Attuned Privacy Policy

Attuned K.K.
CEO: Casey Wahl
VORT Akihabara IV 2F
1-7-8 Kanda Sudacho, Chiyoda-ku, Tokyo 101-0041
Japan

Attuned K.K. (the “Company”) provides “Attuned,” a cloud-based service that enables the Company’s customers (“Customers”) to request specific individuals (“Individual Users”) to answer questions and enables Customers to analyze and use the results for the purpose of improving people management, organizational development, and workplace environments. The Service includes AI TalkCoach and other AI-based analysis and feedback features, as well as email or similar information provision functions.

The Company respects the privacy of Customers and Individual Users (collectively, “Users”) and handles Personal Information appropriately and with due care.

1. Relationship to Other Policies and Terms

The Company handles Personal Information in accordance with:

this Attuned Privacy Policy; and
the Company’s internal information security and privacy policies, as updated from time to time.

This Privacy Policy should be read together with the Attuned Terms of Service. In the event of any inconsistency, the Terms of Service govern contractual matters, and this Privacy Policy governs privacy-related matters.

2. Definitions

Personal Information

Information relating to a living individual that can identify a specific individual (including name, contact information, identifiers, or other descriptions), or information that can be easily collated with other information to identify a specific individual.

Customer Data

All information provided, input, transmitted, uploaded, or generated by Customers, their officers or employees, Individual Users, or other Users in connection with the Service, including survey responses, questionnaire answers, text data, conversation logs, metadata, settings, account information, and, where applicable, audio data.

Outputs

Analysis results, scores, reports, visualizations, feedback, AI TalkCoach coaching content, and other deliverables generated or provided through the Service.

Statistical Information

Information created by processing and aggregating Customer Data so that no individual or specific Customer or Individual User can be identified.

3. Privacy Contact

The Company does not appoint a dedicated Data Protection Officer. For all inquiries regarding Personal Information, please contact:

Privacy Contact: Casey Wahl (CEO)

Company: Attuned K.K.

Email: team@attuned.ai

Address:
VORT Akihabara IV 2F
1-7-8 Kanda Sudacho, Chiyoda-ku, Tokyo 101-0041
Japan

4. Personal Information We Collect

Depending on how the Service is used, the Company may collect and process the following categories of Personal Information:

a. Account and Contact Information

Names, email addresses, organization names, departments, roles, and user identifiers.

b. Service Usage and Technical Data

c. Survey, Questionnaire, and Conversation Content

Survey responses, free-text answers, chat or conversation content submitted to the Service, and related metadata.

d. AI TalkCoach Inputs

Primarily text-based inputs, conversation content, and derived data used to generate coaching feedback. Audio data or transcripts may be processed where applicable, but audio is not required for core Service functionality.

e. Support and Communications

Inquiries, support requests, and communications with the Company.

f. Website Data (Cookies and Analytics)

Cookies, similar technologies, and analytics-related data collected through the Company’s websites.

5. Purposes of Use

The Company uses Personal Information only to the extent necessary to:

Provide, operate, and maintain the Service;
Enable access control, authentication, and account management;
Generate Outputs and provide AI TalkCoach and related features;
Perform billing, payment processing, and contract administration;
Respond to inquiries and communicate with Users;
Deliver newsletters and service-related announcements to Users;
Improve, develop, and maintain the Service, including AI features, models, and algorithms;
Create and use Statistical Information for service improvement, research, marketing, public relations, and publication in media, provided that no individual or specific Customer or Individual User can be identified;
Ensure security, prevent fraud or abuse, and comply with legal obligations.

Note: The Service provides insights for human consideration and is not intended to be used as solely automated decision-making that produces legal or similarly significant effects on Individual Users.

6. Legal Basis for Processing (EEA/UK Users)

For Users residing in the EEA or the United Kingdom, the Company processes Personal Information based on one or more of the following legal bases, as applicable:

Performance of a contract;
Legitimate interests (such as service improvement, security, and prevention of abuse);
Consent, where required by applicable law.

7. Disclosure to Third Parties and Outsourcing

The Company does not sell Personal Information. Personal Information may be disclosed or entrusted to third parties only in the following cases:

1. Service Providers and Subprocessors

Cloud hosting providers, security vendors, analytics providers, customer support tools, and other vendors necessary to provide and operate the Service, subject to appropriate contractual and security safeguards.

2. Foundation Model Providers and External AI Services

To provide AI TalkCoach and other AI-based features, Customer Data (which may include Personal Information) may be transmitted to Foundation Model providers or other external service providers. Where reasonably feasible, the Company endeavors to apply anonymization or de-identification measures; however, complete anonymization cannot be guaranteed due to technical limitations.

3. Legal Requirements

Where disclosure is required by applicable laws, regulations, or lawful government requests.

4. Business Transfers

In connection with a merger, acquisition, reorganization, or transfer of business.

8. International Data Transfers

Personal Information may be processed and stored in Japan and in other countries where the Company or its service providers operate. Where required by applicable law, the Company implements appropriate safeguards for cross-border data transfers.

9. Data Retention and Deletion

The Company retains Personal Information and Customer Data for as long as necessary to provide the Service and for legitimate business purposes, including legal compliance, dispute resolution, audits, security, and backups.

Personal Information and Customer Data are not automatically deleted upon termination of the Individual Agreement.
Deletion or anonymization is performed only upon an explicit written deletion request from the Customer, and within a reasonable and operationally feasible period.
The Company may retain certain Personal Information or Customer Data where required for legal compliance, dispute resolution, audits, security, or other legitimate business purposes.
Statistical Information may be retained indefinitely.

10. User Rights

Users may have rights under applicable law to request access, correction, deletion, restriction, or objection regarding their Personal Information.

Users may submit such requests directly to the Company using the contact details in this Privacy Policy.

However, where the relevant Personal Information is processed as part of a Customer’s use of the Service (for example, in an employer-managed environment), the Company may be required to confirm the request with the Customer or handle the request in accordance with the Customer’s instructions, subject to applicable law.

11. Security Measures

The Company implements reasonable technical and organizational measures to protect Personal Information, including encryption in transit (SSL/TLS), access controls, and internal policies designed to limit data access to authorized personnel only. However, no system can be guaranteed to be completely secure.

12. Cookies and Analytics

The Company’s websites may use cookies and similar technologies to improve usability and analyze website usage. Cookies may be treated as Personal Information if linked to identifiable information.

The Company may use Google Analytics or similar services. For details regarding Google’s data collection and processing practices, please refer to:
https://policies.google.com/technologies/partner-sites

Some marketing or analytics vendors may provide opt-out mechanisms, such as:
https://app.retention.com/optout

13. Amendments to This Privacy Policy

The Company may revise this Privacy Policy from time to time to reflect changes in the Service, legal requirements, or operational practices. Where required by applicable law, the Company will obtain User consent for material changes.

14. Inquiries

For questions, requests, or complaints regarding this Privacy Policy or the handling of Personal Information, please contact: