Date of Enactment: February 5, 2007
Date of Last Amendment: May 27, 2025
Leverages Group (hereinafter referred to as the “Group”) addresses the following in order to properly handle personal information entrusted to us by customers, officers and employees of the Group, and all other stakeholders of the Group.
Obtaining, using and providing personal information
We will properly obtain, use and provide personal information to the extent necessary to conduct our business. We will use the personal information we obtain only for our intended purposes, and will take measures to prevent the unintended use of such information.
In addition, when delegating all or part of the handling of personal information, the Group will select a delegate that fully meets the selection criteria.
Compliance with laws and regulations, guidelines, and standards regarding personal information
When handling personal information, we will comply with laws and regulations, guidelines established by relevant governmental authorities, and other standards regarding the protection of personal information.
Proper management of personal information
We will take appropriate security control measures necessary to prevent any leakage, loss, alteration or other mishandling of personal information.
Responding to complaints and inquiries
We will respond promptly to complaints and inquiries regarding personal information.
Measures to protect personal information
The Group manages the handling of personal information and the personal information protection system so that proper operation is implemented, and continuously reviews and improves its efforts to protect personal information.
Handling of Personal Information
Purposes of using personal information
Personal information and other customer information provided to the Group will be used for the following purposes.
In addition, if the purpose of use is separately indicated to a principal upon collection of personal information and other customer information, such as when specified in the terms of use of services, those purposes are included.
Furthermore, in using personal information, in addition to cases where it is used in combination with other customer information, the Group may obtain (not only directly from a customer, but also from advertisers and other third parties; the same applies below) usage log information such as cookies, device information, IP addresses, attribute information, location information, advertising identifiers, and action history (i.e., the history of opening and using screens on application software, history of clicking on links, history of browsing web pages, and other behavioral history) and utilize them by checking them against the customer's registration information and other personal information held by the Group.
1) Information about individual customers
● Various procedures concerning registration for using services provided by the Group and various procedures concerning identity verification
● Guidance and provision of services for which an inquiry or application has been made
・If a customer uses multiple services offered by the Group, we may view and use the customer's personal information across services.
● Provision of information related to applied services and guidance on other services (including other services provided by each company of the Group and businesses in alliance with the Group, etc.), mediation to other services, and confirmation of use status, etc.
・Guidance may be provided via e-mail (including sending of advertising emails), push notifications by applications for smartphones, etc., or telephone calls, and Internet advertisements (including targeted advertisements) may be distributed and their effectiveness measured.
● Accurate recording and reconfirmation of the contents of calls (including online calls) and utilization for improving the quality of responses
・In the case of communication from customers or from the Group via telephone, online conferencing systems, or any other means, the contents of calls may be recorded or videotaped.
● Analysis for development and improvement of applied services and other services of the Group as a whole, analysis of service registration paths, statistical processing, and utilization for deep learning such as machine learning and large language models (LLMs)
・Depending on the services used, we may continue to use a customer's information after the customer's membership has terminated.
● Requests for cooperation in surveys, etc. relating to the business activities of the Group (including the selection of individuals to whom we will make such request)
● Recruiting of interviewees for creating article content
● Investigation regarding prohibited matters stipulated in the terms of use of applied services and measures based thereon
● Any other tasks equivalent or incidental to the foregoing
2) Information on officers and employees of business partners (including delegates, etc. of business partners)
● Various procedures concerning registration for using services provided by the Group
● Guidance and provision of services for which an inquiry or application has been made, and listening to requests
・If a business partner uses multiple services offered by the Group, we may view and use the personal information across services.
● Provision of information related to applied services and guidance on other services (including other services provided by each company of the Group and businesses in alliance with the Group, etc.), mediation to other services, and confirmation of use status, etc.
・Guidance may be provided via e-mail (including sending of advertising emails) or telephone calls, and Internet advertisements (including targeted advertisements) may be distributed and their effectiveness measured.
● Accurate recording and reconfirmation of the contents of calls (including online calls) and utilization for improving the quality of responses
・In the case of communication from customers or from the Group via telephone, online conferencing systems, or any other means, the contents of calls may be recorded or videotaped.
