This Privacy Policy sets forth the guidelines for the handling of personal information by Macromill CareNet Co., Ltd. (hereinafter referred to as “the Company”). The Company handles personal information in accordance with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”), other relevant laws, regulations, and guidelines, as well as this Policy.

If a privacy policy or terms of use are specified for each service operated or provided by the Company, such privacy policy or terms of use shall apply in addition to this Privacy Policy regarding the handling of personal information and the terms of use for the relevant service.

1. Personal Information Collected

We collect the following personal information to the extent necessary for the purposes described in “2. Purposes of Use of Personal Information” below.

1. (1) Shareholders

   Name, address, and information listed in the shareholder registry

2. (2) Business Partners and Customers

   Information provided to us by business partners, such as name, telephone number (including mobile phone and fax), email address, company or organization name, department and job title, workplace address, work history, and other contact information

3. (3) Applicants for Recruitment/Hiring and Employee Information (including former employees)

   Name, phone number (including mobile phone and fax), address, age, date of birth, email address, and other information listed on resumes or provided to the Company by job applicants through the Company’s websites or other channels

2. Purposes of Use of Personal Information

We will use personal information within the scope of the purposes listed below.

1. (1) Shareholder Information

   1. ① Exercise of shareholders’ rights and fulfillment of their obligations under the law
   2. ② Providing benefits from the Company in connection with shareholders’ status
   3. ③ Implementation of various measures to facilitate the relationship between shareholders and the Company
   4. ④ Management of shareholders, including the creation of shareholder data in accordance with prescribed standards under various laws and regulations

2. (2) Business Partner and Customer Information

   1. ① Negotiations, communications, consultations, deliberations, order placement and receipt, settlement, and other matters related to transactions
   2. ② Provision of services (including various consulting services) and performance of contracts based on transactions
   3. ③ Conducting and managing seminars, events, and other activities, as well as conducting surveys
   4. ④ Providing and communicating information regarding services, events, etc., offered by our company, our group companies, partner companies, and others
   5. ⑤ Analysis of service usage patterns (including advertising effectiveness measurement and AI-based analysis), as well as improvements to the user interface, product and support quality, and other service enhancements based on the analysis results, and the provision of information regarding the services of our company, our group companies, partner companies, etc.
   6. ⑥ Product development and improvement, and service enhancement (including the development and improvement of AI models)
   7. ⑦ Responding to inquiries and consultations

3. (3) Employee information (including information on former employees)

   A) During the recruitment screening process
   1. ① Providing recruitment information to job seekers (including those who wish to receive information regarding recruitment)
   2. ② Reviewing and deciding on hiring decisions, as well as notifying and communicating such decisions
   3. ③ Verification of application history
   B) After Joining the Company
   1. ① Conducting procedures such as payroll processing and social insurance processing
   2. ② Provision of employee benefits
   3. ③ Occupational safety and health management (health checkups, stress assessments, etc.)
   4. ④ Handling procedures related to hiring, onboarding, and resignation
   5. ⑤ Management of human resources and labor affairs
   6. ⑥ Carrying out tasks and procedures required by law, such as reporting on the employment status of foreign nationals
   7. ⑦ Confirmation of disability classifications required for applications for disability pensions and other benefits

In addition, the Company may use AI and other automated analysis tools to achieve the purposes of use listed above.
Furthermore, we will use personal information for tasks related to the matters listed above at our joint users as described in “6. Joint Use of Personal Information.”

3. Supervision of Contractors

The Company may outsource all or part of its personal information handling operations to external contractors. In such cases, the Company will select contractors that meet adequate standards for the protection of personal information, enter into outsourcing agreements regarding the protection of personal information, and thoroughly manage and supervise such contractors.

4. Security Measures for Personal Information

To prevent the leakage, loss, or damage of personal information we handle (including personal information we intend to collect; the same applies throughout this section), we will implement the necessary organizational, personnel, technical, and physical security measures and appropriately manage all personal information we handle.

