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Privacy Policy

This English version of the Privacy Policy is provided for reference purposes only. In the event of any conflict or inconsistency between the Japanese version and the English version, the Japanese version shall prevail.

Shunkan AI Co. Ltd. (hereinafter referred to as "the Company") establishes this Privacy Policy (hereinafter referred to as "this Policy") regarding the handling of personal information obtained through our services. We will promote the protection of personal information by establishing a framework for personal information protection, ensuring that all employees recognize the importance of personal information protection, and thoroughly implementing these measures.

Article 1 (Personal Information)

"Personal Information" refers to "personal information" as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Personal Information Protection Act"), which means information about living individuals that can identify specific individuals by name, date of birth, or other descriptions contained in such information, or information containing personal identification codes.

Article 2 (Types of Personal Information Collected)

The Company collects and uses the following personal information in providing the Service:

1. Information obtained from Google Account

・Google User ID (account identifier)

・Name

・Email address

・Profile image URL

2. Information obtained through Gmail API

・Permission required for sending emails (send-only)

※The Company does not access Gmail data for any purpose other than sending emails.

3. Information voluntarily provided by users

・Phone number

・Company/Organization

・Job title

・Interests

・Email signature

・Timezone

・Language preference

・Business card data (image/text)

The above personal information is either explicitly provided by users or obtained from Google accounts with user consent. The Company will use this information only within the scope of purposes specified in this Privacy Policy and protect it with appropriate security measures.

Article 3 (Purpose of Use of Personal Information)

The Company will obtain and use personal information to the extent necessary for the following purposes. If we need to use personal information beyond these purposes, we will obtain the individual's consent through appropriate methods in advance.

・To provide our services (hereinafter referred to as "the Service")

・To provide integration features with external AI services (OpenAI, Anthropic, Google, etc.) and enable individuals to create personalized emails and other content using these external AI services

・To improve and enhance the Service content or develop new services

・To notify individuals about new features, updates, campaigns, and other services provided by the Company (including sending emails, flyers, and other direct mail)

・To communicate necessary information such as maintenance and important notices

・To respond to inquiries about the Service (including identity verification)

・To report Service usage status

・To request cooperation for surveys and interviews about the Service, invite participation in various events, or report their results

・To analyze Service usage history and use the results for Service improvement, development, and advertisement delivery

・To process data into a form that cannot identify individuals (anonymization or statistical processing, etc.) after withdrawal or termination of the Service, and use it for service quality improvement and statistical analysis

・To provide personal information to participating companies of Company-sponsored events based on consent and application

・To identify individuals who violate the Terms of Service or attempt to use the Service for improper or unfair purposes, and deny their use

Article 4 (Management and Protection of Personal Information)

Personal information will be strictly managed, and we will not disclose or provide data to third parties without the individual's consent, except in the following cases. We will also implement preventive and corrective measures against risks such as unauthorized access, loss, destruction, falsification, and leakage of personal information, considering security.

・When necessary to protect human life, body, or property, and it is difficult to obtain the individual's consent

・When especially necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the individual's consent

・When cooperating with a national agency, local government, or their contractors in executing affairs prescribed by laws and regulations, and obtaining the individual's consent would impede the execution of such affairs

・Other cases permitted by law

Article 5 (Outsourcing of Personal Information Handling)

1. The Company may outsource all or part of personal data handling to external AI service providers and other third parties within the scope necessary to achieve the purposes of use.

2. Regarding external AI service providers, we will review their terms of service and privacy policies, and only establish integration when we determine that the use of such services is necessary and that there are no significant risks in light of the Personal Information Protection Act and other related laws and regulations.

3. When outsourcing personal data handling to other third parties, the Company will establish confidentiality agreements with contractors and provide necessary and appropriate supervision to ensure compliance with the Personal Information Protection Act and other related laws and regulations.

Article 6 (Disclosure of Personal Information)

When an individual (limited to the individual themselves in this Article) requests disclosure of their personal information held by the Company, we will disclose it without delay. However, we may not disclose all or part of the information if disclosure would fall under any of the following cases, and we will notify the individual without delay when deciding not to disclose.

・When there is a risk of harming the life, body, property, or other rights and interests of the individual or third parties

・When there is a risk of significantly hindering the proper execution of the Company's business

・When it would violate other laws and regulations

Article 7 (Correction of Retained Personal Data)

1. An individual may request the Company to correct, add, or delete (hereinafter referred to as "correction, etc.") their personal information held by the Company if it is incorrect.

2. Upon receiving such a request, the Company will conduct necessary investigation without delay and, if the request is found to be justified, make the correction, etc. of the personal information without delay.

3. The Company will notify the individual without delay of its decision regarding whether to implement the correction, etc. based on the preceding paragraph.

Article 8 (Suspension of Use of Personal Information)

1. An individual may request the Company to suspend the use, delete, or stop third-party provision (hereinafter referred to as "suspension of use, etc.") of personal data held by the Company.

2. Upon receiving such a request, the Company will conduct necessary investigation without delay and, if the request is found to be justified, implement the suspension of use, etc. of the personal data. However, if the suspension of use, etc. requires considerable expense or is otherwise difficult to implement, and alternative measures can be taken to protect the individual's rights and interests, we may implement such alternative measures.

3. The Company will notify the individual without delay of its decision regarding whether to implement the suspension of use, etc. based on the preceding paragraph.

Article 9 (Procedure for Privacy Policy Changes)

The Company will periodically review and strive to improve the content of this Policy. The content of this Policy may be changed except for matters stipulated by laws and regulations or otherwise specified in this Policy. The revised Privacy Policy shall take effect when notified through the Company's prescribed method or posted on the Company website.

Article 10 (Compliance with Laws and Regulations)

The Company will comply with Japanese laws and other regulations applicable to personal information we hold.

Article 11 (Response to Complaints and Inquiries)

The Company will accept and respond appropriately and promptly to complaints and inquiries regarding the handling of personal information. We will also respond promptly and appropriately to requests from individuals for disclosure, correction, addition, deletion, refusal of use or provision of their personal information.

Article 12 (Security Management Measures)

Personal information obtained through our services will be protected by implementing organizational, physical, human, and technical measures, such as access restrictions to personal information files, recording access logs, and implementing security measures to prevent unauthorized access from external sources. These measures prevent unauthorized access to personal information and its loss, destruction, falsification, and leakage. In the event of a personal information leak or similar incident, the Company will promptly report to the supervisory authority in accordance with the Personal Information Protection Act and related guidelines, and take necessary measures as directed by the supervisory authority, including measures to prevent similar incidents and recurrence.

Article 13 (Company Address, Representative Name, and Personal Information Protection Manager)

The Company address, representative, and personal information protection manager are as follows:

Address: 5F Wakoh Miyamasuzaka Building, 2-19-19 Shibuya, Shibuya-ku, Tokyo

Representative: Kiyoshi Matsuura

Personal Information Protection Manager: Ryohei Kamiya

Article 14 (Contact Information)

For inquiries regarding the Company's handling of personal information, please contact us at:

Shunkan AI Co. Ltd. Customer Support

5F Wakoh Miyamasuzaka Building

2-19-19 Shibuya, Shibuya-ku, Tokyo

TEL: 03-6820-3939

Mail: support@panacel.ai

Supplementary Provisions

Established and Enacted: January 16, 2025

Revised: February 11, 2025