Privacy Policy

Ptmind Inc. (hereinafter referred to as "the Company," "we," "us," or "our") provides services that leverage our data, including analysis, implementation of measures such as A/B testing, and automation, as well as an interactive AI assistant tool for improving business efficiency. We recognize that the protection of personal information, Individual Numbers, and Specific Personal Information of our customers, business partners, employees, and other related parties is a significant responsibility. Therefore, based on our personal information protection philosophy and our self-established code of conduct, we are fully aware of our social mission and will protect the rights of individuals and comply with laws and regulations concerning personal information.

Public Notice Regarding Personal Information Protection

  1. Purposes of Use of Personal Information Handled by Our Company a) Personal Information Acquired Directly from the Individual via Written Document:
    • ① User Information for the Ptmind Service:
      • To customize the use of this service, information, and advertisement delivery to suit the customer.
      • To create statistical data in a form that does not identify individuals in the use of this service.
    • ② Employee Information of Our Company:
      • For personnel and labor management, operations management, health management, and security management of employees.
    • ③ Applicant Information for Our Company:
      • For contacting job applicants and managing our company's recruitment operations.
    • ④ Inquiry Information:
      • For communication regarding inquiries such as requests for materials.
    b) Personal Information Acquired by Methods Other Than A) Above:
    • ① Personal Information Entrusted to Us When Commissioned with Business by a Customer:
      • To perform the commissioned business.
  2. Joint Use of Personal Information Within our group companies, we will jointly use personal data of job applicants for recruitment operations management in accordance with Article 27, Paragraph 5, Item 3 of the Act on the Protection of Personal Information, as follows: a) Items of Personal Information to be Jointly Used:
    • Applicant information (name, address, date of birth, telephone number (including email address), etc.)
    • Employee information (employee name, working hours, payroll information, etc.)
    b) Scope of Joint Users:
    • The names of the companies that jointly use personal information are as follows: <Our Group Companies> BEIJING BOJIN ZHIHUI INTERNET TECH.LTD.
    However, if the consent of the individual is required for the transfer of personal data under other laws and regulations, joint use will be carried out after obtaining consent in accordance with those laws and regulations. c) Purposes of Use by Joint Users:
    • Applicant information: For recruitment management operations at our group companies.
    • Employee information: For payroll transfer processing.
    d) Person Responsible for Management of Jointly Used Personal Information:
    • Yuan Zheng, CEO, BEIJING BOJIN ZHIHUI INTERNET TECH.LTD
    e) Acquisition Method:
    • Internet (web and email), written documents, etc.
  3. Notification of Matters Concerning Retained Personal Data a) Name of Our Company's Representative and Manager Regarding Personal Information:
    • Name: Ptmind Co., Ltd.
    • Representative: Yuan Zheng, Representative Director and CEO
    • Manager: WeiQiang Wang, Personal Information Protection Manager
    • Address: Frontier Gran Nishi-Shinjuku 10F, 3-7-30 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023, Japan
    • Contact: TEL: 03-6380-4268 E-mail: cs@ptmind.co.jp
    b) Purposes of Use of Retained Personal Data:
    • Purposes of use in 1.a) above.
    c) Contact for Complaints Regarding the Handling of Retained Personal Data:
