Privacy Policy

Article 1. Definitions

Terms used in this Policy have the meanings given in the Act on the Protection of Personal Information (the “APPI”).

Article 2. Compliance with laws

We comply with the APPI, related laws and regulations, and guidelines of the Personal Information Protection Commission, and handle personal information appropriately. We do not obtain personal information by deception or other improper means, and we do not use personal information in a manner that is likely to encourage or induce illegal or improper acts.

Article 3. Information we obtain

We obtain the following information through the Site.

• 1. Information you enter in the contact form: company name, department, department size, job title, name, email address, telephone number, enquiry details, how you learned about us, and any other optional details you provide.
• 2. Information obtained automatically when you browse the Site: cookies and other identifiers, pages viewed, time on site, referrers, IP address, and device and browser information.

We do not offer membership registration, take payments, or collect identity documents on the Site.

Article 4. Purposes of use

We use personal information obtained for the following purposes.

• 1. To respond to enquiries, contact you in that connection, and verify identity.
• 2. To propose our products and services, send materials, and communicate about business discussions and other transactions.
• 3. To understand and analyse Site usage and to improve the Site and our services.
• 4. To prevent improper submissions and otherwise secure the Site.
• 5. Purposes incidental to the purposes above.

Article 5. Changes to purposes of use; prohibition of use beyond purpose

• 1. Except as permitted by law, we will not handle personal information beyond the scope necessary to achieve the purposes in the preceding article without obtaining the individual’s prior consent.
• 2. We may change a purpose of use only within a scope reasonably related to the purpose before the change. Where we do so, we will notify the individual of the changed purpose or publish it on the Site.

Article 6. Accuracy and erasure

Within the scope necessary to achieve the purposes of use, we endeavour to keep personal data accurate and up to date. We endeavour to erase without delay personal data that is no longer needed.

Article 7. Security control measures

To prevent leakage, loss or damage of personal data and for other security control, we take the following measures.

• We limit persons who handle personal data to the minimum necessary and manage access rights.
• We inform employees who handle personal data of points to note in that handling.
• For services and devices that store personal data, we prevent unauthorised access, theft and loss through stronger authentication, encryption of communications and similar measures.
• We maintain arrangements to report and respond promptly if a leakage or similar incident occurs.
• Some personal data is handled on services of businesses located in the United States; we take security control measures after understanding that country’s personal information protection framework.

Article 8. Entrustment

Within the scope necessary to achieve the purposes of use, we may entrust all or part of the handling of personal data to external providers for email delivery, operation of servers and networks, analytics and similar work. In that case we select providers appropriately and supervise them as necessary and appropriate.

Article 9. Provision to third parties

1. Except in the following cases, we will not provide personal data to a third party without obtaining the individual’s prior consent.

• (1) Where required by law.
• (2) Where necessary to protect a person’s life, body or property and it is difficult to obtain the individual’s consent.
• (3) Where particularly necessary to improve public health or promote the sound upbringing of children and it is difficult to obtain the individual’s consent.
• (4) Where necessary to cooperate with a national or local government body, or a party commissioned by them, in performing affairs prescribed by law, and obtaining consent risks impeding those affairs.
• (5) Other cases permitted under the APPI.

2. Where personal data is provided in connection with entrustment under the preceding article, or in connection with a business succession following a merger or other cause, the recipient is not treated as a third party.

Article 10. Provision to third parties in foreign countries

To handle enquiries, we use an email delivery service of a business located in the United States, and information entered in the contact form is sent to that business. That business takes measures to protect personal information under its own privacy policy and data-processing terms. For information on the personal information protection framework of the United States, please refer to materials on foreign systems published by the Personal Information Protection Commission.

The contact form is submitted only after you agree to this Policy.

Article 11. Requests regarding retained personal data

• 1. An individual or their agent may request notification of the purposes of use, disclosure (including disclosure of records of provision to third parties), correction, addition or deletion, suspension of use or erasure, and suspension of provision to third parties, regarding retained personal data we hold.
• 2. Please contact us via the point in Article 14. We may ask you to provide information necessary to confirm that the requester is the individual or a duly authorised agent.
• 3. Disclosure is made by a method the individual designates among provision of an electromagnetic record, delivery of a written document, or other methods we prescribe. If the designated method is difficult, we disclose by delivering a written document.
• 4. We respond to requests without delay as required by the APPI. If we do not grant all or part of a request, or take a different measure, we notify the individual without delay and endeavour to explain the reasons.
• 5. There is no fee for requests.

Article 12. Use of analytics and related tools

To understand and improve how the Site is used, we use Google Analytics 4 provided by Google LLC. Google Analytics 4 collects information such as pages viewed, time on site, referrers, and device and browser details using cookies and similar technologies. Information collected is managed under Google’s privacy policy. For Google’s use of information, see How Google uses information from sites or apps that use our services. You can stop collection by disabling cookies in your browser settings or by using the Google Analytics opt-out browser add-on.

In addition, we use tools from external providers to aggregate browsing activity on the Site and to prevent improper submissions to the contact form. In connection with those uses, information about your device and browser may be sent to those providers.

Information obtained in these ways may constitute personal information when matched with other information.

Article 13. Changes to this Policy

We may change this Policy as needed for amendments to law, changes in our practices, or other reasons. The amended Policy takes effect when posted on the Site. Changes to purposes of use follow Article 5.

Article 14. Enquiries and complaints

Enquiries and complaints about this Policy or our handling of personal information, and requests under Article 11, are received at the following contact point.

commissure, Inc. Personal Information Contact, 〒153-8505 4-6-1 Komaba, Meguro-ku, Tokyo, University of Tokyo Komaba II Campus, Collaborative Research Building, Room 507

Please contact us via the contact form.