oVice Recruitment Privacy Policy

oVice, Inc. (the “Company”, which herein includes all of its subsidiaries) appropriately handles personal information acquired from a candidate (the “Candidate”) in relation to the Company’s recruitment activities (the “Recruitment Activities”) by establishing this Recruitment Privacy Policy (the “Policy”) which is to be followed for the purpose of appropriately managing and using the personal information. The Company asks each Candidate to provide personal information when participating in the Recruitment Activities. The Company asks that all Candidates read the Policy carefully as the Candidates will consent to the use and disclosure of their personal information in accordance with the Policy. For the privacy policy regarding the Company’s services, please click here.

Article 1 (Acquisition of Personal Information)

In this Policy, “Personal Information” means personal information as stipulated in Article 2(1) of the Act on the Protection of Personal Information (Act No. 57 of 2003, which will be referred to as “APPI”). The Company will clearly determine in advance the purposes of acquiring Personal Information within the scope of its legitimate business and acquire and use Personal Information in a lawful and fair manner to the extent necessary for achieving such purposes.

Article 2 (Personal Information to be Acquired)

The Company will acquire Personal Information, including the information below, from a Candidate for achieving the purposes as stipulated in Article 3.
(1) name, age, address, date of birth, phone number, email address, educational background, professional background, certifications, current income, expected income, and other information;
(2) any information included in documents the Candidate provides to the Company when applying to Recruitment Activities, including but not limited to resume, curriculum vitae, application form, or survey;
(3) any communication between the Company and the Candidate in any form, such as face-to-face, email, or phone calls (including but not limited to communication regarding interviews);
(4) any information the Company acquires during screening procedures such as aptitude tests and other examinations, background checks, reference checks, and other confirmation procedures in the candidate screening process; and
(5) the Candidate’s history of application to and participation in Recruitment Activities, as well as screening results.
The Company acquires each Candidate’s Personal Information including the information stipulated in each Item of the preceding Paragraph from recruitment agencies and third parties subcontracted for background checks, etc. or via external tools used for the proper management of Candidates’ information in order to achieve the purposes as stipulated in Article 3.
Unless expressly agreed by the Candidate concerned or permitted by laws and regulations, the Company will not, in principle, acquire Personal Information containing the following contents.
(1) Matters concerning a thought, creed, or religion;
(2) Matters which can be a cause of social discrimination, including those of race, ethnic groups, family origins, domiciles of origins (excluding information concerning a prefecture where a person is located), physical or mental disabilities, or criminal histories;
(3) Matters concerning workers’ right to organize themselves, or their bargaining or acting collectively;
(4) Matters concerning the participation in a demonstration, or the exercise of the right to petition or of any political rights; or
(5) Matters concerning health or medical issues or sexual life.

Article 3 (Purpose of Using Personal Information)

The Company will use Personal Information which the Company acquires from a Candidate as stipulated in the preceding Article for the following purposes.
(1) Evaluating the qualifications of Candidates in recruitment screenings at the Company(including aptitude tests and other examinations, background checks, reference checks, and any other screening procedures);
(2) Carrying out the related procedures in the event that the Company decides on an exceptional basis to assist a Candidate in obtaining necessary visas and/or work permits;
(3) Responding to applications by Candidates or contacting Candidates regarding employment opportunities;
(4) Responding to inquiries from Candidates regarding the Company’s Recruitment Activities;
(5) Managing Candidates’ information properly;
(6) Managing Candidate’s employment if the Candidate joins the Company (this includes ensuring the Candidate's suitability for a job (e.g., assignment) and health);
(7) Providing Candidates with information regarding the Company’s Recruitment Activities(this includes providing information on events, etc. related to the Company’s Recruitment Activities);
(8) Conducting the surveys and analysis of or making the improvements or enhancements of the Company’s Recruitment Activities (this includes the aggregation of information obtained by statistically processing Personal Information, conducting various types of surveys, etc.);
(9) Utilizing information on Candidates as data for the Company's future Recruitment Activities and recruitment plans;
(10) Exercising rights or fulfilling obligations under laws, regulations, contracts, etc.; and
(11) For other purposes incidental to the preceding Items.

Article 4 (Change of Purpose)

The Company may change the purpose of using Personal Information as stipulated in the preceding Article; provided, that it is reasonably considered that new purpose after such change is relevant to those before such change.
If the Company is to use such Personal Information beyond such purpose as stipulated in the preceding Article, the Company will obtain the consent of such Candidate in advance.
If such purpose in the preceding Article is changed, the Company shall inform Candidates of the new purpose after such change by means prescribed by the Company or by publishing on its website.

Article 5 (Third Party Provision of Personal Data)

In principle, the Company will not provide personal data to third parties without the prior consent of the Candidate concerned, except for the following cases.
(1) If the third-party provision is in accordance with laws and regulations;
(2) If the third-party provision is necessary for protecting human lives, properties, or assets and it is difficult to obtain the consent of the User concerned;
(3) If the third-party provision is especially necessary for improving public hygiene or promoting sound growth of children and it is difficult to obtain the consent of the User concerned; or
(4) If the relevant business operator handling Personal Information is an academic or equivalent organization and it is necessary to provide the relevant personal data for the purpose of academic research (this type of provision includes cases where a part of the purpose to provide such personal data is for academic research and does not include cases where such provision might unjustly damage personal rights or interests; provided, that such relevant business operator handling Personal Information and the relevant third party jointly conduct academic research.).

Article 6 (Third-Party Service Providers)

The Company may grant access to any Candidate’s personal data to the extent necessary for achieving the purposes as stipulated in Article 3. The Company will evaluate the potential risks of using a third-party service provider (the “Subprocessor”) which has access to the Candidate’s personal data and conduct necessary and appropriate supervision.
As a condition of permitting a Subprocessor to process personal data, the Company will enter into a written agreement with each Subprocessor containing data protection obligations at least as protective as the technical and organizational measures the Company has put into place to protect Candidates’ personal data from accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access.
The Company’s Subprocessors shall be provided in the following list which will be updated from time to time.

Entity Name

Subprocessing Activity

Entity Country

Workable, Inc.

Personal Data Processing for Recruitment Activities

United States

HERP, Inc.

Personal Data Processing for Recruitment Activities

Japan

Google LLC

Personal Data Processing for Recruitment Activities

United States

Article 7 (Personal Data Provision to Third Parties in Foreign Countries)

The personal data of Candidates are processed by the Company in Japan, where the Company’s primary processing facilities are located. The acquired personal data of Candidates may directly be processed by the Company in Japan or transferred to the Company in Japan for the Company’s Recruitment Activities. In each case, the Company takes care to use appropriate safeguards to ensure Candidates’ personal data remain protected in compliance with data protection and privacy laws in the relevant jurisdictions.
In some cases, a third party or Subprocessor (“Third Parties”) as stipulated in Articles 5 and the preceding Article is located in a foreign country. In such cases, the Company will obtain the relevant Candidate’s consent by, in principle, providing such Candidate with the name of such foreign country, such foreign country’s system for protecting Personal Information acquired through appropriate and reasonable means, and information on Third Parties’ measures for protecting Personal Information, except for the following cases.
(1) If the relevant Third Parties are located in a country which the Personal InformationProtection Committee designates as a foreign country with a system for protection PersonalInformation at the same level as the equivalent system in Japan (such foreign country includes the U.K. and countries as stipulated in European Economic Area (EEA) agreement.).
(2) If the relevant Third Parties in a foreign country establish and maintain a system conforming to the standard required by the APPI (this includes cases where a CBPR certification of APEC is obtained. In such cases, the Company will take measures necessary and appropriate to continuously maintain such system conforming to the standard and will provide the relevant Candidate with information on such necessary measures.).
The Company provides Candidates’ personal data to Third Parties in foreign countries and takes measures necessary to secure continuous implementation of reasonable measures by such Third Parties in accordance with Article 28(3) of APPI and Article 18(1) of the Enforcement Rules for APPI. In order to find out about such necessary measures please contact the Company’s customer desk as stipulated in Article 16.

