Privacy Policy | Findy Inc.

The following is the policy regarding the handling of personal information at Findy, Inc. (hereinafter referred to as "Findy Group").

1. Personal Information

Personal information refers to information relating to a living individual that falls under any of the following categories:

Information that can identify a specific individual by name, date of birth, or other descriptions contained therein (referring to all matters described or recorded in documents, drawings, or electromagnetic records, or expressed by voice, movement, or other methods) (including information that can be easily cross-referenced with other information to identify a specific individual)
Information that contains individual identification codes (as defined in Article 2, Paragraph 2 of the Act on the Protection of Personal Information; the same shall apply hereinafter)

2. Purpose of Use of Personal Information

Findy Group uses personal information within the scope of the purposes set forth below.

Personal information of Users
Personal information of those who use the services provided by Findy Group (hereinafter referred to as the "Services") (hereinafter referred to as "Users")

To provide information to recruiting companies when Users apply for job openings (including requests for informal interviews without a selection process), make inquiries, etc. to such recruiting companies
The personal information that Users have registered in the Services will be provided.
To provide appropriate employment placement services, including job matching, provision of job information, screening at companies applied to, and provision of information to recruiting companies based on applications
To confirm the usage status of the Services
To investigate and respond to unauthorized access, system failures, etc.
To confirm facts regarding applications, joining, and leaving companies, etc.
To improve the Services and develop new services
To respond to inquiries (including identity verification)
To provide information and deliver advertisements regarding the Services, including new features
To provide information about seminars, events, etc.
To conduct surveys
To perform statistical processing of Users' profiles, etc.

Personal information of business partners

To consider transactions with business partners (including potential business partners)
To properly execute and manage contracts with business partners
To conduct and communicate regarding business meetings and consultations
To manage entry and exit at Findy Group offices and facilities

Personal information of shareholders

To exercise rights and fulfill obligations under the Companies Act and the Commercial Code
To implement various measures aimed at facilitating the relationship between shareholders and the company
To manage shareholder records

Personal information of those who wish to join Findy Group
"Joining" refers to engaging in the business of Findy Group by entering into an employment contract with Findy Group, regardless of the title or contract period, including contract employees, part-time employees, temporary employees, etc.

To contact applicants regarding recruitment activities by Findy Group
To evaluate the suitability of applicants during the hiring process (including background checks, reference checks, and other verification procedures)
To improve the recruitment process of Findy Group
To determine job aptitude and ensure health for assignments and other business operations at Findy Group
To provide information about employment opportunities, events, etc. at Findy Group
To conduct satisfaction surveys and make improvements regarding employment opportunities, events, etc. at Findy Group
For purposes ancillary to recruitment activities, such as formulating recruitment plans
To manage applicant information

Personal information of those who wish to receive outsourced work from Findy Group

To evaluate the suitability of prospective contractors in connection with entering into contracts
To improve the contract execution process of Findy Group
To provide information about seminars, events, etc. of Findy Group
To improve and conduct satisfaction surveys regarding seminars, events, etc. of Findy Group
To contact prospective contractors regarding contract-related activities by Findy Group
To manage information of prospective contractors

Personal information of employees of Findy Group

For business communications, preparation of employee directories, legally required procedures, and other employment management purposes
For personnel selection, determination of assignments, secondments, and dispatches
For determining and paying compensation, tax processing, social insurance-related procedures, and providing welfare benefits
For safety management measures in online monitoring, etc.
For Findy Group PR or promotional activities in promotional materials, etc. (individual consent will be obtained in advance before use)
For proper health management (health information of workers, such as health examination results, will not be obtained, used, or provided except as required by law)

Personal information of those who have left Findy Group

For social insurance-related procedures, legally required procedures, and post-departure communications for alumni recruitment purposes
For preparing various statistical data and improving work environments and labor efficiency

Personal information of those who make inquiries (including requests for materials) to Findy Group, participate in seminars, events, etc., or respond to surveys

To accurately understand and address the content of inquiries and communications
To provide information about the Services, seminars, events, etc.
To provide and communicate recruitment and hiring information
To conduct surveys
To distribute email newsletters
To analyze and use for marketing purposes in order to sell the Services, etc.
To use as non-personally identifiable statistical data for public relations, advertising, sales, recruitment activities, etc.
To record photos, videos, audio, etc. of seminars, events, etc. (hereinafter referred to as "Event Records") for use in public relations, advertising, and sales activities

3. Joint Use of Personal Information

Findy Group may jointly use the personal information entrusted to us as described below.