    • Ptmind Co., Ltd., Personal Information Inquiry Desk Frontier Gran Nishi-Shinjuku 10F, 3-7-30 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023, Japan TEL: 03-6380-4268 E-mail: cs@ptmind.co.jp
    d) About Accredited Personal Information Protection Organizations:
    • Our company is not affiliated with an accredited personal information protection organization.
    e) Measures Taken for the Safe Management of Retained Personal Data:
    • When handling personal information, our company takes safety management measures from the perspectives of organizational safety management measures, human safety management measures, physical safety management measures, and technical safety management measures based on the "Japanese Industrial Standard (JISQ15001) Personal Information Protection Management System." We have established a system to promptly respond to specific inquiries regarding safety management measures for retained personal data.
    f) Procedures for Responding to Requests for Disclosure, etc., of Retained Personal Data:
    • You can request disclosure, etc. (notification of purpose of use, disclosure, correction/addition/deletion of content, suspension of use, suspension of provision to third parties, erasure, and disclosure of records of provision to third parties) of retained personal data acquired and managed by us to our inquiry desk.
    • In that case, we will verify your identity and respond within a reasonable period.
    • Please contact the above-mentioned personal information inquiry desk for inquiries regarding personal information.
    1. Flow of Procedures for Responding to Requests for Disclosure, etc., of Retained Personal Data:
      • ① After receiving the request, we will mail the prescribed request form to you.
      • ② Please mail the completed request form, documents confirming that the request is made by an agent if applicable, and a postal money order for the fee (only in the case of a request for notification of purpose of use and disclosure) to the above Personal Information Inquiry Desk.
      • ③ After receiving the above request form, in order to confirm your identity, we will ask you for information that can confirm your identity, such as about two items of personal information registered with our company (e.g., telephone number and date of birth).
      • ④ As a general rule, the response will be made in writing (sealed mail) to the person.
    2. In the case of a request by an agent, materials confirming that the person is an agent:
      • If the person requesting disclosure, etc., is an agent, please enclose materials proving that you are an agent and materials proving the agent's identity. Information on the registered domicile included in each material should be limited to the prefecture, and information after that should be blacked out, etc.
        • ① Materials proving that the person is an agent:
          • <In the case of an agent delegated by the person to make a request for disclosure, etc.>
            • Power of attorney from the person (original)
            • Copy of family register, certificate of residence (with relationship stated), or other official document that can confirm legal representation
          • <If the agent is the legal representative of an adult ward> Copy of either:
            • Certificate of matters registered regarding guardianship registration, etc., or other official document that can confirm legal representation
        • ② Materials proving the agent's identity:
          • Copy of driver's license, passport, health insurance card, certificate of residence, or Basic Resident Register card
    3. Fee for Requesting Notification of Purpose of Use or Disclosure:
      • 1,000 yen per request (Please enclose a postal money order with the request form to be sent.)

