We have established this privacy policy (the “Policy”) to set forth guidelines regarding the handling and management of Personal Information collected by us when you participate (a “Participant”) in our market research, studies or testing sessions or when you use (a “User”) any software application or service provided by us (the “Services”). 

Personal Information

In this policy, “Personal Information” refers to “Personal Information” as defined in the Personal Information Protection Law (“APPI”), and means information about living individuals, including the name, date of birth, address, telephone number and contact information of an individual, and any other description or information that can be used to identify a specific individual, such as the appearance and voice of an individual or other types of personal identification information. 

Information that We Collect

(Personal Information Collected from Participants)

We may ask Participants to provide Personal Information such as their [name, date of birth, address, telephone number, email address and educational background]. Occasionally, we may also make audio or video recordings of the market research, studies or testing sessions which will contain personal identification information such as the appearance or voice data of the Participants. We will collect Personal Information provided by the Participants or generated in connection with participation in the market research, studies or testing sessions.

(Personal Information Collected from Users)

In order to use our Services, Users may be asked to create an account and set up a username and password. Further, we may ask Users to provide Personal Information such as their [name, date of birth, address, telephone number, email address, gender, weight, interest/hobbies, credit card information and appearance data]. Additionally, a User may choose to voluntarily share certain Personal Information while using the Services. For example, a User may upload a picture or video, create posts or logs containing geo-location information or import personal health information such as heart rate from other applications or devices. We will collect the Users’ basic account information and any Personal Information provided in connection with the use of our Services. 

Why We Collect Personal Information

We collect and use Personal Information for the following purposes (the “Purpose”).

(Purposes of collecting Personal Information from Participants)

• To administer and conduct market research, interviews, surveys or testing sessions.
• To analyze the results of such market research, interviews, surveys or testing sessions.
• To contact Participants when necessary to provide updates, important notices, etc.
• To contact Participants in the event of a disaster or other emergency.
• All other purposes incidental to the purposes listed above.

(Purposes of collecting Personal Information from Users)

• To provide or improve the Services.
• To manage and perform analysis of the usage of the Services.
• To handle inquiries regarding the Services.
• To investigate any unauthorized access to or misuse of the Services or breach of our terms and conditions.
• To contact Users when necessary to provide updates, important notices, etc.
• To contact Users in the event of a disaster or other emergency.
• All other purposes incidental to the purposes listed above.

Sharing Your Information

In principle, we will not share your Personal Information with third parties without your prior consent. However, we may share Personal Information with a third party without your consent as needed to run our business, provide the Service and fulfill the Purpose, or where required for legal purposes. 

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Here are the situations where we may share your Personal Information.

• We may share information with third parties who assist us with conducting or analyzing the results of, our market research, studies or testing sessions.
• We may share information with third parties who provide services that we use to support, improve, promote or secure our Services, including payment processing and content management. The service providers will only have access to the Personal Information necessary to perform their limited functions on our behalf and they are required to protect your information.
• Depending on the Service, we may share the information or content you provide us with other users and the public in accordance with your privacy controls and settings on that Service. In these situations, we will have the option to change your privacy settings on the Service you are using. 
• If you are using a Service through your organization or have an account assigned by your organization, we may share your information with your administrator or the representative of your organization for account management purposes such as to manage how users from your organization use the Service or to help users reset passwords. 
• We may share information if it is reasonably necessary to protect the life, body, or property of Launchpad and our Shared Parties, our Participants or Users, or a third party. 
• We may share information to address any issues of national security or of public importance, to prevent or detect fraud, security or technical issues or violations of our Terms of Service, or to address any abuse of our Services or its users.
• We may share information, including with law enforcement, public or governmental agencies, or private litigants, within or outside of your country of residence, if we determine that such disclosure is allowed by law or reasonably necessary to comply with the law. This may include situations where we are asked to respond to court orders, warrants, subpoenas or other legal or regulatory requirements.
• We may share information with our legal counsel and other consultants or third parties to protect our business operations or our legal rights. 

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Additionally, we may share non-personally identifiable information publicly or with our business partners (such as publishers, advertisers or developers) to help support, improve, promote or secure our Services. 