● Management of business partners
● Analysis for development and improvement of applied services and other services of the Group as a whole, statistical processing, and utilization for deep learning such as machine learning and large language models (LLMs)
● Requests for cooperation in surveys, etc. relating to the business activities of the Group (including selection of request targets)
● Recruiting of interviewees for creating article content
● Investigation regarding prohibited matters stipulated in the terms of use of applied services and measures accompanying this
● Any other tasks equivalent or incidental to the foregoing
3) Information on other related parties
① Information acquired from publicly disclosed or limitedly disclosed information:
● Building business relationships
● Guidance on various services provided by each company of the Group and alliance partners, and sending materials
● Analysis for service development and improvement, statistical processing, and utilization for deep learning such as machine learning and large language models (LLMs)
② Information acquired in connection with the Group being outsourced business:
● Execution of outsourced business
③ Information acquired in connection with receiving inquiries, etc.:
● Responding to inquiries, etc.
● Identity verification of a principal
● Guidance on various services provided by each company of the Group or businesses in alliance with the Group, and sending materials
● Accurate recording and reconfirmation of the contents of calls (including online calls) and utilization for improving response quality
・In the case of communication from customers or from the Group via telephone, online conferencing systems, or any other means, the contents of calls may be recorded or videotaped.
● Understanding service usage, and aggregating and analyzing data, and preparing statistical materials for quality improvement
④ Information obtained through public relations interviews:
● Publication in public relations media and various media of each company of the Group
● Communication regarding public relations activities
⑤ Information on those who applied for questionnaires, campaigns, presents, events, etc.:
● Drawing and sending of prizes (awards)
● Communication to applicants
● Operation and implementation of applied campaigns, etc.
⑥ Information on visitors to offices:
● Security management such as crime prevention
● Reservation management and history management of visitors to the Group facilities, equipment, etc.
⑦ Information on those who applied for recruitment (including internships) of the Group:
● Recruitment activities of the Group (not limited to the entity to which the application was made)
● Selection, decision-making, and interviews regarding recruitment
● Personnel management of applicants after joining the Company
● Guidance on various briefing sessions of the Group (not limited to the entity to which the application was made) and acceptance of applications
● Guidance on various information, etc. and sending materials concerning the Group (not limited to the entity to which the application was made)
● Clarification of recruitment criteria of the Company and the Group, and analysis for recruitment selection efficiency (including comparison with data of employees of the Group at the time of their application selection, etc.)
● Any other tasks equivalent or incidental to the foregoing
※Please note that some of the documents entrusted to us may not be returned.
Provision of Personal Information to Third Parties
1) Personal information of individual customers may be provided and disclosed to third parties as set out below:
Recipient: Companies, businesses, organizations, etc. using the services of the Group, as well as businesses in alliance with the Group and companies, businesses, organizations, etc. using the services of said businesses (hereinafter collectively referred to as "Business Partner Companies, etc.")
【Occasions of Provision】
● The Group, for the purpose of providing services such as job offerings, projects, or scouting for freelancers, regular employees, or temporary employees based on the request of a customer, and for the purpose of smooth implementation of consideration, selection, etc. at Business Partner Companies, etc. to which introductions are made, provides customer information on behalf of the customer or by itself to the various services of the Group, or to Business Partner Companies, etc. using alliance partners or the services of alliance partners, or discloses it by displaying/posting it on websites or applications that these Business Partner Companies, etc. can browse. In such provision/disclosure, the Group may limit the provision of customer information by making part of the customer's information unbrowsable.
In addition, as part of providing the above services, information may be provided in the following situations:
－When an individual customer directly transmits information (e.g., applying for projects/jobs): Information is provided to the recruiter by operating the application screen.
－When applying for events: Registration information is provided to event participating companies on behalf of the registered person.
－When answering questionnaires provided by recruiters, etc.: The Group may provide answers on behalf of the individual customer.
●The Group provides customer information to Business Partner Companies, etc. within the necessary scope for dispatching services, human resource education (schools), platform provision, moving-in introduction services, in-house media, and other service provisions of the Group.
【Items Provided】
●Customer's name, contact details (address, phone number, e-mail address, etc.), qualifications, profile information such as educational and occupational history, service utilization information such as questionnaire answers and analysis results thereof, and other information provided by the customer to the Group or obtained from provided information.
●Information notified by the individual customer to the Group representative (in the case of employment placement, information provided during the employment placement process).