Items of personal information to be jointly used: Name, address, date of birth, phone number, email address, work history and skill information, inquiry history, usage status of the relevant services, and all other information obtained through the services.
Scope of parties jointly using the information: Affiliated companies of Findy Group.
The affiliated companies are as follows:
- Career Development Associates, Inc.
*If subsidiaries or other affiliated companies are added in the future, this will be announced in the Privacy Policy or on the affiliated companies page.
Purpose of joint use: The same as the purposes set forth in Section 2 "Purpose of Use of Personal Information" of this Policy.
Entity responsible for managing jointly used personal information: Findy, Inc. (address and representative as stated at the beginning of this Policy)

4. Restrictions on Use of Personal Information

Findy Group will not handle personal information beyond the scope necessary for achieving the purpose of use without obtaining prior consent from the individual. However, this shall not apply in the following cases:

When required by laws and regulations (including ordinances; the same shall apply hereinafter)
When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual
When it is particularly necessary for improving public health or promoting the sound development of children, and it is difficult to obtain the consent of the individual
When it is necessary for Findy Group to cooperate with a national or local government agency, or a person entrusted thereby, in performing duties prescribed by laws and regulations, and obtaining consent from the individual may impede the performance of such duties
When Findy Group provides personal data to an academic research institution, etc., and such institution needs to handle the personal data for academic research purposes (including cases where part of the purpose of handling the personal data is for academic research purposes, excluding cases where there is a risk of unjustly infringing upon the rights and interests of the individual)

5. Correction and Suspension of Use of Personal Information

Correction of Personal Information
When Findy Group receives a request from an individual for the correction, addition, or deletion (hereinafter referred to as "Correction, etc.") of personal information based on the provisions of the Act on the Protection of Personal Information (hereinafter referred to as the "APPI") on the grounds that the personal information is not factually accurate, Findy Group will, after verifying that the request is from the individual themselves, promptly conduct a necessary investigation within the scope necessary for achieving the purpose of use, and based on the results, correct the content of the personal information and notify the individual accordingly (if a decision is made not to make the correction, the individual will be notified to that effect). However, this shall not apply in cases where Findy Group is not obligated to make such corrections under the APPI or other laws and regulations.

Suspension of Use of Personal Information
When Findy Group receives a request from an individual for (1) the suspension of use or deletion (hereinafter referred to as "Suspension of Use, etc.") of their personal information under the APPI on the grounds that it is being handled beyond the scope of the publicly announced purpose of use, or is being used in a manner that may promote or induce illegal or unjust acts, or was obtained by deception or other wrongful means; (2) the suspension of provision (hereinafter referred to as "Suspension of Provision") under the APPI on the grounds that personal information is being provided to a third party without the individual's consent; or (3) on the grounds that Findy Group no longer needs to use the individual's personal information, that a situation prescribed in the main text of Article 26, Paragraph 1 of the APPI has occurred regarding the individual's personal information, or that there is a risk of harm to the rights or legitimate interests of the individual due to the handling of their personal information, and when such request is found to be justified, Findy Group will, after verifying that the request is from the individual themselves, promptly suspend the use or provision of the personal information and notify the individual accordingly. However, this shall not apply in cases where Findy Group is not obligated to suspend use or provision under the APPI or other laws and regulations.

6. Procedure for Disclosure of Personal Information

If Users wish to request disclosure of personal information that cannot be confirmed on the website related to the Services (hereinafter referred to as "this Website") or records under Article 29, Paragraph 1 or Article 30, Paragraph 3 of the APPI, please contact the following:

Contact: Findy, Inc. Personal Information Handling Office
E-MAIL: personal.info@findy.co.jp

Identity Verification
Necessary information will be requested to verify that the person making the disclosure request is the individual themselves.

