MACROMILL, INC. Privacy Policy

MACROMILL, INC. (the “Company”) contributes to society by providing information about consumer awareness and behavior to corporations and organizations through market research, public opinion surveys, social research and medical related surveys (collectively, “Marketing Research”)

In doing so, to protect the personal information of the Company’s information sources, i.e. consumers, the Company complies with the Marketing Research Code of Conduct and the Marketing Research Industry Guidelines for Protection of Personal Information as stipulated by the Japan Marketing Research Association (JMRA).

In order to ensure the protection of personal information, the Company hereby establishes and proclaims its implementation of this Privacy Policy to take appropriate measures to secure, store and manage personal information acquired from participants in the Company’s Marketing Research (“Survey Respondents”) through their responses to the Company’s surveys, as well as personal information acquired from the Company’s stakeholders, such as the Company’s business partners, and from other relevant parties.

1. Appropriate acquisition, use and provision of personal information

The Company acquires personal information for definite purposes in a fair and just manner, and uses personal information only to the extent necessary to achieve such purposes. When using the same beyond this extent, the Company will obtain the prior consent of the information subjects. The Company also takes necessary measures to prevent the handling of personal information beyond the extent necessary to achieve the purposes. Upon providing personal information to a third party, the Company will obtain the prior consent of the information subject, unless this Privacy Policy stipulates otherwise.

2. Safety management of personal information

The Company prevents and rectifies unauthorized access to, and the loss, destruction, falsification and leakage of, personal information by taking organizational, personal, physical, and technical security measures against such risks.

3. Compliance with laws, regulations and other rules about the protection of personal information

Upon handling personal information, the Company complies with domestic laws and regulations about personal information protection, guidelines stipulated by the governing authorities, the Marketing Research Code of Conduct and the Marketing Research Industry Guidelines for Protection of Personal Information stipulated by the JMRA, along with other relevant rules.

4. Continuous improvement of the Company’s personal information protection management system

To implement this Privacy Policy appropriately and effectively, the Company has established and operates a personal information protection management system (the “PMS”). To increase the effectiveness of the PMS, the Company provides training to all of its employees and audits the operation of the PMS for continuous review and improvement.

5. Handling of complaints and inquiries

If you have any inquiries and complaints about the Company’s handling of personal information, you can contact the Company as shown in the “Inquiries and Complaints” chapter of this document.

As for personal information subject to disclosure, the Company will promptly handle requests from the information subject or his/her representative to notify the purposes of use of, to disclose, rectify (including making additions to or deleting part of), or suspend the use of (including suspending third-party provision of and eliminating), such personal information.

The Company strives to protect personal information by ensuring that its officers and employees fully understand the purposes and intent of this Privacy Policy and conduct daily operations with the greatest care.

6. Change to Privacy Policy

The Company may change this Privacy Policy due to any amendments to the laws or regulations, etc., the Company’s business operational needs or any other circumstances. In the case of making the said change, the Company will publicize such change in an appropriate manner.

June 30, 2016 (established)
March 18, 2022 (last modified)

Toru Sasaki, President, Representative Executive Officer and Global CEO
MACROMILL, INC.
11th Floor, Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo

Purposes of Use of Personal Information

1. Marketing Research

• The Company’s main business is Marketing Research. The Company surveys consumer awareness and behavior about products and services, and provides information acquired through such surveys to corporations, other organizations, etc.

• The Company’s methods of acquiring personal information in the process of conducting the Marketing Research business and the principal information acquired thereby are as follows.

• The Company uses the personal information of Survey Respondents that is acquired through each of the methods above for the purposes set forth below (the “Marketing Research-Related Purposes”); provided, however, that the location information (the “Location Information”) acquired by the Company through the applications it provides (the “Apps”) shall be excluded from such personal information. Please refer to “Location Information” for the purposes of use of the Location Information. If the Company uses the personal information for any purpose other than the purposes set forth below, the Company will obtain the consent of Survey Respondents by giving prior notification of the details of such usage by stipulating such details in the Company’s terms and conditions posted on the Company’s website or other documents, etc., or by email or phone call, unless obtaining consent is not required under the laws and regulations.

