Privacy policy

This Privacy Policy is established by CAELUM LIMITED (hereinafter referred to as "the Company") to publicize the purpose of use, disclosure, correction, complaints, and other matters related to personal information acquired from customers of HOXTON STUDIO (hereinafter referred to as "the Website"), job applicants to the Company, and employees of the Company, in accordance with applicable laws such as the Act on the Protection of Personal Information and the Telecommunications Business Act. This policy also defines the basic policy for the protection of personal information within the Company.

Philosophy of Personal Information Protection

The Company shall handle personal information with care, respecting individual dignity and adhering to relevant laws and regulations.
The Company will specify the purpose of use of personal information as much as possible and will handle personal information within the scope of that purpose. Except in cases based on laws and regulations, with customer consent, or when necessary for providing products and services to customers, personal information will not be handled.
The Company will take necessary and appropriate measures to ensure the security management of personal information, such as preventing leakage, loss, or damage. When handling personal information by employees or contractors, necessary supervision will be conducted to ensure security management.
The Company will strive to establish and maintain a necessary system for the appropriate and prompt handling of complaints regarding the handling of personal information.

Definition of Personal Information

In this Privacy Policy, "personal information" refers to information that can identify a living individual, such as:
1. Name, address, date of birth, etc.
2. Data such as images, videos, sounds
3. Biometric information used for fingerprint, vein, or voiceprint authentication
4. Numbers and symbols such as pension numbers, social insurance numbers, credit card numbers

Purpose of Use of Personal Information

The Company will handle personal information for the following purposes:
1. Establishing and maintaining communication connections with the Website
2. Storing and providing individual settings for each customer on the Website
3. Optimizing information displayed on the Website for each customer
4. Announcing products, campaigns, events, and conducting surveys by the Company
5. Distributing newsletters if the customer has requested it
6. Verifying identity
7. Responding to inquiries, consultations, complaints, and requests regarding personal information
8. Selection of job applicants who applied to the Company
9. Handling wages, social insurance procedures, labor insurance procedures, labor safety, welfare, personnel evaluation, and other employment management and legal operations for employees
10. Maintenance and operation necessary for fixing issues and running the Website
11. Statistical analysis for improving the quality of the Website
The Company will handle personal information within the scope of the purposes specified above and will not use personal information beyond these purposes.
The Company may change the purposes of use within a reasonable range related to the purposes before the change. In such cases, the Company will disclose the changes and the effective date on the Website.

Items of Personal Information to be Collected

For the purposes mentioned in the previous article, we may collect the following personal information:
1. Personal identification information such as name, date of birth, and address.
2. Contact information such as shipping address, phone number, and email address.
3. Any other information voluntarily registered by the customer on this website.
4. Results of aptitude tests and other information related to eligibility for recruitment selection.
5. Qualifications, work history, and other information included in resumes and CVs.
6. Basic pension number, social insurance subscriber number, and other employment management information.
7. Any other information necessary for recruitment selection and employment management in addition to the items mentioned in 6 to 8.
We may automatically collect the following personal related information (information related to individuals that does not identify the individual) on this website. We do not cross-reference this personal related information with other information to identify individuals:
1. Attribute information linked to the customer, such as IP address, screen size, language settings, OS type and version, and connection device (approximate age, gender, etc.), and other information related to the connection device.
2. User ID and other identifiers, approximate login region, login date and time, URL of the access source, web browser type and version, and other information related to the connection status.
3. Accessed URLs (within this website only), titles of accessed pages (within this website only), history of various actions on this website, and other information related to the customer's usage of this website.
4. Any other information automatically obtained during the establishment and maintenance of communications.
Personal information collected by us will be deleted from our database without delay if the customer deletes their account on this website. Personal information not linked to an account on this website (such as personal information submitted during inquiries) will be deleted from our database without delay one year after the date of acquisition. However, personal information not included in this website's database (such as personal information contained in our mail server) will be deleted without delay during maintenance three years after the date of acquisition.
Notwithstanding the preceding paragraph, anonymized and extracted statistical information may be retained for continued use in improving the quality and maintenance of this website.