5. Provision of Personal Information to Third Parties

The Company will not provide personal information to third parties except in any of the following cases:

1. ① When required by law
2. ② When it is necessary to protect a person’s life, body, or property, and it is difficult to obtain the individual’s consent
3. ③ When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the individual’s consent
4. ④ When it is necessary to cooperate with a national agency, a local government, or a party entrusted by such an entity in the performance of duties prescribed by laws and regulations, and obtaining the individual’s consent would likely hinder the performance of such duties
5. ⑤ When the recipient is an academic research institution or similar entity, and such recipient needs to handle the personal information provided by our company for academic research purposes (including cases where part of the purpose for handling such personal information is for academic research, excluding cases where there is a risk of unduly infringing on the rights and interests of individuals)

6. Joint Use of Personal Information

We may jointly use the personal information we have collected as follows.

Items of information to be jointly used	The information listed in “1. Personal Information Collected”
Scope of joint users	Our company, our parent company Macromill, Inc. (hereinafter referred to as “Macromill”), and Macromill’s group companies (meaning the companies listed on the Macromill website (https://www.macromill.com/en/company/group.html))
Purpose of Joint Use	The purposes of use specified in “2. Purposes of Use of Personal Information” of this Privacy Policy
Name and other details of the party responsible for managing the joint use	Our Company 11th Floor, Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo Shigeji Tokuda, President and CEO

7. Provision of Personal Information to Third Parties Located Overseas

The Company will not provide personal information to third parties located overseas, except in any of the following cases:

1. ① When providing personal information to a third party in a country specified by the Rules of the Personal Information Protection Commission as having a system for the protection of personal information that is recognized as being at a level equivalent to that of Japan in terms of protecting the rights and interests of individuals
2. ② When the recipient of the personal information has established a system that complies with the standards set forth in the Personal Information Protection Commission Regulations as necessary to continuously implement measures in accordance with the intent of Chapter 4, Section 2 of the Personal Information Protection Act, regarding the handling of said personal information by the recipient, through appropriate and reasonable means
3. ③ In other cases where disclosure is permitted under the Act on the Protection of Personal Information

Furthermore, in cases falling under item (2) above, the Company takes the necessary measures to ensure that the third party continues to implement appropriate measures.

8. Requests for Disclosure, etc., of Retained Personal Data

The Company will respond without delay to requests from the data subject or their representative regarding retained personal data, including requests for notification of the purpose of use, disclosure, correction, etc. (correction, addition, or deletion of content), suspension of use, etc. (suspension of use, erasure, and suspension of provision to third parties), and disclosure of records of provision to third parties (hereinafter collectively referred to as “Disclosure, etc.”). Please contact us here for details on the procedures for Disclosure, etc. and any applicable disclosure fees.

9. Use of Google Analytics

We use Google Analytics, provided by Google, to track user access to our website and to improve the website. Data collected through Google Analytics is managed by Google in accordance with its privacy policy.

Please visit the website below for information on Google Analytics, its Terms of Service, Google’s handling of collected information, and opt-out settings.

• ・Google Analytics Terms of Service
• ・Google Privacy Policy
• ・Google’s Use of Data When Users Use Google Partners’ Sites and Apps
• ・Google Analytics Opt-Out Add-on

When you use the websites or apps provided by our company, information about you—such as access logs and activity logs—may be sent from your device to our company or to third-party companies we have pre-approved. As a general rule, information collected by third-party companies is handled in accordance with the privacy policies of those third-party companies and under their responsibility. For details on the transmission of information to third-party companies, please see the following page.

Transmission of User Information to Third-Party Companies (PDF)

If you wish to stop us from collecting your browsing history using cookies, please click the opt-out button below. Please note that while your browsing history will no longer be collected after you opt out, you will need to set up the opt-out again if you change browsers or delete cookies. Please also be aware that opting out may prevent you from using some of the services we provide.