  • Matters required for Marketing Research, such as selection of Survey Respondents, requests for participation, sending survey sheets, examination and analysis of the survey results, and provision of the survey results to the Company’s clients (including providing the survey results to the Company’s clients on the assumption that it will be re-provided to any end-client^* in the case that a client conducts Marketing Research entrusted by the said end-client, or to the co-implementers of the Marketing Research in the case that a client implements the said Marketing Research with multiple companies);
    * An end-client refers to a customer of the Company’s client.
  • Interviews or door-to-door surveys conducted by researchers;
  • Delivery of targeted advertisements for the purpose of extracting Survey Respondents^*;
    * For example, in order to ask Survey Respondents about their recognition or impression, etc. of the web advertisements which are the subjects of the Marketing Research (the “Research Target Web Advertisements”), the Company may deliver the Research Target Web Advertisements through the web services that the said Survey Respondents are using on a daily basis.
  • Matters required for the implementation of extended advertisement delivery^** (meaning methods such as finding users acting analogous to the users who have visited the relevant website, but have not visited the said website yet, and delivering targeted advertisements to them, or finding users acting analogous to the users who have purchased a certain merchandise or service, and delivering targeted advertisements to them; the same shall apply hereinafter);
    ** Extended advertisement delivery is a method to find users whose purchase behaviors or web behaviors are analogous to the Survey Respondents and to deliver advertisements to them, and is not something that delivers advertisements directly targeting the Survey Respondents.
  • Provision/redemption of points, payment of gratuities, and sending free gifts and samples to Survey Respondents;
  • Responses to inquiries from Survey Respondents, and making contact to check the details of support and registered information;
  • Identity verification, display of registered information, and other procedures on the membership page of a Survey Respondent;
  • Campaigns or rewards relevant to the operation of Marketing Research, sending of email newsletters, etc.;
  • Development and improvement of advertisement delivery models, purchase prediction models and other marketing solutions; and
  • Other matters accompanying or related to the above.

2. Transactions such as business activities

When the Company’s business partners such as the Company’s customers and related companies inquire about the Company’s services or participate in a seminar or campaign sponsored or supported by the Company, the Company will use personal information acquired from the Company’s business partners, such as by exchanging business cards, for the purposes defined below:

• For negotiation, communication, discussion, examination, order placement, settlement and response about business transactions;
• For providing and receiving services based on business transactions; and
• For providing, collecting, and transmitting information about the Company’s services.

3. Recruitment activities

The Company uses the personal information of a job seeker who applied for or inquired about the Company’s job offer for the following purposes. If the job seeker has joined the Company, the Company will use the personal information of such person for employment management purposes.

• To provide recruitment information to the job seeker;
• To examine and determine whether or not to employ the job seeker and provide notification of the result; and
• To check application history.

4. Matters concerning shareholders

The Company will use the personal information about the Company’s shareholders for the following purposes:

• To enable the exercise of rights or the fulfillment of obligations as shareholders under the laws;
• To provide benefits to shareholders;
• To take measures to promote a favorable relationship between shareholders and the Company; and
• For shareholder management, such as the creation of shareholder data based on specific standards under laws and regulations.

5. Use of published information

The Company will use information published online or offline for the following purposes:

• Implementation of Marketing Research
• Development and improvement of marketing solutions

Personal Information Subject to Disclosure

For the purpose of this Privacy Policy, “Personal Information Subject to Disclosure” means personal information that forms part of a collection of information in such a way that specific personal information can be retrieved by a computer, or a collection of information to which a fixed set of rules is applied to arrange the personal information contained therein so that it is structurally organized to enable specific personal information to be easily retrieved from it, and which has a table of contents, an index, or anything else that aids in retrieval, for which the Company is authorized to respond to all requests made by the information subject to disclose, rectify, make additions to, delete part of, suspend the use or third-party provision of, or eliminate, the information.

* The following shows the types of Personal Information Subject to Disclosure that the Company handles and its purposes of use. The Company treats any information as Personal Information Subject to Disclosure only when the above definition applies.

1. Types of Personal Information Subject to Disclosure

• Information about Survey Respondents:

  Information that includes the name, address, age, date of birth and email address that the Survey Respondent has registered on the website operated by the Company and other information that the Company has acquired during Marketing Research, as well as records related to the provision of such information to or from any third party (hereinafter referred to as “Third-Party Provision Records,” excluding those designated under any ordinance as information regarding which revealing its existence damages the public interest or any other interest).