●Service utilization and behavioral history (processed information based on service utilization and behavioral history is also provided).
Recipient: Employment placement agencies
【Occasions of Provision】
In connection with the provision of applied services, when another employment placement agency contacts a job seeker, introduces a job, or invites them to an interview, information is provided on behalf of the individual customer.
●Contact to job seekers by employment placement agencies: Accompanied by the provision of applied services, other employment placement agencies will be able to browse information.
●Desire for interviews with employment placement agencies: Provided when, after contact from an employment placement agency, the customer desires an interview with the employment placement agency holding the job offering.
【Items Provided】
●Customer's name, contact details (address, phone number, e-mail address, etc.), qualifications, profile information such as educational and occupational history, service utilization information such as questionnaire answers and analysis results thereof, and other information provided by the customer to the Group or obtained from provided information.
●Information notified by the individual customer to the Group representative (in the case of employment placement, information provided during the employment placement process).
●Service utilization and behavioral history (processed information based on service utilization and behavioral history is also provided).
Recipient: Client business operators (dispatch destinations)
【Occasions of Provision】
When utilizing the temporary staffing services of the Group, information may be provided to client business operators based on laws and regulations such as the Worker Dispatching Act, or to respond to qualification inquiries regarding temporary workers from the client business operator.
【Items Provided】
Information registered by temporary workers in the Group's system, information concerning job performance capabilities (including qualification certificates such as nursing licenses).
Recipient: Alliance partners
【Occasions of Provision】
Information may be provided to alliance partners of the Group on behalf of customers for mediation to services provided by said alliance partners.
【Items Provided】
Customer's name, phone number, address, and other information provided by the customer to the Group (items necessary for the occasion of provision are provided).
Recipient: Business operators outsourced with introducing the Group's services
【Occasions of Provision】
Information may be provided to business operators outsourced with introducing the Group's services for marketing activities including advertising distribution and measurement of its advertising effectiveness, improvement/expansion of targets, calculation of commissions, and stopping guidance distribution after user registration.
【Items Provided】
Fact of registration, registration information, dates such as registration date of the customer, and other personal information held by the Group (information necessary for advertising distribution and measurement of advertising effectiveness).
Recipient: Advertising distribution business operators
【Occasions of Provision】
Provided to advertising operators for advertising distribution and measurement of advertising effectiveness concerning services provided by the Group.
【Items Provided】
Customer registration information, utilization log information, and other personal information held by the Group (e-mail address, phone number, and other information necessary for advertising distribution and measurement of advertising effectiveness).
Recipient: Alliance partners (subcontractors supporting the operations of the Group)
【Occasions of Provision】
Within the scope necessary to achieve the purposes described in the preceding Paragraph 1, the handling of various types of information may be outsourced to subcontractors in Japan or other countries. Such subcontractors include IT service providers and data hosting providers, etc.
【Items Provided】
User's registration information, dates such as registration date, and other personal information held by the Group (items necessary for the occasion of provision are provided).
*In addition to the above, personal information may be provided to third parties if the principal's consent is obtained.
2) Provision of Customer Information to Third Parties in Foreign Countries
●The Group may provide customer information when a customer conducts job-hunting activities/applications, etc. to foreign companies, when a business operator in a foreign country conducts scouting/recruitment activities, etc. through services operated by the Group, or when necessary for the Group to provide services. The items to be provided are as described in the preceding section.
Please check below for details regarding the recipient:
Name of the foreign country where the recipient is located: Japan (if information is located outside Japan), United States of America, United Mexican States, India, Socialist Republic of Vietnam, Hong Kong, People's Republic of China, Republic of Singapore, Republic of Indonesia, Republic of the Philippines, and other countries where recruiters are located.
Personal information protection system in the foreign country of the recipient: The personal information protection systems of each country are posted under the "Documents on Information Provision" section of the "Survey on Systems for Protection of Personal Information in Foreign Countries" page of the Personal Information Protection Commission website (link below). Please check the contents of the personal information protection system of the country where the foreign company you applied to or conducted job-hunting activities with is located:
Personal information protection measures taken by foreign business operators: In contracts with foreign companies that are recipients, it is stipulated that the recipient shall comply with the personal information protection system of the country where said foreign company is located.
