of employees), and for screening and communication in recruitment activities (for personal information of applicants)
(10) For shareholder management and for handling procedures under Japan's Companies Act and other laws and regulations (for personal information of shareholders, holders of share options, and the like)
(11) For other purposes incidental to the purposes of use above

3. Changes to the purposes of use of personal information

The Company may change the purposes of use of personal information within a scope reasonably deemed to be relevant, and if it does so, it will notify customers of the change or make it public.

4. Use of personal information

4-1.

Except where permitted by the APPI or other laws and regulations, the Company will not handle personal information beyond the scope necessary to achieve the purposes of use without obtaining the customer's consent. However, this does not apply in the following cases.

(1) Cases based on laws and regulations
(2) Cases in which it is necessary to protect the life, body, or property of a person and it is difficult to obtain the customer's consent
(3) Cases in which it is specially necessary to improve public health or promote the sound growth of children and it is difficult to obtain the customer's consent
(4) Cases in which it is necessary to cooperate with a national government organ, a local government, or a person entrusted by either of them in performing affairs prescribed by laws and regulations, and obtaining the customer's consent is likely to interfere with the performance of those affairs

4-2.

The Company will not use personal information in a way that may encourage or induce unlawful or unjust conduct.

5. Proper acquisition of personal information

5-1.

The Company will acquire personal information properly and will not acquire it by deception or other wrongful means.

5-2.

Except in the following cases, the Company will not acquire special care-required personal information (meaning that defined in Article 2, paragraph (3) of the APPI) without obtaining the consent of the customer in person in advance.

(1) Cases falling under any of the items of Section 4.1
(2) Cases in which the special care-required personal information has been made public by the individual, a national government organ, a local government, a person set forth in any of the items of Article 57, paragraph (1) of the APPI, or any other person prescribed by rules of the Personal Information Protection Commission
(3) Cases in which the Company acquires special care-required personal information that is apparent from the individual's outward appearance by visually observing or photographing or filming the individual
(4) Cases in which the Company receives special care-required personal information from a third party and that provision by the third party falls under any of the items of Section 8.1

5-3.

When receiving personal information from a third party, the Company will confirm the following matters as prescribed by rules of the Personal Information Protection Commission. However, this excludes cases in which the provision of the personal information by the third party falls under any of the items of Section 4.1 or any of the items of Section 8.1.

(1) The name and address of the third party and, in the case of a corporation, the name of its representative (or, in the case of an unincorporated body that has a designated representative or administrator, the name of that representative or administrator)
(2) The circumstances under which the third party acquired the personal information

6. Security control of personal information

To ensure the security control of personal information against risks such as loss, destruction, falsification, and leakage, the Company will exercise necessary and appropriate supervision over its employees. In addition, when entrusting all or part of the handling of personal information, the Company will exercise necessary and appropriate supervision to ensure the security control of personal information at the entrusted party. For the specific security control measures for the retained personal data held by the Company, please contact the inquiry desk set out in Section 16. The Company will respond without delay.

7. Reporting and the like in the event of leakage

If a situation such as leakage, loss, or damage of personal information handled by the Company occurs and a report to the Personal Information Protection Commission and notice to customers are required under the provisions of the APPI, the Company will make that report and give that notice.

8. Provision to a third party

8-1.

Except where disclosure is permitted under the APPI or other laws and regulations, the Company will not provide personal information to a third party without obtaining the customer's consent in advance. However, the following cases do not constitute provision to a third party as set out above.

(1) Cases in which the Company entrusts all or part of the handling of personal information within the scope necessary to achieve the purposes of use
(2) Cases in which personal information is provided in connection with a business succession resulting from a merger or other grounds
(3) Cases in which it is necessary to cooperate with a national government organ, a local government, or a person entrusted by either of them in performing affairs prescribed by laws and regulations, and obtaining the customer's consent is likely to interfere with the performance of those affairs
(4) Other cases permitted by the APPI or other laws and regulations

The Company may publish aggregated data and statistical data that do not constitute personal information, or provide them to customers such as the Company's partners and advertising distribution businesses.

8-2.

Notwithstanding Section 8.1, except in cases falling under any of the items of Section 4.1, when the Company provides personal information to a third party (excluding a person that has established a system conforming to the standards designated by rules of the Personal Information Protection Commission under Article 28 of the APPI) in a foreign country (excluding countries designated by rules of the Personal Information Protection Commission under Article 28 of the APPI), the Company will obtain in advance the customer's consent to the provision to a third party in a foreign country.

8-3.

When obtaining the customer's consent to provision to a third party in a foreign country under Section 8.2, the Company will provide the customer with information on the following matters. However, if the matter in item (1) cannot be identified, the Company will, in place of the matters in items (1) and (2), provide a statement that the matter in item (1) cannot be identified and the reason for this, as well as any information that would serve as a reference for the customer in place of that matter.

(1) The name of the foreign country
(2) Information on the system for the protection of personal information in the foreign country
(3) Information on the measures the third party takes to protect personal information (if this information cannot be provided, a statement to that effect and the reason)

8-4.

