rinna Co., Ltd. ("the Company") sets forth this Privacy Policy (this "Policy") regarding the handling of user information, including personal information, obtained by the Company. Regarding the addresses and names of representatives of the Company, please see here. In the event that a separate privacy policy is established for specific service provided by the Company, such privacy policy shall take precedence over this Policy.

1. Definition

1. "Personal Information" means personal information as defined by Article 2.1 of the Japan Personal Information Protection Act or local privacy laws and regulations as applicable.
2. "User Information" means information pertaining to the identification of users, action history on communication services, and other information generated or accumulated in relation to users or their devices, which is collected by the Company in accordance with this Policy.
3. "User" means any individual that uses the services provided by the Company.

2. User Information to be collected and the method of collection

1. User Information to be collected by the Company on the Services provided by us (the "Services") or our website depending on its method of collection is as follows:
   1. Information provided by external services.
      When the Service is linked to a social networking service, business communication tool, or other service provided by an entity partnering with the Company or other entity other than the Company (collectively referred to in this policy as "External Service"), the Company may collect the following information from such External Service.
      • The account name, icon image, and status message used by the User on the External Service, as well as internal identifiers assigned independently by the operator of the service.
      • Other information that the User has authorized to be disclosed to the partnering party according to the privacy settings of the External Service.
   2. Information collected by the Company at Users'use of the Services.
      We may collect information about the content posted by Users on the linked External Services described in (a) above, the content posted by Users on the feedback page of our website, and other information about access to and use of the Service. This includes the following information:
      • Referrer
      • IP address
      • Information on server access logs
      • Cookies, ADIDs, IDFAs, and other identifiers
   3. Information collected by the Company with individual consents at Users' use of the Services.
      If a User individually consents to the use of the Service by the method specified in 4(1), the Company will collect the following information from the device being used:
      • Location information
2. Information collected by the Company at Users'use of our website.
   We may collect information about the content of your postings on our website, the content posted by Users on the feedback page of our website, and other information about access to and use of the Service. This includes the following information:
   • Referrer
   • IP address
   • Information on server access logs
   • Cookies, ADIDs, IDFAs, and other identifiers
3. Information collected by the Company in response to inquiries from Users.
   The Company may collect information regarding the content of inquiries from Users by telephone or e-mail. We may record the call in order to accurately understand the content of the User's inquiry.
4. Information collected from children.
   The Company does not and will not knowingly collect information from any unsupervised person under the age of 13. For the processing of the Personal Information of a child below the age of 13, the consent of the holder of parental responsibility is necessary. The Company shall make reasonable efforts to verify in such a case that consent is given or authorized that way, taking into consideration available technology.

3. Purpose of use

The specific purposes of use of User Information and Personal Information of our employees related to the provision of the Service and our website are as follows.

1. User Information
   
   1. To provide, maintain, protect and improve the Services (including the generation of messages, images, audio and other content using artificial intelligence).
   2. To create statistical data related to our Services in a format that does not allow individuals to be identified.
   3. To provide information and respond to inquiries regarding the Service, the Company's website, or the Company's business.
   4. To respond to violations of the Company's terms, policies, etc. (the "Terms and Conditions, etc.") regarding the Service.
   5. To notify you of changes in the Terms and Conditions, etc. of this Service.
   6. To deliver and display advertisements and measure their effectiveness.
   7. To carry out the selection process of applicants for employment.
   8. To conduct the seminar for which you have registered.
   9. To provide information necessary for public relations activities.
2. Personal Information of business partners, Personal Information of participants in events and seminars that we sponsor, co-sponsor, or participate in, and Personal Information of members of media to which we submit articles or advertisements.
   1. To do business communication, execute transactions and contracts, and other management.
   2. To send information and other communications regarding events, seminars, etc.
   3. To provide information and proposals regarding our products and Services.
3. Personal Information obtained in connection with inquiries
   1. To accurately ascertain inquiries, etc., respond to them, send materials and other communications.
   2. To improve response to inquiries.
4. Personal Information of officers and employees
   1. To determine and pay salaries, etc.
   2. For operations related to welfare and other benefits.
   3. For operations related to the implementation of personnel systems, employment management, human resources development, skills development, etc.
   4. To investigate and improve working conditions.
   5. For various procedures at the time of employment and resignation, and for various procedures and communications necessary in the course of business.
   6. To manage the use of our facilities by our employees.
   7. To perform other tasks incidental to the above.
5. Personal Information of employment applicants
   1. To arrange interviews, notify interview results, and do other communications
   2. To carry out the selection process of applicants for employment

4. Method of notification, publication, or obtaining consent, and method of requesting suspension of use.

1. The following User Information shall be subject to the consent of the User before it is collected.
   • Location information
2. A User may request the suspension of use of all or part of the User Information by making the prescribed settings for the Service, and in such case, the Company shall promptly suspend the use of the User Information in accordance with the Company's policies. Since the collection or use of some items of User Information is a prerequisite for the Service, the Company will stop collecting or using such information only when the User stops using the Service in accordance with the prescribed method of the External Service with which the Service is linked, or when the User withdraws from the Service in accordance with the Company's prescribed method.

5. Provision to third parties

The Company will not provide the information to any third party (including parties located outside of Japan) without obtaining the prior consent of the individual, except in cases where disclosure is permitted under the Japan Personal Information Protection Act or other local laws and regulations as applicable. However, this shall not apply to the following cases where there is a need to provide Personal Information to a third party (including parties located outside of Japan).

