Created November 15, 2023

 

We at BLUE Symphony Corporation (together with our affiliates, “BLUE Symphony”, “we”, “our” or “us”) has established the following Privacy Policy regarding the handling of users’   Personal Information we collect from or about you when you use our website, applications, and services (collectively, “Services”).

 

 

1. Personal information we collect

We collect personal information relating to you (“Personal Information”) as follows:

 

Personal Information You Provide: We collect Personal Information if you create an account to use our Services or communicate with us as follows:

• Account Information: When you create an account with us, we will collect information associated with your account, including your name, date of birth, contact information, account credentials, payment card information, and transaction history, (collectively, “Account Information”).
• User Content: When you use our Services, we collect Personal Information that is included in the input, file uploads, or feedback that you provide to our Services (“Content”). 
• Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send (“Communication Information”).
• Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube, LinkedIn and so on. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
• Other Information You Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys or provide us with information to establish your identity (collectively, “Other Information You Provide”

 

Personal Information We Receive Automatically From Your Use of the Services: When you visit, use, or interact with the Services, we receive the following information about your visit, use, or interactions (“Technical Information”):

• Log Data: Information that your browser or device automatically sends when you use our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our Services.
• Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
• Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
• Cookies: We use cookies to operate and administer our Services, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website.
• Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

 

2. How we use personal information

We may use Personal Information for the following purposes:

• To provide, administer, maintain and/or analyze the Services;
• To improve our Services and conduct research;
• To communicate with you; including to send you information about our Services and events;
• To develop new programs and services;
• To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks;
• To carry out business transfers; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

 

Aggregated or De-Identified Information. We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyze the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy.

 

3. Provision of personal information to third parties

In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the law:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, email communication software, web analytics services, and other information technology providers, among others. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us.
• Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal Requirements: We may share your Personal Information, including information about your interaction with our Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.
• Affiliates: We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with BLUE Symphony, or is owned at least 1/3 of its shares by shareholders who owned at least 1/3 of the shares of BLUE Symphony. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
• Other Users and Third Parties You Share Information With: Certain features allow you to display or share information with other users or third parties. For example, you may share Smart Insight conversations obtained from Smart Insight on the customer’s account, with other users via shared links. Be sure you trust any user or third party with whom you share information.

 

4. Disclosure of personal information

When we receive a request for disclosure of personal information from the person concerned, we will disclose it to the person concerned without delay. However, we may decide not to disclose all or part of the information if disclosure would result in any of the following cases, and if we decide not to disclose the information, we will notify you to that effect without delay. A fee of 1,000 yen or 10 U.S. dollars will be charged for each case of disclosure of personal information:

• If there is a risk of harm to the life, body, property, or other rights or interests of the person concerned or a third parties
• If there is a risk of significant hindrance to the proper conduct of our business
• If it violates any other laws or regulations

 

5. Your rights to correct, delete, or discontinue the use of personal information

Depending on location, individuals may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:

• Access your Personal Information and information relating to how it is processed.
• Delete your Personal Information from our records.
• Rectify or update your Personal Information.
• Transfer your Personal Information to a third party (right to data portability).
• Restrict how we process your Personal Information.
• Withdraw your consent—where we rely on consent as the legal basis for processing at any time. 
• Object to how we process your Personal Information.
• Lodge a complaint with your local data protection authority.

You can exercise some of these rights through your BLUE Symphony account. If you are unable to exercise your rights through your account, please submit your request through privacy☆a-i.bz. (Please replace ☆ with @.)

 

 

Correction, Deletion, Suspension of Use, etc. of Personal Information in Japan. Correction and deletion of personal information, as follows.

• If your personal information held by BLUE Symphony is incorrect, you may request BLUE Symphony to correct, add, or delete collectively, “correct” or “correction”) his/her personal information in accordance with the procedures prescribed by BLUE Symphony.
• If we deem it necessary to respond to the request from you as described in the preceding paragraph, we will correct, etc. the relevant personal information.
• When BLUE Symphony makes a correction, etc. based on the preceding paragraph or decides not to make a correction, etc., BLUE Symphony will notify you of such decision.

