PRIVACY POLICY

Article 1. Scope and basic policy

AINSEL Technology Corporation (株式会社エインセルテクノロジー; the “Company”) handles personal information in connection with its official website (https://www.ainsel.co.jp/; the “Website”), responses to inquiries, and business activities involving engineering support, primarily through SES (system engineering services), and business partnerships. We comply with Japan’s Act on the Protection of Personal Information and other applicable laws and guidelines, and handle such information appropriately in accordance with this Privacy Policy (the “Policy”).

“Personal information,” “personal data,” “retained personal data” and other statutory terms have the meanings defined in Japan’s Act on the Protection of Personal Information. Any purposes of use or handling conditions separately specified when information is collected also apply.

Article 2. Information collected and collection methods

Within the scope necessary to achieve our stated purposes, we appropriately collect the following information through contact forms, our dedicated skill sheet submission form, email, business discussions, and communications concerning contracts.

• Company, department and position; name; email address; telephone number; and other contact details.
• Details of inquiries and consultations, communication history, and records of our responses.
• Technical fields, work experience, qualifications, availability and other information needed to consider engineering support or partnerships. We receive skill sheets through a dedicated form or other method that we specify.
• Information associated with the Google account used to submit a skill sheet, such as name, email address and profile photo, together with submission and consent records.
• Contact person details, addresses, and contract and billing information needed to manage transactions and agreements.
• Communication and access information arising from use of the Website, including IP address, browser and operating environment, access time and pages viewed.

The information collected depends on the inquiry or transaction. Before obtaining special care-required personal information, we obtain the individual’s consent unless an exception under law applies. At the initial inquiry stage, please do not send Individual Numbers (My Numbers), identity documents, health information, other people’s personal information, client names, non-public project details or other confidential information unless we have instructed you to do so.

Article 3. Purposes of use

We use personal information to the extent necessary for the following purposes.

• Responding to inquiries, consultations and requests; contacting the individual; and maintaining response records.
• Responding to recruitment-related questions and consultations, confirming experience, learning activities and fields of interest, and making related contact.
• Confirming, proposing and coordinating work, required technologies and project stages, project start dates, availability and other conditions for SES and engineering support.
• Contacting potential partners, confirming experience and technical capabilities, considering partnerships, and coordinating conditions.
• Preparing quotations, entering into and performing agreements, billing, payments and other transaction administration.
• Maintaining and improving the Website, responding to problems, preventing unauthorized access or use, and ensuring information security.
• Responding to personal information requests, consultations and complaints, and fulfilling legal obligations.

Before providing a skill sheet or other material that identifies an individual to a business partner, we explain the recipient, information to be provided and purpose, and obtain the individual’s prior consent, unless an exception under law applies. Viewing the Website or making an inquiry alone does not constitute consent to disclosure to third parties.

We do not use contact details obtained through inquiries to send sales emails, newsletters, seminar announcements or other promotional emails separately from our response and necessary related communications.

If we change a purpose of use, the change will remain within a scope reasonably considered related to the original purpose, and we will notify the individual or make the change public. Use beyond that scope requires prior consent unless an exception under law applies.

Article 4. Contact forms and skill sheet submissions

The Website uses contact forms running on WordPress. Depending on the nature of your inquiry, you can use the following contact portals: CONTACT, CAREER INQUIRIES , PARTNERSHIP INQUIRIES , PRIVACY INQUIRIES .

Forms request your name, email address, inquiry type and message. Depending on the portal, they may also request your company or business name, telephone number, fields of interest, experience and learning activities, technical capabilities, project stages and industry experience. Each form identifies the information requested and whether it is required or optional.

Submissions are emailed to the responsible Company contact and handled for the purposes stated on the form and related purposes in Article 3, including responding to inquiries, considering partnerships, and handling personal information requests. The forms require confirmation of consent to the handling of personal information before submission.

The contact forms on this Website do not accept attachments. Please do not submit resumes, skill sheets, identity documents or other detailed materials with an initial inquiry. Where necessary, we will separately confirm the permitted sharing scope and submission method.

Skill sheet submissions: Google Forms and Google Drive

If we have invited you to submit a skill sheet, please use the SKILL SHEET FORM (Google Forms; Japanese, external site) . We use Google Forms’ file upload feature to store skill sheets in Google Drive managed by the Company. Before submitting, review the purposes of use and consent statements displayed on the form.

A Google account sign-in is required. The submission records the submitter’s name and affiliation, relationship to the individual, skill sheet, information associated with the Google account such as name, email address and profile photo, consent details, and submission date and time. Responses and files are handled through Company-managed accounts within the scope necessary for our work.

If you submit information on someone else’s behalf, explain the purposes of use, storage destination and this Policy to that individual, and confirm their consent and your authority to submit. Before providing information to clients or other recipients, we separately obtain or verify any necessary consent and maintain records as described in Articles 3 and 7. Submission through this form alone does not constitute consent to such disclosure.

Do not upload Individual Numbers (My Numbers), identity documents, health information, home addresses or other unnecessary personal information, or client or confidential information that you are not authorized to disclose. For information about Google’s handling of data, please also review the Google Privacy Policy (external site) and related information.

Preventing automated abuse: Cloudflare Turnstile

The Website uses Turnstile, provided by Cloudflare, Inc., to prevent automated abuse and spam. To distinguish human users from bots, Turnstile sends Cloudflare information such as IP address, browser information, technical communication characteristics and referring site information for assessment. Cloudflare also processes this information to detect and block bots and improve Turnstile’s detection capabilities.

