Privacy Policy

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Protection of Personal Information

Under our mission of "We contribute to society by generating opportunities for people around the world to engage in dialogue," the Company and its Group engage in business including the provision of coaching programs and consulting services, as well as the development of other communication tools. We have formulated this Policy as follows to appropriately manage and protect the personal information provided by you in the course of our business and will handle such information in a responsible manner so that we meet the trust you place in us by providing us with your information.

1. We will identify the purposes of use of personal information to the extent possible and handle such information appropriately within the scope necessary to achieve such purposes. In addition, we will take measures to prevent the use of such information for unintended purposes.
2. We will obtain personal information using lawful and proper methods.
3. We will not provide personal information to any third party without the consent of the data subject.
4. We will comply with the laws and regulations, etc. and will set forth internal regulations concerning the protection of personal information and review them on a continuous basis. In addition, we will provide education for officers and employees, etc. on a continuous basis to ensure that these rules, etc. are thoroughly understood and enforced among them.
5. We will use appropriate safeguards in order to configure and manage appropriate access permissions for personal information, prevent unauthorized external access, and prevent divulgence, damage, or falsification, etc. of personal information.
6. We will provide a contact desk to accept complaints and consultations concerning personal information and strive to respond to such complaints and consultations in a prompt and appropriate manner.

Junji Kouketsu, Chief Executive Officer
COACH A Co., Ltd.

(Established on July 1, 2008)
(Revised on November 1, 2019)
(Revised on November 11, 2022)

Guidelines for Protection of Personal Information

COACH A Co., Ltd. (the "Company") will manage and handle personal information provided by you with the utmost care.

１．Purposes of Use of Personal Information
The purposes of use of personal information are as described below:

1. Personal information concerning coaching program participants (trainees)
   - Registration in and implementation of coaching programs based on agreements with trainees or their companies, etc.;
   - Communications necessary for the operation of coaching programs;
   - Development and improvement of goods and services concerning coaching and other businesses;
   - Research, study and analysis concerning coaching and other related fields; and
   - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
2. Personal information concerning people who have an association with coaching program participants (stakeholders)
   - Implementation of coaching programs based on agreements with trainees' companies, etc.;
   - Communications necessary for the operation of coaching programs;
   - Development and improvement of goods and services concerning coaching and other businesses; and
   - Research, study and analysis concerning coaching and other related fields.
3. Personal information of persons in charge at the coaching program secretariat department
   - Communications necessary for the operation of coaching programs; and
   - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
4. Personal information of participants in various seminars, as well as users of goods and services related to coaching programs
   - Registration in and necessary communications for seminars, as well as provision of goods and services related to coaching programs;
   - Development and improvement of goods and services concerning coaching and other businesses;
   - Research, study and analysis concerning coaching and other related fields; and
   - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
5. Personal information of outsourced coaches
   - Performance of obligations and exercise of rights concerning outsourced services;
   - Communications necessary for the operation of coaching programs;
   - Development and improvement of goods and services concerning coaching and other businesses;
   - Research, study and analysis concerning coaching and other related fields; and
   - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
6. Personal information concerning employees and officers of business partners other than those listed in items (i) through (v) above
   - Performance of obligations and exercise of rights concerning transactions;
   - Collection and communication, etc. of information necessary for business; and
   - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
7. Personal information concerning those who submitted inquiries or consultations, etc.
   - Appropriate handling of inquiries and consultations, etc.; and
   - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
8. Personal information concerning shareholders
   - Exercise of rights and performance of obligations under the Companies Act;
   - Sending and communication of year-end business reports and other distributions;
   - Shareholder management such as creation of shareholder data pursuant to prescribed criteria based on various laws and regulations; and
   - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
9. Personal information concerning job applicants;
   - Screening for employment;
   - Management of prospective recruits;
   - Consideration of more effective recruitment activities; and
   - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
10. Personal information concerning internship applicants
    - Screening for employment and labor management for open internship positions;
    - Recruitment activities (including guidance on screening for employment);
    - Consideration of more effective operation of the internship system; and
    - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
11. Personal information concerning resigned employees;
    - Communications necessary for business;
    - Provision of information concerning the Company's status; and
    - Distribution of email newsletters and other information on coaching and the Company's services, as well as announcement of events and seminars, etc.
12. Personal information concerning subjects recorded by security cameras located within the Company's facilities
    - Prevention of crimes and maintenance of security within the facilities.