June 9, 2015 (Enacted)
July 1, 2026 (Last Revised)

Macromill CareNet Co., Ltd. (hereinafter referred to as “the Company”) handles personal information regarding individuals who participate in surveys conducted by the Company and related services (hereinafter referred to as “the Services”)—including by responding to questionnaires,participation in interview surveys, or use of applications provided by the Company (including cloud services and other services provided by third parties; hereinafter referred to as “the App”)—the Company hereby establishes the following Privacy Policy (hereinafter referred to as “this Policy”) regarding the handling of personal information of individuals who participate in such research activities (hereinafter referred to as “Survey Participants”).

Please review this Policy before using the Services and use them only after agreeing to its terms. If a privacy policy or terms of use are specified for any service operated by the Company, such privacy policy or terms of use shall apply in addition to this Policy regarding the handling of personal information and the terms of use for that specific service.

1. Compliance with Laws and Regulations

We will handle personal information regarding survey participants in accordance with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”), other relevant laws and regulations, guidelines, and this Policy. Please refer to our Personal Information Protection Policy for information regarding our representative and Personal Information Protection Officer.

2. Personal Information Collected

We will collect the following information regarding survey participants to the extent necessary for the purposes described in “3. Purposes of Use of Personal Information” below.

• ① Information Provided by Survey Participants
  • ・Name, address, date of birth, age, email address, and other information registered by the survey participants themselves
  • ・Survey response content (including information automatically entered based on the survey participant’s browser, system, or other mechanisms, as well as other information that the survey participant was able to recognize at the time of entry), statements made during interview surveys, scenes from the survey administration, and information regarding the survey participant obtained using measurement devices, etc.
  • ・In addition to the above, information voluntarily provided to us by survey participants when using this service
• ② Information provided by the party commissioning the research or other services (our client) or by third parties with whom we have a partnership
  • ・Information regarding research participants held by the commissioning party or third parties with whom we partner
• ③ Information automatically collected from the survey participant’s device
  • ・Device information collected via our applications (device ID, device identifiers, advertising identifiers, OS type and version, device settings, etc.), application operation logs, IP addresses, location information, and other such information
  • ・Information obtained via our website, such as online identifiers (advertising identifiers, cookie IDs, IP addresses, etc.), access logs, web ad exposure logs, user agents, device, browser, and interface information, and hashed information generated from these
• ④ Information collected in connection with ID linking with third-party services
  • ・Authentication information, such as IDs and email addresses, used by the subject of the survey on external services
  • ・Other information that the subject of the survey has authorized to be provided to us from external services
• ⑤ Collection of information publicly available online or offline
  • ・Publicly Available Information

3. Purposes of Use of Personal Information

We will use the personal information of survey participants to the extent necessary to achieve the following purposes (hereinafter collectively referred to as “Research and Related Purposes”).

• ① Provision of this Service
  • ・Selection of survey participants, survey requests, survey implementation, analysis, provision of results to clients (including provision on the premise that our direct clients will reshare the information with other clients), and other matters necessary for conducting research and related activities
  • ・Conducting data analysis activities (including the integration of collected information and the analysis, measurement, prediction, or profiling of survey participants’ (including individuals from whom clients provide personal information or personal-related information) hobbies, preferences, interests, attitudes, behaviors, locations, and other matters) and providing the analysis results to clients
  • ・Payment of compensation to survey participants and shipment of prizes, survey samples, and other items
  • ・Responding to and providing support for inquiries from survey participants, managing survey participants, etc.
  • ・Conducting campaigns or sweepstakes related to the operation of research, etc., and sending email newsletters, etc.
  • ・Prevention of fraudulent activities, as well as operation and maintenance
• ② Conducting marketing communications regarding our company’s or third parties’ products, services, etc.
  • ・Delivery of targeted advertisements
  • ・Expanded Ad Delivery (This refers to a method of identifying and targeting users similar to website visitors or purchasers of specific products or services, and includes delivery via push notifications, messages such as email or LINE, or direct mail . The same applies hereafter.) Please note that this method does not directly target survey respondents; even if survey respondents are included among the recipients, we will endeavor to ensure that they account for 1% or less of the total recipients.
  • ・Analyzing the marketing needs and challenges of our company, clients, contractors, and partners, and implementing marketing initiatives and communications in response
• ③ Development and improvement of our own or third-party products, services, etc.
• ④ Other matters incidental or related to the above

In addition, we may use AI and other automated analysis tools to achieve the purposes of use listed above.