When the Company has provided personal information to a third party, it will prepare and keep records in accordance with Article 29 of the APPI.

8-5.

When receiving personal information from a third party, the Company will carry out the necessary confirmation in accordance with Article 30 of the APPI and will prepare and keep records of that confirmation.

9. Disclosure of personal information

When a customer requests disclosure of personal information, the Company will, after confirming that the request comes from the customer in person, disclose it to the customer without delay (if the personal information does not exist, the Company will notify the customer to that effect). However, this does not apply where the Company has no obligation to disclose under the APPI or other laws and regulations. The Company may charge a fee prescribed by the Company for the disclosure of personal information.

10. Correction and the like of personal information

When a customer requests, under the provisions of the APPI, the correction of, addition to, or deletion of the content of personal information ("correction, etc.") on the grounds that the personal information is not true, the Company will, after confirming that the request comes from the customer in person, conduct the necessary investigation without delay within the scope necessary to achieve the purposes of use, carry out the correction, etc. of the content of the personal information based on the results, and notify the customer to that effect (if the Company decides not to carry out the correction, etc., it will notify the customer to that effect). However, this does not apply where the Company has no obligation to carry out the correction, etc. under the APPI or other laws and regulations.

11. Cessation of use and the like of personal information

If a customer requests the Company, under the provisions of the APPI, (1) to cease the use of or erase the customer's personal information ("cessation of use, etc.") on the grounds that it is being handled beyond the scope of the purposes of use made public in advance, or is being used in a way that may encourage or induce unlawful or unjust conduct, or on the grounds that it was acquired by deception or other wrongful means; (2) to cease the provision of personal information ("cessation of provision") on the grounds that it is being provided to a third party without the consent of the individual; or (3) to carry out cessation of use, etc. or cessation of provision on the grounds that the Company no longer needs to use the customer's personal information, that a situation prescribed in the main clause of Article 26, paragraph (1) of the APPI has occurred with respect to the customer's personal information, or that the handling of the customer's personal information otherwise may harm the customer's rights or legitimate interests, and it is found that the request has grounds, the Company will, after confirming that the request comes from the customer in person, carry out the cessation of use, etc. or cessation of provision of the personal information without delay and notify the customer to that effect. However, this does not apply where the Company has no obligation to carry out cessation of use, etc. or cessation of provision under the APPI or other laws and regulations.

12. Provision of personally referable information to a third party

12-1.

When it is expected that a third party will acquire personally referable information (meaning that prescribed in Article 2, paragraph (7) of the APPI, and limited to information constituting a personally referable information database or the equivalent prescribed in Article 16, paragraph (7) of the APPI; the same applies below) as personal data, the Company will not provide that personally referable information to the third party without confirming the following matters in advance as prescribed by rules of the Personal Information Protection Commission, except in the cases set forth in the items of Section 4.1.

(1) That the customer's consent has been obtained to the third party receiving personally referable information from the Company and acquiring it as personal data by which the customer is identified.
(2) In the case of provision to a third party in a foreign country, that, when the customer's consent under the preceding item is to be obtained, information on the system for the protection of personal information in the foreign country, the measures the third party takes to protect personal information, and other information that would serve as a reference for the customer has been provided to the customer in advance as prescribed by rules of the Personal Information Protection Commission.

12-2.

When the Company has provided personally referable information to a third party, it will prepare and keep records in accordance with Article 31 of the APPI.

12-3.

When receiving personally referable information from a third party, the Company will carry out the necessary confirmation in accordance with Article 31 of the APPI and will prepare and keep records of that confirmation.

13. Handling of pseudonymized personal information

13-1.

When creating pseudonymized personal information (meaning that prescribed in Article 2, paragraph (5) of the APPI, and limited to information constituting a pseudonymized personal information database or the equivalent prescribed in Article 16, paragraph (5) of the APPI; the same applies below), the Company will process personal information in accordance with the standards prescribed by rules of the Personal Information Protection Commission.

13-2.

When the Company has created pseudonymized personal information, or has acquired pseudonymized personal information and the deleted or other related information pertaining to that pseudonymized personal information (meaning that prescribed in Article 41, paragraph (2) of the APPI; the same applies below), it will take measures for the security control of the deleted or other related information in accordance with the standards prescribed by rules of the Personal Information Protection Commission as necessary to prevent leakage of the deleted or other related information.

13-3.

With respect to pseudonymized personal information (limited to that which is personal information; the same applies below in this Section 13.3), the Company will comply with the following provisions.

(1) Notwithstanding Section 4.1, except in cases based on laws and regulations, the Company will not handle pseudonymized personal information beyond the scope necessary to achieve the purposes of use.
(2) In applying Section 3 to pseudonymized personal information, the phrase "change the purposes of use of personal information within a scope reasonably deemed to be relevant" in that Section is to be read as "change the purposes of use of personal information", and the phrase "notify customers of the change or make it public" is to be read as "make the change public".
(3) Notwithstanding Sections 8.1 through 8.3, except in cases based on laws and regulations, the Company will not provide personal data that is pseudonymized personal information to a third party. However, the cases set forth in the items of Section 8.1 do not constitute provision to a third party as set out above.
(4) In handling pseudonymized personal information, the Company will not collate that pseudonymized personal information with other information in order to identify the customer to whom the personal information used to create that pseudonymized personal information relates.
(5) In handling pseudonymized personal information, the Company will not use contact details or other information contained in that pseudonymized personal information to make telephone calls, send items by post or correspondence delivery, deliver telegrams, transmit by facsimile or electronic or magnetic means, or visit a residence.
(6) Section 7 and Sections 9 through 11 do not apply to pseudonymized personal information.

