Privacy Policy

α & Company, Inc. (the “Company”) respects the privacy of users of Alpha Advisors and related programs and services (the “Users”) and hereby sets out the Company’s privacy policy (the “Privacy Policy”) for the purpose of ensuring the proper handling of the personal information of the Users.

1. Personal Information

In the Privacy Policy, the “Personal Information” includes name, birth date, age, gender, address, phone number, family structure, hobbies, preference, e-mail address, ID, Internet Protocol (IP) address, time stamp, workplace, company name, work address, work phone number, credit card number, bank account number, website browsing history, complaints, and inquiry details, one or more of which can identify the individual.

2. Purpose of Use of the Personal Information

The Company will use the Personal Information which is acquired by the Company for the following purposes:
(1) providing the Company’s services of supporting job search, career change,
university entrance examination and studying abroad, and providing relevant information etc.;
(2) requesting payments from the Users who use the Company’s services for a fee;
(3) contacting the Users for notification, providing information on products and services, and mailing gifts etc.;
(4) customizing information, services, and advertisement contents of the Company’s website to match the Users’ age, job, gender, hobbies, and preference;
(5) improving the Company’s existing services and developing new services;
(6) preventing the Users from using the Company’s services in violation of the terms and conditions or rules of such services; and
(7) creating, in connection with the Company’s services, statistical data in a processed form by which any individual is not identified.

3. Restrictions by Purpose of Use

The Company will use the Personal Information to the extent necessary to achieve the purposes mentioned in 2. above. When the Company handles the Personal Information beyond the scope of such purposes, the Company shall in advance obtain the User’s consent. Provided however, the foregoing shall not apply to the cases where:
(1) the laws and regulations require;
(2) there is a need to protect a life, body or property of the User, and when it is difficult to obtain the User’s consent;
(3) there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain the User’s consent; or
(4) there is a need to cooperate with a central government organization, a local government, or a person entrusted by them to perform affairs prescribed by laws and regulations, and when there is a possibility that obtaining the User's consent would interfere with the performance of the said affairs.

4. Acquisition of the Personal Information

• The Company shall acquire the Personal Information through a lawful and fair manner. The Company shall not acquire the Personal Information in an improper way that is against the User’s will.
• The Company shall, if it indirectly acquires the Personal Information, confirm that such Personal Information is properly acquired from the User by the previous holder which provided the Company with such Personal Information.

5. Notification of Purpose of Use upon Acquisition

When acquiring the Personal Information, the Company shall in advance notify or publish the purpose of its use. The Company shall also notify the Users of any change to the purpose of use. The Company shall properly use the Personal Information to the extent necessary to achieve the purpose of use.

6. Proper Protection of the Personal Information

The Company shall ensure that the Personal Information of the Users is accurate and kept up-to-date. Furthermore, the Company shall take necessary and appropriate action for the security control of the Personal Information including preventing the leakage, loss or damage of its handled Personal Information of the Users. Please contact at 17. Contacts below for questions on the security control of the Personal Information.

7. Supervision over Employees and Trustees

The Company shall have its employees who handle the Personal Information under its necessary and appropriate supervision. The Company may entrust the handling of the Personal Information acquired by it. In such a case, the Company shall execute a necessary agreement regarding the entrustment of the Personal Information with the entrusted party, and have such entrusted party under its necessary and appropriate supervision.

8. Provision of the Personal Information to Third Parties

The Company shall not provide the Personal Information to a third party without the User’s consent. The Company may, only if it obtains the User’s consent specifying the third party and what is provided to such third party, provide the Personal Information to a third party. However, the foregoing shall not apply if:
(1) the Company’s subcontractor provides the information or services via direct mails, e-mails, and/or other measures on behalf of the Company;
(2) it is necessary for the Company’s subcontractors to provide any individual service including after-sales service on behalf of the Company;
(3) for the purpose of providing statistical data, each Personal Information is accumulated or analyzed, and processed in a form which cannot identify the individual, and such statistical data is provided to a third party;
(4) the Company entrusts the Personal Information to its subcontractors such as a settlement system company, a credit card company and a bank (each of which executes a confidential agreement with the Company) for the purpose of requesting the Users to pay for the Company’s services;
(5) the Company provides the Personal Information of the User to delivery companies for the purpose of delivering gifts or presents;
(6) other than the cases mentioned in (1) through (5) above, the Company outsources to the extent necessary to achieve the purpose of use of the Personal Information;
(7) providing the Personal Information to a third party is permitted under laws and regulations; or
(8) upon joint use of the Personal Information, the Company provides the Personal Information to the party specified by the Company as “the party who jointly uses the Personal Information”.

9. Disclosure of the Personal Information

The Company shall, if requested by the User, disclose the Personal Information of such User without delay. However, the Company may not disclose all or a part of the Personal Information if:
(1) a life, body, property or other rights and benefits of the User or a third party may be harmed;
(2) any serious trouble to the proper execution of the Company’s services may be caused; or
(3) the relevant disclosure of the Personal Information falls under the breach of laws and regulations.

10. Procedures for Correction or Suspension of Use etc. of the Personal Information

If the Company is requested from the User to notify of utilization purpose of, correct, add, delete, suspend the use of or eliminate, or cease to provide to a third party the User's Personal Information, the Company shall, after the User’s identity is verified, respond within a reasonable period of time.

11. Disclaimers

The Company shall not be liable for the acquisition of the Personal Information by a third party in the cases where:
(1) the User discloses the Personal Information by himself/herself to a third party using any function of the Company’s service or in any other way; or
(2) the individual can be identified by the information which the User enters to the Company’s service.

12. Use of Statistical Data

The Company may prepare statistical data in a way or form that cannot identify the individual, using the Personal Information of the Users which the Company acquires.
Statistical data that cannot identify the individual may be used by the Company without any restrictions.

13. Use of Cookies etc.

• The Company automatically receives from the User’s browser the User’s IP address, cookie information, browsing history of websites and advertisements, and each User’s internet environment and keeps records on the Company’s server, when the User uses the services of or browses the websites of the Company or its business partner companies.
• The Company may use the Users’ information on gender, job, age, browsing history of websites and advertisements, when and how they use, and the internet environment so that the Company may consider its new services or make the existing services and advertisements more suitable for the Users.
• The Company may analyze the information of the Users or extract the questionnaire targets for analysis to analyze what kind of advertisements, information, and services would effectively be posted and to provide the sponsors, information providers and service providers with such analysis. The results of such analysis will not include any information which can identify individuals.
• The Company may entrust a third party to display and distribute a part of advertisements which are posted on the Company’s website. If such third party sets up cookies, the information will be recorded on the third party's server and handled under the third party's privacy policy.

14. Amendment to the Privacy Policy

A part or all of the Privacy Policy may be amended by the Company. Such amendment shall follow the procedures in accordance with laws and regulations. If the change is material, the notice thereof will be posted on the Company’s website.

15. Compliance with Relevant Laws, Regulations, and Guidelines

The Company shall comply with the Act on the Protection of Personal Information, other laws and regulations, and Guidelines of the Personal Information Protection Commission.

16. Name, Address, and Representative of the Company

α & Company, Inc.
11th floor 3-6-7 Kita-Aoyama, Minato-ku
Tokyo 107-0061 Japan
Representative Director, Toshihiko Irisumi

17. Contacts

Head of Alpha Academy shall be responsible for management of the Personal Information. For any question, complaint, request for disclosure, correction, deletion, or suspension of use regarding the Personal Information, please contact:
Office of Alpha Academy

October 1, 2014 as amended
[January 21, 2022 ] as amended