Established: May 1, 2020
Last amended: February 10, 2023

Aidemy, Inc. (hereinafter referred to as “we”, “our” or “us”) provides an e-learning platform “Aidemy Business” for DX human resource development with a focus on AI, “Modeloy”, a “project-support” service that provides comprehensive support from project planning to operation, and “Aidemy Premium”, an online programming school specializing in Python. We recognize that the protection of personal information of our customers, business partners, employees, and other related parties is an important responsibility. Therefore, based on our philosophy of personal information protection and the code of conduct we have established for ourselves, we are fully aware of our social mission and comply with laws and regulations regarding the protection of the rights of individuals and personal information. In addition, we hereby declare that we have established a personal information protection management system to realize the following policy, and that we will make company-wide efforts for its continuous improvement, always recognizing the latest trends in IT technology, changes in social demands, and changes in the business environment. We hereby declare that we will make company-wide efforts for its continuous improvement.

1.We will acquire, use, and provide personal information in an appropriate manner, and will not handle personal information beyond the scope necessary to achieve the specified purpose of use. We will also take measures to this end. 2
2. We shall comply with laws, national guidelines, and other norms regarding the handling of personal information.
3. We will continuously improve the security system of personal information by injecting management resources that match the actual conditions of our business in order to prevent the risk of leakage, loss, or damage of personal information by taking reasonable security measures. In the event of an emergency, we will promptly take corrective measures. 4.
4. We will respond promptly and sincerely to complaints and consultations regarding the handling of personal information.
5. The personal information protection management system will be reviewed and improved continuously in a timely and appropriate manner in light of changes in the environment and circumstances surrounding us.

ISHIKAWA Akihiko, Representative Director, President and CEO, Aidemy Inc.
The end of document.

【For inqurery:Aidemy Inc. Personal Information Consultation Desk】
Post Code: 100-0004
Otemachi One tower 6F, 1-2-1, Otemachi, Chiyoda City, Tokyo, Japan
Email: privacy[at]aidemy.co.jp
*Please refrain from sending specific e-mails

Aidemy, Inc. (hereinafter referred to as “we”, “our” or “us”) publicly announce that we use personal information only within the scope of the following purposes of use in accordance with Article 18, Paragraph (1) of the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as “APPI”). We obtain information relating to you from data management platforms operated by third parties, such as your web browsing history collected utilizing cookies and the results of analysis of that history, and use such information relating to you after associating it with your personal information held by us. However, if we are required by the APPI to obtain your consent (including consent from customers) to associate information relating to you with your personal information, we will associate information relating to you with your personal information only after obtaining your consent to this privacy policy in compliance with the APPI and related guidelines. The purposes of use of such information is “for establishing policies, contents, and methods for advertising activities, campaigns, explanations of services, etc.” as described in the “Purposes of Use of Personal Information (1) [1]; – For improving our services, developing new services, using for marketing and other sales activities; Applicable personal information; b.” below.

We may provide your personal data to third parties (excluding third parties in foreign countries) in the following cases:

(i) When we have obtained your consent in advance; or

(ii) In the situations stipulated in Article 27 of the Act on the Protection of Personal Information when we are not required to obtain your consent.

We may entrust the handling of personal information in whole or in part externally (including to contractors located in foreign countries) within the scope necessary to achieve the purpose of use stated above. We will supervise our contractor as necessary and appropriate in this case.

Purposes of use of personal information
（１）Purposes of use of your personal information contained in documents, etc. (hereinafter referred to as “documents”) directly provided by you (including via a website or email):

①Purposes of use of the personal information of our customers and persons who have contacted us:
・For providing our services and executing contracts, and performing services incidental thereto （Applicable personal information: Of the personal information we collect from our customers, names, email addresses, telephone numbers, residential addresses, card information, and attendance status）
・For providing customer support , such as providing responses to questions and comments concerning our services
（Applicable personal information: Of the personal information we collect from our customers, names, email addresses, telephone numbers, details of questions and comments, answers to questionnaires, and attendance status）
・For improving our services, developing new services, using for marketing and other sales activities
（Specifically, we intend to analyze the information we obtain, such as attendance status, and use the analyzed information
for distributing advertisements for new services based on customer tastes and preferences, and for distributing,
displaying and measuring the effectiveness of advertisements）
（Applicable personal information:
A. Of the personal information we collect from our customers, names, email addresses, telephone numbers, details of questions and comments, answers to questionnaires, and attendance status; and
B. Information relating to you that we obtain from data management platforms operated by third parties, such as your web browsing history collected utilizing cookies and the results of analysis of that history,
that is associated with your personal information held by us; The specific purposes of use of
such personal information are “For establishing policies, contents, and methods for advertising activities, campaigns, explanations of services, etc.”.）
・For improving features to enhance convenience for our customers
（Applicable personal information: Of the personal information we collect from our customers, names, email addresses, telephone numbers, details of questions and comments, answers to questionnaires, and attendance status）
・For creating statistical data by processing personal information into a format in which individuals cannot be identified and using such statistical data in order to promote innovation
（Applicable personal information: Of the personal information we collect from our customers, names, email addresses, telephone numbers, details of questions and comments, answers to questionnaires, and attendance status）
・For making responses, conducting researches and reporting as necessary for security purposes
（Applicable personal information: Of the personal information we collect from our customers, names, email addresses, telephone numbers, residential addresses, and card information）
・For handling an act which violates our rules, policies, etc., in relation to services we provide
（Applicable personal information: Of the personal information we collect from our customers, names, email addresses, telephone numbers, residential addresses, and card information）