• Information about business partners:

  Information provided to the Company by business partners, such as names, telephone numbers (including mobile and fax numbers), email addresses, company/organization names, division names, titles, workplace addresses, and any other contact information, as well as Third-Party Provision Records of such information.

• Information about job seekers

  Names, telephone numbers (including mobile and fax numbers), addresses, ages, dates of birth, email addresses, and any other information described in the CV or provided by the job seeker to the Company via the website operated by the Company, as well as Third-Party Provision Records of such information.

• Information about shareholders:

  Names, addresses, and any other information in the shareholder registry, as well as Third-Party Provision Records of such information.

• Public information:

  Information published online or offline, as well as Third-Party Provision Records of such information.

2. Purposes of use of Personal Information Subject to Disclosure

The Company uses Personal Information Subject to Disclosure only within the range of the purposes defined in “Purposes of Use of Personal Information” in this Privacy Policy.

Request to Disclose Personal Information Subject to Disclosure

As for Personal Information Subject to Disclosure, the Company will promptly handle requests from the information subject or his/her representative to notify the purposes of use, to disclose, rectify (including making additions to or deleting part of), or suspend the use of (including suspending third-party provision of and eliminating), such information.

<Click here for the types of information for which you can request the above actions.>

1. Contacts for the request for disclosure

• For information provided as the Company’s monitor on the website operated by the Company, please use the email address and login password that you used to register as a monitor to log in to the website operated by the Company; and then move to the MACROMILL monitor page (MY PAGE) to ask for disclosure, etc. The Company will then promptly handle such request.

• For the disclosure of information that cannot be handled as set forth in (1), please complete the Company’s form described below, enclose all the required documents, and mail them to the following address. Please write, “Request form for disclosure of personal information enclosed,” in red on the envelope.
  
  Personal information protection administrator, MACROMILL, INC.
  11th Floor, Shinagawa East One Tower, 2-16-1, Konan, Minato-ku, Tokyo, 108-0075

2. Documents to submit when making a request for disclosure, etc.

• When you make a request for disclosure using the method set forth in Section 1, Paragraph (2) above, please download the request form set forth in (i) below, fill in the necessary information, and enclose it together with two of the documents for personal identification listed in (ii).

  • A request form prescribed by the Company (Request form for disclosure of Personal Information Subject to Disclosure)

  • Documents for personal identification:

    • A copy of your driver’s license
    • A copy of your health insurance card;
    • A copy of your passport;
    • A copy of your basic resident register card; and/or
    • A copy of any other official documents for personal identification.

• When a request for disclosure is made by a legal representative of a minor or adult ward or a representative appointed by the information subject to make a request for disclosure, please also enclose the following documents in addition to the documents listed in the preceding paragraph.

  • In the case of a legal representative (one copy each of a, b, and c):

    • Document that verifies the legal representation authority One copy of the family register, extract of family register, certificate from the court of domestic solutions, certified copy of registration, or any other document that proves the qualification
      * It must be a copy that was issued within 30 days before the request for disclosure.
      * Please black out the registered domicile information before submission.

    • Document that identifies the person with parental authority or the guardian of the adult ward One copy of the driver’s license, passport, health insurance card or basic resident registration card that indicates the same name and address as those in the form submitted by the person who requests the disclosure
      * Please black out the registered domicile information before submission.

    • One original certified copy of the residence certificate (photocopy not acceptable)

  • In the case of a representative appointed by the information subject (one copy each of a and b)

    • One copy of the Company’s proxy form; and
    • One original copy of the registered seal certificate of the person.

3. Fees for requests for notification of purposes of use and for information disclosure

With regard to any request for notification of the purposes of use or for information disclosure made by the information subject or his/her representative, the Company will charge a certain fee, depending on the details of the request and the method of notification or disclosure by the Company. Such fee shall be paid via bank transfer into the bank account designated by the Company (any bank transfer fee shall be borne by the requester). In this case, the Company will respond to the request after confirming the bank transfer of such fee.

4. Method for responding to requests for disclosure

The Company will respond to any request for the notification of the purposes of use of, or rectification or suspension of use, etc. of, personal information by mail.

In principle, the Company will respond to any request for information disclosure by mailing a written document or a CD-ROM containing electronic records of the relevant information, in accordance with the requester’s designation upon making the request; provided, however, that in cases where it is difficult for the Company to disclose the relevant information using the method designated by the requester, such as where the mailing of the CD-ROM containing electronic records requires great expense, the Company may respond to such request by mailing a written document, despite the designation.

