Privacy Policy

Terilogy Holdings's Approach to Personal Information Protection and Requests to Website Users

Terilogy Holdings Corporation (hereafter, "the Company") takes the greatest care possible in the management of personal information belonging to users of the Terilogy website (hereafter, "the Company Website").

Gathering of Personal Information and Personal Information Disclosure

When users input information via the Company Website, the Company may request, when necessary, that users voluntarily provide their name, e-mail address and other personal information in survey format or similar. In principle, the Company does not disclose personal information to any third party except when so required by law or similar.

Personal Information Management

The Company carefully and strictly manages personal information collected from users.
The Company implements preventive measures against unauthorized access to users' personal information, as well as loss, destruction, fabrication, leakage and so forth of users' personal information. If any of these should occur, the Company will take immediate corrective measures.

Personal Information Usage

In principle, the Company uses personal information for the following purposes only, and for no other purpose. In the case of personal information usage for any purpose not described below, notification will be made on the websitein question or a separate, suitable website

As in-house reference information for purposes of improving the Company's services
As reference information in cooperative activities with the Company's business partners for purposes of improving the Company's services
For required purposes in conformity with the law, such as confirming bank account or credit card authenticity, validity, etc.
For purposes of contacting users regarding delivery of prizes won as part of prize or reward campaigns

Advertising and Promotional E-mail and Postal Mail

The Company may send information it deems useful via e-mail or postal mail to users, using registered personal contact information (e-mail address and/or postal address) and only after receiving permission in advance from each applicable user. After giving permission to the Company to send such materials and messages, the user may rescind said permission at a later date.

Please note that information on this website may be changed without prior user notification if the Company deems it necessary in response to changes in the Company's services and/or changes in online technologies.

Personal Information Protection Policy

Basic Policy on Personal Information Protection

Regarding the protection of personal information of our customers (including persons in charge at our business partners, applicants for employment at our company, and our employees), our company has established the following Basic Policy on Personal Information Protection (hereinafter referred to as "this Policy") and will handle personal information appropriately based on this Policy. Furthermore, the meanings of the terms used in this Policy shall comply with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act").

1. Regarding the Purpose of Use of Personal Information

Our company acquires the following personal information regarding customers:

Information regarding identity verification
Name, address, postal code, gender, date of birth, telephone number, email address, account ID and password, SNS account information, information regarding official certificates such as driver's license and certificate of residence, etc.
Information regarding transactions
Information regarding transaction details and purchase history, etc.
Information regarding payments
Information regarding financial institution accounts, information regarding payments and their methods, etc.
Information acquired upon using services
Online identifiers such as cookie IDs, terminal information used, location information, browsing history, and other service usage status (including access logs, IP addresses, browser information, browser language settings, etc.), etc.
Information captured by security cameras
Information regarding appearance, etc., captured by security cameras installed by our company
Information acquired in connection with recruitment screening
In addition to name, contact information, resume, etc., audio data and video data during interviews (including facial expression analysis), etc.
Other information
Information regarding inquiries and communications, etc., from customers to our compan

2. Purpose of Use

Our company will acquire and use customers' personal information within the scope of the following purposes of use (hereinafter referred to as "these Purposes of Use").

For registration to services, identity authentication during service use, and management of customers
For the delivery, provision, and after-sales service of products, etc.
For billing for the consideration of products, etc., and services
For the prevention of and response to fraudulent acts, etc.
For the maintenance and management of services
For the research and analysis of marketing data, as well as the consideration and implementation of marketing measures
To provide, solicit, advertise, and perform other marketing for products, etc., and services of our company or a third party, tailored to interests and concerns, etc., based on the analysis of customer attributes and behavior history, on the media of our company or a third party
For the implementation of campaigns, sweepstakes projects, and questionnaires
For the improvement of products, etc., and services, as well as the planning, research, and development of new products, etc., and services
For responding to inquiries and contacting customers
For crime prevention at facilities managed by our company
For provision to third parties by the methods described in this Policy
To analyze and utilize audio data and facial expression analysis data using AI, etc., with the consent of the applicant, for aptitude evaluation, hiring decisions, and quality improvement of the interview process in the course of recruitment screening

Furthermore, our company will also acquire and use customers' personal information for operations related to each of the above matters at our group companies (referring to our company or its parent company and their subsidiaries or affiliated companies. Please refer to this for our group companies at present).

