NEWS

Personal Information Protection Policy unclassified

Personal Information Protection Policy

Incubate Fund Inc. (hereafter referred to as "the Company") provides job placement services (hereafter referred to as "our services") to contribute to the development and HR of human resources in the venture industry, including job seekers interested in the startup industry and the companies in which we invest. (hereinafter referred to as "the Company") provides a recruiting service (hereinafter referred to as "our service") to contribute to the development of human resources and HR in the venture industry, including job seekers interested in the startup industry and our portfolio companies. In providing our website and services, we respect the privacy of users and manage personal information appropriately and safely in accordance with the Act on the Protection of Personal Information (hereinafter referred to as the "Act") and the Employment Security Act. All of our employees are committed to respecting the privacy of users and to managing personal information appropriately and safely. We have established policies and procedures to protect personal information obtained through our services, fund management, and the investment review process (hereinafter collectively referred to as "our services, etc."). The Company has established a policy for the protection of personal information obtained through its services, fund management, and investment review process (hereinafter referred to as "our services, etc.").

Handling of Personal Information

We ask that users of our services (hereafter referred to as "users") read and agree to the following policies regarding the handling of personal information entrusted to us and the prescribed agreement for the use of our services before using our services. We ask that you please read the following policy regarding the handling of personal information entrusted to us and the prescribed agreement items when using our services before using our services. We ask that you please read the following policy regarding the handling of personal information entrusted to our company and the prescribed terms of agreement when using our services before using them.

1. Personal Information
Personal information shall mean "personal information" as defined in Article 2, Section 1 of the Act on the Protection of Personal Information.

2. Compliance with Laws and Regulations We will comply with laws and regulations such as the Act on the Protection of Personal Information, guidelines set by the government, our personal information protection policy (hereinafter referred to as "this policy"), and other norms.

Personal information received from users of our services will be used for the following purposes. The Company will use personal information received from users of the Company's services, etc. for the following purposes.

Application and disclosure to employers based on the user's consent and agreement.
Providing information and services related to employment and career change.
Confirmation of employment, job change, and other situations related to the user during or after the provision of services.
(Additional information related to personnel, annual income, labor, etc. may be obtained within the scope of the purpose of use without the user's additional consent, or information related to the user's employment status may be obtained. (We may obtain additional information related to personnel, annual income, labor relations, etc. within the scope of the purpose of use without obtaining additional consent from the user.)
Exchanging and disclosing personal information regarding employment status with affiliated job advertisers and recruitment agencies, etc.
Advising and suggesting recruitment plans for hiring companies
(2) Responding to acts that violate the Company's terms and conditions, policies, etc., concerning the Company's services.
Notification of changes to the terms and conditions of our services
Listening to opinions, requests, etc. for the purpose of service improvement
To organize, manage, and provide information on services, exhibitions, seminars, and other various events.
Notification of existing and new services handled by the Company
To provide a wide range of services, including the distribution of information via e-mail newsletters, etc. ・Respond to inquiries, consultations and complaints, and resolve disputes.
To process personal information in such a way that individuals cannot be identified and to use it for aggregation, statistics, etc.
Other matters related to the Company's recruiting business
Establishment and management of funds
Investment Activities

4. Submission of Personal Information When users submit personal information in response to our request, they do so on a voluntary basis. When we ask you to submit your personal information in response to our requests, we ask you to do so on a voluntary basis. When users submit personal information in response to our requests, they do so on a voluntary basis, and even if such submitted information includes sensitive personal information as defined by law, we assume that the user has submitted the information with consent. We will assume that you have submitted the information with your consent even if such information includes sensitive personal information as defined by law.