Handling of User Information for the Ptmind Service

Article 1 (Definition of User Information)

In this Ptmind Privacy Policy (hereinafter referred to as "this Policy"), "User Information" shall mean personal information (meaning any data relating to an identified or identifiable natural person; the same shall apply hereinafter), your behavioral history on communication services, and other information generated or stored on your device that we collect in accordance with this Policy.

Article 2 (Handling Based on Consent and the Right to Withdraw Consent)

By expressing your consent to this Privacy Policy, you shall be deemed to have consented to our handling of your personal information, and we will handle your personal information based on such consent. However, you may withdraw such consent at any time. Furthermore, for users under the age of 16 to use the services provided by the Company (hereinafter referred to as "the Service"), they must either have a parent or guardian consent to the use of the Service, or obtain permission from a parent or guardian before consenting to the use of the Service. The personal information that you are asked to provide is necessary for us to provide the Service to you. Therefore, if you do not provide it, you may not be able to use the Service.

Article 3 (User Information Collected by the Service)

  1. In the Service, we will ask you to provide the following information:
    • Company name
    • Full name
    • Email address
    • Phone number
    • Date of birth
    • Credit card information
    • Other information that you enter in the registration form specified by us.
  2. In the Service, we collect and acquire the following information on our system:
    • userAgent: Information regarding the type of personal computer, mobile phone, smartphone, personal digital assistant, or other information terminal (hereinafter simply referred to as "device") that you use to access the Service.
    • resolution: Information quantifying the display resolution of the device you use.
    • colordepth: Information regarding the range of colors that the display of the device you use can show.
    • browser width: The horizontal size of the browser when you view a website on your device.
    • browser height: The vertical size of the browser when you view a website on your device.
    • language: The language setting in the web browser when you view a website on your device.
    • charset: Information on the character encoding.
    • platform: Information on the OS version.
    • X and Y position of tap: The coordinates indicating the position tapped on the device's display.
    • referrer: Information regarding the referral source to the website related to the Service.
    • title: Information indicating from which website you came to the website related to the Service.
    • URL: The URL of the website associated with the "title".
    • Browser Information: Information regarding the type of web browser you use to access the Service.
    • IP Address: The number assigned to a device connected to the internet. However, in this Service, the IP Address is automatically processed at the time we acquire it, rendering it incapable of identifying a specific individual. Therefore, we cannot identify individuals through this method.
    • Pages Accessed: Information about the number of visits to an accessed website.
    • Time of Visit: Information about the time a website was accessed.
    • Time of Last Visit: Information about the last time a website was accessed.
    • Geographical Location: Information about the location of the person who accessed the website. Note that for Japan, this information is only displayed down to the prefecture level, and for countries other than Japan, only down to the city level. Consequently, this does not allow us to ascertain the user's address.
    • User Content: Any and all data, files, materials, and inputs (including but not limited to voice, images, documents, screenshots, knowledge bases, data source connection information) that the user transmits, saves, creates, or generates through the Service.
    • Operation History: The date and time of access to the Service, functions used, frequency of use, time zone, country, region, and other history of the user's operations of the Service.
  3. When you access a website where you are using the Service, we automatically acquire information from your browser, such as your IP address, advertisement and website browsing history and status, and your usage environment (including operating system and browser type), using technologies like cookies and web beacons.
  4. Although the combination of information we collect and acquire as defined in Paragraph 2 of this Article allows us to understand visitor behavior on webpages, we make it impossible to identify a specific individual by automatically processing the IP Address. Therefore, even when we collect and acquire this information, we cannot identify individuals.
  5. When implemented using the Google Tag Manager integration feature within the Service, a Ptengine tag is automatically added to the Google Tag Manager connection account, but we do not store any of your information.

Article 4 (Purpose of Use)

  1. We will not process your User Information acquired through the use of the Service beyond the scope of the purposes of use specified below in this article without your consent. "Processing" refers to any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means (e.g., collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction). However, we may process personal information beyond the scope of the following processing purposes in cases where:
    • providing personal information is required in accordance with laws and regulations;
    • we have obtained separate consent from you;
    • processing of personal information is necessary for the performance of a contract with you;
    • data processing is necessary for compliance with a legal obligation to which we are subject;
    • processing is necessary to protect the vital interests of you or another natural person;
    • processing is necessary for the performance of a task carried out in the public interest (including for medical purposes such as public health, social protection, and healthcare services) or in the exercise of official authority vested in us; or
    • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
    Purposes: (1) For user registration, identity verification, and other system operations necessary for the provision, maintenance, improvement, and implementation of the Service. (2) For billing of usage fees, late payment charges, etc. (3) For verifying the validity of credit cards in payment settlements, etc. (4) For customizing information and advertisement delivery within the Service tailored to you. (5) For providing information regarding the Service. (6) For notifying of the suspension, discontinuation, or termination of the Service. (7) For responding to acts that violate the terms of use of the Service. (8) For notifying of changes to our terms of use, this Policy, etc., regarding the Service. (9) For responding to disputes, litigation, etc. (10) For creating statistical data in a format that cannot identify individuals. (11) For improving the quality, developing functions, and enhancing the Service. (12) For purposes incidental to the preceding items. (13) To be used as training data for AI after being processed into a form that cannot identify individuals.
  2. After obtaining your prior consent, we may mutually provide User Information, including personal information, with third parties to the extent necessary to achieve the purposes set forth in the preceding paragraph.

Article 5 (Changes to the Purpose of Processing)

We may change the purpose of processing set forth in the preceding article within a scope reasonably deemed relevant to the original purpose of processing. In the event of such a change, we will notify you or make a public announcement through a method we separately specify and obtain your consent again.

Article 6 (Acquisition of User Information)

  1. We will acquire User Information properly, not through deceit or other wrongful means.
  2. As a general rule, we will not acquire User Information by methods other than through your use of the Service. Should the need to acquire information by other methods arise, we will provide prior notification or public announcement of the purpose and method of acquisition.