 

In addition, the suspension of use of personal information, etc., is as follows.

• When we receive a request from a customer to stop using or delete (hereinafter referred to as “stop using, etc.”) his/her personal information on the grounds that it has been handled beyond the scope of the purpose of use or that it has been obtained by wrongful means, we will conduct the necessary investigation without delay. When a request is made to suspend the use of personal information or to erase such information (hereinafter referred to as “suspension of use, etc.”) on the grounds that the information is handled beyond the scope of the purpose of use or that the information was obtained by wrongful means, we will conduct the necessary investigation without delay.
• If, based on the results of the investigation in the preceding paragraph, we deem it necessary to comply with the request, we will suspend the use of the relevant personal information without delay.
• When BLUE Symphony suspends the use of personal information in accordance with the preceding paragraph or decides not to suspend the use of personal information, BLUE Symphony will notify youof this decision without delay.
• Notwithstanding the preceding two paragraphs, if the suspension of use involves a large amount of cost or if it is otherwise difficult to suspend the use of personal information, and if alternative measures can be taken to protect the rights and interests of you, these alternative measures shall be taken.

 

6. Additional U.S. state disclosures

The following table provides additional information about the categories of Personal Information we collect and how we disclose that information. You can read more about the Personal Information we collect in “Personal information we collect” above, how we use Personal Information in “How we use personal information” above, and how we retain Personal Information in “Security and Retention” below.

Category of Personal Information	Disclosure of Personal Information
Identifiers, such as your name, contact details, IP address, and other device identifiers	We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; to corporate administrators of enterprise or team accounts; and to other users and third parties you choose to share it with.
Commercial Information, such as your transaction history	We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to corporate administrators of enterprise or team accounts.
Network Activity Information, such as Content and how you interact with our Services	We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to other users and third parties you choose to share it with.
Geolocation Data	We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; and to parties involved in Transactions.
Your account login credentials and payment information (Sensitive Personal Information)	We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.

To the extent provided for by local law and subject to applicable exceptions, individuals may have the following privacy rights in relation to their Personal Information:

• The right to know information about our processing of your Personal Information, including the specific pieces of Personal Information that we have collected from you;
• The right to request deletion of your Personal Information;
• The right to correct your Personal Information; and
• The right to be free from discrimination relating to the exercise of any of your privacy rights.

 

Verification. In order to protect your Personal Information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request.

Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us. Authorized agent requests can be submitted to privacy@a-i.bz.

Appeals. Depending on where
you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please send your request to privacy@a-i.bz.

 

7. Links to other websites

The Service may contain links to other websites not operated or controlled by BLUE Symphony, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

 

8. Security and Retention

We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.

We’ll retain your Personal Information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

 

9. International users

By using our Service, you understand and acknowledge that your Personal Information may be disclosed to our service providers and affiliates in other jurisdictions outside of the location where you are using the service.

 

Legal Basis for Processing.
Our legal bases for processing your Personal Information include:

 

• Performance of a
  contract with you when we provide and maintain our Services. When we process Account Information, Content, and Technical Information to provide our Services to you, this information is necessary to be able to provide our Services. If you do not provide this information, we may not be able to provide our Services to you. 
• Our legitimate interests in protecting our Services from abuse, fraud, or security risks, or in developing, improving, or promoting our Services, including when we train our models. This may include the processing of Account Information, Content, Social Information, and Technical Information.
• Your consent when we ask for your consent to process your Personal Information for a specific purpose. You have the right to withdraw your consent at any time.
• Compliance with our legal obligations when we use your Personal Information to comply with applicable law or when we protect our or our affiliates’, users’, or third parties’ rights, safety, and property.

 

 Data Protection Officer. You can contact our data protection officer at privacy☆a-i.bz in matters related to Personal Information processing.

 

 

10. Changes to the privacy policy

We
may update this Privacy Policy from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law.

 

11. How to contact us

If
you have any questions or concerns not addressed by this Privacy Policy, please
contact Support. For inquiries regarding the policy, please contact the
following.

 

Head Office     : 1-1-27, Chuo-ku, Osaka-shi, Osaka, 541-441 Japan

Company          : BLUE Symphony Corporation