Privacy Policy

Article 1 (Business Name, Address, and Representative)

Business Name

Sekigin LLC

Address

5-32-12 Shiba, Minato-ku, Tokyo 108-0014, Japan

Representative

Representative Member: Tatsuya Tanaka

Related Entity

UK Entity: ELT SCHOOL OF ENGLISH LIMITED. Address: 35 Ballards Lane, London, N3 1XW, United Kingdom

Article 2 (Definition of Personal Information)

"Personal information" in this Policy refers to "personal information" as defined in Article 2, Paragraph 1 of the Personal Information Protection Act, and includes name, date of birth, address, phone number, email address, employer information, account information for Zoom and other online meeting services, information related to lessons and counseling, and other information that can identify a specific individual (including information that can identify a specific individual by easily cross-referencing with other information).

Article 3 (Methods of Acquiring Personal Information)

The Company acquires personal information through lawful and fair means, including the following methods:

• Input into various forms on this Site (inquiry forms, document request forms, application forms, etc.)
• Information provided through email, telephone, online meeting systems, chat tools, etc.
• Information acquired through the Company's instructors and advisors during the provision of lessons, counseling, interviews, recruitment services, etc.

The Company will not acquire personal information through deception or other improper means.

Article 4 (Purpose of Use)

The Company uses acquired personal information within the scope necessary to achieve the following purposes:

The purpose of use may be changed within a reasonably related scope. In such cases, the Company will publish the changed purpose on this Site or notify the individual in accordance with applicable laws.

Article 5 (Provision of Personal Data to Third Parties)

The Company will not provide personal data to third parties without prior consent of the individual, except in the following cases:

• When required by law
• When necessary to protect life, body, or property of a person, and it is difficult to obtain the individual's consent
• When particularly necessary for improving public health or promoting the sound development of children, and it is difficult to obtain the individual's consent
• When it is necessary to cooperate with a national agency, local government, or an entity entrusted by them in executing affairs prescribed by law, and obtaining the individual's consent may impede the execution of such affairs
• When personal data is provided in connection with business succession due to merger, company split, business transfer, or other reasons, and the data will be handled within the scope of purposes before the succession

Notwithstanding the above, the Company may provide personal data in the following cases that do not constitute "provision to third parties" under the Personal Information Protection Act:

• When the Company entrusts all or part of the handling of personal data to the extent necessary to achieve the purposes of use
• When jointly using personal data in accordance with Article 7 (Joint Use)
• When it does not constitute provision to third parties under the Personal Information Protection Act or other laws

Article 6 (Entrustment of Personal Data Handling)

The Company may entrust the handling of personal data to system operators, payment processors, email distribution services, cloud service providers, instructors, advisors, etc. to the extent necessary for providing the Services. In such cases, the Company conducts sufficient verification in selecting contractors, concludes appropriate contracts, and supervises in accordance with the Personal Information Protection Act.

Article 7 (Joint Use)

The Company may jointly use personal data as follows:

1. Scope of Joint Users

Sekigin LLC ELT SCHOOL OF ENGLISH LIMITED. (UK Entity)

2. Items of Personal Data Jointly Used

Name, contact information (address, phone number, email address, etc.) History of lessons, training, counseling, grades, and evaluation information Contract details, payment status, etc.

3. Purpose of Joint Use

To provide, operate, and improve the quality of the Services To provide lessons and support through instructors and staff including overseas locations

4. Entity Responsible for Joint Use Management

Sekigin LLC

Article 8 (Provision of Personal Data to Third Parties in Foreign Countries)

1. The Company may provide personal data to third parties located in foreign countries, including the UK Entity, or store personal data in foreign countries for providing the Services, system operation, cloud service use, etc.
2. The Company strives to ensure appropriate security management measures by understanding the personal information protection systems in such foreign countries and the handling of personal data by such third parties, and by establishing necessary contracts and systems in accordance with the Personal Information Protection Act and related guidelines.
3. When consent is required by law, the Company will provide necessary information including the above and obtain the individual's consent before providing data.