●The Group may provide customer information when utilizing services provided by foreign advertising operators for advertising distribution and measurement of advertising effectiveness concerning services of the Group. The items to be provided are as described in the preceding section.
Please check below for details regarding the recipient:
Name of the foreign country where the recipient is located: United States of America, French Republic, Republic of Singapore.
Personal information protection system in the foreign country of the recipient: The personal information protection systems of each country are posted under the "Documents on Information Provision" section of the "Survey on Systems for Protection of Personal Information in Foreign Countries" page of the Personal Information Protection Commission website (link below). Please check the contents of the personal information protection system of the country where said advertising operator is located:
Personal information protection measures taken by foreign business operators: It is confirmed that measures corresponding to the 8 OECD Privacy Principles, or measures for personal information protection recognized to be at a level equivalent to Japanese law, are taken.
3) Provision to Third Parties Based on Laws and Regulations
Personal information may be provided to third parties based on laws and regulations, such as when providing information pursuant to each item of Article 27, Paragraph 1 of the Act on the Protection of Personal Information.
Joint Utilization of Information of Individual Customers, Officers/Employees of Business Partners, and Other Related Parties
To comprehensively provide services utilizing the expertise of each group company, the Group jointly utilizes information of individual customers, officers and employees of business partners, and other related parties as follows:
① Items of personal information to be jointly utilized: Name, contact details (address, phone number, e-mail address, FAX number, etc.), name, department, location, and job title of affiliated organization, history of transactions, business discussions, and communications, qualifications held, profile information such as educational and occupational history, and other information necessary for providing the Group's services and achieving the purpose of joint utilization.
② Scope of joint utilizers: Each company of the Group (including Group companies in foreign countries).
※In the case of joint utilization with Group companies in foreign countries, it will be confirmed that the foreign Group companies have established a system conforming to standard requirements.
③ Purposes of utilization by joint utilizers:
・For guidance, mediation, and provision of services provided by each company of the Group and related information (including methods of matching customer information to confirm utilization status of other services of the Group and optimize the targets of guidance).
・For recruitment activities of the Group (not limited to the entity to which the application was made).
・For personnel, labor management, organizational restructuring, etc. of the Group.
・For analysis aimed at improving and developing the service quality of the Group as a whole.
・For listening to and responding to opinions and requests from customers.
・Other purposes of utilization described in "1. Purposes of Use of Personal Information."
④ Entity responsible for management of jointly utilized personal information:
Disclaimers Regarding Acquisition of Personal Information by Third Parties
The Group assumes no responsibility whatsoever even if a third party acquires personal information under the following circumstances:
1) When the user themselves discloses their own personal information to a third party, such as a recruiting company, utilizing the functions of the Group's services or other means.
*For example, the occurrence of such an event is anticipated by registering information such as the following when registering a profile or skill sheet on the Group's services:
・Describing detailed descriptions of work experience with proper nouns that may easily envisage the user
・Posting photographs that can clearly identify the user
・Describing records of writing including books and research papers.
・Describing IDs, account names or links of public web services such as social media
2) When the user is identified by a third party due to information posted by the user on public web services such as social media regarding the utilization of the Group's services.
3) When a person other than the user themselves obtains information that can identify the user themselves.
4) When there are no reasons attributable to the Group
Receipt of Personal Information from Business Partners, etc. of the Group
● The Group may receive personal information from recruiters, etc. to whom individual customers have applied or made inquiries using services provided by the Group. In such cases, personal information is properly received through written or electromagnetic methods.
1) Purpose of receipt by the Group
・Confirmation of billing targets with recruiters, etc. to whom individual customers applied/requested utilizing the Group services.
・Operation of Group services utilized by individual customers, and communication/information provision with individual customers accompanying this
・Improvement/new development of Group services, and surveys, analysis, and marketing incidental thereto
2) Items of personal information received
Fact of utilization, utilization status, and utilization results of services provided by the Group
● When a customer permits linkage with other services such as social networking services in utilizing the services of the Group, the following information is collected from said external service based on the contents agreed to upon permission:
1) Purpose of receipt by the Group:
To simplify the procedures for logging into the Group's services or membership registration by utilizing registration information of the external service
2) Items of personal information received:
ID utilized by the user in said external service, and other information that the user permitted to disclose to linked parties through privacy settings of the external service
Voluntariness of Providing Personal Information
The Group requests the provision of personal information to the extent necessary for the purposes set forth herein. Except when based on laws and regulations (such as verification of identity or residence status of foreigners, or provision of MyNumber [excluding the forbidden numeric digits], etc., where required by Japanese law), the provision of information is voluntary. However, please note that if you cannot respond to the Group's request or if there are deficiencies in the provided content, we may not be able to respond to the provision of services or other requests.