For information about Turnstile’s data handling, please review the Cloudflare Turnstile Privacy Addendum (external site) and the Cloudflare Privacy Policy (external site) .

Article 5. Cookies and access information

The Website may use cookies and similar technologies for functions such as displaying content and retaining settings. Access information is handled within the purposes in Article 3, including Website maintenance and improvement, responding to problems, and preventing unauthorized access.

You can reject or delete cookies through your browser settings, although some functions may become unavailable. Where cookies or similar information can identify a particular individual when combined with other information, we handle it appropriately as personal information.

The Website uses the following external delivery services to display text and provide interface functions.

• Web font delivery (webfonts.xserver.jp): Delivery of font-related files used to display text on the Website.
• jsDelivr (cdn.jsdelivr.net): Delivery of JavaScript libraries and other files used for display and interaction.

When your browser loads files from these providers, information such as IP address and browser details may be sent to them. The information transmitted depends on browser settings, communications and other circumstances.

If we introduce external analytics, advertising or similar tools, we will provide necessary information appropriate to their actual use, including tool names, recipients, information transmitted, purposes and opt-out methods, and obtain any consent or take other steps required by law. Where personally referable information is provided to a third party and is expected to be acquired as personal data by the recipient, we will also verify the individual’s consent and take other steps required by law.

Article 6. Security measures and retention

To prevent leakage, loss or damage to personal data, we implement necessary and appropriate safeguards suited to the circumstances. These include assigning responsible personnel and reporting procedures, informing and supervising staff, managing devices and access rights, preventing unauthorized access, and supervising service providers. Upon request through the contact in Article 11, we will respond without delay regarding the details of our safeguards, except for information whose disclosure could hinder security.

Retention periods are determined with regard to purposes of use, contract performance, statutory retention obligations and the need to address disputes. Once personal data is no longer needed, we endeavor to erase it without delay, except where retention is required by law or other relevant circumstances apply.

If a leakage or similar incident occurs, we will investigate the facts, prevent further harm, identify the cause and take steps to prevent recurrence. Where required by law, we will report to the Personal Information Protection Commission or other relevant authority and notify affected individuals.

Article 7. Third-party disclosure and outsourcing

We do not provide personal data to a third party without the individual’s prior consent, except where permitted by law. Such exceptions include disclosure required by law or necessary to protect a person’s life, body or property where obtaining consent is difficult. We carry out verification and recordkeeping for third-party disclosures as required by law.

We may outsource all or part of personal data handling to external providers within the scope necessary to achieve our purposes of use. We select providers appropriately, establish handling requirements through contracts or other arrangements, and exercise necessary and appropriate supervision. Outsourcing and business succession that do not constitute third-party disclosure under law are also subject to applicable obligations concerning purposes of use and security.

Article 8. Overseas disclosure and joint use

When providing personal data to a third party in a foreign country, we follow the procedures permitted by Japan’s Act on the Protection of Personal Information. These may include obtaining consent after providing the necessary information in advance, or selecting a recipient with a system for continuously implementing equivalent measures. For disclosures based on such a system, we ensure continued implementation as required by law and provide necessary information upon the individual’s request. When personal data is handled overseas, we ascertain the relevant foreign legal framework and take necessary and appropriate safeguards.

Before jointly using personal data, we notify the individual or make readily available the fact of joint use, the data items, scope of joint users, purposes, and the name or entity name and address of the party responsible for management, together with the corporation’s representative’s name. Publication of this Policy alone does not constitute consent to any particular joint use or overseas disclosure.

Article 9. Requests concerning personal data

Subject to the requirements of Japan’s Act on the Protection of Personal Information, an individual or their representative may request notification of purposes of use; disclosure, correction, addition or deletion of retained personal data; suspension of use or erasure; cessation of third-party disclosure; and disclosure of third-party disclosure records.

Contact the office in Article 11 with the type of request, information concerned, your name and contact details. We will explain the necessary identity or representative authority checks and the steps leading to a response. We limit verification information to what is necessary for the request. If documents are required, we will first explain how to mask unnecessary numbers or details and submit them securely. You do not need to attach identity documents to your initial email.

Disclosure will be made by providing electronic records or another method requested by the individual. Where that method would involve substantial expense or other circumstances permitted by law apply, we may disclose in writing instead. If we do not fulfill a request or cannot use the requested disclosure method, we will notify the individual of the decision and reasons without delay, as required by law.

The fee for notification of purposes of use, disclosure of retained personal data, or disclosure of third-party disclosure records is JPY 3,000 per request. Before proceeding, we will explain the scope of the request, total fee and payment method. The fee covers administrative work such as investigation and verification, postage and other costs of notifying the result. It is non-refundable even if disclosure is refused or the requested information does not exist, because we still carry out notification and related work. This does not apply to incorrect or duplicate charges or other cases where a refund is legally required. This fee does not apply to requests for correction, addition, deletion, suspension of use, erasure or cessation of third-party disclosure.

Article 10. Changes to this Policy

We review this Policy as laws and handling practices change. Changes and their effective dates will be announced on the Website or by other means. Where an individual’s consent is legally required, we will obtain it separately. We do not use a Policy revision alone as a reason to use previously collected personal information beyond its original purposes.

Article 11. Company details and contact

For consultations, complaints, inquiries about safeguards, or requests concerning personal information, please contact the office below.

Personal information handling business operator

AINSEL Technology Corporation

Representative

小山陽平

Address

2F-C, Shibuya Dogenzaka Tokyu Building, 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan

Personal information contact

General Affairs Department — Personal Information Protection Officer

Contact form

PRIVACY INQUIRIES

Email address

privacy@ainsel.co.jp