2. Provision or Joint Use of Personal Information To/With Third Parties
The Company will not provide personal information it has obtained to any third party without the prior consent of the data subject (excluding cases where such provision is required by the laws and regulations); provided, however, that the Company will use the personal data of data subjects jointly with third parties to achieve the purposes of use listed in Section 1 above to the following extent:

1. Data items jointly used
   All personal data of the data subject, excluding cases where the data subject has specifically requested otherwise
2. Scope of entities which use data jointly
   COACH A Co., Ltd. and its affiliated companies
3. Purposes of use for entities which use data jointly
   Same as Section 1 above.
4. Name of person responsible for managing such personal data
   COACH A Co., Ltd.

３．Entrustment of Personal Information Handling
The Company may entrust the handling of personal information to external parties within the scope necessary for achieving the purposes of use. In this case, the Company will select an entrustee which agrees to handle personal information appropriately, require the selected entrustee to handle personal information appropriately by executing an agreement, etc., and confirm the status thereof on a regular basis.

４．Handling of Requests for Disclosure and Correction, etc. of Personal Information
If data subjects themselves have an account for the coaching program My Page or other websites, they may check or correct the details of information by visiting such account. If such account is not available to data subjects, the Company will handle any requests concerning their own personal information made by data subjects, etc. for notification of the purposes of use; disclosure; correction, addition or deletion; cessation of use; erasure; and cessation of provision to third parties; upon confirming that the requesting party is the data subject, unless there are reasonable grounds for not doing so. You may submit your request here.

５．Handling of Inquiries and Complaints, etc. Concerning Personal Information
Inquiries and complaints, etc. concerning the handling of personal information can be made to the following:
- Company name: COACH A Co., Ltd.
- Management officer and contact person for inquiries: Personal information protection and management officer
- Tel.: +81-3-3237-8050
- Email address: privacy@coacha.com

６．Cookies
The Company's website may use cookies to enable the more efficient use of the website or to improve the usability of the Company's website by improving and enhancing the services provided to you through such website. In addition, the Company may use cookies to analyze the interests of users based on their browsing history and combine and link such information with personal information of the user, such as email address, to distribute email newsletters and other information and announce events and seminars, etc., only if the user has provided consent through separate terms of use, etc.
In addition, the Company obtains statistical information on website usage from third-party companies using cookies and/or web beacons and distributes ads via third-party companies, as described below, to conduct user access analysis and optimal ad distribution. Individuals will never be identified based on cookie information used for access analysis and ad distribution involving third-party companies.

1. Analysis of access to the Company's website
   The Company uses the following tools for website access analysis and ad serving:
   - Google Analytics, Google Ads, Google Optimize
   Provider: Google
   Privacy Policy
   - Pardot
   Provider: Salesforce.com Co., Ltd.
   Privacy Policy
2. Online ad remarketing
   The Company uses the following tools for online ad remarketing:
   - Yahoo! Japan Display Ad Network (YDN)
   Provider: Yahoo Japan Corporation
   Privacy Policy
   - Facebook Ad
   Provider: Facebook, Inc.
   Privacy Policy

Procedures Concerning Requests for Disclosure, etc. of Personal Information Subject to Disclosure

1. Personal Information Subject to Disclosure and Purposes of Use
The Company handles requests for notification of the purposes of use; disclosure; correction, addition, or deletion; cessation of use; erasure; and cessation of provision to third parties (collectively, "Requests for Disclosure") made by the data subject of the personal information subject to disclosure(*) or his/her agent. (*) "Personal information subject to disclosure" (personal data in possession) means searchable personal information possessed by the Company for more than six (6) months after obtaining the same or planned to be possessed by the Company, and for which the Company has all the authorizations necessary to conduct the above procedures in response to any Request for Disclosure by the data subject (or his/her agent).

