Handling of Personal Information

SAMADHI Co.,Ltd. (thereafter “Samadhi”) shall exercise appropriate measures and privacy protection management procedures as required in “Personal information protection Management Systems” (JIS Q 15001), in handling personal information in its businesses operations to comply with Act on the Protection of Personal Information as well as other regulations and guidelines set by Japanese Government.

1.Name of Organization

SAMADHI Co.,Ltd.

2.Privacy Protection Officer

Director of Administration and General Affairs, SAMADHI Co.,Ltd.

3.Definition of Personal information

Personal information herein this statement is defined as any information related to and associated with existing individuals (not including ones deceased). Such information includes, but not limited to, name, date of birth, telephone number, email address, name of institution and other information, with which a specific individual is identifiable. Information is also regarded as personal when an individual is identifiable through matching with existing information held at Samadhi collected when delivering its services.

4.Usage of Personal Information

Samadhi may use personal information collected for below purposes:

Information
Purpose
personal information collected via Samadhi’s cloud services
(thereafter “the cloud services”) such as “Feelnote”
(1)identification of the cloud services
(2)delivery of notifications and messages associated with the cloud services
(3)personal promotion for admissions to educational institutions, corporates, partners and other organizations
(4)delivery of advertisement and its contents based on user information, device information, geolocation and action history
(5)generation of statistical data, after being masked so that individuals are not identifiable
(6)other related purposes than above
personal information of individuals lodged comments or inquiries via Samadhi’s website responses and answers to inquiries
personal information associated with trades
  1. client information management and promotion activities
application information collected during recruitment activities notifications of selection outcome and other associated communication
current and past employees’ and their family members’ personal information labor management, employment, welfare and benefits, social insurance and emergency contacts

5.Retention and management of personal information

Samadhi shall exercise, within a reasonable scope, any necessary and appropriate actions in order to maintain security and confidentiality of personal information it possesses.

6.Provision of Personal Information to Third-party

Samadhi shall not and will not disclose any personal information obtained to third-parties, except when consent of a person the information belongs to is obtained, or when required by laws of Japan.

7.Consignment of Handling of Personal Information

Samadhi may entrust or reassign, all or a part of, duties related to handling of personal information. In such circumstance,
Samadhi shall select organizations or individuals with sufficient privacy protection standards, and shall ensure via relevant
contracts that the organizations or individuals are to take appropriate measures.

8.Disclose and Complaint of Personal Information

Individuals wishing Samadhi to disclose, correct, add, delete or terminate use of their personal information, or wishing to place a complaint with regard to handing of their personal information, may do so by directing their inquiries to:

 SAMADHI Co.,Ltd.
 Hideko Muto, Privacy Complaint Officer
 Email:support@samadhi-group.com

Please refer to “how to lodge a disclosure or other request of your personal information” for more information.

Name and contact information of a certified personal information protection organization:
Name of organization JIPDEC
Contact for dispute resolution Counseling desk for Personal information protection
Address
  1. Roppongi First Bldg, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
Telephone 03-5860-7565
0120-700-779

※ above is not a point of contact for products and/or services offered by Samadhi.

9.Notes for Individuals Providing Personal Information

Submitting or providing personal information is completely optional and at discretion of individual wishing to use products and/or services by SAMADHI Co.,Ltd.

10.Obtaining personal information via methods or techniques not easily detectable

Samadhi does not collect any personal information through methods that are not easily detectable by individuals using services, e.g. cookies, web beacons.

11.Security Measures

Hi Samadhi shall exercise necessary and appropriate measures to prevent and/or recover leakage, loss and damage of collected personal information, as well as other actions required for maintaining security of the information.