3. Provision to Third Parties

Our company will not provide personal information handled by our company to a third party without obtaining the prior consent of the customer, except in the following cases.
- Cases based on laws and regulations.
- When it is necessary for the protection of a person's life, body, or property, and it is difficult to obtain the customer's consent.
- When it is especially necessary for the improvement of public health or the promotion of the sound growth of children, and it is difficult to obtain the customer's consent.
- When it is necessary to cooperate with a state organ, a local government, or a person entrusted by them in executing the affairs prescribed by laws and regulations, and obtaining the customer's consent is likely to impede the execution of the said affairs.
- Other cases permitted by laws and regulations.
Our company may provide your personal data to third parties in the following foreign countries. The country-specific information that should serve as a reference in such cases is currently as follows.
In order to select appropriate business operators as needed and outsource, although the contractors and their located countries cannot be specified at present, there are cases where we may outsource (provide) personal data to contractors in foreign countries other than the following. In this case, we may start outsourcing to a new contractor without obtaining the customer's consent again.
- United States of America (State of California)
- State of Israel
When providing personal information to a third party in a foreign country that has taken measures equivalent to those required to be taken by a personal information handling business operator based on the Personal Information Protection Act, our company takes necessary measures to ensure the continuous implementation of the said measures. For details on the said measures, please contact the "9. Inquiry Desk".

4. Joint Use

Our company will jointly use personal information as listed below.

Items of personal information to be jointly used
Information described in "1. Items of personal information to be acquired"
Purpose of use of personal information to be jointly used
These Purposes of Use
Scope of joint users
Our group companies （details here）
Management representative for joint use
Our company (1-1-1 Kanda-Jimbocho, Chiyoda-ku, Tokyo: Director and Executive Advisor Akihiko Abe)

5. Security Control Measures

Our company responds to requests for disclosure, etc. (referring to requests for notification of purpose of use, disclosure of personal information or third-party provision records, correction/addition/deletion, and suspension of use/suspension of third-party provision) as prescribed below.

6. Requests for Disclosure, etc.

Notification of purpose of use or disclosure of personal information or third-party provision records
Customers may request our company to notify the purpose of use or disclose personal information or third-party provision records within the scope permitted by the Personal Information Protection Act, in accordance with the procedures prescribed in (4). However, our company may not make a disclosure if any of the following items apply:
- When disclosure is likely to harm the life, body, property, or other rights and interests of the person themselves or a third party;
- When disclosure is likely to seriously impede the proper execution of our company's business;
- When disclosure would violate laws and regulations;
- When it cannot be confirmed that the request for disclosure is from the person themselves.
Correction, addition, deletion
Customers may request the correction, addition, or deletion of personal information in accordance with the procedures prescribed in (4). In that case, our company will conduct an investigation without delay within the scope necessary to achieve the purpose of use, and based on the results, correct, add, or delete the said personal information within the scope permitted by the Personal Information Protection Act.
Suspension of use or suspension of third-party provision
Customers may request the suspension of use or the suspension of third-party provision of personal information in accordance with the procedures prescribed in (4). In that case, our company will respond appropriately in accordance with the Personal Information Protection Act.
Procedures
When making a request for disclosure, etc., customers should contact the contact point prescribed in "9. Inquiry Desk". In addition, for the notification of the purpose of use and the disclosure of personal information or third-party provision records, we will charge a fee of 1000 yen per request. Please transfer it to the transfer destination described in the invoice. Furthermore, the prescribed fee will also be charged in the case of non-disclosure and non-notification of the purpose of use.

7. Handling of Cookies

Our company's website uses cookies and other similar technologies for tracking or analysis (hereinafter collectively referred to as "Cookies").

Overview of Cookies
A cookie is a small file in which arbitrary characters are written, and when a customer browses a website, it is exchanged between the web server and the viewer's internet browsing software (browser) and stored on the viewer's terminal. By utilizing this, we may acquire attribute information that cannot identify individuals, such as the customer's browsing history, service usage history, location information, etc. By configuring browser settings, customers can display in advance that it is a site using cookies, disable cookies, and delete already saved cookies. Please note that if you refuse to use cookies or delete cookies, the functions that can be used on the website may be restricted.
About Google Analytics
Our company uses Google Analytics provided by Google. Our company may receive the results of Google collecting and analyzing customers' browsing history based on cookies set by our company or Google, and use them to grasp customers' usage status or for our company's services. For Google's handling of data in Google Analytics, please see the company's site. "How Google uses information from sites or apps that use our services"

8. Inquiry Desk

For comments, questions, complaints, and other inquiries regarding the handling of personal information, please contact the desk below.

Address: 1-1-1 Kanda-Jimbocho, Chiyoda-ku, Tokyo
Inquiry form：https://www.terilogy-hd.com/contact/contact/index.html
Telephone number：03-3237-3291 (Reception hours: 9:30 - 17:00, excluding public holidays.)

Established: April 1, 2023
Revised: July 24, 2025
Revised: May 7, 2026
Terilogy Holdings Corporation