Attuned Privacy Policy
EQIQ K.K.
CEO Casey Wahl
10F 3-5-20 Kojimachi, Chiyoda-Ku, Tokyo
EQIQ K.K. (hereinafter, the “Company”) provides services related to (i) having individuals (hereinafter, the “Subjects”) answer questions and provide the results thereof to the Company’s customers (hereinafter, the “Customers”) to for the use of, among others, improve human resource management and conduct analyses to improve the working environment, and (ii) providing various information through e-mail services accompanying thereto.
The Company shall respect the privacy of the Customers and the Subjects (hereinafter collectively referred to as the “Users”) who use “Attuned” services provided by the Company, and shall exercise the duty of care to manage and properly handle Personal Information (as defined below) of the Users.
1. Handling of Personal Information by Company
The Company shall handle Personal Information in accordance with the “Information Security Policy”, “EQIQ Privacy Principles” as well as the policies set forth in this “Attuned Privacy Policy”, both set forth by the Company.
2. Personal Information
Personal Information shall mean information related to living individuals who are Users, based on which specific Users can be identified by names, dates of birth or other descriptions contained in such information. Information which does not by itself allow identification of specific Users is also included in the category of Personal Information, if such information allows easy reference to other information and will thereby enable the identification of specific Users.
3. Data Protection Officer
A Data Protection Officer who presides over all the management of personal information of the Company.
EQIQ K.K. CTO
email: team@attuned.ai
4. Purposes of Acquisition and Use of Personal Information
The purposes of the acquisition and use of Personal Information shall be as follows.
The Company shall acquire Personal Information from Users to the extent necessary to:
(1) Provide services to Users;
(2) Bill for compensation for providing the services;
(3) Allow Users to log in to the services;
(4) Provide information on test results, including the Subject’s motivation profile and engagement;
(5) Provide Personal Information to Customers based on the consent of Subjects;
The purpose of acquisition and use of Personal Information provided to the Customers, as well as other details, shall be as follows:
Purpose: To improve human resource management and to improve the working environment, etc.
Personal Information to be provided: Entries registered upon use of the services as well as the answers provided to the questions asked.
Method of provision: Provision by data or written document.
(6) Present information to client companies as statistical information to introduce the Company and its services;
(7) Deliver newsletters to Users;
(8) Respond to inquiries and contact individuals in emergency situations;
(9) Contact to Users.
※ The lawful basis for the processing (as set out in Article 6 of the EU General Data Protection Regulation - GDPR) is as follows:
Consent: The User has given clear consent for the Company to process their personal data for a specific purpose.
Legitimate interests: The processing is necessary for the Company’s legitimate interests.
5. Handling of personal information associated with business succession
When personal information is acquired due to succession of business from another business operator handling personal information due to merger or other reasons, we will not handle such personal information beyond the extent necessary to achieve the purpose of use of the personal information before the succession without obtaining the consent from a data subject in advance.
6. Change of Personal Information
Users may change, add, or delete Personal Information that they have submitted. Users may also request the Company to supply all their data in electronic format. Lastly, Users may withdraw their consent to the Company to use their data. (In case the User withdrew their consent, it will not affect its compliance with the agreed terms of the policy.) If so requested, the Company will either delete all User’s Personal Information, or anonymize it to ensure that it is not possible to identify a specific User.
7. Disclosure of Personal Information to Third Parties
The Company shall not disclose Personal Information of Users to any third party without the Users’ consent, unless the following criteria are met:
(1) Explicitly requested to do so by the related laws and regulations;
(2) In the event that the Company entrusts all or a part of the handling of Personal Information to a third party in order to deliver services to Customers; or
(3) In the event that Personal Information is provided as a result of a succession of business in a merger or similar change in the structure of the Company.
8 Indemnification
The Company shall not be liable for the acquisition of Users’ Personal Information by any third party in any of the following situations:
(1) In the event that the User himself/herself discloses his/her Personal Information, using the functions of Attuned or other ways;
(2) In the event that the User himself/herself has shared information such as ID and password which can identify individuals.
(3) Someone other than the User himself/herself gained information such as ID and password which can identify individuals from which the Company has no relation to.
9 Outsourcing
The Company may entrust all or a part of the handling of Personal Information to a third party in order to deliver services to Customers. In that case, the company oversees appropriately such a trustee to ensure safety management of Personal Information upon selecting an appropriate trustee and executing non-disclosure agreement with a trustee.
10 Use of Statistical Information, etc.
The Company may, based on the Personal Information provided by Users, create statistical information from data that has been processed so that individuals cannot be identified, and use such information without limitation. Copyrights pertaining thereto shall belong to the Company.
11 Management of Personal Information
The Company has been making efforts to conduct continuing security management measures that are technically and organizationally necessary to protect against the risk of wrongful access to Personal Information or the loss, destruction, falsification, or disclosure of Personal Information. The Company shall also comply with the laws and regulations pertaining to the protection of Personal Information, industry standards and customs, and laws and regulations related to maintaining the public order and morals.
