The term “personal information” as used in this Policy shall refer to any information relating to a natural person that corresponds to one or more of the following. Furthermore, in the event that the Act on the Protection of Personal Information or any other relevant laws and regulations are revised, the definition of the term “personal information” as used herein shall conform to such revision(s).

(1)Any name, date of birth, or other descriptions that can be used to identify an individual (including information which can be easily combined with other information to identify an individual), whether stated, recorded, or otherwise expressed using voice, movement, or other methods in a document, drawing, or electromagnetic recording; or

(2)Any information containing an individual identification code.

MIMIR uses personal information for the purposes listed below.

(1)To provide and manage transactions related to the products and services offered by MIMIR;

(2)To provide information on, engage in marketing activities related to, and respond to inquiries concerning the products and services offered by MIMIR and Uzabase, Inc., including its subsidiaries and affiliates (hereinafter referred to as the “Uzabase Group”);

(3)To provide information on surveys, campaigns, and other correspondence from MIMIR and the Uzabase Group;

(4)To address any violations of the MIMIR Terms of Use or other policies (hereinafter referred to as the “Terms and Conditions”) pertaining to the use of the products and services offered by MIMIR;

(5)To provide notice of any revisions to the Terms and Conditions pertaining to the products and services offered by MIMIR;

(6)To assist in the development of new services (including the creation of a new database for the launch of a new service) or the improvement of existing products and services offered by MIMIR and the Uzabase Group;

(7)To compile, analyze, or otherwise manipulate statistical data relating to the products and services offered by MIMIR and the Uzabase Group in a manner that does not allow for the personal identification of individual owners of such data;

(8)To plan, operate, hold, or provide notice of events, conferences, and seminars organized by MIMIR and the Uzabase Group; and

(9)Any other purposes related to those listed above.

To the extent that it is reasonably deemed to be relevant, MIMIR may change the purposes for which it utilizes the personal information it collects. However, in such cases, MIMIR will issue a public announcement or notify the individual owner of such information (hereinafter referred to as the “Individual”) of any such changes.

Except where explicitly permitted by the Act on the Protection of Personal Information or any other relevant laws and regulations, MIMIR shall not collect any personal information in excess of that required for the fulfillment of the above-mentioned purposes without first receiving the consent of the concerned Individual.

5.1 MIMIR obtains personal information in a proper manner and does not acquire such information by deception or other wrongful means.

5.2 MIMR does not acquire sensitive personal information without first obtaining consent from the concerned Individual to do so, except in the following cases:

(1)Cases in which it is permitted by the Act on the Protection of Personal Information or under other applicable laws and regulations;
(2)Cases in which such sensitive personal information has already been made public by the Individual, a national government agency, a local government, an academic research institution, a business operator set forth in one of the items of Article 57.1 of the Act on the Protection of Personal Information, or any other person or business operator prescribed by rules of the Personal Information Protection Commission;
(3)Cases in which an Individual is visually observed or photographed, and the sensitive personal information is acquired in such a way that is obvious from their external appearance; or
(4)Cases in which sensitive personal information is acquired in a manner that is not deemed to constitute provision to a third party under Article 7.1 of this Policy.

5.3 Upon receiving personal data (as defined in the Act on the Protection of Personal Information) from a third party, MIMIR shall confirm the following in accordance with the rules of the Personal Information Protection Commission. However, this shall not apply to cases in which such personal data is acquired in a manner that is not deemed to constitute provision to a third party under the Act on the Protection of Personal Information or under Article 7.1 of this Policy.

(1)The name and address of such third party, as well as the name of its representative in the case of a corporation (or the name of its representative or administrator in the case of non-corporate entity with such a position)
(2)Circumstances under which such personal data was acquired by such third party

MIMIR supervises its employees to the extent that it is appropriate and necessary to ensure that personal information in its possession is managed securely against risks such as loss, destruction, alteration, and unauthorized disclosure. In cases where the handling of personal information is subcontracted (in part or in whole), MIMIR will conduct the necessary and appropriate supervision of such subcontracted third party to ensure that such personal information is securely managed.

7.1 MIMIR does not provide personal data to any third parties without receiving prior consent from the concerned Individual except in the following cases which, for the purposes of this Policy, shall not constitute a provision of personal information to a third party.

