Privacy Policy

Privacy Policy Overview

Last Updated: May 15, 2024

TOHO International Co., Ltd. (hereinafter referred to as "the Company") places great importance on the protection of your personal information and is committed to safeguarding it. This Privacy Policy explains how the Company collects, uses, discloses, stores, and protects your personal information, as well as the rights you hold with respect to your personal information.

This Privacy Policy has been prepared in accordance with Japan's Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter "APPI") and related laws and regulations, and applies to the TenZai AI products and services provided by the Company. Please read this Privacy Policy carefully and in its entirety before using our products or services.

1. Types of Personal Information We Collect

The Company collects the following types of personal information:

• Basic Information: When you register an account or use our services, we collect information such as your name, email address, telephone number, company name, and job title.
• Account Information: Your account login credentials (such as your username and encrypted password), account settings, and preferences.
• Financial Information: If you use our paid services, we collect the payment information and transaction records necessary to process your payments.
• Usage Data: We collect information about how you use our services, including access dates and times, features used, clicks, and browsing activity.
• Device Information: This includes technical information such as your IP address, browser type and version, device type, and operating system.
• Customer Support Information: We collect information you provide when interacting with our customer support team.

2. How We Collect Personal Information

The Company collects personal information in the following ways:

• When you provide information directly to us (such as by completing forms, registering an account, or contacting customer service);
• Information collected automatically when you use our services (such as logs, cookies, and similar technologies);
• Information obtained from third parties (such as business partners and service providers, subject to compliance with applicable laws and regulations).

3. Purposes for Using Personal Information

In accordance with the provisions of Japan's Act on the Protection of Personal Information, the purposes for which the Company collects and uses your personal information include, but are not limited to, the following:

• Providing, maintaining, and improving our products and services;
• Creating and managing your account;
• Processing your transactions and payments;
• Providing customer support and responding to your inquiries;
• Sending technical notices, updates, security alerts, and support information;
• Sending marketing and promotional communications where you have given your consent;
• Detecting, preventing, and resolving technical issues, security problems, or fraudulent activity;
• Complying with applicable legal requirements.

The Company will use your personal information only to the extent necessary to fulfil the purposes for which it was collected. We will not use your personal information for any other purpose unless we have obtained your consent or as permitted by applicable law.

4. Sharing and Disclosure of Personal Information

The Company may share your personal information in the following circumstances:

• Service Providers: We may share your personal information with third-party service providers that assist us in delivering our services (such as providers of cloud storage, payment processing, and data analytics). These third parties may only process your personal information in accordance with our instructions, and they are contractually obligated to protect your personal information.
• Business Partners: Where you use our services through one of our business partners, we may share information necessary for that partner to provide services to you.
• Legal Requirements: We may disclose your personal information where we are required to do so by law, court order, governmental authority request, or other legal process.
• Protection of Rights: We may disclose your personal information where we reasonably determine that such disclosure is necessary to protect the rights, property, or safety of the Company, you, or others.
• Business Transfers: If the Company is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your personal information may be transferred as part of the business assets.

In all cases, the Company requires recipients to implement appropriate confidentiality and security measures to protect your personal information.

5. International Data Transfers

While our servers are primarily located within Japan, we may transfer your personal information to servers or storage facilities outside Japan in order to provide better services. In such cases, the Company will comply with the provisions of Japan's Act on the Protection of Personal Information regarding international data transfers and will ensure that recipients provide an adequate level of protection.

Prior to making any international data transfer, the Company will, in accordance with the Act on the Protection of Personal Information:

• Confirm that the recipient is located in a country or region recognised by the Personal Information Protection Commission of Japan as providing an equivalent level of protection; or
• Confirm that the recipient has implemented protective measures that meet the standards established by the Personal Information Protection Commission of Japan; or
• Obtain your explicit consent for the specific international data transfer in question.

6. Data Retention

The Company retains your personal information for as long as is necessary to fulfil the purposes for which it was collected, or for such period as is required by applicable law.

