Privacy Policy (Holoeyes Edu Service)

Holoeyes Inc. (hereinafter referred to as the “Company”) shall recognize the importance of protecting user information with regard to services operated and provided under the name of “Holoeyes Edu Service” as a Holoeyes Edu business, and shall comply with the provisions of the Act on the Protection of Personal Information (Act No. 57 of 2003, including subsequent revisions; hereinafter referred to as the “Personal Information Protection Act”) and other related laws and regulations, and shall endeavor to appropriately handle and protect the personal information of users (meaning personal information as defined in Paragraph 1 of Article 2 of the Personal Information Protection Act; the same shall apply hereinafter) and other user information in accordance with this Privacy Policy (hereinafter referred to as the “Privacy Policy”).
The definitions of terms used in this Privacy Policy shall be as per those stipulated in the Terms of Use (Holoeyes Edu Service) established by the Company (hereinafter referred to as the “Terms of Use”) with respect to the Holoeyes Edu Service provided by the Company (hereinafter referred to as the “Service”) except for those otherwise defined in this Privacy Policy.

1. Acquisition of Information
In order for a user to use this Service, the Company shall acquire personal information and other user information (including, but not limited to, the information listed below; hereinafter referred to as “User Information”) to the extent necessary for business by lawful and fair means (including, but not limited to, written documents, email, website pages, and oral reports), not by deception or other wrongful means.
(1) User’s email address
(2) The status of the use of this application by the user and the status pertaining to the viewing of polygon data and MR capture data (excluding personal information about the user)
(3) Information entered or sent by the user through an application form or other means specified by the Company

2. Purpose of Use of User Information
The Company shall use User Information for the following purposes:
(1) Acceptance of registrations for the Service, authentication of users, as well as the start, provision, maintenance, protection and improvement of the Service
(2) Analysis of the usage status of this application by the user and the viewing status of polygon data and MR capture data, and the use of the results of such analysis
(3) Implementation of surveys regarding the Service
(4) Provision of the Service and related maintenance and support
(5) Confirmation of circumstances after the use of the Service
(6) Announcements, sales and marketing activities by email or other methods concerning other services provided by the Company and other companies
(7) Marketing, surveys and analyses aimed at improving and enhancing the quality of the Service
(8) Response to inquiries, etc. to the Company
(9) Response to actions that are in breach of the Company’s Privacy Policy, Terms of Use and other terms of the Service (hereinafter collectively referred to as the “Terms, etc.”)
(10) Notifications such as changes to the Terms, etc. of the Service or other important information
(11) Other uses reasonably considered necessary for the provision of services provided by the Company

3. Change to the Purpose of Use of User Information
The Company may change the purpose of use of User information set forth in the preceding article to the extent that it is reasonably recognized that there is considerable relevance to the original purpose of use with users notified of the said changes or announced publicly in a manner separately specified by the Company.

4. Restrictions on Use Pertaining to User Information
Except as permitted by the Personal Information Protection Act and other laws and regulations, the Company shall not handle any User Information beyond the scope necessary to achieve the purpose of use specified above in Article 2, without the consent of the user. However, this shall not apply in the following cases:
(1) Cases in which the handling of User Information is based on laws and regulations.
(2) Cases in which the handling of User Information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the user.
(3) Cases in which the handling of User Information is specfically necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the user.
(4) Cases in which the handling of User Information is necessary for cooperating with a state organ, a local government or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the user is likely to impede the execution of the affairs concerned.

5. Security Control of User Information
The Company shall exercise necessary and appropriate supervision over the Company’s employee to ensure the security control of User Information for the prevention of loss, damage, falsification, or leakage of User Information. When the Company entrusts an individual or a business operator with the handling of User Information in whole or in part, the Company shall exercise necessary and appropriate supervision over the trustee to ensure the security control of the entrusted User Information.

6. Provision of Personal Information to a Third Party
The Company shall not provide personal information out of User Information to any third party except when disclosure is permitted under the Personal Information Protection Act or other laws and regulations. However, the following cases shall not fall under the provision of personal information to a third party as stipulated above:
(1) Cases in which a user has given consent (including cases where consent has been obtained for the Terms of Use that specify the provisions concerning the provision of personal information to a third party).
(2) Cases in which the Company entrusts the handling of personal information in whole or in part within the scope necessary for the achievement of the purpose of use set forth in Article 2.
(3) Cases in which personal information of users is provided as a result of the succession of business in a merger, company split, transfer of business or otherwise.
(4) Cases in which personal information is used jointly pursuant to the provisions of Article 7.
(5) Cases in which the handling of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the user.
(6) Cases in which the handling of personal information is specifically necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the user.
(7) Cases in which the handling of personal information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the user is likely to impede the execution of the affairs concerned.

7. Joint Use of Personal Information
In order to provide the Service to users, the Company may use the users’ personal information jointly with its Service-related partners within the scope necessary for the achievement of the purpose of use set forth in Article 2. In such a case, the Company shall publicly announce in advance the name of such partner, the purpose of joint use, the items of the information to be used jointly, and the person responsible for managing the information to be used jointly.

