Privacy Policy

1.Definition

In this Policy, “Personal Information,” “Personal Data,” and other words that have definitions in the Act on the Protection of Personal Information （Act No. 57 of 2003, hereinafter the “Act”）has the meaning defined in the Act.

2.Information collected and its purpose of use

We may acquire, or may acquire in the future, the following information on the following occasions for the following purpose of use.

Provision of Personal Data to Third Parties, etc.

1. 3.1Provision of Personal Data to Third Parties

   We will not provide your Personal Data to a third party except where otherwise provided in this Policy or in cases set forth below:

   1. upon your prior approval;

   2. cases based on laws and regulations;

   3. cases in which there is a need to protect the life, well-being, or property of an individual, and it is difficult to obtain your consent;

   4. cases in which there is a special need to improve public well-being or promote healthy child development, and it is difficult to obtain your consent; or

   5. cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and obtaining your consent is likely to interfere with the performance of those functions.

2. 3.2Entrustment of the Handling of Your Personal Data

   In order for the operation of our services and within the scope necessary for achieving the purpose of use, we may entrust the handling of your Personal Data to a third party. In this case, we will exercise the necessary and adequate supervision over the person we entrust.
   Further, upon such entrustment, we may entrust the handling of your Personal Data to a third party in a foreign jurisdiction. The details of such a third party are described as follows.

   Name of the service	Zendesk
   Content of the service	Respond to your inquiries and handle the inquiries history
   Service operator	Zendesk, Inc.
   Jurisdiction of the service operator	State of California, U.S.A.
   Information regarding the protection of Personal Information in the said jurisdiction	See the document posted in the Personal Information Protection Commission’ website in the URL below: https://www.ppc.go.jp/files/pdf/california_report.pdf
   Information regarding the protection of Personal Information taken by the service operator	See the service operator’s privacy policy in the URL below: https://www.zendesk.co.jp/company/agreements-and-terms/privacy-notice/

   When providing Personal Data to a third party in a foreign jurisdiction who is taking equivalent measures that the businesses handling Personal Information shall take, we will take necessary measures to ensure continuous implementation of the equivalent measures by the third party. For information on the necessary measures, please contact the inquiry form set out in the last part of this Policy.

3. 3.3Joint Use of the Personal Data

   We will jointly use your Personal Data according to the following:

   1. Details of Personal Data that are jointly used
      Your information prescribed in Section 2. “Information collected and its purpose of use”

   2. Purpose of use of Personal Data that are jointly used
      The purpose of use prescribed in Section 2. “Information collected and its purpose of use”

   3. The extent of the joint users
      Our affiliates and the affiliates of Komatsu Ltd. (For details, see https://www.earthbrain.com/company/ and https://www.komatsu.jp/ja/aboutus/locations）

   4. The person responsible for managing the jointly-used Personal Data
      EARTHBRAIN Ltd.
      29F Izumi Garden Tower, 1-6-1 Roppongi, Minato-ku, Tokyo 106-6029 Japan
      Representative Director: Akinori Onodera

4. 3.4External websites

   For the handling of Personal Data in external websites or services linked by our website or our services, please look at privacy policies in such websites or services.

5. 3.5Use of Google Analytics, etc.

   We may use Google Analytics or Firebase (“Google Analytics, etc.”), both of which are the services of Google LLC (“Google,”) to measure the frequency or other status of your usage of our websites or services for their improvements and updates. For this reason, Google Analytics, etc. collect anonymous traffic data, which will not identify you. For the information that Google Analytics, etc. collect and its handling, please access Google’s Privacy Policy and its webpage on “Google’s use of information collected from websites and apps which use Google service.”
   （www.google.com/intl/jaen/policies/privacy/partners/）

6. 3.6Collection of your information by third parties

   With regard to the collection of your information by third parties, we disclose the related information as follows.

   Third party collecting information	Third party services collecting information	The purpose of collecting information	Information collected by third party	Opt-out of the collection and other information
   Google LLC	Google Analytics	Analyzing your access history in order to improve our services	Frequency of access, time spent on webpage, user agent, geographical diversity of users, inbound traffic, search words, etc.	✓service website ✓privacy policy ✓opt-out
   Google LLC	Firebase	Analyzing your access history in order to improve our services	Access history and information necessary to identify the accessing person or device	✓service website ✓privacy policy ✓opt-out feature is yet to be enabled

4. Measures for Managing the Security of Personal Data

We will take the necessary and appropriate measures for managing the security of Personal Data, including preventing the leaking, loss, or damage of the Personal Data we handle. For details of those measures, please contact the inquiry form set out in the last part of this Policy.

5. Procedures of disclosures, rectifications, etc.

When we receive a request from you or your agent for notification of the purpose of use, disclosure, rectification or deletion, suspension of use, or provision to third parties of your Personal Data retained by us, we will respond to that request according to applicable laws and ordinances. For these requests, please contact the inquiry form set out in the last part of this Policy.

6. Revisions of Policy

We may revise the provisions of the Policy. The changes will be disclosed and notified to you by the means designated by us.

7. About Us

Our corporate name, address, and the name of our representative director are as follows.
EARTHBRAIN Ltd.
29F Izumi Garden Tower, 1-6-1 Roppongi, Minato-ku, Tokyo 106-6029 Japan
Representative Director: Akinori Onodera

8. Inquiry

For requests on Personal Data handled by us, and other inquiries relating to this Policy, please contact us via the contact form in https://www.earthbrain.com/contact/form

Established June 16, 2023
Updated December 26, 2023