Handling of Sensitive Personal Information Requiring Special Consideration
The Group, based on laws and regulations, or based on the consent or request of a customer, may acquire sensitive personal information requiring special consideration (personal information containing descriptions, etc. stipulated by Cabinet Order so that special consideration is required in its handling in order to prevent unfair discrimination, prejudice, or other disadvantages to the principal, such as race, creed, social status, medical history, criminal record, or the fact of having suffered damage from crimes) and provide it to third parties within the scope of laws and regulations or consent.
Utilization of Statistical Data
The Group may create statistical data processed so that individual customers cannot be identified based on personal information provided by customers. The Group may utilize statistical data that cannot identify individual customers without any restrictions.
Anonymously Processed Information
The Group continuously creates anonymously processed information, processed in accordance with proper processing methods stipulated by laws and regulations so that individuals cannot be identified and personal information cannot be restored, and provides said anonymously processed information within the scope stipulated in Section 2.
Items contained in anonymously processed information to be created and provided are personal attribute information of customers such as sex, date of birth, experience, and history. Provision is conducted through written documents, verbal communication over the phone, FAX, delivery of electromagnetic recording media, or electromagnetic communication means such as electronic mail.
Security Control Measures
The Group implements the following security control measures for retained personal data (hoyuu kojin data):
【Organizational Security Control Measures】
・To take security control measures for personal data, an Information Manager is set up in each department as a person responsible for management.
・When cases of leakage of personal data or the risk thereof occur, necessary measures to be taken are implemented according to the case, such as prompt investigation of facts and determination of causes, in accordance with the reporting and communication system stipulated within the Group.
・Regarding the handling of personal data, regular confirmations are conducted using access logs, etc. concerning the establishment and compliance of internal manuals and the utilization status of the system.
【Personnel Security Control Measures】
・Regular training and dissemination are conducted for employees regarding rules, matters to be noted in handling personal data, and cases of accidents that occurred at other companies.
・Confidentiality obligations of personal data during employment and after retirement of employees are stipulated in employment regulations and other internal regulations.
【Physical Security Control Measures】
・Security measures are implemented for entering and leaving the offices of the Group, such as requiring IC cards, etc.
・Equipment, etc. that can be brought into the office is restricted, and for managing personal data, storage is conducted in lockable locations, servers requiring authentication, etc.
・In discarding personal data, processing that cannot be restored is conducted, such as dissolution or shredder processing.
・When moving or carrying electronic devices, etc., password locks are applied to said devices, etc. to prevent leakage, etc. of personal data.
・Storage on equipment with encryption applied, or storage of personal data on file servers, clouds, etc. with advanced security measures applied is conducted to prevent loss, theft, etc. of personal data.
【Technical Security Control Measures】
・In using personal data, access controls are conducted, such as restricting access by IP addresses, requiring IDs and passwords in accessing databases, setting two-factor authentication, and limiting employees who can browse according to the type of information.
・The installation of security software is thoroughly implemented on devices used by employees.
【Understanding of External Environments】
When storing personal data in a foreign country, security control measures are implemented after understanding the personal information protection systems in said country where personal data is stored.
For the status of understanding external environments, please contact each contact window separately. We will respond individually according to the Group's service you are utilizing.
Acquisition of Personally Referable Information by Methods Not Easily Recognized by the Principal
On this website, technologies such as Cookies and web beacons may be used for the purpose of obtaining statistical information such as service improvement and access status. However, information obtained by these technologies does not include information that can identify specific individuals on its own.
1) Cookies
a. What is a Cookie?
