ACES, Inc. (the “Company”) sets forth its policy concerning the handling of Personal Information in relation to a business AI cloud provided by the Company which records and analyzes online business meetings (the “Service”) as follows.
The terms used in the main text are as defined in the Act on the Protection of Personal Information (the “Act”) and other relevant laws and regulations.

1　Purposes of Use of Personal Information

The Company will observe the Act, related laws and regulations, and guidelines established by the Personal Information Protection Commission, and this Privacy Policy, and will appropriately handle Personal Information (meaning “Personal Information” as defined in paragraph 1 of article 2 of the Act. Same applies hereinafter.) in compliance with laws.

2　Acquiring Personal Information

The Company will observe the Act, related laws and regulations, and guidelines established by the Personal Information Protection Commission, and this Privacy Policy, and will appropriately handle Personal Information (meaning “Personal Information” as defined in paragraph 1 of article 2 of the Act. Same applies hereinafter.) in compliance with laws.

1. Name of the user of the Service and the company to which he or she belongs (company name).
2. Address
3. Telephone number
4. Sex
5. Birthdate
6. E-mail address
7. User ID
8. Password
9. Or other items which enable the identification of a specific individual by integrated items displayed by using video, sound, behavior or other means described or recorded on various devices such as storage (including such items as will allow easy reference to other information and will thereby enable the identification of a specific individual).

3　Purposes of Use of Personal Information

The Company will use the customer’s Personal Information within the following scope of purposes of use (the “Purposes of Use”) or within the scope of the Purposes of Use as is evident from the circumstances of the acquisition of the Personal Information, and will not use it for any other purpose except with the consent of the customer or as otherwise permitted by laws or regulations.

1. To provide the Service provided by the Company;
2. To provide after-sales-support and answer inquiries from customers of the Service;
3. To provide latest information related to the Company, such as information about other services and new products and services provided by the Company;
4. For the billing, refunding, payment, and other related administrative processes;
5. To conduct delegated work when handling Personal Information as a subcontractor delegated by a third party; and
6. To prepare anonymously processed or statistical information in a form where specific individuals cannot be identified.

4　Delegation of Handling Personal Data

The Company may delegate the handling of personal data of the customers to a partner company to an extent necessary for achieving the Purposes of Use set forth in the preceding paragraph. Ho Company will not provide the personal data of customers to third parties (except subcontractors) unless prior consent has been obtained from the customer as to personal data acquired by the Company or as is permitted by laws and regulations.

5　Providing Personal Data to Third Parties

The Company will not provide the personal data of customers to third parties (except subcontractors) unless prior consent has been obtained from the customer as to personal data acquired by the Company or as is permitted by laws and regulations.

6　Management of Personal Data

1. Ensuring the Accuracy of Data
   The Company will strive to keep the personal data of the customers accurate and up-to-date to the extent necessary for achieving the Purposes of Use and to erase such personal data when its use is no longer necessary.
2. Security Control Measures
   The Company will take necessary and appropriate measures to prevent the leakage, loss, or damage of the customers’ personal data and ensure its security.
3. Supervision of Employees
   When allowing employees to handle the personal data of customers, the Company will ensure that the employees are thoroughly informed of the proper handling of Personal Information, provide employees with appropriate training, and supervise employees’ handling of personal data as required and appropriate.
4. Supervision of Subcontractors
   When the Company delegates the handling of personal data of customers, it will select a partner company that takes appropriate safety control measures and supervise the subcontractor as required and appropriate.

7　Receipt regarding Retained Personal Data

1. Upon receipt of a request from a user or its agent of notice of the Purpose of Use of retained personal data, the Company will notify the customer without delay except in the following cases:
   
   • When the Purposes of Use of the retained personal data by which the customer is identified is clear;
   • When there is a risk of harm to the life, body, property, or other rights or interests of the user or third parties;
   • When there is a risk of harming the Company’s rights or legitimate interests; or
   • When it is necessary to cooperate with a national body or a local public entity in executing the affairs prescribed by laws and regulations, and the execution of such affairs is likely to be hindered by notice of the Purposes of Use of retained personal data.
2. Upon the request from a user or its agent to disclose retained personal data, the Company will disclose the customer without delay except in the following cases:
   
   • When there is a risk of harm to the life, body, property, or other rights or interests of the user or third parties;
   • When there is a risk of significant hindrance to the proper execution of the Company’s business; or
   • When there is a violation of any laws or regulations.
3. In the event of a request by the user or its agent for the correction, addition, or deletion of such retained personal data, the Company will investigate such request without delay and take appropriate action based on the results of such investigation.
4. If the user or its agent requests the discontinuance of its utilization of such retained personal data or its erasure, if the request is found to be reasonable, the Company will respond appropriately.
5. To make a request as set forth in the four preceding items, after filling in the request form prescribed by the Company, please send it together with the documents mentioned in the request form to the Company’s point of contact set forth in paragraph 8 below. The Personal Information provided by the user will be used for the purpose of responding to the user’s request and will be securely stored. Please note that no request form or attached documents will be returned.

8　Contact point for processing inquiries and complaints

ACES, Inc

Yushima First Genesis Bldg. 3F, 2-31-14, Yushima, Bunkyo-ku, Tokyo, Japan (postal code)113-0034

Office hours : 10:00 to 19:00 (excluding Saturdays, Sundays, public holidays, and Company’s non-business day)
※During these hours, you will receive initial responses to inquiries within 3 hours, and detailed responses within 48 hours.

E-mail：support-acesmeet@acesinc.co.jp

9　Revision of Privacy Policy

The Company may review the content of this Privacy Policy from time to time and make changes as needed. In such case, the revised privacy policy will apply from the date of publication of the revised edition.

Established as of March 16, 2020
Revised as of October 20, 2021