13-4.

With respect to pseudonymized personal information (excluding that which is personal information; the same applies below in this Section 13.4), the Company will comply with the following provisions.

(1) Except in cases based on laws and regulations, the Company will not provide pseudonymized personal information to a third party. However, the cases set forth in the items of Section 8.1 do not constitute provision to a third party as set out above.
(2) To ensure the security control of pseudonymized personal information against risks such as leakage, the Company will exercise necessary and appropriate supervision over its employees. In addition, when entrusting all or part of the handling of pseudonymized personal information, the Company will exercise necessary and appropriate supervision to ensure the security control of personal information at the entrusted party.
(3) In handling pseudonymized personal information, the Company will not acquire deleted or other related information, or collate that pseudonymized personal information with other information, in order to identify the customer to whom the personal information used to create that pseudonymized personal information relates.
(4) In handling pseudonymized personal information, the Company will not use contact details or other information contained in that pseudonymized personal information to make telephone calls, send items by post or correspondence delivery, deliver telegrams, transmit by facsimile or electronic or magnetic means, or visit a residence.

14. Handling of anonymized personal information

14-1.

When creating anonymized personal information (meaning that prescribed in Article 2, paragraph (6) of the APPI, and limited to information constituting an anonymized personal information database or the equivalent prescribed in Article 16, paragraph (6) of the APPI; the same applies below), the Company will process personal information in accordance with the standards prescribed by rules of the Personal Information Protection Commission.

14-2.

When the Company has created anonymized personal information, it will take measures for security control in accordance with the standards prescribed by rules of the Personal Information Protection Commission.

14-3.

When the Company has created anonymized personal information, it will make public the categories of information relating to individuals contained in that anonymized personal information as prescribed by rules of the Personal Information Protection Commission.

14-4.

When providing anonymized personal information (including that created by the Company and that received from a third party; the same applies below unless otherwise provided) to a third party, the Company will, as prescribed by rules of the Personal Information Protection Commission, make public in advance the categories of information relating to individuals contained in the anonymized personal information to be provided to the third party and the method of its provision, and will clearly indicate to the third party that the information being provided is anonymized personal information.

14-5.

In handling anonymized personal information, the Company will not, in order to identify the individual to whom the personal information used to create the anonymized personal information relates, (1) collate the anonymized personal information with other information, or (2) acquire the descriptions and the like or individual identification codes deleted from that personal information, or information on the method of processing carried out under Article 43, paragraph (1) of the APPI ((2) applies only to anonymized personal information received from a third party).

14-6.

The Company will endeavor to take, on its own, necessary and appropriate measures for the security control of anonymized personal information, and measures necessary to ensure the proper handling of anonymized personal information, such as the handling of complaints about the creation and other handling of anonymized personal information, and to make public the content of those measures.

15. Use of cookies and other technologies

The Company's services may use cookies and similar technologies. These technologies help the Company understand how its services are used and the like, and contribute to improving the services. Customers who wish to disable cookies can do so by changing their web browser settings. However, if cookies are disabled, some functions of the Company's services may no longer be available.

The Company's website uses the following external services. The providers of these services may use cookies and the like to acquire information about browsing, and the information acquired is handled in accordance with each provider's privacy policy.

Access analytics

To understand how its website is used, the Company uses Google Analytics by Google LLC and Microsoft Clarity by Microsoft Corporation. The Company also uses Google Tag Manager by Google LLC to manage these tags.

Ad delivery and measurement of effectiveness

To deliver the Company's advertisements and measure their effectiveness, the Company may use ad delivery services such as Google Ads (Google LLC) and Yahoo! JAPAN Ads (LY Corporation).

Display of text

To display the text on its website, the Company uses Google Fonts by Google LLC.

For how each provider handles information, please see the following pages.

Customers who wish to stop the collection of information or the display of advertisements based on behavioral history can change their settings on the following pages.

16. Contact

Please direct requests for disclosure and the like, opinions, questions, complaints, and other inquiries about the handling of personal information to the contact desk below.

4-4-11, 8F, Tenjin, Chuo-ku, Fukuoka 810-0001, Japan

Symbe, inc. (CEO: Masaru Takeuchi) Personal Information Inquiry Desk

Email: sales@symbe.co.jp

17. Continuous improvement

The Company will review the status of its operations for handling personal information as appropriate and endeavor to make continuous improvements, and may change this Privacy Policy as necessary. If the Company makes a material change to this Privacy Policy, it will endeavor to provide customers (excluding end users) with an opportunity to review the revised policy and express their opinions before they continue to use the Company's services.

[Established October 20, 2026]