8. Creation and Use of Statistical Data
The Company may create statistical data relating to User Information based on User Information obtained from a user, after taking measures to prevent the identification of the specific individual and the restoration of such personal information. The Company shall appropriately use and provide such statistical data to a third party pursuant to the provisions of the Personal Information Protection Act.

9. Entrusting the Handling of User Information
The Company may entrust the handling of User Information obtained from the user in whole or in part to a third party. In such a case, the Company shall select a trustee to handle User Information appropriately, conclude a confidentiality agreement, etc. that is in compliance with this Privacy Policy with said trustee in advance, and exercise necessary and appropriate supervision over the trustee to ensure the secure control of the entrusted User Information.

10. Disclosure of Personal Information
When the Company is requested by a user to disclose personal information (including records on a third-party provision, hereinafter the same shall apply in this article)pursuant to the provisions of the Personal Information Protection Act, the Company shall disclose such personal information to the user without delay after confirming that the request has been made by the user themselves (in the event that such personal information does not exist, the Company shall notify to that effect). However, this provision shall not apply to cases where the Company is not obligated to disclose such information under the Personal Information Protection Act or other laws and regulations. 
Users may choose the method of disclosure from the following methods:
- Sending a written document
- Sending an e-mail to the e-mail address designated by the user
 *In cases where the contents to be disclosed are video or audio data, the method of disclosure may be determined separately by the Company. 
*In cases where disclosure by providing an electromagnetic record would require a large amount of cost, or in other cases where disclosure by such method is difficult, the Company will notify the user to that effect without delay and disclose the information in writing.
In addition, it should be noted that the handling fee (1,000 yen per case [excluding tax]) will be charged for the disclosure of personal information.

11. Correction, etc. of Personal Information
When the Company is requested by a user to correct, add, or delete personal information (hereinafter collectively referred to as “Correction, etc.”) pursuant to the provisions of the Personal Information Protection Act on the grounds that the personal information is contrary to fact, the Company shall confirm that the request has been made by the user themselves (including the confirmation of the identity and authority of an agent in cases where an application is being made by an agent). Thereupon, the Company shall conduct a necessary investigation without delay within the scope necessary for the achievement of the purpose of use as set forth in Article 2, and based on the results, make the Correction, etc. of the personal information, and notify the user to that effect (or if the Company makes a decision not to make the Correction, etc., the Company shall notify the user to that effect). However, this provision shall not apply to cases where the Company is not obligated to make Corrections, etc. under the Personal Information Protection Act or other laws or regulations, where the same or similar requests for Corrections, etc. have been made repeatedly without justifiable reason, or where excessive technical work is required to make the Correction, etc.

12. Discontinuation of Use, etc. of Personal Information
Where the Company is requested by a user to discontinue the use of or to erase their personal information (hereinafter referred to as “Discontinuation of Use, etc.”) pursuant to the provisions of the Personal Information Protection Act on the grounds that the personal information of the user is being handled beyond the scope of the purpose of use that has been publicly announced in advance or was obtained through deception or other wrongful means, or other grounds that are legally mandated, or where it is requested by the user to discontinue providing such personal information (hereinafter referred to as “Discontinuation of Provision”) pursuant to the provisions of the Personal Information Protection Act on the ground that personal information is being provided to a third party without the consent of the user, or other grounds that are legally mandated, and where it is found that there is reason for such request, the Company shall confirm that the request has been made by the user themselves (including the confirmation of the identity and authority of an agent in cases where an application is being made by an agent). The Company shall then discontinue using or providing the personal information without delay and notify the user to that effect. However, this provision shall not apply where the Company is not obligated to discontinue use or provision under the Personal Information Protection Act or other laws or regulations, or where the same or similar requests for Discontinuation of Use, etc. or Discontinuation of Provision have been made repeatedly without justifiable reason, or where excessive technical work is required to discontinue use or provision of personal information.

13. Use of Cookies and Other Technologies
The Service may use cookies and similar technologies. These technologies are useful for the Company to obtain an understanding of the situation of use of the Service and improve the Service. Users who wish to disable cookies can do so by changing their web browser settings. It should be noted, however, that some features of the Service may not function if cookies are disabled.

14. Inquiries
With respect to requests for disclosure, etc., comments, questions, complaints, and other inquiries regarding the handling of User Information, please use the following contact method:
Holoeyes Inc.
#303 Mourin Bldg., 2-17-3 Minami Aoyama, Minato-ku, Tokyo 107-0062
Email: info[at]holoeyes.jp  Attention: Personal Information Protection Desk
(When sending emails, please replace [at] with an @ mark)
(Reception hours: 10 a.m. to 6 p.m. on weekdays)

15. Procedures for Changing this Privacy Policy
The Company shall change this Privacy Policy as necessary. However, in cases in which any changes made to this Privacy Policy require the consent of users in accordance with applicable laws and regulations, the revised Privacy Policy shall apply only to users who have agreed to the changes in a manner prescribed by the Company. In the event that the Company makes any changes to this Privacy Policy, the Company shall publicly announce or notify users of the effective date and content of the revised Privacy Policy by posting it on the Company’s website or by other appropriate means.

Established: April 1, 2020
Last updated: April 13, 2022