Privacy Policy

Privacy Policy

Lucky Job Co., Ltd. (hereinafter referred to as the “Company”) recognizes the importance of protecting personal information and complies with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”). The Company strives to handle and protect personal information appropriately in accordance with the following Privacy Policy (hereinafter referred to as this “Policy”). Unless otherwise defined in this Policy, the definitions of terms used herein shall follow those set forth in the Personal Information Protection Act.

1. Definition of Personal Information

In this Policy, “personal information” shall mean personal information as defined in Article 2, Paragraph 1 of the Personal Information Protection Act.

2. Purpose of Use of Personal Information

The Company uses personal information for the following purposes:

• To provide the Company’s services, products, etc. (collectively, the “Services”)
• To respond to inquiries and provide information related to the Services
• To notify users about the Services
• To take actions against acts that violate the Company’s terms, policies, etc. (collectively, the “Terms”)
• To notify users about changes to the Terms or other important matters
• To improve the Services and develop new services or products
• To understand and analyze browsing history, behavior history, and purchase history to improve the Services, add functions, and develop or advertise new products and services suited to users’ interests and preferences
• For employment management and internal administrative procedures (for employees)
• For shareholder management and legal procedures required by the Companies Act or other laws (for shareholders or stock option holders)
• To create statistical data in a form that does not identify individuals, in relation to the Services
• For the Company’s information provision, including advertising
• For other purposes incidental to the above

3. Change of Purpose of Use

The Company may change the purpose of use of personal information within a reasonably related scope and, when doing so, will notify or announce such change to the individual (hereinafter referred to as the “Data Subject”).

4. Restriction on Use of Personal Information

Except as permitted under the Personal Information Protection Act or other laws, the Company shall not handle personal information beyond the scope necessary to achieve the stated purposes of use without the consent of the Data Subject. However, the following cases are exceptions:

1. When required by law
2. When necessary to protect a person’s life, body, or property and obtaining consent is difficult
3. When especially necessary for improving public health or promoting the sound growth of children and obtaining consent is difficult
4. When necessary to cooperate with government agencies or local public bodies in performing legal duties, and obtaining consent would impede such duties
5. When providing data to academic research institutions for academic purposes (including partial academic use), provided that individuals’ rights and interests are not unjustly infringed

5. Proper Acquisition of Personal Information

5.1 The Company shall acquire personal information appropriately and not through false or other improper means.
5.2 The Company shall not acquire “special care-required personal information” (as defined in Article 2, Paragraph 3 of the Act) without prior consent of the Data Subject, except in the following cases:

• Cases corresponding to any of the items in Article 4 above
• When obtained from academic research institutions for academic purposes (including partial academic use) jointly with the Company
• When the information has been disclosed by the Data Subject, government bodies, or other designated entities
• When obtained visually or through photography, and the special nature of the information is obvious
• When provided under a form that does not constitute third-party provision as specified in Article 7.1

6. Security Management of Personal Information

The Company implements appropriate supervisory measures to prevent loss, destruction, alteration, or leakage of personal information and ensures proper management by employees and contractors.
Major measures include:

• Compliance with relevant laws and guidelines; inquiries and complaints are handled via the contact listed in Article 15
• Establishment of internal handling procedures and designation of responsible personnel for each process (acquisition, use, storage, deletion, etc.)
• Regular inspections and reporting systems for violations or risks
• Employee training and confidentiality obligations in work regulations
• Physical security measures (locked storage, anti-theft measures, restricted access)
• IT security measures (access control, antivirus, protection against unauthorized access)
• Verification and documentation of deletion or disposal of media containing personal data

7. Provision to Third Parties

7.1 Except in cases listed in Article 4, the Company will not provide personal information to third parties without the Data Subject’s consent. However, the following cases are not considered third-party provision:

• When outsourcing the handling of personal information within the scope necessary for achieving the purpose of use
• When personal information is provided due to business succession (e.g., merger)
• When jointly used as provided by law

7.2 If providing personal information to a third party located in a foreign country (excluding countries designated by the Personal Information Protection Commission as having equivalent standards), the Company will obtain prior consent or take measures required by law.

7.3 The Company keeps records of all third-party provisions as required by Article 29 of the Act.

7.4 The Company confirms and records when receiving personal information from third parties, as required by Article 30 of the Act.

7.5 Notwithstanding the above, the Company may provide user information to partner companies in accordance with its service terms or special agreements.

8. Handling of Personally Related Information

When obtaining “personally related information” from a third party as personal data, the Company will obtain prior consent from the Data Subject and use the data only within the purposes specified in Article 2.
When providing such information to third parties expected to use it as personal data, the Company will ensure that the recipient has obtained prior consent from the Data Subject.

9. Disclosure of Personal Information

Upon a Data Subject’s request for disclosure of retained personal data or third-party provision records, the Company will confirm the identity of the requester and disclose the information without delay (or notify if no such data exist). However, the Company may refuse disclosure if exempted by law.

10. Correction, etc. of Personal Information

When the Data Subject requests correction, addition, or deletion of personal information on the grounds of inaccuracy, the Company will confirm the requester’s identity, conduct necessary investigations, and make corrections or notify if no corrections are made, unless otherwise exempted by law.

11. Suspension of Use, etc. of Personal Information

If the Data Subject requests suspension of use, deletion, or cessation of provision of personal information based on legal grounds (e.g., improper acquisition or unauthorized use), the Company will confirm the identity of the requester, investigate, and act accordingly without delay, except where not required by law.

12. Handling of Anonymously Processed Information

12.1 The Company will process personal information into anonymously processed information in accordance with the standards set by the Personal Information Protection Commission.
12.2 The Company will take safety measures when creating such information.
12.3 The Company will disclose the items of personal information included in the anonymously processed information.
12.4 When providing anonymously processed information to third parties, the Company will disclose the items and methods of provision and indicate that the data are anonymized.
12.5 The Company will not collate anonymized data with other information or obtain deleted identifiers to re-identify individuals.
12.6 The Company will implement necessary safety and complaint-handling measures and publicly disclose such efforts.

13. Use of Cookies and Similar Technologies

The Company’s services may use cookies and similar technologies to understand usage and improve the service. Users can disable cookies in their browser settings, but some functions may become unavailable.

14. Use of External Services

The Company uses the following external services for analytics purposes:

Google Analytics and Google Analytics Advertising Features, including:

• Google Analytics Remarketing
• Google Display Network Impression Reports
• User Attributes and Interest Category Reports

Users can disable cookies or opt-out of data collection as described in each service’s privacy policy:

• Google Inc. Privacy Policy: https://policies.google.com/privacy
• Google Analytics Opt-Out Add-on: https://tools.google.com/dlpage/gaoptout

15. Name and Address of the Personal Information Handling Business Operator

Lucky Job Co., Ltd.
2-18-10 Okubo, Shinjuku-ku, Tokyo 169-0072, Japan
Shinjuku Sky Plaza 707

16. Contact for Inquiries

For disclosure requests, opinions, questions, or complaints regarding personal information, please contact:

Personal Information Inquiry Desk
Main Phone:：03-6685-4334

Phone：080-9368-2801 

17. Continuous Improvement

The Company will regularly review its personal information management practices and may revise this Policy as necessary.

Enacted on January 9, 2025