1. Strengthening employee education

The Company shall prepare learning materials on protection of personal information, distribute them to all of its regular employees and temporary employees, and implement training at least once a year for all of its regular employees and temporary employees who handle personal information.

2. Developing internal regulations concerning protection of personal information

The Company shall develop internal regulations concerning protection of personal information, present a clear policy for handling personal information, and ensure that the Company’s strict stance on personal information leaks, etc., is disseminated in-house.

3. Assigning a Personal Information Protection Manager and strengthening the manager’s function

The Company shall establish the post of Personal Information Protection Manager, assign the Information Security Administration Manager to the post, and develop a system where the role of the manager is clarified, for the purpose of supervising compliance with laws, regulations and guidelines, formulation of internal regulations, development of an audit system and other handling of personal information.

4. Implementing appropriate information security measures

To prevent leakage, loss and corruption of personal information and otherwise manage the safety of personal information, the Company shall take necessary and appropriate measures, such as managing access to personal information, putting restrictions on taking out personal information, and preventing unauthorized access by outside parties.

5. Contracting out operations

1.  The Company may contract out all or a part of operations for handling personal information, with respect to sales of various services, etc., responses to inquiries, equipment maintenance, fee-related operations, marketing and other operations.
2. When entering into a service contract, the Company shall conduct a full review of whether the counterparty is qualified as a contractor. In a service contract, the Company will set forth safety management measures, maintenance of confidentiality, subcontracting conditions and other matters related to appropriate handling of personal information, and properly supervise its contractors by implementing measures, such as periodically monitoring the status of how outsourced work is conducted.
3. The Company will use personal information provided (entrusted) by the outsourcing client in connection with commissioned work only to the extent necessary to achieve the purpose of the contract with that client.

6. Developing and improving an audit system

The Company will develop a system that enables it to internally audit whether personal information is protected properly.
In addition, audits using access logs are considered in promptly identifying persons responsible for personal information leaks and preventing leaks through the deterrent effect of such identification. Therefore, the Company will consider how to implement such audits.

7. Appropriate collection, use, provision, publication, etc. of personal information

When collecting personal information, the Company shall clarify the purpose of use of the information and employ fair and legitimate means, such as application forms and other documents, screens on website and similar interfaces, and oral communication. In addition, the Company shall appropriately take actions such as using, providing and publicizing personal information, taking into account the nature and size of business, and implement measures to prevent the use of acquired personal information for any purpose other than the intended purpose.

8. Responses to inquiries

With respect to personal information related to a person and handled by the Company, if the Company receives a complaint, request for consultation, or inquiry from that person about disclosure, correction, suspension of use or other matters, the Company shall make an appropriate response.

9. Continuous improvement of activities to protect personal information

The Company shall review and improve activities in 1. to 8. above related to protection of personal information on a continual basis.

10. Revision

The Company may revise the whole or a part of the Code of Conduct for Protecting Personal Information.
If any material changes are made, the Company will provide notice in an easy-to-understand manner on its website or by other appropriate means.

Scope of the Code of Conduct for Protecting Personal Information

The terms “personal information,” “personal data” and “retained personal data” used in the Code of Conduct for Protecting Personal Information have the meanings defined in the Act on the Protection of Personal Information, regardless of whether such information or data relates to our customers, employees of companies we transact with, or our employees.
Unless otherwise stated in each section, the Code of Conduct for Protecting Personal Information shall apply to all personal information acquired by the Company and all personal data managed by the Company.

Established August 3, 2015
Revised December 26, 2017
Revised April 1, 2022
Revised April 14, 2026
Revised May 27, 2026
AI inside Inc.
Taku Toguchi, Representative Director, President & CEO

< Contact Information Regarding Personal Information Protection >
Personal Information Consultation Desk
Personal Information Protection Manager: Administration Division Director
Tel: +81-3-5468-5041

1. Purposes of use of personal information (including retained personal data)

AI inside Inc. (hereinafter the “Company”) shall use personal information for the following purposes.