Article 9 (Security Management Measures)

The Company implements necessary and appropriate security management measures to prevent leakage, loss, or damage of personal data, including the following:

• Organizational security measures (development of personal information handling regulations, appointment of responsible persons, inspection and auditing of handling status, etc.)
• Human security measures (employee education and training, confidentiality agreements, etc.)
• Physical security measures (access control, locked storage of documents and media, etc.)
• Technical security measures (access control, authentication and password management, encryption, log management, etc.)

When handling personal data in foreign countries, the Company implements appropriate security management measures considering the systems of such countries.

Article 10 (Requests for Disclosure, etc. of Retained Personal Data)

When the individual makes the following requests regarding retained personal data, the Company will respond without delay in accordance with the Personal Information Protection Act:

• Notification of purpose of use
• Disclosure (including disclosure of third-party provision records)
• Correction, addition, or deletion of content
• Suspension or erasure of use
• Suspension of provision to third parties

1. When making such requests, the individual may be asked to follow the Company's prescribed procedures and present documents to verify identity.
2. A fee equivalent to actual costs may be charged for disclosure requests. For details on fees and payment methods, please contact the inquiry desk in Article 15.

Article 11 (Use of Statistical Data, Anonymously Processed Information, etc.)

1. The Company may create statistical data processed so that individuals cannot be identified from acquired personal information, and use such data for service improvement, marketing, and other purposes. Such statistical data may be used and provided to third parties within a scope where individuals cannot be identified.
2. When the Company creates anonymously processed information or pseudonymously processed information (as defined in the Personal Information Protection Act), the Company will implement appropriate security management measures and fulfill obligations for publication and disclosure in accordance with the Act and related guidelines.

Article 12 (Use of Cookies, etc.)

The Company may use cookies, web beacons, advertising identifiers, and other similar technologies (hereinafter referred to as "Cookies, etc.") on this Site.

Cookie等は、以下の目的で利用されます。

• Analysis of traffic and usage of this Site
• Improvement of functionality and convenience of this Site
• Measurement of effectiveness of the Services and advertisements
• Delivery of content and advertisements tailored to customer interests

The Company may use the following third-party services:

• Google Analytics 4 (provided by Google LLC or its affiliates)
• Google Ads (provided by Google LLC or its affiliates)
• Meta Ads (Facebook Ads, Instagram Ads, etc.; provided by Meta Platforms, Inc. or its affiliates)

These operators may use third-party Cookies, etc. in addition to Cookies, etc. issued by the Company to acquire and analyze access information of customers on this Site and other sites for advertising delivery, etc.

Customers can refuse to receive Cookies or delete already stored Cookies by changing browser settings. However, some features of this Site may not be available in such cases.

For details on data use by Google Analytics, Google Ads, and Meta Ads and opt-out methods, please refer to the privacy policies and opt-out pages provided by each company.

Article 13 (Notes on Handling Personal Information in Online English Conversation and Recruitment Services)

Article 14 (Personal Information of Minors)

1. When minor customers use the Services, applications should in principle be made with parental or guardian consent.
2. Personal information of minors acquired on the assumption of parental or guardian consent will also be handled appropriately in accordance with this Policy.

Article 15 (Inquiries, Complaints, and Consultation Desk)

For inquiries, complaints, consultations, and requests for disclosure of retained personal data regarding the Company's handling of personal information, please contact the following desk:

Article 16 (Changes to This Policy)

1. The Company may review and change the content of this Policy as necessary in accordance with legal revisions and other circumstances.
2. When this Policy is changed, the Company will publish it on this Site or by other methods prescribed by the Company, and the changed Policy will apply from the time of publication.
3. When the changes require customer consent under applicable laws, the Company will obtain customer consent through methods prescribed by the Company.