②Other purposes of use of personal information
・he personal Information of our shareholders is used for communication, provision of various information, etc., shareholder management and performance of services related or incidental thereto.
（Applicable personal information: Of the personal information we collect from our individual shareholders, names and residential addresses）
・The personal Information of our employees is used for personnel and labor management, business management, health management, security management, etc.
（Applicable personal information: Basic information on our employees or other relevant persons such as names, identification numbers assigned to them (e.g. employee numbers), residential addresses, affiliation, and job titles; information on family members of our employees or other relevant persons such as names of family members and their dependency status; information on personnel management such as our employees’ or other relevant persons’ qualifications, transfers, performance reviews, awards, and disciplinary actions; information on salaries, bonuses, retirement allowances, corporate pensions, etc.; information on welfare such as utilization status of welfare services; information on health such as results of medical examinations; and any other information collected or held by us for the purposes of personnel management or business operations management）
・The Personal Identification Numbers of our employees and their dependent spouses are used for the purposes of use specified by laws.
（Applicable personal information: Personal Identification Number）
・Information on persons who submit applications for employment directly to us is used for conducting recruitment operations.
（Applicable personal information: Applicant names, email addresses, academic background, work experience, qualifications, and any other basic information on the applicants）

・For providing our AI-focused DX talent development service for corporations that we are contracted to provide, and improving the quality and features of the service
（Applicable personal information: Of the personal information we collect from our corporate customers, the names and email addresses of the persons who use our DX talent development service）
・Information on the personnel of partner companies is provided to the person or entity that contracts us to perform services so that such person or entity can confirm their skills.
（Applicable personal information: Job history, qualifications, and other information related to work）
・Information on applicants from public employment security offices and websites for private job placement services is used for conducting recruitment operations.
（Applicable personal information: Applicant names, email addresses, academic background, work experience, qualifications, and any other basic information on the applicants）

（３）Purposes of use of personal information collected by us and then provided to a third party by us
・For causing the third party to partially manage the personal information in the course of provision of our services
・For executing a use agreement in the event it is necessary to disclose the personal information
of a user of our services to a company other than one who is a party to the agreement based on an individual corporate use agreement for our services (in principle, with the prior consent of the user）
・For disclosing personal information as required by laws and regulations
・For protecting human life, body and property
・For public hygiene and raising healthy children
・For succession of business due to merger, business transfer, etc.
End

We handle your personal information appropriately in compliance with the APPI and this privacy policy. In addition, we implement the following security controls to prevent inappropriate handling of personal information, such as the use of personal information for purposes other than the uses specified in this privacy policy, and to ensure the security of the personal information and information systems which process personal information.

・We shall appoint a person in charge of handling personal information.
・We shall clarify the scope of personal information handled by ourselves and shall establish a system for reporting and communicating, to the person in charge appointed pursuant to the preceding provision, any fact or sign of any violation of the APPI, laws and regulations related to the APPI, and our internal rules on handling of personal information upon detection of such fact or sign.
・We shall periodically provide our employees with education on matters concerning the handling of personal information.
・We shall implement access controls to limit the scope of the personal information databases, etc. to be handled and the persons who handle them.”

The retained personal data (i.e. data for which we have authority to give notice of purposes of use, or data which we are authorized to disclose, correct, add, delete or erase, or data for which we have authority to suspend utilization or to cease provision to a third party) that we possess is as follows.

１．Name, affiliation and contact information of the manager concerning personal information Personal Information Protection Manager:Aidemy, Inc.Chairperson of the Information Management Committee
Email: privacy[at]aidemy.co.jp

２．Purposes of use of retained personal data

①Purposes of use of the personal information of our customers and persons who have contacted us:
・For providing our services and executing contracts, and performing services incidental thereto
・For providing customer support , such as providing responses to questions and comments concerning our services
・For improving our services, developing new services and using the retained personal data for marketing activities, etc.
・For improving features to enhance convenience for our customers
・For creating statistical data by processing the retained personal data into a format in which individuals cannot be identified and using such statistical data in order to promote innovation
・For making responses, conducting researches and reporting as necessary for security purposes

②Other purposes of use of personal information
・The personal Information of our shareholders is used for communication, provision of various information, etc., shareholder management and performance of services related or incidental thereto.
・The personal Information of our employees is used for personnel and labor management, business management, health management, security management, etc.
・The Personal Identification Numbers of our employees and their dependent spouses are used for the purposes of use specified by laws.
・Information on persons who submit applications for employment directly to us is used for conducting recruitment operations.

