Personal data processing policy
We comply with applicable personal data protection laws and regulations in each jurisdiction such as the Personal Data Protection Act of Japan to process personal data (that is defined as personal data under applicable personal data protection laws and regulations in each jurisdiction; the same applies hereinafter) of test takers (including test takers’ lawful representative as necessary if test takers are minors; the same applies hereinafter) of the Test Of Fundamental Academic Skills that we develop and operate independently (“TOFAS”).
Acquisition of personal data
We will collect personal data of TOFAS test takers directly from the test takers or indirectly from third parties such as our business partners, but we will collect and use personal data in a legal and fair manner.
If the TOFAS test taker is a minor;
- (i) we will collect such test taker’s personal data together with a consent form from his/her lawful representative such as a parent where necessary; and
- (ii) we will collect the personal data of his/her lawful representative which the test taker does not possess (for example, email addresses as referred to below).
We will collect the following personal data from TOFAS test takers:
- Age and date of birth;
- Email address;
- Behavioral interests data such as browsing history of our website (the “Website”);
- Cookies (for details, please refer to the note in “Purposes of use of personal data” below); and
- TOFAS score and any other data that the test takers provide us in t taking TOFAS.
Purposes of use of personal data
We will collect and use personal data within the scope necessary for achieving the purposes of use by specifying those intended purposes of use in advance and will not use it for any other purposes without the consent of TOFAS test takers, except as permitted under the personal data protection laws of the applicable jurisdiction. We will use personal data within the scope of the following purposes of use to the extent necessary to carry out our tutoring school business, educational materials publishing business, and educational IT business (including the operation of TOFAS) ( “Our Business”):
- To create and analyse statistical data categorized by attributes of TOFAS test takers;
- To analyse data of attributes and behavioral interests such as browsing history of the Website in order to provide information on products and services that match the attributes of TOFAS test takers’ interests and develop new products and services;
- To disclose TOFAS test takers’ personal data to financial institutions to process their payment transactions when we provide products or paid services to TOFAS test takers;
- To improve the convenience of the contents of the Website; and
- To achieve other purposes of use that we expressly specified when collecting personal data of TOFAS test takers.
If the purposes of use are deemed to be reasonably clear in view of the circumstances of collection of personal data of TOFAS test takers, such purposes of use may not appear above as we may omit to give notice of the same.
Information about TOFAS test takers that we collect through our products and services (including the Website and apps) may be used in conjunction with other personal data of the test takers which has already been retained by us. In this case, the information associated with the personal data will also be managed in accordance with this Privacy
We may use data collected by using Cookies (including user activities, user environment (IP addresses, etc.), and user attributes) for analysis of trends and interests of TOFAS test takers based on their access status and for engaging in sales activities associated with the data registered by the TOFAS test takers.
If TOFAS test takers do not wish for data to be collected using Google Analytics, TOFAS test takers may turn off Google Analytics by invalidating it in the add-on settings of their browsers. To turn off Google Analytics, please download and install the “Google Analytics Opt-out Add-on” from the Google LLC Opt-out Add-on download page and change the add-on settings in your browser.
Google Analytics Opt-out Add-on
Legal basis of processing of personal data
If a TOFAS test taker does not wish to provide his/her personal data even though the provision of personal data is a statutory or contractual requirement or is a necessary element for execution of contract, we may not be able to provide our products and services (including the Website and the apps) to the TOFAS test taker.
Retention period of personal data
We maintain the accuracy of personal data up to date to the extent necessary to achieve the purposes of use. Further, to determine an appropriate retention period for personal data, we take into account the volume, nature, and sensitivity of the personal data, the risk of potential damage from unauthorized use or disclosure of the personal data, the purposes for which we process the personal data and whether we can achieve those purposes by other means, and applicable legal requirements. If the personal data of TOFAS test takers that we have collected is no longer necessary for legal and business purposes, we will delete or anonymise such personal data, and if such measures are impracticable (for example, if such personal data has been stored in back-up archives), we will store the personal data of TOFAS test takers safely until deletion becomes practicable and ensure that no new processing of personal data takes place thereafter.