Disclosure Method
Findy Group will make the disclosure as set forth in this section by the method requested by the person making the disclosure request (if the disclosure by such method requires substantial costs or is otherwise difficult, by delivery of a written document). Please note that when disclosure is made in writing, it may take several days for postal delivery. In addition, the person making the disclosure request may be asked to bear the cost of postage. Furthermore, disclosure under Article 33, Paragraph 1 of the APPI may not be made in the following cases. If a decision is made not to disclose, the reason will be notified.

When there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party
When it would significantly impede the proper conduct of business
When disclosure would violate other laws and regulations

7. Outsourcing of Personal Information

Findy Group may entrust the handling of personal information to subcontractors in the course of business operations. In such cases, Findy Group will confirm that the subcontractor has a management system capable of appropriately protecting personal information and meets the standards necessary for preventing leakage of personal information before entrusting the work.

8. Storage of Information through Recording

Findy Group may record and store the contents of phone calls, web conferences, etc. for the purpose of confirming the content of communications and improving service quality.

9. External Transmission of Information Relating to Users

In accordance with Article 27-12 of the Telecommunications Business Act and related laws and regulations, Findy Group hereby publishes the following matters regarding external transmission.
Findy Group uses external transmission tools utilizing cookies and other technologies to obtain information relating to users for the purposes of improving the operational management of the Services and Findy Group websites, analyzing usage status, enhancing user convenience, protecting privacy, delivering optimal advertisements, and obtaining statistical data.
The external transmission tool providers listed below may use user information in accordance with their respective privacy policies, in addition to the purpose of providing external transmission tool services to Findy Group. Please refer to the privacy policies of each external transmission tool provider for information on the purpose of use of user information by each provider.

Name of External Transmission Tool	Name of External Transmission Tool Provider	Privacy Policy of External Transmission Tool Provider	User Information Transmitted by External Transmission Tool
Google Analytics	Google LLC	https://policies.google.com/technologies/partner-sites?hl=ja	Number of page views, time spent on pages, usage environment, referral sources, and search terms
Google Tag Manager	Google LLC	https://policies.google.com/technologies/partner-sites?hl=ja	Visitor actions and pages viewed
Google Optimize	Google LLC	https://policies.google.com/technologies/partner-sites?hl=ja	Data related to visitor devices and browsers, and user actions
Google Ads	Google LLC	https://policies.google.com/technologies/partner-sites?hl=ja	Visitor actions and pages viewed
Microsoft Advertising	Microsoft Corporation	https://privacy.microsoft.com/ja-jp/privacystatement	Visitor search terms
Microsoft Clarity	Microsoft Corporation	https://privacy.microsoft.com/ja-jp/privacystatement	Visitor actions and pages viewed
Bing ads	Microsoft Corporation	https://x.com/ja/privacy	Visitor location information, content displayed, and other information
X Analytics	X Corp.	https://www.criteo.com/jp/privacy/	Hashed browsing information such as mobile device IDs and email addresses
Criteo Ads	Criteo	https://www.criteo.com/jp/privacy/	Visitor actions and pages viewed
Facebook Ads	Meta	https://www.facebook.com/privacy/policy	Visitor actions and pages viewed
X Ads	X Corp.	https://business.x.com/ja/help/ads-policies.html	Visitor actions and pages viewed
X Developer Platform	X Corp.	https://business.x.com/ja/help/ads-policies.html	Visitor actions and pages viewed
X link service	X Corp.	https://business.x.com/ja/help/ads-policies.html	Visitor actions and pages viewed
LINEYahoo for Business	LY Corporation	https://www.lycorp.co.jp/ja/company/privacypolicy/	Visitor region of residence, gender, date of birth, and service usage history
Access Trade	Interspace Co., Ltd.	https://www.accesstrade.ne.jp/privacy	Personal identification information
STUDIO (PV measurement)	STUDIO Inc.	https://studio.inc/privacy	Visitor actions and pages viewed
STUDIO	STUDIO Inc.	https://studio.inc/privacy	Visitor actions and pages viewed
SmartNews Ads	SmartNews, Inc.	https://www.smartnews.com/privacy/#jp	Visitor actions and pages viewed
HubSpot	HubSpot Japan K.K.	https://legal.hubspot.com/jp/privacy-policy	Visitor actions and pages viewed
Marketing Cloud Account Engagement	Salesforce, Inc.	https://www.salesforce.com/jp/company/privacy/full_privacy/	Visitor actions and pages viewed
KARTE	PLAID, Inc.	https://karte.io/karte-policy.html	Visitor actions and pages viewed