◆ Purposes of use of personal information subject to disclosure
The Company will use all personal information subject to disclosure within the scope described in "1. Purposes of Use of Personal Information" in the "Guidelines for Protection of Personal Information." You are advised to read the above section if you wish to receive the notification of the purposes of use.

Please follow the procedures in Section 2 below if you are unable to confirm the purposes of use in the said section or if the coaching program My Page or any other account is not available to you and you wish to make a Request for Disclosure

2. Procedures for Requests for Disclosure
The procedures necessary for making Requests for Disclosure concerning personal information subject to disclosure are as described below:

1. Where to submit requests and required documents
   Please send your request to the following address, together with the required documents, via registered mail (delivery certification requested).
   [Where to submit]
   Italian Cultural Institute Bldg. 10F 2-1-30 Kudan-Minami, Chiyoda-ku, Tokyo 102-0074
   Attn.: Personal information protection and management officer, COACH A Co., Ltd.
   [Documents required]
   (i) "Disclosure Request Form"
   (ii) "Identity verification documents" *See item (2) below. Documents in item (4) below are also required if an agent is making the request.
2. Identity verification documents
   Please submit a copy of any one of the following identity verification documents. (Please black out any section in the copy where your domicile of origin is stated.)
   - Driver's license, health insurance card, basic resident registration card, pension handbook, alien registration certificate, or passport
3. Fees
   Please enclose the fee of 600 yen (in the form of a stamp or fixed-amount postal money order) per request, only if the request you are making is for "notification of the purposes of use" or "disclosure." Please be advised that this fee will not be returned even if the Company determines that the Request for Disclosure cannot be accepted.
4. Requests for Disclosure by agents
   If the data subject entrusts an agent to make a Request for Disclosure, the agent needs to submit the documents in subitems (iii) and (iv) below, in addition to the identity verification document in item (2) above.
   (iii) Documents to confirm the proxy authority
   Power of Attorney (registered seal affixed) and certificate of registered seal (of both the data subject and the agent)
   (iv) Identity verification document of the agent
   Any one of the identity verification documents of the agent listed in Section (2) above

1. Cases where requests for notification of purposes of use or disclosure are not accepted No notification or disclosure will be made in the cases below. If the Company decides not to make a notification or disclosure, the Company will notify you to that effect. In addition, please be advised in advance that, even if the notification or disclosure is not made, the Company will use the prescribed fees for the stamp to mail you the notice of not making notification or disclosure.
   1. Cases where identity cannot be verified due to, for example, the address stated in the certificate of registered seal and the address registered with the Company not matching;
   2. Cases where the proxy authority of the agent making a request cannot be confirmed;
   3. Cases where a Request for Disclosure is made for personal information which is not subject to disclosure;
   4. Cases where rights or legitimate interests of the Company may be harmed if notification of the purposes of use is made;
   5. Cases where the proper operation of the Company's business may be significantly hindered if the disclosure is made;
   6. Cases where life, body, property, or any other rights or interests of the data subject or any third party may be harmed;
   7. Cases where the disclosure violates other laws and regulations; or
   8. Cases otherwise provided for in the Act on the Protection of Personal Information, etc.
2. Cases where requests for correction, addition, deletion; cessation of use; erasure; or cessation of provision to third parties are not accepted
   The Company may not accept requests in the following situations. In this case, the Company will notify you to that effect.
   1. Cases where identity cannot be verified due to, for example, the address stated in the certificate of registered seal and the address registered with the Company not matching;
   2. Cases where the proxy authority of the agent making a request cannot be confirmed;
   3. Cases where a request is made for personal information which is not subject to disclosure;
   4. Cases where provision to a third party is carried out without violating the Act on the Protection of Personal Information; or
   5. Cases otherwise provided for in the Act on the Protection of Personal Information, etc.

Efforts to protect personal information

* PrivacyMark is a mark which indicates that an entity is a private business operator which has established a system where appropriate measures to protect personal information are being taken, and is granted and authorized by JIPDEC to be used by such entity upon screening and certification.