Change of purposes of use of personal data
If we change the purposes of use of personal data, we will not make a change beyond the extent to which it is reasonably relevant to the original purposes of use, and we will notify TOFAS test takers of the changed purposes or make such change public.
Provision of personal data to third parties
We will disclose personal data of TOFAS test takers to third parties only to the extent necessary for the legitimate execution of Our Business, and only with the consent of TOFAS test takers. However, please note that we may disclose personal data of TOFAS test takers to third parties without obtaining your consent in the following situations where:
- the disclosure is required or authorised based on the applicable laws and/or regulations;
- the disclosure is necessary to protect the life, body, or property of an individual and it is difficult to obtain a consent of TOFAS test takers;
- the disclosure of personal data is particularly necessary to improve public health or promote the soundness of individuals, and it is difficult to obtain a consent of TOFAS test takers;
- the disclosure is necessary to cooperate with a national agency, a local government, or a person or organisation entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and there is a risk that obtaining a consent of TOFAS test takers may impede the execution of the affairs concerned;
- a third party is an academic research institute, etc., and the third party needs to process the personal data for the purposes of academic studies (including cases where a part of the purposes for processing the personal data concerned is for academic research, except where there is a risk of violation of the rights and interests of individuals);
- Our Business is succeeded due to a merger, a company split, a transfer of business, or any other similar reason, and the personal data we collected is succeeded as a part of the action above; and
- (other cases permitted under applicable laws and regulations (for example, we may jointly use personal data with a specified person on the grounds of joint use under the Personal Data Protection Act of Japan).
Notwithstanding the above, we are entitled to provide personal data that has been de-identified or aggregated to become statistical information, without restriction.
If we outsource the processing of personal data to processors (service providers), we will exercise necessary and appropriate supervision over such processors to ensure the security of personal data management.
Outsourcing of processing of personal data
We may outsource all or a part of the processing of personal data we have collected to third parties to the extent necessary for the legitimate purposes of Our Business.
For example, we may implement outsourcing of TOFAS, outsourcing of waste disposal, outsourcing to advertising production companies, outsourcing of database construction, etc. When we outsource processing of personal data to a third party, we will carefully screen and confirm that the third party has a sufficient personal data protection management system in place before entering into a service agreement with the third party, and we will take necessary steps and appropriate supervision to ensure that the outsourced third party manages personal data securely.
Disclosure, etc. of personal data
If a TOFAS test taker requests disclosure, correction, erasure, suspension of use, or deletion (hereinafter “Disclosure”) of his/her personal data, we will respond to such requests without delay in accordance with the provisions of applicable law after confirming the identity of the TOFAS test taker. However, this does not apply to the cases where we are not obliged to do the Disclosure regarding such personal data under applicable laws and regulations. Please be aware that a handling fee of 880 yen (including tax) will be charged to respond to requests for the Disclosure of personal data.
Secure management of personal data
To process personal data of TOFAS test takers, we have established the Personal Data Handling Regulations to serve as the highest standard for our company based on various laws and regulations such as the Personal Data Protection Act and any other related laws, regulations, guidelines of the Personal Data Protection Commission and any other guidelines that we must comply with in each jurisdiction where such test takers are residing, and we will ensure that our officers and all of our employees abide by these regulations and exercise necessary and appropriate supervision to ensure the secure management of personal data.
In order to prevent the leak, loss, or damage of personal data and for other secure management purposes, we will take necessary steps and appropriate measures, such as managing access to personal data, restricting the means of taking personal data out of the company’s premises, and preventing unauthorized access by external entities.
Metropolitan Plaza Building 12th Floor, 1-11-1, Nishi-Ikebukuro, Toshima-ku, Tokyo 171-0021
Representative: Hiroyuki Tsuneishi (Mr.)
Complaints and inquiries
If you have any questions regarding the processing of personal data, please contact our inquiry desk listed below.
Inquiry desk: Sprix Corporation Administration Department
Phone number: +81-03-5927-1687
Office hours: 1:00 p.m. to 6:00 p.m.
Effective Date: 22 April, 2022