Value Shift Inc. (hereinafter referred to as “the Company”) respects your privacy and considers the protection of personal information to be a crucial responsibility. We will comply with the “Act on the Protection of Personal Information” (hereinafter referred to as the “Personal Information Protection Act”) and other relevant laws and regulations, and we are fully committed to safeguarding your privacy.

Collection and Use of Personal Information

When you provide personal information to us, we will clearly specify the purposes of its use in advance and collect it within an appropriate scope. We will not use your personal information for purposes other than those specified and closely related purposes without your permission. However, for the personal information you provide and the personal data we already possess, We may use them for purposes such as contacting you about our services, providing related information, informing you about our services or products, fulfilling contracts, and business-related communications, without specifying the purpose each time. We will not use your personal information and existing personal data for purposes other than those mentioned above without your consent.

Our company will use personally identifiable information, such as web page browsing history, search history, location information, access analytics data, cookies, and similar data collected through our acquisition, affiliate sites, data analysis tool providers, advertising partners, and other partners (hereinafter referred to as “partners”), after linking it to the personal information held by our company. However, in cases where obtaining your consent is required under the Personal Information Protection Act for such linking, we will only perform the linking if you have consented to this Privacy Policy in accordance with the Personal Information Protection Act and related guidelines.

Provision of Personal Information

Unless otherwise explicitly consented to by the customer or as specified in the above cases, the personal information provided by customers will not be disclosed to any third party. However, this restriction does not apply in cases where disclosure is required by law, where disclosure is permitted without consent under the Personal Information Protection Act, or where disclosure is requested by public authorities such as the courts or the police.

Our company may provide our partners with personally identifiable information, such as web page browsing history, search history, location information, access analytics data, cookies, and similar data collected by our partners, linked with customer-specific information we have acquired, such as the customer’s registration status with us or the purchase of specific courses. However, in cases where obtaining your consent is required under the Personal Information Protection Act for such linking and provision to partners, we will only perform the linking if you have consented to this Privacy Policy in accordance with the Personal Information Protection Act and related guidelines.

Management of Personal Information

Our company takes appropriate measures to manage the personal information provided by customers securely.

In the protection and management of personal information (including information that has been processed to the extent that it cannot be used to identify a specific individual by removing part of the personal information or all of the personal identification codes, referred to as “anonymized processed information” hereinafter), our company implements safety management measures to prevent the leakage, loss, or damage of personal data and ensure the security of personal data (information security measures) as follows:

(1) Establishment of a responsible person for handling personal information and clarification of their role.

(2) Clarification of employees who handle personal information and the scope of personal information they handle, establishment of a reporting and communication system to responsible personnel in case of violations of the Personal Information Protection Act or internal regulations related to the handling of personal information, or the occurrence or signs of incidents such as data leaks.

(3) Regular training for employees on the handling of personal information.

(4) Access control measures in areas where personal information is handled, including access control, entry and exit management of employees, and prevention of unauthorized access to personal information.

(5) Limiting the scope of handlers and personal information databases, and implementing access control measures. When our company creates anonymized processed information, we will disclose the items of information related to individuals contained in the anonymized processed information as required by the Personal Information Protection Commission regulations.

Our company will only provide personal information to third parties who have implemented safety management measures that meet our company’s standards. When our company provides anonymized processed information to third parties, we will disclose in advance the items of information related to individuals contained in the anonymized processed information and the method of provision in accordance with the Personal Information Protection Commission regulations. We will also clearly indicate to the third party that the information provided is anonymized processed information.

In the event of incidents such as the leakage, loss, or damage of personal information, our company will report to the relevant authorities in accordance with the Personal Information Protection Act and related guidelines. We will also follow the instructions of the relevant authorities and take necessary measures to prevent recurrence, among other actions.

Handling of Personal Information Outsourcing

Our company may outsource all or part of the handling of personal information provided by customers to our business partners. In such cases, we will provide necessary and appropriate supervision to the outsourcing party to ensure the secure management of the personal data entrusted to them.

Third-Party Provision of Personal Information

Our company will not provide the personal information provided by customers to third parties without the customer’s consent, except as required by law.

When our company intends to provide a customer’s personal information to a third party located outside the country, we will obtain the customer’s consent in advance. However, this does not apply if the foreign country is determined by the regulations of the Personal Information Protection Commission to have a system for protecting personal information that is at a level equivalent to that of our country and if the third party continuously maintains a system that complies with the standards set forth in the regulations of the Personal Information Protection Commission, as required for the handling of personal data by personal information handling businesses.