Furthermore, we will use your personal information for operations related to the above matters at our joint users (defined in “7. Joint Use of Personal Information with Our Subsidiaries and Affiliates” below).

4. Supervision of Contractors

We may outsource all or part of our personal information handling operations to external parties. In such cases, we will select contractors that meet adequate standards for the protection of personal information, enter into contracts regarding the protection of personal information with them, and thoroughly manage and supervise them.

5. Management of Personal Information

To prevent the leakage, loss, or damage of personal information we handle (including personal information we intend to collect; the same applies throughout this section), as well as unauthorized access to such information, we will implement organizational, personnel, technical, and physical security measures to appropriately manage all personal information we handle.

6. Provision of Personal Information to Third Parties, etc.

• (1) We will manage the personal information we have acquired appropriately and will not provide such information to third parties without the prior consent of the individual, except in the following cases:

  • ① When required by law
  • ② When it is necessary to protect human life, physical safety, or property, and it is difficult to obtain the individual’s consent
  • ③ When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the individual
  • ④ When it is necessary to cooperate with a national agency, a local government, or a party entrusted by them in performing duties prescribed by laws and regulations, and obtaining the individual’s consent would hinder the performance of such duties
  • ⑤ When the recipient is an academic research institution or similar entity, and such recipient needs to handle the personal information provided by our company for academic research purposes (including cases where part of the purpose of handling such personal information is for academic research, excluding cases where there is a risk of unduly infringing on the rights and interests of individuals)
  • ⑥ When we outsource the handling of personal information, in whole or in part, to the extent necessary to achieve the purposes of use
  • ⑦ When personal information is provided in connection with a business succession resulting from a merger or other reasons
  • ⑧ In other cases specifically permitted by applicable laws and regulations

• (2) Notwithstanding the preceding paragraph, based on consent to this Privacy Policy, we may provide personal information (including re-disclosure from clients, etc., to third parties) to third parties such as clients, business partners, and other research firms (hereinafter referred to as “clients, etc.”) for the purposes listed below at such third parties

  • ① Research and other related purposes
  • ② To identify overlap between survey respondents and the client’s panels, members, or customers.
  • ③ To enable Clients, etc. to cross-reference information they hold regarding their own monitors, members, customers, etc., with information held by the Company regarding survey respondents

  * The personal information provided includes, but is not limited to, the information listed in “2. Personal Information Collected.”

  * The Company shall impose as a contractual condition that cooperating research firms or clients, etc., do not use personal information for any purposes other than those stated above.

• (3) Notwithstanding Paragraph 1, we may cross-reference information provided by clients, etc., in connection with a commissioned project with information held by us, provided that such cross-referencing is within the scope of the purposes of use.

• (4) With regard to personal information provided by us to third parties, the privacy policies and other relevant guidelines established by such third parties shall apply.

7. Joint Use of Personal Information with Our Subsidiaries and Affiliates

We may jointly use the personal information we have acquired as described below. We will strive to maintain strict information management when jointly using personal information.

Items of Information Subject to Joint Use	Information listed in “2. Personal Information Collected”
Scope of joint users	Our group companies (referring to the companies listed as group companies on this website (https://www.macromill.com/en/company/group.html))
Purpose of Joint Use	The purposes of use described in “3. Purposes of Use of Personal Information”
Name and Contact Information of the Person Responsible for Managing Joint Use:	Our Company (11th Floor, Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo) Shigeji Tokuda, President and CEO

8. Provision to Third Parties Located Overseas

• (1) The Company may provide personal information it has collected to a third party located in a foreign country (meaning a country or region outside the territory of Japan) in any of the following cases:

