1. Acquisition of Personal Information

Our company will acquire personal information by means and within the scope necessary for the purposes of use specified in "2. Purpose of Use of Personal Information".

2. Purpose of Use of Personal Information

Our company will use the acquired personal information for the following purposes:

1. To register for our services and services of our company’s consolidated subsidiary companies ("our group"), authenticate member information during service use, provide various information as part of service provision to clients, and provide follow up services.
2. To prevent and deal with illicit activities and the like.
3. To provide third parties such as business operators or companies affiliated with our group, by the methods described within this policy.
4. To operate and manage seminars, various events, etc. provided by our group.
5. To provide information on services, various events, etc. provided by our group.
6. To provide information or send email newsletters about our group to clients, as well as provide other information about the services of our group.
7. To conduct campaigns, surveys, etc.
8. To improve services, as well as plan, research, and develop new services.
9. To respond to inquiries and questions from clients.
10. To develop and maintain the services provided by our group.
11. To create (including publication of such data and provision to third parties) statistical information, market information, trend information, and other similar data that are edited to make individuals unidentifiable, for the purpose of marketing, service improvement, market analysis, etc.
12. To use for other purposes in which we have notified in advance and obtained consent from the clients.
13. For other businesses related purposes stated in the above paragraphs.

3. Management of Personal Data

Our company will take necessary and appropriate measures to prevent leakage, loss (regular deletion of personal data is not considered loss), or damage of personal data. In addition, we will conduct necessary and appropriate supervision of our employees to ensure the safe management of personal data, and when we entrust all or part of the handling of personal data to an external contractor, we will conduct necessary and appropriate supervision of the contractor.

4. Provision of Personal Data to Third Parties

1. Our company will not provide personal data to third parties, except when we have obtained the prior consent of the individual or when it is permitted by law.
2. Notwithstanding the above, our company may provide personal information we handle to third parties in the following cases:
   1. When clients are seeking a job or hiring, we may provide the client’s personal information to our affiliated recruitment agencies, job seekers, and potential job candidates.
   2. When clients wish to rent, lease, sell, or purchase a property, we may provide the client’s personal information to our affiliated real estate brokers, potential contract parties, etc.
   3. When clients wish to transfer or acquire a business, we may provide the client’s personal information to our affiliated brokers, potential contract parties, etc.

5. Shared Use of Personal Data

Our company may share use of the personal data in the manner described below:

1. Personal data that may be shared:
   Name, postal code, address, phone number, age, date of birth, gender, occupation, work history, email address, transaction history information, and other necessary information.

2. Entities that may share use of the personal information:
   Our group companies (please refer to the following link for the extent of group companies.)
   https://naciel-holdings.co.jp/group/

3. Purpose of using the personal information:
   The purposes described in "2. Purpose of Use of Personal Information" above.

4. Official representative of company responsible for managing the personal information:
   Naciel Holdings Inc.,
   Seika Building 4th floor, 1-18-2 Nishi-shinjuku, Shinjuku-Ku, Tokyo, Japan
   CEOs Shunsuke Goto, Koji Nakamura

6. Entrustment of the Handling of Personal Information to Third Parties

Our company may entrust all or part of the handling of the personal information to a subcontractor within the scope necessary to fulfill the purpose of using the information as listed under "2. Purpose of Use of Personal Information" above. In such cases, we will thoroughly examine whether the subcontractor meets the subcontractor selection criteria set by our group, and ensure that personal information will be properly managed when entering into a contract.

7. Acquisition of Cookies

On our website, we use cookies (IDs composed of unique strings for each browser) to enhance the convenience of our clients and collect information about clients (information about individuals, such as browsing history on websites). This information about clients does not include information that can identify specific individuals. Furthermore, we do not provide cookie information to third parties.

8. Request for Notification of Purpose of Use, Disclosure, Correction, Suspension of Use, etc. of Personal Data

For personal data we hold, if we receive a request from a client for any of the following, we will respond in accordance with the provisions of the APPI after confirming that the request is from the client themselves or the representative. For details about these requests, please check "個人情報の開示等請求手続き方法（ https://naciel-holdings.co.jp/privacy/disclosure/ ）".

1. Notification of purpose of use
2. Disclosure of personal data or third-party provision records pertaining to the client held by our company
3. Correction, addition, or deletion of personal data held by our company that pertains to the client
4. Suspension of use, deletion, or suspension of provision to third parties

9. Security Management Measures

Our company takes reasonable precautions to protect the acquired personal information and implements protection both online and offline. We use technologies such as SSL to take utmost care in handling personal information and the like, and we limit access only to those who are given necessary authority for business purposes.

10. Inquiries

For inquiries about this privacy policy or its handling, please contact the following corresponding department.
Contact Information MAIL: privacys-arcana.co.jp

11. Changes to this Privacy Policy

Our company may change this privacy policy as necessary. If we change this privacy policy, it will be posted on our website.