Opting Out of Email Newsletter and Notifications

If you do not wish to receive emails such as our company’s newsletters, you have the option to request the cessation of such communication from us. However, please note that this exclusion does not apply to essential notifications related to the purchase of our company’s products, transaction processing, service fulfillment, and other necessary business-related communications.

Disclosure of Personal Information

If a customer (including a representative) requests the disclosure of their personal information or third-party disclosures of such information, our company will promptly respond after verifying and conducting an investigation in the manner specified by us. However, we may choose not to disclose all or part of the information if any of the following circumstances apply:

(1) There is a risk of harming the life, body, property, or other rights and interests of the individual or a third party.

(2) There is a significant risk of significantly hindering the proper execution of our company’s business.

(3) Disclosure would violate other laws and regulations. If our company decides not to disclose all or part of the requested personal information, if the personal information does not exist, or if disclosure according to the method requested by the customer is difficult, we will promptly notify the customer of such determination.

Suspension of Use of Personal Information

If a customer (including a representative) requests the suspension or deletion of the use of their personal information based on any of the following circumstances, our company will promptly respond after verifying and conducting an investigation in the manner specified by us. We will only suspend the use of personal information or take other actions if the grounds for such a request are recognized, and we will notify the customer accordingly:

(1) Personal information is being handled beyond the scope of the stated purpose of use without the individual’s consent, even when there are no grounds under Article 18, Paragraph 3 of the Personal Information Protection Act.

(2) Personal information is being used through methods that violate Article 19 of the Personal Information Protection Act, and there is a risk of promoting or inducing illegal or unfair activities.

(3) The personal information was obtained through fraudulent means.

(4) It is sensitive personal information obtained without the individual’s consent and without any grounds under Article 20, Paragraph 2 of the Personal Information Protection Act (as defined in Article 2, Paragraph 3 of the Personal Information Protection Act).

(5) Our company no longer requires the use of the customer’s personal information.

(6) Other grounds specified for requesting suspension of use or deletion under the Personal Information Protection Act.

Suspension of Third-Party Provision of Personal Information

If a customer (including a representative) requests the suspension of third-party provision (hereinafter referred to as “suspension of third-party provision”) on the grounds that their personal information has been provided to a third party without their consent, in violation of the provisions of Article 27, Paragraph 1 or Article 28 of the Personal Information Protection Act, our company will promptly respond after verifying and conducting an investigation in the manner specified by us. We will only suspend third-party provision if it is determined that there are legitimate grounds for the request in accordance with the law, and we will notify the customer accordingly.

Correction or Deletion of Personal Information

If a customer (including a representative) requests the correction or deletion of their personal information managed by our company on the grounds that the information is not accurate, our company will promptly respond after verifying and conducting an investigation in the manner specified by us.

Contact Information for Privacy Inquiries

For inquiries related to personal information protection, please contact us at the following email address: privacy@valueshift.co.jp

Handling of Information on Our Service Website

Our service website employs SSL (Secure Sockets Layer), an encryption technology, to secure communications by encrypting data, ensuring safety and security.

To provide you with a smooth experience on our service website, we utilize common technologies such as IP addresses and cookies. Cookies are used to record information when you access our service website, enabling a smoother experience during your next visit.

We may collect information about the device you are using (e.g., operating system, advertising ID, computer name, language settings). Furthermore, we may link this information to internal identifiers assigned by our company. These details are used to enhance our services, confirm your identity, and prevent unauthorized actions that may disrupt the provision of our services.

Moreover, we may refer to your cookie information to obtain access history and other data, linking it with the personal information we hold to utilize for marketing purposes, such as displaying behavior-targeted advertisements.

For the improvement and quality enhancement of our service website, we may use access analysis tools like Google Analytics. These tools use cookies for data collection. While the data collected by these tools does not include personal information, we may link the data collected through cookies with the personal information we hold to obtain information like your web page access history and use it for marketing purposes, such as displaying behavior-targeted advertisements.

※Cookies are a feature that records information about a user’s visit to a website on their computer. Cookies do not contain information that can identify individuals, such as names or email addresses.

※You can refuse the use of cookies by configuring your web browser settings. You can also set your web browser to allow cookies only for trusted websites. To smoothly use our website, we recommend configuring your settings to allow cookies for our website.

We strive to comply with relevant regulations and maintain a robust information security management system.

Effective Date: October 1, 2022