(1)Cases in which such provision is conducted in accordance with MIMIR’s outsourcing of the handling of personal data (in part or in whole) to the extent necessary for fulfilling the above-mentioned purposes;
(2)Cases in which such provision is conducted in accordance with a business succession resulting from a merger, acquisition, or other related action;
(3)Cases in which such provision is conducted in accordance with shared use as permitted under the Act on the Protection of Personal Information; or
(4)Cases in which such provision is conducted in accordance with the Act on the Protection of Personal Information or other applicable laws and regulations.

7.2 By agreeing to the terms of this Privacy Policy, both Consultees (users who have entrusted MIMIR or the Uzabase Group with the task of acquiring knowledge from Experts in MIMIR’s Expert Network) and Experts (individuals who have registered as Experts under MIMIR’s Expert Network and who provide knowledge to Consultees in accordance with commissions from MIMIR) shall be deemed to have consented to the provision of personal data to third parties outlined in (i) and (ii) below; provided, however, that such provision shall be limited to parties that have pledged to MIMIR and/or the Uzabase Group that they recognize the importance of safeguarding personal information and will comply with the Act on the Protection of Personal Information and any related guidelines, and maintain the confidentiality of such data and not provide it to any third party without obtaining the prior consent of the providing Expert or Consultee.

(1)Provision of personal data pertaining to Experts to current or prospective Consultees to the extent necessary for the provision of services or informational purposes
(2)Provision of personal data obtained by MIMIR from Consultees to Experts

7.3 The provision of personal data to third parties located in foreign countries (i.e., any countries or territories located outside the borders of Japan) is stipulated in Article 9 of this Policy.

7.4 In the event that it provides any personal information to a third party, MIMIR shall create and keep a record of any such provisions in accordance with the Act on the Protection of Personal Information.

7.5 In the event that it obtains any personal information from a third party, MIMIR shall make any necessary confirmations and create and keep a record of such confirmations in accordance with the provisions of Article 5.3 above.

In order to provide higher quality services, MIMIR shares personal data under strict management and with appropriate security measures in place.

Shared Personal Data
Personal data obtained by MIMIR such as names, e-mail addresses, genders, phone numbers, dates of birth, addresses, industries of expertise, areas of specialization, short CVs, career summaries, detailed work histories, employers, and job titles

Scope of Sharing
Uzabase Group

Purpose of Shared Usage
Identical to the purpose stipulated in Article 2 of this Policy (however, with instances of “MIMIR” replaced with “Uzabase Group”)

Responsible Party for Shared Usage of Personal Data
Uzabase, Inc. (see here for contact details)

For more information on the shared usage of personal data with Uzabase Group companies located in foreign countries, see Article 9 below.

MIMIR may provide personal data to third parties located in foreign countries to be used, stored, or otherwise handled (hereinafter referred to as “Provision, etc.”) in the following cases. To view a list of the names and information on the relevant privacy regulations of countries to which MIMIR may make such Provision, etc., see here (Japanese only).

When Providing Personal Data to Third Parties (Including Outsourcing of its Handling)
MIMIR may provide personal data to third parties located in foreign countries to the extent required to fulfill the purposes outlined above. However, as indicated therein, any such provision of personal data as stipulated in Article 7.2 above shall be limited to parties that have pledged to MIMIR and/or the Uzabase Group that they recognize the importance of safeguarding personal information and will comply with the Act on the Protection of Personal Information and any related guidelines, and maintain the confidentiality of such data and not provide it to any third party without obtaining the prior consent of the providing Expert or Consultee.

MIMIR may also outsource the handling of personal data (in part or in whole) to a third party located in a foreign country. In such cases, MIMIR shall conduct necessary and appropriate supervision of such subcontracted third parties to ensure that the personal information in its possession is securely managed.

When Sharing Personal Data with Uzabase Group Companies in Foreign Countries
MIMIR shares personal data with Uzabase Group companies located in foreign countries in accordance with the provisions of Article 8 above.
Each company of the Uzabase Group located outside of Japan has implemented the necessary systems to ensure that measures equivalent to those required by enterprises handling personal information under the Act on the Protection of Personal Information can be continuously taken.

See here for a list of countries and regions where Uzabase Group companies are located.

When Outsourcing the Storage of Personal Data to Third Parties in Foreign Countries
MIMIR may outsource the storage of personal data via a cloud-based service or other means to a subcontracted third party located in a foreign country (in cases where it does not constitute the outsourcing of the handling of such personal data). In such a case, MIMIR shall conduct necessary and appropriate supervision of such subcontracted third party to ensure the protection of such data.