  • ① When providing personal information to a third party located in a foreign country (as defined by the Personal Information Protection Commission Regulations; this includes countries within the EEA and the United Kingdom) that is recognized as having a system for the protection of personal information equivalent to that of Japan in terms of protecting the rights and interests of individuals;
  • ② When appropriate and reasonable measures are in place between the Company and the recipient of the personal data to ensure that the recipient handles such personal data in accordance with the intent of applicable laws and regulations
  • ③ When the recipient of the personal data has been certified under an international framework governing the handling of personal information
  • ④ When any of the grounds listed in “6. Provision of Personal Information to Third Parties, etc.” applies
  • ⑤ When we have obtained the data subject’s consent to provide personal information to a third party located abroad

• (2) Regarding the name of the foreign country to which the data is provided, since we will determine which country the third party is located in on a case-by-case basis, we cannot specify the name of the foreign country at the time you agree to this Policy. Please note that information regarding personal information protection systems in various countries is published on the Personal Information Protection Commission’s website (https://www.ppc.go.jp/enforcement/infoprovision/laws/); please refer to it.

• (3) Regarding the measures taken by third parties in foreign countries to protect personal information, since we will determine to which third parties to provide such information on a case-by-case basis, we are unable to provide information regarding these measures at the time you agree to this Policy. However, we will endeavor to enter into agreements with third parties in foreign countries that include provisions regarding the protection of personal information.

9. Requests for Disclosure, etc., of Retained Personal Data

With regard to retained personal data, we will respond without delay to requests from the individual to whom the retained personal data pertains or their agent for notification of the purpose of use, disclosure, correction, etc. (correction, addition, or deletion of content), suspension of use, etc. (suspension of use, erasure, and suspension of provision to third parties), and disclosure of records of provision to third parties (hereinafter collectively referred to as “disclosure, etc.”). Please contact us here when making a request.

10. Regarding Personal-Related Information

When we provide personal-related information held by our company to a third party, and it is anticipated that such third party will acquire the personal-related information as personal data, we will confirm that the third party has obtained the consent of the individual concerned regarding the acquisition of the information as personal data, except in cases falling under any of the grounds listed in (1) items (i) and (v) of “6. Provision of Personal Information to Third Parties, etc.” Furthermore, if the third party is located overseas, we will confirm that, prior to the third party obtaining consent, information intended to serve as a reference for the individual has been provided in accordance with applicable laws and regulations.

Item	Details
Content of Location Information	① GPS location information for this device [Detailed Items] ⚫︎Latitude and Longitude* Depends on GPS accuracy ⚫︎Date and Time of Measurement ⚫︎Date and time of transmission ⚫︎Advertising identifier ⚫︎Device Information ⚫︎GPS Accuracy (Margin of Error) ⚫︎Name of Measurement App ② Beacon Information Related to This Device [Detailed Items] ⚫︎Information on Beacon Devices Encountered ⚫︎Measurement Date and Time (for each entry into and exit from the area) ⚫︎Date and time of transmission ⚫︎Advertising identifier ⚫︎Device Information ⚫︎Beacon Signal Strength ⚫︎Distance from Beacon ⚫︎Name of Measurement App *Measurements depend on the condition of this device and signal strength.
Purpose of Use	⚫︎To analyze and aggregate this location data to generate statistical outputs (including cases where it is linked with other information held by our company) ⚫︎To select survey respondents for questionnaires using this location information ⚫︎To provide this location information to our customers or other third parties ⚫︎To develop and improve products and services provided by us, our customers, our partners, and others
Provision of Information from Us to Third Parties	⚫︎We may provide this location information to our customers or other third parties after processing it appropriately, such as by converting it into a grid format. However, this location information does not include any information (such as names, detailed addresses, phone numbers, or email addresses) that can directly identify a specific individual based solely on that information, without cross-referencing it with other information.
Benefits for Survey Participants in Providing This Location Information to Us	⚫︎You will have the opportunity to be selected as a survey participant for research and other studies conducted by us that utilize location information. However, since the selection of survey participants is conducted by lottery or similar means from among those who meet the eligibility criteria, we cannot guarantee that you will definitely be able to participate in research or other studies utilizing location information.

June 9, 2015 (Enacted)
July 1, 2026 (Last Revised)

The English version of the Privacy Policy has been translated using machine translation; please refer to the Japanese Privacy Policy for the correct content.