Cookies are a mechanism to save utilization histories, input contents, etc. transmitted and received between the browser and server as a file on the computer when utilizing a website. When accessing the same page next time, the website operator can change the display for each user using Cookie information. If the browser settings permit transmitting and receiving Cookies, the website can obtain Cookies from the user's browser. For privacy protection, the user's browser only transmits Cookies transmitted and received by the server of the utilized website.
b. About Cookie Settings
Settings concerning transmitting and receiving Cookies can be changed from the browser's settings screen (such as "Allow all cookies" or "Refuse"). Setting methods differ depending on the browser; please check the "Help" menu, etc. of the browser you are using.
Please note that if you select settings to refuse all cookies, you may receive restrictions in utilizing various services on the internet, such as being unable to receive services requiring authentication.
2) Web Beacons
On the Group's website, there are pages using web beacons for the purpose of obtaining statistical information concerning the utilization status of Group services and improving services. Information obtained using web beacons does not include information identifying specific individuals.
Please check "Informative Data" for conditions concerning the purpose of utilization and third-party provision of information including 1) and 2) above.
Changes to the Privacy Policy
The Group may arbitrarily change this Privacy Policy within a scope that does not violate laws and regulations.
Requests for Disclosure, etc. of Personal Information
1) Notification of Purpose of Utilization or Disclosure of Personal Information or Third-Party Provision Records
Regarding retained personal data held by the Group, requests from a principal or their agent for notification of purpose of utilization, disclosure, or disclosure of third-party provision records will be promptly responded to in accordance with prescribed procedures set by the Group. However, if any of the following apply by responding to the request, we may not be able to respond to the request after explaining the reason and that we cannot respond to the principal or their agent:
① When there is a risk of harming the life, body, property, or other rights and interests of the principal or a third party.
② When there is a risk of causing significant hindrance to the proper implementation of the Group's operations.
③ When it results in violating laws and regulations
2) Correction, Addition, or Deletion
Regarding retained personal data held by the Group, requests from a principal or their agent for correction, addition, or deletion will be promptly responded to in accordance with prescribed procedures set by the Group, and correction, addition, or deletion of said personal information will be conducted within the scope permitted under the Personal Information Protection Act.
Please note that if personal information is deleted, you may not be able to receive services currently utilized.
3) Suspension of Utilization, Erasure, or Suspension of Third-Party Provision
Regarding retained personal data held by the Group, requests from a principal or their agent for suspension of utilization, erasure, or suspension of third-party provision will be promptly responded to in accordance with prescribed procedures set by the Group, and properly handled in accordance with the Personal Information Protection Act.
Please note that if utilization of personal information is suspended, etc., you may not be able to receive services currently utilized.
4) Request Procedures, etc.
When making requests in 1), 2), or 3) above (hereinafter referred to as "Requests for Disclosure, etc."), please fill in the necessary matters in the application form (specified form of the Group) and send it back together with the identity verification documents shown in "a" or "b" below. No fees, etc. will be charged for requests concerning notification of purpose of utilization or disclosure of personal information among said requests.
Regarding responses to Requests for Disclosure, etc., they will be sent by e-mail or mailed in writing to the designated address within 14 business days after receiving the application form filled with necessary matters and identity verification documents.
a. In the case of the individual himself/herself:
When making Requests for Disclosure, etc., please enclose a copy of any one of the following identity verification documents. Unless the address is written as "same as above" with the permanent registered domicile (Honseki-chi), please black out or erase the permanent registered domicile.
・Driver's License
・Individual Number Card (MyNumber Card - please submit a copy of the front side only. Do not submit a copy of the back side on which the Individual Number is written.)
・Residence Card
・Passport
b. In the case of a representative/agent:
If the person making Requests for Disclosure, etc. is a representative/agent, please submit the following identity verification documents (copies) in addition to the documents above. Confirm the current address, and keep the permanent registered domicile section blacked out.
・In the case of a statutory agent:
Documents to confirm that there are statutory representation rights (certified copy of family register, etc.)
Documents to confirm the identity of the statutory agent themselves (same as the identity verification documents described in "a" above)
・In the case of an authorized agent by mandate:
Power of Attorney
Documents to confirm the identity of the agent themselves (same as the identity verification documents described in "a" above)
Personal information provided in this Request for Disclosure, etc. will be utilized within the scope necessary for procedures of the Request for Disclosure, etc. Entrusted identity verification documents or agent verification documents will be discarded by a proper method immediately after confirmation tasks. In addition, application forms after a certain period has elapsed after the completion of procedures will also be discarded by a proper method.