5. Purposes of use of personal information acquired in relation to a request for disclosure, etc.

The Company will only use the personal information acquired in relation to a request for disclosure, etc. to the extent necessary to handle the request. The submitted documents will be stored for two years after the response to the request is completed and will be disposed of after such period.

6. Cases wherein the Company cannot respond to a request for disclosure, etc.

Please note that there may be cases where the Company cannot respond to a request for disclosure, etc. if any of (i) to (xi) below applies. In that case, the Company will notify the applicant to that effect, together with the reason therefor.

• The Company cannot identify the information subject, for example, because the addresses indicated in the form, indicated in the documents for identification, and registered at the Company, do not match;
• The Company cannot verify the representative’s right of representation for a request by the representative;
• The application documents are deficient;
• The information that the applicant asks to disclose is not Personal Information Subject to Disclosure;
• The fulfillment may risk the life, body, property, or any other right or interest, of the information subject or a third party;
• The fulfillment may encourage or induce illegal or unjust acts;
• The fulfillment may risk national security, damage the relationship of trust with other countries or international organizations, or cause a disadvantage in negotiations with other countries or international organizations;
• The fulfillment may obstruct the prevention, suppression, or investigation of crimes or the maintenance of public safety and order;
• The fulfillment may seriously obstruct the Company’s appropriate business operations;
• The fulfillment violates the laws and regulations; or
• The Company does not bear any obligations for disclosure, etc. under the laws or regulations.

Third-Party Provision of Personal Information

• The Company properly manages the personal information it has acquired, and will not provide information from which a specific individual can be identified directly, such as names, addresses, phone numbers, email addresses, etc., to any third party without the prior consent of the information subject, except in the cases where:

  • The provision is based on the laws and regulations;
  • The provision is required to protect the life, body or property of any person, and it is difficult to obtain the consent of the information subject;
  • The provision is particularly required to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the information subject;
  • The provision is required to support the activities defined under the laws and regulations that are conducted by governmental organizations, local governments, or those delegated thereby, and the acquisition of consent from the information subject may obstruct the conduct of such activities;
  • The receiver of such information is an academic research institute, etc., and the receiver needs to handle the personal data provided by the Company for academic research purposes (including cases where such academic research constitutes part of the purposes for handling such personal data, but excluding cases where such handling threatens to wrongfully infringe upon the rights and interests of an individual);
  • The Company asks other research companies (“Partner Research Companies”) for cooperation in Marketing Research, and the Company needs to check for the existence of any overlap of monitors between the Partner Research Companies and the Company; or
  • The Company receives an inquiry from its client or any third party with whom the Company has a contractual relationship, such as its alliance partner (an “Alliance Partner;” collectively referred to with the clients as “Clients, etc.”) about the existence of any overlap between the Company’s Survey Respondents and the monitors, members and customers of such Client, etc., and the Company needs to respond to such inquiry to the extent required for the Marketing Research-Related Purposes;
  • The Company or any of its Clients, etc. provides telephone numbers or email addresses to any other Client, etc. of the Company to the extent necessary for extended advertisement delivery; or
  • It is necessary to confirm the Survey Respondents’ usage status of the websites and applications subject to research in order to obtain the results intended by the Company or Client, etc. through Market Research, and it is necessary to provide telephone numbers and email addresses to the Company’s Clients, etc. in order to acquire such information.
  * In cases where Item (vi), (vii), (viii) or (ix) applies, the Company shall impose on the relevant Partner Research Companies or Clients, etc. the condition that they must not use personal information for any purpose other than those set forth above. The Company shall provide personal information to the Partner Research Companies or Clients, etc. by taking necessary procedures to improve security, such as hashing or encryption.