Article 7 (Regarding Cookies and Anonymous IDs)

The Service may use Cookies and similar technologies to collect information such as your browsing status of the Service. These technologies are useful for us to understand the usage of the Service and contribute to service improvement. You can change your browser settings to display a warning before accepting Cookies or to refuse them. However, please be aware that if you refuse Cookies, the Service may not function correctly. Related Link 1) Information Collected and Acquired by Ptengine

Article 8 (Security Management)

  1. We will take necessary and appropriate measures, including anonymization, to prevent the leakage, loss, or damage of User Information and to otherwise manage its security.
  2. In connection with our interactive AI assistant tool for improving business efficiency, "Kocoro," we may, to achieve the purposes of use, provide User Information to the following third parties located outside of Japan as part of outsourcing the handling of such information:
    • OpenAI, L.L.C. (3180 18th St, San Francisco, California, 94110, United States)
    • Google, L.L.C. (1600 Amphitheatre Parkway, Mountain View, CA 94043, United States)
    For information on the personal information protection systems in the United States, where these companies are located, please refer to the following links:
  3. Furthermore, if we entrust all or part of the handling of User Information to a third party, we will enter into a confidentiality agreement with said third party that is compliant with this Policy in advance, take necessary measures as stipulated by law, and conduct necessary and appropriate supervision to ensure the security of the User Information is managed by said third party.

Article 9 (Disclosure and Sharing of User Information)

With respect to personal information within User Information, in addition to cases where disclosure is permitted under the Personal Information Protection Act and other laws and regulations, we may disclose or share it with third parties with your consent in the following cases:
  1. When we entrust all or part of the handling of personal information to a third party to the extent necessary to achieve the purpose of use.
  2. When we entrust the personal information of customers using the Service to payment system companies, credit card companies, and banks for the purpose of billing usage fees.
  3. When a user engages in or attempts to engage in actions that harm others or violate public order and morals within the Service, and it is necessary to take measures in response.
  4. When personal information is provided in connection with a business succession due to a merger or other reasons.
  5. When there is an imminent danger to life, property, etc., and there is an urgent need.
  6. When disclosure is requested by a public institution such as a court or the police based on laws and regulations.
  7. When we have a legal obligation to disclose based on other laws and regulations.

Article 10 (Disclosure, Correction, etc., of User Information)

  1. You have the following rights with respect to us:
    • Access to personal information
    • Correction or erasure of personal information
    • Restriction of processing
    • Objection to processing
    • Right to data portability
  2. If you wish to exercise the rights stipulated in the preceding paragraph regarding the personal information you have provided, please contact us at the inquiry point specified in the next article.
  3. Upon receiving a request as described in the preceding paragraph, we will, after verifying your identity, respond to your request regarding your personal information within a reasonable scope. However, this shall not apply if we are not obligated to disclose, etc., under the Personal Information Protection Act or other laws and regulations.
  4. You have the right to lodge a complaint with the competent data protection authority regarding the handling of your personal information.

Article 11 (Inquiries)

For opinions, questions, complaints, or any other matters concerning our handling of User Information, please contact us at the following: E-mail: cs@ptmind.co.jp

Article 12 (Organization and Structure)

We appoint our Representative Director, Zheng Yuan, as the User Information Management Officer, and will implement proper management and continuous improvement of User Information.

Article 13 (Changes to this Policy)

We will review the operational status of our handling of User Information as appropriate and strive for continuous improvement. We may change this Policy as necessary without your prior approval. Unless the changes to the content legally require your consent, the revised Policy shall become effective immediately after being published on our website. However, if we make changes to the content that legally require your consent, we will obtain your consent through a method specified by us.

Article 14 (Links to Services Not Managed by the Company)

The Service provided by us may contain links to services not managed by us. We assume no responsibility whatsoever for the content or protection of User Information on these external services.

Article 15 (Retention Period of Personal Information)

When the personal information we acquire and process from you is no longer necessary in light of the purposes stipulated in Article 2, we will promptly erase it. However, in the following cases, we may retain it even if it is no longer necessary in light of the purposes stipulated in Article 2:
  1. When retaining it is for the public interest.
  2. When processing it is for scientific research purposes.
  3. When processing it is solely for statistical purposes.