1. When we outsource all or part of the handling of Personal Information within the scope necessary to achieve the purpose of use.
2. Cases in which Personal Information is provided as a result of the succession of business due to merger or other reasons.
3. Cases in which it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining your consent is likely to impede the execution of such affairs.
4. Other cases permitted under the Japan Personal Information Protection Act or other local laws and regulations as applicable.

6. Disclosure of Personal Information, etc.

When the Company receives a request from a person for disclosure of his/her Personal Information or records provided to a third party in accordance with the provisions of the Japan Personal Information Protection Act or other local laws and regulations as applicable, we will disclose such information to the person without delay after confirming that the request is made by the personal data subject himself/herself (if such Personal Information or records provided to a third party do not exist, we will notify the person to that effect). However, this does not apply to cases in which we are not obligated to disclose the information under the Japan Personal Information Protection Act or other laws and regulations as applicable. Please note that a fee (JPY1,000 per case) will be charged for each disclosure of such Personal Information.

7. Correction and suspension of use of Personal Information

1. When the Company is requested by a person to correct or suspend the use of his/her Personal Information in accordance with the provisions of the Japan Personal Information Protection Act or other local laws and regulations as applicable for any of the following reasons, it will conduct the necessary investigation without delay after confirming that the request is made by the personal data subject himself/herself, and based on the results, correct or suspend the use of the Personal Information, and notify the individual to that effect. The Company will also notify the person of the decision made not to correct or suspend the use of the Personal Information.
   1. When a request is made to correct Personal Information on the grounds that it is untrue, in accordance with the provisions of the Japan Personal Information Protection Act or other local laws and regulations as applicable.
   2. The grounds that Personal Information is handled beyond the scope of the purpose of use publicly released in advance.
   3. The grounds that Personal Information was collected through deception or other wrongful means.
   4. The grounds that Personal Information is being used in a manner that may encourage or induce illegal or unjust acts.
2. If a person requests that the Company deletes his/her Personal Information, and we deem it necessary to comply with the request, the Company will delete the Personal Information after confirming that the request is made by the personal data subject himself/herself, and notify the person to that effect.
3. The provisions of 7(1) and 7(2) do not apply to cases in which the Company is not obligated to make corrections, etc. or suspend use, etc. under the Japan Personal Information Protection Act or other local laws and regulations as applicable.

8. Safety control measures

The Company takes the following measures to ensure the security of Personal Information.

1. Formulation of basic policy
   To ensure the proper handling of Personal Information, we have established and are operating this policy.
2. Discipline for the handling of personal data
   For each stage of acquisition, use, storage, provision, deletion/disposal, etc., we have established and are operating rules for handling Personal Information ("Personal Information Protection Rules"), including handling methods, responsible persons/persons in charge, and their duties.
3. Organizational safety control measures
   We have appointed a person responsible for the handling of Personal Information (Personal Information Protection Manager), and have clarified who is responsible for the work handling Personal Information and the scope of such handling.
4. Personnel safety control measures
   Regular training is provided to employees on points to keep in mind regarding the handling of Personal Information.
5. Physical safety control measures
   In the area where Personal Information is handled, we control the access of employees and take measures to prevent unauthorized persons from viewing Personal Information.
6. Technical safety control measures
   Access control is implemented to limit the scope of persons in charge and Personal Information handled.
7. Understanding the external environment
   When storing Personal Information in a foreign country, we implement safety control measures based on our understanding of the systems for the protection of Personal Information in that country.

9. Handling of Cookies

Our website uses cookies and other similar technologies for tracking and analysis ("Cookies") in order to provide more appropriate services to our Users.

1. Overview of Cookies
   Cookies are small text files containing arbitrary characters that are exchanged between the web server and the User's Internet browsing software (browser) and stored on the User's terminal when the User visits a website. By using this, the Company may obtain non-personally identifiable attribute information such as User browsing history, service usage history, and location information.
   If User rejects the use of cookies or deletes cookies, the User may be limited in the functions he/she can use on the website. Please note that if User rejects or deletes cookies, his/her ability to use the website may be limited.
2. About Google Analytics
   The Company uses Google Analytics provided by Google. Google may collect and analyze User's browsing history based on Cookies set by the Company or by Google and use the results to understand his/her usage and to provide our Services. For more information about Google's treatment of data in Google Analytics, please visit their site（"How Google uses information from sites or apps that use our services"）.

10. Contact for inquiries

Please direct requests based on Article 6 or 7, any comments, questions, complaints, or other inquiries regarding the handling of usage information to the following contact point.

Address: 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6139, Japan
Shibuya Scramble Square 39F WeWork
rinna Co., Ltd. Department in charge: Privacy & Security Dept.
E-mail：privacy@rinna.co.jp

11. Procedures for changing the Privacy Policy

We will review the operational status of the handling of User Information from time to time and strive for continuous improvement, and may change this Policy as necessary. However, in the case of changes to the content of this Policy that require the consent of the individual concerned under laws and regulations, such changes shall be applied only to those individuals who have consented to such changes in the manner prescribed by the Company. In the event of any changes to this Policy, we will notify you of the effective date and content of the revised Policy by displaying the revised Policy on our website or by any other appropriate means.

Published on October 20, 2020
Revised on March 31, 2022
Revised on December 1, 2022
Last revised on March 13, 2023