Inquiries
Shibuya Scramble Square 24F/25F, 2-24-12 Shibuya, Shibuya-ku, Tokyo, 150-6190
Customer Service of each company of the Leverages Group
Inquiry Form
TEL: 03-5774-1632
*Inquiries received on Saturdays, Sundays, holidays, year-end and new-year holidays, and other non-business days of the Group will be answered on the next business day or later.
*Requests for Disclosure, etc. of personal information are not accepted by phone or inquiry forms. Only procedures based on Section 13, 1) through 4) above are accepted.
Special Provisions for Handling Personal Information of Retained Users Residing in the State of California
Concerning recruitment and career change services "KikokuGO.com," "ShigotoSagashi.com," and "Leverages Career U.S." (hereinafter referred to as the "Services") provided by Leverages U.S. Inc. (hereinafter referred to as the "Company"), the Company establishes the following additional matters (hereinafter referred to as "these Special Provisions") based on the California Consumer Privacy Act amended by the California Privacy Rights Act (CPRA) (hereinafter referred to as the "CCPA") in addition to the Leverages Group Privacy Policy.
These Special Provisions apply to users who are residents of California subject to the CCPA, and apply when the Company collects, utilizes, discloses, sells, or shares personal information defined by the CCPA (information that can identify, relate to, or be reasonably associated with, directly or indirectly, a specific consumer or household subject to the CCPA; hereinafter referred to as "California Personal Information"). Terms used below have the meanings defined in the CCPA. If there is any conflict between the Leverages Group Privacy Policy and these Special Provisions, the provisions of these Special Provisions shall prevail.
Categories and Sources of California Personal Information
1-1. Categories of California Personal Information
In the past 12 months, the Company has collected the following categories of California Personal Information for the purposes described in "Purposes of using personal information" in the Leverages Group Privacy Policy.
Category
Examples
Identifiers
Real name, e-mail address, user name, Cookies
Personal Information Categories Listed in California Civil Code § 1798.80(e)
Name
Commercial Information
Records of personal purchase or consumption histories or tendencies
Internet or Other Similar Network Activity
Browsing history, search history, information on consumer interactions with internet websites
Geolocation Data
Location information
1-2. Sources of Information
In the past 12 months, the Company collected the above California Personal Information from the users themselves.
Retention Period
The Company retains California Personal Information only for the period necessary to provide the Services. In addition, to comply with legal obligations, secure safety, and handle disputes or claims, California Personal Information is retained within the scope permitted by applicable laws and regulations.
Sale or Sharing of California Personal Information
The Company may provide California Personal Information to the following third parties to the extent necessary for the purposes of (i) distributing advertisements that interest/concern users, and (ii) cooperating with group companies conducting employment placement business so that users can access proper employment-related services or related information:
・Each company of the Group
・Advertising networks
・Analytics providers
In the past 12 months, the Company sold or shared California Personal Information as follows:
Category
Sell / Share
Category of Third Parties
Purpose
Identifiers (Cookies)
Shared
Analytics providers, advertising networks
To distribute advertisements that interest/concern users.
Commercial Information
Shared
Analytics providers, advertising networks
To distribute advertisements that interest/concern users.
Internet or Other Similar Network Activity
Shared
Analytics providers, advertising networks
To distribute advertisements that interest/concern users.
Geolocation Data
Shared
Analytics providers, advertising networks
To distribute advertisements that interest/concern users.
User Rights Concerning California Personal Information
If a user is a California resident, they can exercise the following rights concerning their California Personal Information in accordance with the provisions of the CCPA, except for certain exceptions. The Company will not discriminate against users because they exercised their rights under the CCPA.
① Right to Know: Users can request disclosure of California Personal Information concerning the user collected by the Company described in Section 1-1 of these Special Provisions.
② Right to Request Deletion: Users can request deletion of California Personal Information collected from users by the Company, except for exceptional cases specified in the CCPA.
③ Right to Request Correction: If California Personal Information held by the Company is inaccurate, users can request correction of such inaccurate personal information.
④ Right to Opt-Out of Sale or Sharing of Personal Information: Users can request that the Company do not sell or share California Personal Information collected from users to third parties.