12 Amendments to “Attuned Privacy Policy”
The Company shall review and endeavor to improve this policy on a regular basis. The Company may amend it without notice to Users, unless there is a change in purpose of use or use of personal information, lawful basis regarding the treatment of the personal information in which case requires Users consent.
13 For Users Residing in an EEA country: Explicit Approval for Data Transfer to Outside EEA
By accepting Attuned Privacy Policy, the User accepts the following terms:
The User’s Personal Information will be moved to Japan, which is not residing in an EEA country and has received a decision on the adequacy of data protection from the European Commission.;
Personal Information may be accessed and edited by the User;
The User may request the Company to restrict processing Personal Information which is undergoing verification of accuracy except for saving of the personal data;
The User may file a complaint with an EEA member country's regulatory agency in case of dissatisfaction with the Company’s handling of Personal Information.
By not accepting this Privacy Policy, the User will not be able to use this service.
14 Inquiries and Consultant Service
With respect to the handling of Personal Information, consultation and complaint for Attuned, please feel free to contact us.
Person in charge of handling the personal information
10F 3-5-20 Kojimachi, Chiyoda-Ku, Tokyo 102-0083
EQIQ K.K.
team@attuned.ai
※ Use of Cookies
The website for Attuned may use information called Cookies, which are used to make access more convenient. The Company does not consider Cookies as Personal Information, as it does not allow for the identification of certain individuals. However, it shall be treated as Personal Information if used with any information which allows for the identification of certain individuals.
※ About Google Analytics
The website for Attuned uses access analyzing services provided by Google (Google Analytics) to assess the use of the website. Google Analytics uses Cookies or technology similar to Cookies to collect and process data. The information used in Google Analytics does not contain any content which allows for the identification of individuals. Please see the Google website below for details on Google Analytics’s mechanisms related to the collection and processing of data.
https://policies.google.com/technologies/partner-sites
Supplementary Provisions
Date of enactment: June 6, 2018
Revised as of: October 7, 2019
Revised as of: April 27, 2020
Revised as of April 1, 2022
Revised as of September 29, 2023
Regarding Procedures for Disclosure, etc. of Personal Information
Regarding personal information handled by our company, Attuned, we will respond without delay upon request from you of notification of the purpose of use, disclosure, correction / addition / deletion, and suspension of use / erasure / suspension of provision to third parties (hereinafter referred to as, “Disclosure, etc.”) of your personal information. If you wish Disclosure, etc. of your personal information, please make a request according to the following procedure.
1. Types of personal information subject to Disclosure, etc.
Personal information subject to Disclosure, etc. is the personal information of an individual that we have the authority to answer to all requests from the said individual for disclosure, correction / addition / deletion, and suspension of use / erasure / suspension of provision to third parties.
2. Where to request Disclosure, etc.
Upon requests for Disclosure, etc., please send the specified documents by registered mail to the address below.
Person in charge of handling the personal information
10F 3-5-20 Kojimachi, Chiyoda-Ku, Tokyo 102-0083
EQIQ K.K.
team@attuned.ai
3. Documents to be submitted upon request for Disclosure, etc.
(1) Please print out and fill out the "Application for Disclosure, etc. of Your Personal Information".
(2) Personal identification document
A copy of the document such as a driver's license, passport, health insurance card, pension certificate, etc. that publicly verifies your identity.
* When the legal representative of a data subject or an agent delegated by a data subject requests for Disclosure / correction, etc., please enclose the following documents (3) and (4) in addition to the above (1) and (2).
(3) - 1. When you are a legal representative of a minor
One copy of the data subject’s family register, one copy of the data subject’s certificate of residence, and an identification document of the legal representative
(3) - 2 When you are a legal representative of an adult ward
Certificate of registration based on Article 10 of the Act on Guardianship Registration, etc. and an identification document of the legal representative
(4) When you are an agent delegated by a data subject
One copy of the data subject’s certificate of registered seal, a power of attorney (which is signed by the data subject and sealed with his/her registered seal) and an identification document of the agent
4. Fees required for notification of purpose of use and request for Disclosure, and its collection
A fee of 500 JPY will be charged for each request for notification of purpose of use and disclosure of personal information. Please enclose 500 JPY postal money order with the above documents.
5. Cases where Disclosure, etc. is not made
Disclosure, etc. cannot be made in the following cases.
In such a case, we will inform you of the reason, but please be informed that you will not be refunded even if you paid a fee.
(1) when we cannot verify your identification;
(2) when the type of personal information requested is not subject to Disclosure, etc.;
(3) when the documents are incomplete or insufficient;
(4) when you do not make the payment of the fees;
(5) When there is a risk of harming the life, body, property or other rights and interests of the data subject or a third party;
(6) When there is a possibility that it will significantly hinder the proper operation of our business;
(7) When it violates the law or regulations; and
(8) When we can refuse the request for Disclosure etc. for other reasons.