（Last updated: March 2024）

This Privacy Policy explains how polisee Inc. (“Company”) collects, uses, and provides the personal data acquired from the Company’s customers or related to the Company’s customers.

This Privacy Policy applies to (1) the personal data acquired from the Company’s customers or related to the Company’s customers that was obtained and is managed by the Company, (i) when a customer visits a website operated by the Company linked to this Privacy Policy (collectively, “Company’s Websites”); (ii) when a customer uses the Company’s services accessible through the Company’s Websites or a mobile application (collectively, “Company’s Services”); (iii) when a customer contacts the Company through the Company’s customer support or the like; and (iv) when a customer participates in a Company event or demonstration; and also applies to (2) the personal data registered in the Committee Members Information Databases (defined below), among the information disclosed by the government and other entities and collected by the Company.

1. Information Collected by the Company

(1) Information associated with using the Company’s Services

The Company might collect information from its customers or related to its customers, when a customer performs the below-listed actions.

This collected information might contain a customer’s personal data (including the customer’s name, email address, address, telephone number, and credit card information).

• Creating or registering an account, or managing an account;
• Entering, posting, or uploading information, data, or other content through the Company’s Services;
• Sending a question, request, or other communication to the Company via the various communication channels;
• Contacting the Company for customer support or technical support;
• Accessing the Company’s website or downloading a Company application;
• Participating in a Company event, demonstration, survey, or other marketing event; and
• Acquiring information automatically collected regarding the customer’s method of using the Company’s Services (including the customer’s IP address; the browser, OS, ISP, platform, and device type used by the customer; the customer’s mobile identifiers (such as, the manufacturer and model details), and the customer’s carrier).

In addition, the Company collects, as statistical data, information that does not identify a specific customer, such as information about the frequency of the customer’s access to the government information contained in the Company’s Services and its relevance.

(2) Personal data contained in the Committee Members Information Databases

The Company collects disclosed information about concerned individuals (such as, members, experts, and observers) of committees organized by the government, political parties, and these related entities that create a secretariat. Furthermore, the Company registers the disclosed information in information databases used in the Company’s Services (“Committee Members Information Databases”) for the purpose of providing the information to third parties (such as, individuals with a contract to use the Company’s Services and prospective customers).

Please refer to Sections 2(2) and 2(3) for more details about the Committee Members Information Databases.

2. Purposes of Use for the Information Collected by the Company

The Company uses the personal data it collected for the following purposes.

(1) Purposes of use for the Company’s customers’ personal data collected in association with the customers using the Company’s Services

• To provide the Company’s Services;
• For after-sales services related to the Company’s Services;
• To notify customers about information related to relevant services;
• To improve or enhance the functionality of the Company’s Services, as well as to research and develop the Company’s Services and their related services;
• To conduct market research and surveys;
• To manage customers (such as, using the customer’s contact person’s name, manager’s name, or the like, when, for example, contacting a customer regarding a transaction with the customer);
• To confirm the customer’s identity, or the customer’s representative’s identity;
• To perform legal obligations or to exercise legal rights. These include (i) responding to legal requests and procedures; (ii) protecting the Company, a customer, or another individual’s rights or property (such as, executing the Company’s contract or policies), and; (iii) detecting, investigating, and preventing misconduct, as well as taking action in response thereto; and (iv) decreasing credit risk.

(2) Purposes of use for personal data acquired using Committee Members Information Databases

• To provide the personal data to users and prospective customers of the Company’s Services

(3) Option to opt out of personal data in the Committee Members Information Databases

(a) Methods for acquisition of personal data and provision to third parties by the opt out option

The Company’s methods for acquiring the data registered in the Committee Members Information Databases used in the Company’s Services are described below.

• Acquisition of disclosed information by government or political press releases or related to councils, committees, and other meeting bodies to be held by the government or political entities;
• Acquisition of an individual’s public information disclosed by a committee member, government official, or diet member, or by the company, entity, or other organization the individual belongs to, on a web page or via SNS; or
• Purchase of a newspaper or book.

(b) Provision methods to third parties and personal data categories provided to third parties

The Company provides online or in a print form to users of the Company’s Services the personal data registered in the Committee Members Information Databases for the purpose of providing the personal data to third parties. The details of the Company’s Services and the categories of the personal data provided to third parties consist of the name, title at committee or other meeting bodies held by government or political parties, and occupation; the law handled by the relevant council, committee, or division, and its content; the committee member’s birthdate, gender, birthplace (prefecture), educational background, work experience, qualifications, affiliated organizations, received awards, hobbies, and major copyrighted work titles.

(c) Procedures to prevent provision of personal data to third parties (opt out option) based on a committee member’s request

The Company will not provide to a third party personal data that can identify a committee member (opt out option) based on a committee member’s request in connection with the committee member’s personal data. A committee member should submit their request to prevent the Company’s provision of their personal data to a third party by sending an email to privacy@polisee.com or by post (addressed to “polisee’s privacy officer” to the address at the end of this Privacy Policy).  The Company shall explain what to do in compliance with the prescribed procedures, accordingly. The Company sends notifications to the Personal Information Protection Committee regarding the opt out option stipulated in this section (Notice Number 2023-100309).

3. Provision of Information

The Company might provide the information it collected as follows.

• To the Company’s contractors for providing the Company’s Services. The Company’s contractors include, but are not limited to, contractors involved in data storage, hosting, payment processing, and marketing.
• A customer shall agree to make accessible to the concerned individuals of counterpart organizations, to the extent allowed under the contract, when multiple customers enter into a contract allowing for group work as part of the Company’s Services.

4. Queries about this Privacy Policy and Customers’ Personal Information

Questions, consultations, and other queries regarding this Privacy Policy or a customer’s personal information should be sent via email to privacy@polisee.com.

polisee Inc.

President & CEO, Kyoichiro Suzuki

Nagatacho Hokkaido Square 7F

2-7-17 Nagatacho, Chiyoda-ku, Tokyo 100-0014