⑤ Right to Limit Utilization/Disclosure of Sensitive Personal Information: The Company utilizes sensitive personal information only for legitimate purposes listed in California Code of Regulations § 7027(m), such as identity verification, provision and maintenance of services, and law compliance, and does not utilize or disclose sensitive information for purposes other than those. In addition, sensitive personal information is not obtained or processed for the purpose of inferring characteristics of customers.
Methods for Exercising Rights
5-1. When exercising rights, please contact the contact details described in Section 7 of these Special Provisions. When contacted for exercising rights, identity verification will be conducted by sending a copy of a government-issued identification card such as a passport or driver's license, or a student ID card. Please note that additional information may be requested at that time.
When exercising the right to opt-out
If a user requests that the Company do not sell or share California Personal Information collected from the user to third parties, please submit a request form from here ("Do Not Sell or Share My Personal Information"). In addition, users can also exercise the opt-out right through a browser or the user's account page utilizing Global Privacy Control.
5-2. Exercise of Rights by Agents
Users can designate an agent to exercise their rights. In such cases, except for certain cases, the agent must show a document proving authority signed by the user themselves to the Company.
Users Under 16 Years Old
The Company does not intentionally collect, sell, or share California Personal Information from users under 16 years old. If a guardian of a user under 16 years old wishes for proper handling, please contact the contact details described in Section 7 of these Special Provisions.
Contact Details for Inquiries Concerning These Special Provisions and Privacy Policy
Requests for exercising rights based on these provisions, opinions, questions, complaints, and other inquiries should be directed as follows:
Leverages U.S. Inc.
E-mail: info-us@leverages.com
TEL: 03-5774-1632
Date of Last Amendment
June 30, 2026
Washington State Consumer Health Data Privacy Policy
This policy complements the Leverages Group Privacy Policy and applies to personal data falling under "Consumer Health Data" subject to the Washington State "My Health My Data Act" (hereinafter referred to as the "MHMDA").
Collection of Information
Leverages Group may collect data identifying a user's past, present, or future physical or mental health status. Such data may include:
(a) Information concerning health status, treatment, diseases, diagnosis, diagnostic testing, medical treatment, or medication obtained in connection with the utilization of our services
(b) Bodily functions, vital signs, symptoms, or body measurements
Leverages Group may collect biometric information such as facial recognition scans for health, safety, and security screening, and other administrative tasks. This information may fall under "Consumer Health Data" defined in the MHMDA.
Disclosure of Information
To the best of our knowledge, we do not "sell" or "share" users' consumer health data. However, if Leverages Group receives consumer health data, we may disclose consumer health data of each of the above categories to third parties.
We may disclose consumer health data to selected third parties in accordance with applicable laws and regulations, including cases specified below:
(a) Group Companies: We may disclose consumer health data to our affiliates and group companies within a reasonably necessary scope.
(b) Service Providers: We may disclose consumer health data to companies with whom we have entered into contracts to provide services on our behalf, such as website hosting, IT infrastructure operation, conducting surveys, analysis of our website, and analysis to improve the quality of our business, website, products, and services. We oblige these service providers to protect the confidentiality of consumer health data and restrict the utilization of data in accordance with the requirements of the MHMDA.
(c) Disclosure for Other Reasons: We may disclose consumer health data when obtaining user consent, when disclosure is obliged or permitted by laws and regulations, or when determined necessary to comply with legal requirements or legal procedures raised against us, when determined necessary to protect or defend our rights or properties, or when determined necessary to protect the personal safety of individuals in emergency situations.
Methods for Exercising Rights
Users have certain rights concerning consumer health data held by us. Users have the right to confirm whether we collect or share their health data, the right to access said data, the right to confirm that we do not sell consumer health data, and the right to request us to delete consumer health data. If we process consumer health data based on your consent, you have the right to withdraw that consent. The Company will not treat users discriminatorily because they exercised these rights.
If you have questions about your rights or wish to exercise your rights, please contact info-us@leverages.com. At that time, please specify that it is a request based on "Washington State Privacy Rights (MHMDA)."
If a request concerning the exercise of rights based on the MHMDA is rejected, you can appeal against the rejection. The method for submitting an appeal will be described in our response. If the appeal is not accepted, you can raise concerns or file complaints with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