10. Provision to Third Parties for Advertising, etc.

Findy Group may link with user lists held by advertising-related businesses to identify users of the services provided by such businesses and provide information management services, deliver advertisements, and perform marketing analysis on those services.
Findy Group may provide personal information to the following partner companies (including those located in foreign countries) with the consent of Users, in order to deliver more relevant advertisements to Users and to perform advertising delivery, effectiveness measurement, analysis, etc.

Recipients

Meta Platforms, Inc. (California, United States)
Google LLC (California, United States)
LY Corporation (Japan)
X Corp. (California, United States)
LinkedIn Corporation (California, United States)
CRITEO K.K. (Paris, France)
Microsoft Ireland Operations Limited (Ireland)

Personal information provided
Email addresses and phone numbers (however, these are hashed and processed into a format from which the original email addresses cannot be restored)

11. Safety Management Measures for Personal Information

Findy Group provides necessary and appropriate supervision to its employees to ensure the safe management of personal information against risks such as loss, destruction, alteration, and leakage of personal information. Findy Group may also entrust the handling of personal information to subcontractors in the course of business operations. When selecting subcontractors, Findy Group requires that they have a management system capable of appropriately protecting personal information, and includes provisions in contracts regarding appropriate management of personal information, confidentiality, and other matters necessary for preventing leakage of personal information. The specific safety management measures regarding personal data held by Findy Group are as follows:

Establishment of Basic Policy	This Privacy Policy has been established as a basic policy covering "compliance with relevant laws, guidelines, etc." and "contact points for questions and complaints," etc., to ensure the proper handling of personal data.
Development of Rules for Handling Personal Data	Rules for handling personal data have been established for each stage of acquisition, use, storage, provision, deletion and disposal, covering handling methods, responsible persons and personnel, and their duties.
Organizational Safety Management Measures	1) A responsible person for handling personal data has been appointed, and the employees who handle personal data and the scope of personal data they handle have been clarified. A reporting system to the responsible person has been established for cases where violations or signs of violations of laws or handling rules are detected. 2) Regular self-inspections of the handling status of personal data are conducted, along with audits by other departments and external parties.
Human Safety Management Measures	1) Regular training is provided to employees on matters to be noted regarding the handling of personal data. 2) Matters concerning confidentiality of personal data are included in employment regulations or rules.
Physical Safety Management Measures	1) In areas where personal data is handled, management of employee entry and exit and restrictions on equipment brought in are implemented, along with measures to prevent viewing of personal data by unauthorized persons. 2) Measures are taken to prevent theft or loss of equipment, electronic media, and documents that handle personal data, and when transporting such equipment and electronic media (including movement within offices), measures are implemented to ensure that personal data cannot be easily identified.
Technical Safety Management Measures	1) Access controls are implemented to limit the scope of personnel and personal information databases they handle. 2) Systems that handle personal data are protected from unauthorized external access or malicious software through the introduction of protective mechanisms.
Understanding of External Environment	When storing personal data in cloud services, etc. located in foreign countries, appropriate safety management measures are implemented after understanding the systems for protecting personal data in those countries.

12. Changes to the Privacy Policy

Except where otherwise required by laws and regulations, Findy Group may change this Policy at any time by publishing changes on the Findy Group website without prior consent of Users and other users of the services.

Established / Effective: September 11, 2016
Supplementary Provisions
Revised: March 1, 2017
Revised: January 20, 2020
Revised: June 11, 2021
Revised: April 1, 2022
Revised: December 21, 2022
Revised: October 25, 2023
Revised: July 8, 2024
Revised: August 28, 2024
Revised: December 11, 2024
Revised: March 19, 2025
Revised: September 30, 2025
Revised: April 20, 2026