Article 8 (Cookie)

The Company uses cookies to improve convenience and quality. The Company does not use cookies for a purpose or in a manner that identifies a Candidate as a specific individual. For more information on the Company’s use of cookies, please visit the “ovice Cookie Policy".

Article 9 (Notification of Personal Data Usage Purpose and Application for Disclosure, Correction, and Cessation of Use)

If the Company receives an application for (i) notification or disclosure of usage purpose, (ii) correction, addition, or deletion of personal data, (iii) cessation of use or erasure of personal data, (vi) cessation of provision to third parties or disclosure of third party provision records in accordance with APPI concerning a Candidate’s personal data retained by the Company, then the Company will verify whether the applicant is the Candidate himself or herself and will make an appropriate response in accordance with the relevant laws and regulations including APPI.
If a Candidate wishes to make an application as stipulated in the preceding Paragraph, please contact the customer desk as stipulated in Article 16.
If an application does not meet the requirements of APPI or if any relevant laws and regulations allow the refusal of application including for disclosure and a ground for such refusal exists, then the Company may refuse such application. As for notification or disclosure of usage purpose, or disclosure of third-party provision records, the Company will charge such Candidate for JPY 1,000 (excluding tax) per application.

Article 10 (Security Management Measures)

In order to prevent any personal data related problems such as leakage, loss, or damage, the Company will take necessary and appropriate measures and manage personal data appropriately. Also, for safely managing personal data, the Company will conduct necessary and appropriate supervision over its employees and in cases of entrusting its handling of personal data, will conduct necessary and appropriate supervision so that such entrustee will safely manage such personal data.
In handling the Candidate's personal data in a foreign country, we will regularly collect and check information on systems for the protection of personal information in that foreign country and take appropriate security control measures, and will provide information on such security control measures to the extent that it does not hinder the Candidate upon his/her request.

Article 11 (Storage Term of Personal Information)

The Company will store Personal Information acquired by the Company to the extent necessary to achieve the usage purposes or in accordance with laws and regulations. After the achievement of such usage purposes or the passage of statutory storage terms, the Company will appropriately handle such Personal Information, including by deleting it or destroying relevant equipment and electronic media.

Article 12 (Scope of the Privacy Policy)

This Policy will not be applicable to any websites or webpages represented by links on websites operated by the Company’s business alliance partners, outsources, or the Company. TheCompany will not be responsible for any problems on such websites or webpages. Candidates are required to check the handling of Personal Information on such websites or webpages by themselves.

Article 13 (Changes to the Privacy Policy)

The Company will review the operational status concerning the handling of PersonalInformation in a suitable manner and use efforts to make continuous improvements. Therefore, this Privacy Policy may be updated from time to time, and the latest version of this PrivacyPolicy will always be posted on the website a Candidate is now visiting. Please check the latest version of this Privacy Policy carefully.
Except as otherwise stipulated by the Company, changes to this Privacy Policy will be effective from the date of revision which will be described in this Privacy Policy for each change. Any changes to this Privacy Policy will be notified to Candidates individually or publicly posted on our website. If required by applicable law, the Company will request the separate consent of the Candidate concerned.

Article 14 (Compliance)

The Company will comply with laws and regulations including the laws and regulations ofJapan applicable to Personal Information retained by the Company, provisions concerning the secrecy of communications in the Telecommunications Business Act, and other relevant laws and regulations as well as other norms including guidelines concerning the protection of Personal Information in telecommunications business.

Article 15 (Company Address and Representative’s Name)

Address: “E”-bu 113-B, Motofuchu-machi, Nanao-shi, Ishikawa
Representative’s name: Sae Hyung Jung

Article 16 (Customer Desk)

Regarding inquiries, including questions and complaints, on the Company’s handling of Personal Information, please contact the customer desk below.

[Customer Desk on Personal Information]
oVice, Inc.
Division in charge: HR Division
E-mail: privacy@ovice.co

[Effective on October 1, 2020]
[Revised on October 5, 2023]
[Revised on July 11, 2024]