External Transmission of Access Information

The Company will automatically transmit the following personal-related information to the following external businesses for the purposes listed below:

Recipient Service	Recipient Business	Purpose of Use	External link
Google Analytics	Google LLC	For statistical analysis to improve the quality of the Website For further details on the purposes of use at the recipients, please refer to the external links below:	https://policies.google.com/privacy/

Provision of Personal Information to Third Parties

The Company may provide a part of the personal information it holds to affiliated stores, partners, credit card companies, payment processing companies, system development companies, delivery companies, labor and social security attorneys, health insurance societies, tax accountants, and other third parties within the necessary scope to achieve the purposes listed in "Purpose of Use of Personal Information."
Except in the following cases, the Company will not provide personal information to third parties:
1. With the individual's consent
2. When disclosure/provision is requested by judicial or administrative bodies based on laws and regulations
3. When necessary for protecting life, body, or property and it is difficult to obtain the individual's consent
4. When disclosed/provided in a form that does not identify individuals, such as statistical data
5. When the business is succeeded due to mergers, company splits, business transfers, etc.
6. When otherwise permitted by applicable laws and regulations

Consultation and Request Procedures

The Company will accept requests for disclosure, correction, suspension of use, deletion, suspension of provision to third parties, complaints, consultations, and issuance of necessary forms regarding the handling of personal information from customers at the following contact point ("Personal Information Consultation Desk").

Company Name	CAELUM LIMITED
Department in Charge	Privacy Inquiries Contact
Email Address	hoxton@nullhoxton.jp
Reception Hours	10:00 - 16:00

Customers can make the following requests by submitting the prescribed form along with identification documents to the Personal Information Consultation Desk:
1. Request for disclosure of data related to the individual by electromagnetic record or written method
2. Request for disclosure of third-party provision records by electromagnetic record or written method
3. Request for correction, addition, or deletion of content
4. Request for suspension of use or deletion
5. Request for suspension of provision to third parties
Identification documents for the above requests, unless otherwise specified by the Company, will be a copy of a photo ID (driver's license, passport, etc.) or two copies of non-photo IDs (health insurance card, pension book, etc.). If the request is made by a representative, in addition to the above, the representative's identification documents and a power of attorney will be required.
The Company will promptly conduct necessary investigations upon receiving the above requests from customers and will take measures related to the requests without delay if deemed reasonable. If the requested measures are not taken or different measures are taken, the Company will strive to disclose the reasons.
A processing fee of 500 yen is required for the above procedures, which should be paid by bank transfer, postal money order, or other prescribed methods by the Company.

Safety Management Measures for Personal Information

The Company will take the following measures to prevent leakage, loss, or damage of personal information and strive to maintain and improve safety management:
1. Management of access rights of officers and employees handling personal information
2. Locking storage locations for documents containing personal information and (if possible) restricting access
3. Encrypting electronic files containing personal information and other information security measures
4. Periodic confirmation of items, purposes of use, and records of third-party provision of retained personal information
5. Development of internal regulations regarding the handling of personal information
6. Collection of information on enactments and amendments of laws and regulations regarding personal information protection
7. Other necessary measures to ensure proper handling of personal information

Access from the EU

If customers are located within the EU, the following provisions apply in addition to the above:

Definition of Personal Information: Advertising identifiers and other internet identifiers are treated as personal information within the scope of personal-related information defined in this Privacy Policy.
Disclosure of the legal basis for the processing: The Company handles essential information for the operation of the Website and information such as shipping destinations, names, and payment information for purchased products and services based on the legal grounds of performing contracts with customers. Other personal information not essential for performing contracts is handled based on the consent given by customers to the Company.
Right to File Complaints with Supervisory Authorities: Customers can file complaints with supervisory authorities regarding the handling of personal information by the Company.

Consent for Provision of Personal Information: Customers voluntarily provide personal information to the Company. Customers can refuse to provide personal information to the Company, but this may result in the following:

Items of personal information that the customer chose not to provide.	Potential issues that may arise.
IP address, session identifier, screen size, information about the OS, and other information necessary to maintain normal communication between this website and the customer.	There may be poor connection issues or malfunctions with this website.
User ID and other information necessary for storing and retrieving your personal settings.	There may be a risk of being unable to access personal accounts on this website.
Name, address, payment information, and other information necessary for mail-order sales.	There may be a risk of being unable to purchase goods or services on this website.
Information necessary for identity verification, such as identification documents.	There may be a risk of being unable to recover an account in case of loss or make various requests based on this privacy policy.

Withdrawal of Consent: Customers can withdraw their consent for the handling of personal information at any time in the future. If customers wish to withdraw consent, please notify the Personal Information Consultation Desk by email. The withdrawal of consent does not invalidate the handling of personal information by the Company before the withdrawal. If the Company loses the legal basis for processing personal information due to the withdrawal of consent, the Company will promptly delete such personal information from the database.
Consent from Minors: If customers are under 16 years old (or the age specified under the laws of the country/region), consent for handling personal information by the Company is invalid without the valid consent of a parent or guardian. In this case, customers must obtain consent from a parent or guardian before providing personal information to the Company.
Processing Without Identifying Individuals: If the Company notifies customers that personal information will be processed without identifying individuals according to the purpose of use, the acceptance of requests for disclosure and other matters related to that personal information will end, unless customers provide additional information to identify the individual.
The Company may transfer personal information from the EU to Japan based on adequacy decisions by the European Commission.