Upon receiving a request from an Individual to disclose personal information in accordance with the provisions of the Act on the Protection of Personal Information, MIMIR shall disclose such information to the Individual without delay after first confirming the identity of the Individual in question (if it does not possess such information, MIMIR shall notify the Individual of that fact). However, this shall not apply to information MIMIR is not obligated to disclose under the Act on the Protection of Personal Information or other relevant laws and regulations.

Upon receiving a request from an Individual to correct, add, or delete content from personal information that is not factual (hereinafter referred to as “Corrections, etc.”), MIMIR shall confirm the identity of the Individual in question and, to the extent that it is necessary for the fulfillment of the above-mentioned purposes, conduct a prompt investigation as required. Based on the results of investigation, MIMIR shall make any necessary Corrections, etc. to the personal information and notify the concerned Individual thereof (if it is determined that no Correction, etc. is necessary, MIMIR shall notify the concerned Individual of that fact). However, this shall not apply to information MIMIR is not obligated to make Corrections, etc. to under the Act on the Protection of Personal Information or other relevant laws and regulations.

Upon receiving a request from an Individual to discontinue using or delete their personal information (hereinafter referred to as “Discontinuance of Use, etc.”) in accordance with the provisions of the Act on the Protection of Personal Information for reasons that it is being handled beyond the scope of its publicly announced purposes or has been obtained through fraudulent or otherwise unauthorized means, or upon receiving a request from an Individual to discontinue providing their personal information (hereinafter referred to as “Discontinuance of Provision, etc.”) to a third party in accordance with the provisions of the Act on the Protection of Personal Information for reasons that it is being provided to such third party without permission, MIMIR shall, in the event that such claim is found to have grounds, discontinue the use or provision of such personal information without delay and notify the concerned Individual after first confirming their identity. However, this shall not apply to information whose use or provision MIMIR is not obligated to discontinue under the Act on the Protection of Personal Information or other relevant laws and regulations.

13.1 When producing anonymized information (limited to information constituting an anonymized information database, etc.; the definition of “Anonymized Information” and “Anonymized Information Database, etc.” as used herein shall conform to the definitions stipulated in the Act on the Protection of Personal Information), MIMIR shall process personal information in accordance with the standards prescribed in the Enforcement Rules for the Act on the Protection of Personal Information by the Personal Information Protection Commission of Japan.

13.2 When it has produced Anonymized Information, MIMIR shall take measures to ensure its secure management in accordance with the standards prescribed in the Enforcement Rules for the Act on the Protection of Personal Information by the Personal Information Protection Commission of Japan.

13.3 When it has produced Anonymized Information, MIMIR shall, pursuant to the Enforcement Rules for the Act on the Protection of Personal Information of the Personal Information Protection Commission of Japan, disclose to the public the categories of information relating to an individual contained in any such Anonymized Information.

13.4 When providing Anonymized Information (including information which it produced internally or obtained from a third-party source; hereinafter the same unless otherwise stated) to a third party, MIMIR shall, pursuant to the Enforcement Rules for the Act on the Protection of Personal Information of the Personal Information Protection Commission of Japan, disclose to the public in advance the categories of personal information relating to an individual contained in any Anonymized Information to be provided to a third party and the manner in which it is to be provided. MIMIR shall also explicitly indicate to such third party that such information is Anonymized Information. 

13.5 When handling Anonymized Information, MIMIR shall neither (1) compare such Anonymized Information with any other information, nor (2) obtain any details or descriptions deleted from such personal information, any individual identification codes, or any information relating to the manner in which it was processed pursuant to the provisions of the Act on the Protection of Personal Information in order to identify the Individual to whom the personal information used to produce such Anonymized Information pertains. For the purposes of this section, the provisions of (2) shall only apply to such Anonymized Information obtained from third party sources.

13.6 MIMIR shall endeavor to take all necessary and appropriate measures for the secure management of Anonymized Information and all necessary actions to ensure the proper handling of any Anonymized Information including the handling of any complaints regarding the creation or any other handling of such Anonymized Information. MIMIR shall also endeavor to disclose to the public the content of any such measures and actions taken.

MIMIR may use cookies and other similar technologies on its website(s). These technologies help MIMIR understand how users interact with its services, which contributes to their improvement. Users who wish to disable cookies can do so by changing their browser settings. However, please note that doing so may render certain features of the MIMIR site unusable.

To make a request for disclosure, file a complaint, or make any other inquiries related to the handling of personal information, please contact us at the email address below.

Personal Information Inquiries: privacy@uzabase.com

As part of its constant efforts to improve its management of personal information, MIMIR may regularly review and alter the contents of this Policy as necessary.