CandidatePrivacy Policy

UPSIDER, Inc. (“we”, “us”, or “our”) conducts its recruitment activities in accordance with this Candidate Privacy Policy (this “Policy”). Based on our general Privacy Policy, this Policy outlines how we handle the personal information of applicants, internship participants, attendees of career-related events, and anyone who contacts us regarding employment opportunities (collectively, “candidates”).

It explains how candidates’ personal information is collected, used, and managed during our recruitment process.

To ensure candidates can apply with confidence, we are committed to complying with all applicable data protection laws and maintaining strict internal standards for the collection, use, and management of personal information. By submitting your application, you acknowledge and agree to the handling of your personal information as described in this Policy.

Personal information

“Personal information” refers to any information relating to a candidate that can identify them, such as their name, address, telephone number, email address, or date of birth. This also includes information that may not identify a candidate on its own but can easily be combined with other data to identify them.

Please note that we may also record audio or video during interviews and similar sessions as part of our data collection.

Purposes of use

We will use personal information solely for the following purposes and will not use it beyond this scope:

  • --To evaluate an applicant's qualifications, skills, and experience during document screening and interviews
  • --To communicate with applicants, including scheduling interviews
  • --To check for any previous applications submitted to us
  • --To administer aptitude tests (such as SPI) and conduct reference checks, either directly or through authorized third parties
  • --To generate statistical data for formulating future hiring strategies
  • --To notify candidates about other potential job opportunities
  • --To request participation in surveys aimed at improving our recruitment process
  • --To manage and enhance our overall recruitment process
  • --To provide information regarding recruitment-related events
  • --To send materials related to internship participation
  • --To keep in touch with applicants who declined an offer or were not selected, regarding future job opportunities
  • --For recruitment marketing purposes
  • --For personnel and labor management purposes, if an applicant is hired

Provision to third parties

We will not provide or disclose personal information to third parties without the candidate's prior consent, except as required by law or in the following cases:

  • --When outsourcing tasks related to our recruitment activities
  • --When a candidate applies through a recruitment agency or other intermediary, and we need to share information with them to fulfill the “Purposes of Use”
  • --When necessary to protect human life, body, or property, and obtaining consent is difficult
  • --When necessary to improve public health or promote the sound growth of children, and obtaining consent is difficult
  • --When necessary to cooperate with national or local government agencies in executing their lawful duties, and obtaining consent may impede such duties
  • --When personal information is transferred as part of a business succession, such as a merger, company split, or business transfer
  • --In other cases where we deem disclosure necessary, provided we have obtained the candidate's explicit consent.

Pseudonymously processed information

We may process personal information into Pseudonymously Processed Information (as defined in the Act on the Protection of Personal Information) so that individuals cannot be identified, and use it in that form. This is done by deleting or replacing identifiable data items with random strings to generalize the information. We handle Pseudonymously Processed Information appropriately and strictly within the scope of the purposes of use outlined above.

Joint use of personal information

During our recruitment activities, we may jointly use candidates' personal information with our group companies as detailed below:

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Items of personal information jointly used:
Any items of the acquired personal information necessary to achieve the purposes of joint use
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Purposes of joint use:
The same purposes outlined in the “Purposes of Use” section above
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Scope of joint users:
Our group companies (including our parent company, subsidiaries, and affiliates as defined under applicable financial regulations)
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Party responsible for management of personal information:
7-15-7 Roppongi, Minato-ku, Tokyo
UPSIDER, Inc. Representative Director, Toru Miyagi

Entrustment of personal information

We may outsource the handling of all or part of candidates' personal information to third-party service providers to the extent necessary to achieve our purposes of use. In such cases, we rigorously evaluate the provider's suitability, enforce strict confidentiality agreements, and ensure proper data management protocols are in place. We may also engage in the joint use of personal information in accordance with the Act on the Protection of Personal Information.

Disclosure of personal information

If a candidate requests the disclosure of their personal information (including records of third-party provision) under the Act on the Protection of Personal Information, we will verify the candidate's identity and disclose the information without delay. If the requested information does not exist, we will notify the candidate. However, we may withhold disclosure if we are not legally obligated to provide it under applicable laws.

Correction of personal information

If a candidate requests the correction, addition, or deletion of their personal information on the grounds that it is inaccurate, we will verify their identity, conduct a prompt investigation, and update the information as necessary. We will notify the candidate of the outcome, including any decision not to make corrections. However, we may refuse such requests if we are not legally obligated to fulfill them.

Suspension of use of personal information

If a candidate requests the suspension of use, erasure, or cessation of third-party provision of their personal information, and the request is found to be valid under the Act on the Protection of Personal Information, we will verify their identity and fulfill the request without delay, notifying the candidate accordingly. However, we may deny such requests if we are not legally obligated to comply under applicable laws.

Security

We implement robust security measures to protect the personal information provided by candidates against unauthorized third-party access. We strictly manage data using firewalls, intrusion detection systems, and other internal security standards to prevent loss, destruction, alteration, or leakage. Additionally, we conduct regular internal and external training on data protection for our staff.

Logs

The Recruitment Site collects access and operation logs, which include IP addresses, OS and device information, and access timestamps. This information is not used to identify individuals. Instead, we use it to analyze usage environments, improve our services, and prevent fraudulent activities. Search records are stored anonymously and used strictly for statistical purposes.

Updates to this Policy

We continuously review and strive to improve our data handling practices, and we reserve the right to update this Policy as necessary. Any changes will be published on our website. If a change requires candidate consent under applicable law, we will obtain such consent through our designated procedures.

Contact

Shin-Roppongi Building 811, 7-15-7 Roppongi, Minato-ku, Tokyo 106-0032, Japan

UPSIDER, Inc. — Recruiting Team

Email: [email protected]

Established December 27, 2024

UPSIDER, Inc.

7-15-7 Roppongi, Minato-ku, Tokyo

Representative Director, Toru Miyagi