1. Personal information of companies we transact with and users of our services *
   To exercise rights and perform obligations in accordance with contracts with companies we transact with
   To provide services to users
   To provide information and support regarding our products and services, and to deliver advertisements regarding our products and services based on the interests and preferences of the individual concerned, measure the effectiveness of such advertisements, and provide products and services, including providing necessary information to advertising service providers for these purposes.
   To analyze the browsing history of the screens of our services and use it to improve UIs, support quality, and other services
2. Personal information of our shareholders
   To exercise rights and perform obligations in accordance with the Companies Act and the Commercial Code
   For the Company to provide various benefits
   To implement various measures to facilitate a good relationship between shareholders and the Company
   To manage shareholders, for example, by preparing data of shareholders based on specified criteria in accordance with laws and regulations
3. Personal information of those who wish to join the Company (including those who would like information on jobs in the Company)
   To provide information on job offers, recruitment and other matters to them and be in contact with them
   To conduct recruiting and screening activities
4. Personal information of those who make an inquiry to the Company *
   To accurately understand the details of the inquiry or communication and respond appropriately
   To improve the Company’s customer service
   To provide information and support regarding events, our products, and services that may be of interest to the individual concerned
   To deliver advertisements regarding our products and services based on the interests and preferences of the individual concerned
   To measure the effectiveness of such advertisements
   To provide products and services, including providing necessary information to advertising service providers for these purposes
5. Personal information of those who apply or participate in events, projects, webinars, etc., held by the Company *
   To manage such events (including conducting questionnaires, etc.)
   To provide information and support regarding events, our products and services that may be of interest to the individual concerned
   To deliver advertisements regarding our products and services based on the interests and preferences of the individual concerned
   To measure the effectiveness of such advertisements
   To provide products and services, including providing necessary information to advertising service providers for these purposes
6. Personal information handled in work that is entrusted to us by companies we transact with
   To conduct the work entrusted to us
7. Personal information provided for artificial intelligence development services
   To conduct artificial intelligence development services

*Our partners may contact you in order to fulfill the purpose of use, such as to respond to your inquiry promptly and appropriately or to provide you with information. In addition, we may acquire behavioral history by monitoring the clicks of the URLs in e-mails or by acquiring opening history through a similar mechanism in image data.

Note that if we use relevant personal information for other than the above purposes, we will, in each case, clarify the purpose of use and obtain prior approval from the individual concerned. However, the following cases are excluded:- 

1. Cases in which there is a possibility that informing the individual concerned of, or disclosing to the public, the purpose of use would harm the individual or third party’s life, body, fortune or other rights and interests
2. Cases in which there is a possibility that informing the individual concerned of, or disclosing to the public, the purpose of use would harm the rights or legitimate interests of the Company
3. Cases in which there is a need to cooperate with a central government organization or a local government performing affairs prescribed by laws and regulations, and when there is a possibility that informing the individual concerned of, or disclosing to the public, the purpose of use would interfere with the performance of the said affairs
4. Cases in which it can be recognized, judging from the circumstances of acquisition, that the purpose of use is clear

2. Provision of personal information to third parties

Except in any of the following cases, we will not disclose personal information we handle to any third party.

1. When the individual concerned gives approval
2. When the whole or a part of operations for handling personal information are outsourced to an external contractor with which the Company has concluded a non-disclosure agreement beforehand, to the extent necessary to achieve the purpose of use of the personal information
3. When disclosure is required by a court or public authority in accordance with laws and regulations, etc.
4. When disclosure is necessary to protect the rights or assets of the Company
5. When personal information is provided to advertising service providers to:deliver advertisements regarding our products and services based on the interests and preferences of the individual concerned;measure advertising effectiveness; andprovide products and services;to the extent necessary for such purposes.*
6. When we are permitted by law to disclose personal information

*… When advertising service providers are located outside Japan, personal information may be transferred to the country in which such providers are located, provided that applicable laws, regulations, and guidelines are complied with.

The countries, personal information protection systems, and safeguards implemented by the recipients are as follows:

Personal Information Protection Systems in Each Country: United States of America

3. Consultation desk for inquiries about personal information and contact point for complaints

If you have an inquiry or complaint about the Company’s handling of personal information, please contact:

Personal Information Consultation Desk, AI inside Inc.
Address: Mori JP Tower 48F, 1-3-1 Azabudai, Minato-ku, Tokyo 106-0041, Japan
Please submit your inquiry using the following form:
https://inside.ai/en/contact/other/

4. Contact Information for the Accredited Personal Information Protection Organization to Which the Company Belongs

Accredited Personal Information Protection Organization Administrative Office,JIPDEC (Japan Institute for Promotion of Digital Economy and Community)
Address: Roppongi First Building, 9-9 Roppongi 1-chome,
Minato-ku, Tokyo 106-0032, Japan
Tel: +81-3-5860-7565 / 0120-700-779 (Japan only)

5. Measures taken for the safe management of retained personal data

We take necessary and appropriate measures (including supervision of employees and contractors) to prevent leakage, loss, or damage of retained personal data that we handle and to safely manage personal data. Please contact the “Personal Information Consultation Desk” above for specific details of said measures.