When the Company no longer needs to retain your personal information, it will securely delete or anonymise such information.

7. Your Rights

Under Japan's Act on the Protection of Personal Information, you have the following rights with respect to your personal information:

• Right of Access: You have the right to inquire whether the Company holds your personal information and to obtain a copy of such information.
• Right of Correction: If you believe that any personal information the Company holds about you is inaccurate or incomplete, you have the right to request that we correct or supplement such information.
• Right of Erasure: In certain circumstances (such as where the Company no longer needs your personal information to fulfil the purposes for which it was collected, or where you withdraw your consent), you have the right to request that we delete your personal information.
• Right to Restriction of Processing: In certain circumstances (such as where you contest the accuracy of your personal information), you have the right to request that the Company suspend the processing of your personal information.
• Right to Object: Based on your particular circumstances, you have the right to object to the processing of your personal information that the Company carries out in pursuit of its legitimate interests.
• Right to Data Portability: Where technically feasible, you have the right to receive the personal information you have provided to the Company in a structured, commonly used, and machine-readable format, and to transfer such information to another data controller.
• Right to Withdraw Consent: Where the Company processes your personal information on the basis of your consent, you have the right to withdraw that consent at any time.

If you wish to exercise any of the above rights, please contact us using the contact details provided at the end of this Privacy Policy.

8. Data Security

The Company takes the security of your personal information seriously and implements appropriate technical and organisational measures to protect your personal information from unauthorised access, use, or disclosure. These measures include, but are not limited to:

• Using encryption technology to protect data during transmission and storage;
• Implementing access controls to ensure that only authorised personnel can access personal information;
• Conducting regular security assessments and vulnerability testing;
• Providing employees with data protection and security awareness training;
• Entering into data protection agreements with third-party service providers.

Please note that, notwithstanding these measures, no data transmission over the internet can be guaranteed to be 100% secure. Accordingly, the Company cannot provide an absolute guarantee of the security of personal information that you transmit to us via the internet.

9. Cookies and Similar Technologies

The Company uses cookies and similar technologies to collect and use information about you. Cookies are small text files stored on your device that are used to remember your preferences, improve the user experience, and analyse website usage.

The types of cookies we use include the following:

• Essential Cookies: These cookies are necessary for the basic functioning of the website, such as logging in and submitting forms.
• Preference Cookies: These cookies enable the website to remember your preferences, such as your language selection and regional settings.
• Statistical Cookies: These cookies help us understand how visitors interact with the website by collecting and reporting information about website usage.
• Marketing Cookies: These cookies are used to track visitors' browsing behaviour on the website for the purpose of delivering relevant advertisements or marketing content.

You can control and delete cookies through your browser settings. Please note that if you choose to disable certain cookies, this may affect your ability to use certain features of our website.

10. Children's Privacy

Our services are not directed at children under the age of 16. The Company does not knowingly collect personal information from children under the age of 16. If you are a parent or guardian and believe that your child has provided personal information to us, please contact us immediately. The Company will take the necessary steps to delete such information from our systems.

11. Updates to This Privacy Policy

The Company may update this Privacy Policy from time to time to reflect changes in our practices or in applicable legal requirements. The updated Privacy Policy will be posted on our website, with the date of the most recent update indicated at the top of the page.

For material changes, we will notify you by posting a notice on our website or by contacting you directly by email. We recommend that you review this Privacy Policy periodically to stay informed about how the Company protects your personal information.

12. Contact Us

If you have any questions, comments, or requests regarding this Privacy Policy, or if you wish to exercise your data protection rights, please contact us using the following details:

The Company will respond to your request within a reasonable period of time, ordinarily within 30 days of receipt. If, due to exceptional circumstances, additional time is required to process your request, we will notify you of the reason and the expected response time.

13. Personal Information Protection Commission

If you have a complaint about how the Company handles your personal information, you have the right to lodge a complaint with the Personal Information Protection Commission (PPC).

However, before contacting the supervisory authority, we encourage you to contact the Company first in order to give us the opportunity to address your concerns.