5. Safety control measures
(1) Personal information entrusted to us will be properly managed through technical and organizational security measures and employee training to prevent unauthorized access, loss, falsification, leakage, etc. (1) We will strive to take technical and organizational security measures and employee training to prevent unauthorized access, loss, falsification, leakage, etc., and manage personal information appropriately.
(2) When disclosing, entrusting, or providing personal information of a user to an entity other than the Company, the Company shall make it a condition of disclosure, etc., that the entity concerned has secured a sufficient level of personal information protection. In addition, we will endeavor to provide appropriate advice, guidance, supervision, etc., as appropriate.
(3)When a certain period of time has elapsed since the end of the user's use of our services, etc., we may delete the user's personal information or registration from the perspective of personal information protection. (3) If a certain period of time has elapsed since the end of your use of our services, etc., we may delete your personal information or registration from our database.

6. Provision to third parties Personal information will not be provided to third parties except in the following cases

(1) When the user has given prior consent for the use of the information for a specified purpose, such as applying for a position with a company or disclosing the information.
(2) In accordance with the Personal Information Protection Law and other laws and regulations
(3) When personal data is provided to a third party as a result of a merger, spin-off, transfer of business, etc., in which our business is succeeded by the third party.
(4)When provided to contractors in accordance with the aforementioned "5. Security Control Measures
(5) Exchange and disclosure of personal information with affiliated job advertisers or recruitment agencies, etc., in cases where additional consent has been individually obtained.

7. Changes to the Privacy Policy, including notification to users, and deemed consent by users
(1) Matters described in this policy, together with documents delivered by the Company at the time of application for the Company's services, etc., and matters explained by the Company, etc., shall be "notified to or announced to users" as required by law.
(2) The Company may change the purpose of use, etc., in accordance with Article 15, Paragraph 2 and Article 18, Paragraph 3 of the Act. In the event of any change, the Company shall announce such change on the Company's website.
(3)By using our services, you are deemed to have understood the matters described in this policy and agreed to our use and provision of your personal information based on the contents of this policy. (3) Users are deemed to have understood the matters described in this policy at the time of use of our services, etc., and to have consented to the use, provision, etc., of their personal information based on the contents of the policy. In addition, in the event of a change to this policy based on the preceding item, users who continue to use our services after one month has elapsed from the date of posting will be deemed to have agreed to the content of the revised policy. In addition, in the event of a change to this policy in accordance with the preceding item, users who continue to use our services after one month has elapsed from the date of posting shall be deemed to have agreed to the revised policy.

8. Disclaimer
(1) When we introduce a user to a company that is recruiting for our service, we will promptly provide the advice and guidance described in "5. We assume no responsibility for the handling of personal information by the company or its employees after that time. Please check the personal information protection policy of each company and contact them directly.
(2) In the event that personal information is leaked or disclosed to a third party for reasons attributable to the Company, the Company shall compensate the user only for direct and actual damages incurred by the user.
(3) In the event of intentional or gross negligence on the part of the Company in applying this policy, or in the event that the user falls under the category of consumer under the Consumer Contract Act and the policy is invalid, only the relevant provisions shall be invalid and shall not apply to such user. The Company shall not apply such provisions.

9. Requests for Disclosure, etc. If you wish to request us to notify you of the purpose of use, disclose, correct, add, or delete your personal information, or stop using or providing your personal information to a third party (hereinafter "disclosure, etc."), please contact us at the address in 10. If you contact us, we will promptly respond to your request in accordance with our internal rules. However, we may not be able to respond to requests for disclosure, etc. in cases where there is a risk of disruption of business operations or in other cases as stipulated by law. In addition, we may not be able to respond to requests for disclosure, etc. in cases where there is a risk that it would interfere with our business operations, or in other cases specified by law. For disclosure and notification of purpose of use, a handling fee of 1,000 yen (consumption tax included) will be charged per request. Please enclose 1,000 yen in stamps when you send us the disclosure request form or purpose-of-use notification request form that we ask you to submit (even if the stamps are in excess of the amount enclosed, the excess amount will not be returned). (Please note that the excess amount will not be refunded even if stamps are enclosed.)

10. Contact for inquiries
1-12-32 Akasaka, Minato-ku, Tokyo 107-6003, Japan

Incubate Fund Inc.
Personal Information Manager Shuhei Yoshida

Adopted April 1, 2018
Revised on July 1, 2022

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