6. Disclosure, correction, suspension of use, etc. of retained personal data

The individual concerned may request notification of purpose of use, disclosure, correction, addition or deletion, or suspension of use, erasure or suspension of provision to a third party with respect to retained personal data we handle. Please contact the “Personal Information Consultation Desk” above for specific request procedures.

7．Cookies

Cookies are pieces of information stored on your browser when you access websites.

The Company or the services it uses may use cookies on its websites and related websites to obtain statistical information about access status and to measure advertising effectiveness. Cookies may also be used to track website usage and display appropriate advertisements. Please note that, unless you enter personal information, you cannot be identified and your anonymity will be maintained. If you do not wish cookies to be used, you may configure your web browser to refuse cookies. In that case, restrictions may apply, such as being unable to use some services.

8. Transmission of user information to external parties

The Company may use third-party analytics services and advertising delivery services for the following purposes. In doing so, the Company may transmit information about you that is necessary for such use, while respecting privacy protection.

1. Analysis of website visitors
   To provide better services and experiences for our users by analyzing the visitors to our websites
2. Advertisement distribution
   To deliver advertisements that meet our users’ interests

Transmitted information shall be handled in accordance with the privacy policies for each service.
Please refer to the links below to learn more about the privacy policies and how to opt-out the use of your information.

– Analysis of website visitors 

1. Google Analytics

• Sent to: Google LLC
• Information to be sent: Browser/device information, browsing history, browsing contents, etc.
• Purpose of use by the recipient: Google Privacy Policy, Reference information for notification and publication in accordance with Article 27-12 of the Telecommunications Business Act (for business operators) (*Japanese only)
• Opt out: Opt-out page

2. Microsoft Clarity

• Sent to: Microsoft Corporation
• Information to be sent: Browser/device information, browsing history, browsing contents, etc.
• Purpose of use by the recipient: Microsoft Privacy Statement
• Opt out: Opt-out page

3. Marketing Cloud Account Engagement (formerly Pardot)

• Sent to: Salesforce, Inc.
• Information to be sent: Browser/device information, browsing history, website activity,viewed content, etc.
• Purpose of use by the recipient: Salesforce Privacy Policy

– Advertisement distribution 

1. Google Ads

• Sent to: Google LLC
• Information to be sent: Advertising identifiers, information on terminals and apps, network information, access history, etc.
• Purpose of use by the recipient: Google Privacy Policy, Reference information for notification and publication in accordance with Article 27-12 of the Telecommunications Business Act (for business operators) (*Japanese only)
• Opt out: Opt-out page 

2. Yahoo! JAPAN Ads

• Sent to: LY Corporation
• Information to be sent: Advertising identifiers, information on terminals and apps, network information, access history, etc.
• Purpose of use by the recipient: LY Corporation Privacy Policy
• Opt out: Opt-out page
   
• Sent to: SoftBank Corp.
• Information to be sent: Device information (country/region information, communication environment, etc.), history information (browsing history, etc.), etc. of SoftBank terminals
• Purpose of use by the recipient: To improve delivery of Yahoo! JAPAN Ads
• Opt out: Opt-out page 

3. Facebook Ads

• Sent to: Meta Platforms Technologies Japan G.K.
• Information to be sent: Advertising identifiers, information on terminals and apps, network information, access history, etc.
• Purpose of use by the recipient: Privacy Policy 
• Opt out: Opt-out page

4. Microsoft Ads

• Sent to: Microsoft Corporation
• Information to be sent: Advertising identifiers, information on terminals and apps, network information, access history, etc.
• Purpose of use by the recipient: Microsoft Privacy Statement
• Opt out: Opt-out page 

5. MicroAd Ads

• Sent to: MicroAd, Inc.
• Information to be sent: Advertising identifiers, information on terminals and apps, network information, access history, etc.
• Purpose of use by the recipient: Privacy Policy (*Japanese only)   
• Opt out: Opt-out page (*Japanese only) 

6.Spider AF

• Sent to: Spider Labs Inc.
• Information to be sent: Advertising identifiers, information on terminals and apps, network information, access history, etc.
• Purpose of use by the recipient: Privacy Policy 

9．Personal Information Protection Manager

AI inside Inc.
Personal Information Protection Manager
Administration Division Director