３．Contact information for filing complaints regarding retained personal data

If you have any questions or complaints regarding retained personal data, please contact the consultation counter below.

Personal Information Consultation Counter of Aidemy, Inc.
Post Code: 100-0004
Otemachi One tower 6F, 1-2-1, Otemachi, Chiyoda City, Tokyo, Japan
Email: privacy[at]aidemy.co.jp
*Please refrain from sending specific emails.

４．Information on the accredited personal information protection organizations in which we have membership

Currently, we do not have membership in any accredited personal information protection organizations.

You may request a “notification of purposes of use, disclosure, or correction, addition or deletion of the content, or suspension of utilization, erasure and suspension of provision to third parties” (hereinafter collectively referred to as “disclosure, etc.”) with respect to retained personal data. We will respond to requests for disclosure, etc. of personal information in accordance with the following procedures.

１．Receipt of requests for disclosure, etc.
（１）Please contact the consultation counter below. We will mail you the prescribed form. Upon receiving the form, please consent to the statement titled “Information on the handling of personal information” and either mail or bring the completed form to the following address.

Personal Information Consultation Counter of Aidemy, Inc.
Post Code: 100-0004
Otemachi One tower 6F, 1-2-1, Otemachi, Chiyoda City, Tokyo, JapanPost Code: 100-0004
Otemachi One tower 6F, 1-2-1, Otemachi, Chiyoda City, Tokyo, Japan
Email: privacy[at]aidemy.co.jp
*Please refrain from sending specific emails.

（２）For identification purposes, please mail or bring one of the following documents together with the prescribed form set forth in Paragraph
・A copy of your driver’s license, passport, or other official certificate that can be used for verifying your identity (shows the name and residential address of the person requesting disclosure, etc.)
・A copy of your certificate of residence (prepared within thirty (30) days prior to the date on which the request for disclosure, etc. is submitted)

（３）If an agent will perform the procedure, in addition to the prescribed form set forth in Paragraph (1) and the identity verification document set forth in Paragraph (2), mail or bring one of the documents set forth in Item A), and the document set forth in Item B):

A) Identity verification documents of the agent:
・A copy of a document certifying the agent, the agent’s driver’s license, passport, or other official certificate that can be used for verifying the identity of the agent (shows the name and residential address of the agent requesting disclosure, etc.)
・A copy of the certificate of residence of the agent (prepared within thirty (30) days prior to the date on which the request for disclosure, etc. is submitted)
・If the agent is an attorney-at-law, a document showing their registration number

B) A document certifying the authority of representation (power of attorney, etc.):
・If the registered domicile is clearly indicated on the document certifying the principal or the agent, it can be deleted.
・We will responsibly destroy the document certifying the principal or the agent within two (2) months after receipt.
２．Fee for a request for disclosure, etc. and method for collection of the fee

In the case of a request for notification of the purpose of use or disclosure, the following amount (including expenses incurred in our reply) will be charged per request. Enclose a fixed-amount postal money order for the following amount when mailing the request form.

・Fee amount: 1,000 yen (including tax)
３．Communication of the results of review

We will inform you of the results of our internal review by the following means without delay.

・In the case of notifying the purposes of use or disclosing personal information, we will mail or directly provide the relevant documents.
・In the case of correction, notification or deletion of the content, suspension of use, erasure and suspension of provision to third parties of personal information, we will reply by telephone or email.Documents will be sent to the principal by one of the following means as appropriate:。
・Mailing the reply document to the registered address of the principal
・Faxing the reply document to the registered fax number of the principal
・In the case of prohibition of provision: emailing the reply document to the registered email address of the principal
・Making a telephone call to the registered telephone number of the principal and responding orally
End

Purposes of use：The personal information obtained via the inquiry page of this website is for responding to your request (for consultation, answers to questions, estimates, etc.).

Personal information protection manager：Chairperson of the Information Management Committee of Aidemy, Inc.
Email: privacy[at]aidemy.co.jp

Voluntariness of information provision： Although registration of your personal information is optional when contacting us, please note that it is not possible for us to take the necessary actions if your name, your contact information and details of your inquiry are unknown.

We may use cookies to collect information on the customer’s browser type, operating system, language settings, IP address, number of accesses and other information on devices used, in order to improve customer convenience, to obtain statistical data, to provide appropriate advertisements, and to prevent or restrict certain types of cyber attacks, fraud and spam.

We appropriately manage personal information received from our customers and do not disclose the personal information to third parties unless:

(1)such disclosure is required under laws and regulations;
(2)such disclosure is required for the protection of human life, body or property and where it is difficult to obtain the consent of the principal;
(3)such disclosure is required for public hygiene and raising healthy children and where it is difficult to obtain the consent of the principal;
(4)the handling of personal data is contracted out, in whole or in part, to a third party to the extent necessary to achieve the purpose of use of the personal data;
(5)disclosure to a successor is required in connection with succession of business due to merger, business transfer, etc.; or
(6)we have obtained the consent to such disclosure from the principal.