Any sharing of information in the situations listed above will only be in the scope permitted by the APPI and other laws and regulations. 

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Under the APPI guidelines, there are certain exceptions where we are allowed to share information with outside parties who will not be considered a “third party” for the purposes of the APPI. We may share your Personal Information with an outside party if we outsource all or part of the handling of your Personal Information to the outside party but only to the extent that it is necessary to achieve the Purpose. The outside party handling your Personal Information will not be allowed to use the information it receives for any other purpose. Additionally, in the unlikely event that we undergo a business succession as a result of a merger, business transfer or other reasons, your Personal Information may be shared as part of the business succession. 

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We may also share Personal Information collected from you with [Fujitsu Limited and its subsidiaries and affiliates] (the “Shared Parties”) and the Shared Parties may use your Personal Information for the Purpose set forth in this Policy, or so that the Shared Parties may provide their services to you or improve their services. Depending on the purpose, we may share basic information such as your name, date of birth, address, telephone number, e-mail address or gender or we may share information about your interests/hobbies, educational background; or work experience or non-personally identifiable information and aggregated data. We will be responsible for the management of any Personal Information to be shared with the Shared Parties and you should contact us if you would like to know more about how your information may be used by the Shared Parties.

Disclosing Your Information

If we receive a request from you to disclose Personal Information, we will only disclose the requested information after confirming your identity. However, in some cases, we may refrain from disclosing all or part of the Personal Information. We will notify you if we decide not to disclose the requested information. In addition, a processing fee may be charged for each requested disclosure of Personal Information. We may refrain from disclosing Personal Information in the following cases.

• If there is a risk of harm to the life, body, property, or other rights or interests of another third party or us.
• If there is a risk that the disclosure could have an adverse effect on the operations, integrity or security of our business or the Services.
• If the disclosure would violate any laws or regulations or a legal enforcement authority’s orders.

Correcting and Deleting Your Information

If you become aware that any part of your Personal Information is incorrect, you ask that you correct the inaccuracies as soon as possible. In many cases, you may be able to update your Personal Information on your profile or account by logging into the Service you are using. If you need further assistance correcting inaccurate information, you may contact us directly via the Service or by using the contact information listed at the bottom of this Policy. We will evaluate all requests we receive and if we determine that a correction is necessary, we will correct the relevant Personal Information. If we determine that a correction is not necessary or warranted, we will notify you of our decision. 

You may also delete your profile or account by logging into the Service you are using and following the instructions on the Service, or you may contact us and request that we delete your Personal Information held by us. After you make a deletion request, we will permanently and irreversibly delete your Personal Information from our systems, including backups. Once an account is deleted, all your data, including your profile and account information cannot be reinstated. Therefore, if you would like to retain all or part of your data, including any content you have uploaded, please follow the instructions on the Service you are using to download your data. After you delete your account from a Service or make a deletion request of Personal Information held by us, it may take up to 60 days for us to fully erase your Personal Information from our systems. Additionally, we may retain certain Personal Information despite a deletion request if it is reasonably necessary to retain such information to comply with laws and regulations or to take other actions permitted by law. 

Our Retention Period

We will retain your Personal Information for the period necessary to carry out the Purpose set forth in this Policy subject to any legal obligations to retain your Personal Information for further periods. 

Data Security

We have implemented technical, physical, and organizational measures and controls to safeguard and protect the transmission and storage of the information we collect. We employ reasonable protections for your Personal Information that are appropriate to its sensitivity. While we endeavor to use reasonable security measures to protect against unauthorized access to your Personal Information under our control and strive to prevent any leak or loss of, or damage to, Personal Information, we cannot guarantee absolute security to the Personal Information you provide or that our security measure will prevent unauthorized or illegal access to your Personal Information. If any leakage of Personal Information or other security incident occurs, we will notify you and take necessary actions in accordance with the procedures set forth under the relevant laws and regulations.

Changes to this Policy

As we are constantly launching new services and improving our current offerings, we may update this Policy at any time and for any reason in our sole discretion. Any time we make changes to this Policy, we will provide you with reasonable advance notice of the revisions before the effective date of the amended Policy. The amended Policy will be posted on our website and will become effective on the effective date. 

Contact Information