• Among the Survey Respondents’ personal information possessed by the Company, the Company may, for the Marketing Research-Related Purposes, provide its Clients, etc. with information regarding which a specific individual cannot be identified directly from such information alone, such as: IDs allocated by the Company to Survey Respondents for information management purposes (“Monitor IDs”); and attribute information, survey responses and website access logs of Survey Respondents (the same shall apply in cases where the Clients, etc. re-provide the same to any third parties).
  The Clients, etc. may use any information provided by the Company either alone or in combination with information possessed by the Clients, etc. for the Marketing Research-Related Purposes. In cases where a specific individual may be identified by combining information provided by the Company and that possessed by any Client, etc., the Company shall arrange the following matters with such Client, etc.:

  • Limitation on the use of information provided by the Company within the range of the Marketing Research-Related Purposes;
  • Prohibition on re-identifying an individual such as by combining information provided by the Company with information possessed by the Clients, etc., such as names, addresses, phone numbers and email addresses, from which a specific individual can be identified directly; and
  • Range of persons or entities to which the Clients, etc. may re-provide information (if applicable), and the purposes for which the receiver of the re-provided information shall be permitted to use such information.
  * This provision applies in cases where the Company provides part of the personal information to Clients, etc., and the same shall not apply in cases involving the provision of personally referable information (defined under the amended Act on the Protection of Personal Information in Japan as information relating to a living individual which does not fall under personal information, pseudonymously processed information or anonymously processed information).

• The Company may compare information received from the entruster upon entrustment with information possessed by the Company.

• The Company may subcontract the handling of personal information to a third party within the extent of the purposes of use. In that case, the Company makes a contract with the third party about personal information protection, and obliges the third party to take appropriate safety management measures.

• For the personal information provided by the Company to a third party, the privacy policy, etc. of the said third party shall be applied.

Sharing of Personal Information between the Company and its Subsidiaries and Affiliates

The Company may use personal information obtained by the Company jointly as follows. The Company will make efforts to maintain strict information management when using personal information jointly.

• Jointly used personal data items: Information about Survey Respondents, business partners, and job seekers as set forth in “1. Types of Personal Information Subject to Disclosure” and “Personal Information Subject to Disclosure” in this privacy policy.
• Scope of joint users: The Company and group companies of the Company (the companies which are introduced as group companies on the Company’s website (https://www.macromill.com/global/company/group.html))
• Purpose of joint usage: The purposes set forth in “Purposes of Use of Personal Information” in this Privacy Policy.
• Name of person or business operator responsible for managing the joint usage: The Company

Toru Sasaki, President, Representative Executive Officer and Global CEO
11th Floor, Shinagawa East One Tower, 2-16-1 Konan, Minato-ku, Tokyo

Provision to Overseas Third Parties

• The Company may provide personal information it has acquired to third parties located overseas (meaning countries or areas located outside Japan), in any of the following cases:

  • The Company provides the personal data to third parties located in countries which have systems of personal data protection equivalent to those of Japan in terms of protecting rights and interests of the information subjects set forth in the rules of the Personal Information Protection Commission;
  • It is ensured between the Company and the third parties who receive personal data from the Company that measures are implemented regarding the handling of such personal data according to the intent of the laws and regulations and in a sufficient and reasonable manner;
  • The third parties who receive personal data are certified under certain global frameworks regarding the handling of personal information;
  • Any of the cases set forth in Paragraph (1) of “Third-Party Provision of Personal Information” apply (provided, however, that, in any of the cases set forth in Items (vi) through (ix), provision shall be limited to the personal information of information subjects who have agreed to the application of this Privacy Policy);
  • The Company provides information which cannot, by itself, identify the specific individual, such as Monitor IDs of Survey Respondents, attribute information of Survey Respondents, or the contents of Survey Respondents’ responses to surveys, to the Company’s clients located overseas (regardless of the country) for conducting Marketing Research (limited to personal information of information subjects who have agreed to the application of this Privacy Policy);
    * This provision applies in cases where the Company provides part of the personal information to Clients, etc., and the same shall not apply in cases where personally referable information is provided.
  • The information subject’s consent is obtained for the provision of his/her personal information to third parties, such as in Item (v); or
  • The Company provides information for the purpose of subcontracting all or part of the Marketing Research or the development of marketing solutions, to the extent necessary, to such subcontractor.
• Since the overseas third parties to which the personal information will be provided shall be considered depending on each case, the names of the countries in which such third parties are located cannot be identified at the time of your agreement with this Privacy Policy. Please refer to the website of the Personal Information Protection Commission (https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/) for information on personal information protection systems in foreign countries.
• Since the overseas third parties to which the personal information will be provided shall be considered depending on each case, information related to the measures for personal information protection to be taken by such third parties cannot be provided at the time of your agreement with this Privacy Policy.