Privacy Policy
GENDA Inc. (hereinafter "Company," or collectively referred to as “GENDA” including its group companies) has established the following policies regarding the handling of personal information provided by customers (hereinafter, including shareholders of the Company and those who sent inquiries to the Company, etc.) and personal information provided by customers when they use this website or the Company’s services (hereinafter “the Company’s Services”).
Personal Information Protection Policy
The Company complies with the laws and regulations regarding the protection of personal information and strives to appropriately manage and protect the personal information of customers held by the Company in accordance with this policy.
1. Purpose of Use of Personal Information
The Company will use customers’ personal information which the Company possesses within the scope necessary for the following purposes. In cases where personal information is used beyond the scope of these purposes, the Company shall obtain the appropriate consent from the customer in advance.
(1) To provide the Company's services
(2) To improve and enhance the content of the Company's Services, etc., or to develop new services and products
(3) To provide information on new functions, updates, campaigns, etc. regarding the Company's Services, etc. (including sending e-mails, flyers, and other direct mail)
(4) To contact customers when necessary, such as for maintenance or important announcements
(5) To respond to inquiries from customers regarding this website and the Company’s Services, etc. (hereinafter collectively "this Website, etc.") (including identity verification)
(6) To request cooperation in surveys, interviews, etc. related to this Website, etc. and to report the results
(7) To conduct market research and develop/research products and services
(8) To investigate and analyze the usage history of this Website, etc. and use the results for improving and developing this Website, etc.
(9) To allow the Company and advertising distributors, etc., to deliver advertisements (targeting advertisements) tailored to the customer’s interests and preferences, and to verify the extent to which the delivered advertisements align with the customer’s interests and preferences
(10) In case that the customer is a shareholder of the Company, to manage the shareholders such as (i) to exercise rights and fulfill obligations based on the Companies Act, (ii) to provide various benefits to shareholders in recognition of their status as shareholders of the Company, (iii) to implement various measures to facilitate the relationship between the Company and its shareholders from the perspective of the Company as an organization and its members as individuals and (iv) to prepare shareholder data in accordance with the prescribed standards based on various laws and regulations, etc.
2. Use of Google Analytics
This website uses Google Analytics, an access analysis tool by Google that uses cookies and other similar technologies. The Company receives information on customers' access to this Website, etc., browsing information of this Website, etc., and information on the device used by the customer (device type, OS version, etc.) through Google Analytics. However, none of this information includes personally identifiable information about the customer.
The Company uses Google Analytics to understand the usage status of this Website, etc. and to improve and develop this Website, etc., as well as to deliver advertisements tailored to customers' interests. If you wish to stop the collection of information using Google Analytics or to confirm the privacy policy of Google Analytics, please refer to the relevant documentation.
Google Analytics Privacy Policy (https://policies.google.com/privacy?hl=en-US)
Opt-out (https://tools.google.com/dlpage/gaoptout?hl=en)
3. Use of reCAPTCHA
This website uses "reCAPTCHA" provided by Google to protect the website from spam and other attacks on internet forms.
reCAPTCHA is used to determine whether the submitter is a human or a robot, and it obtains the submitter's IP address and other access information on behalf of the Company. The information collected is managed according to Google's privacy policy, and it does not include information that can identify the customer on its own. If you wish to review the terms of use and privacy policy of reCAPTCHA, please refer to the following links:
Google Terms of Service (https://policies.google.com/terms?hl=en-US)
Google Privacy Policy (https://policies.google.com/privacy?hl=en-US)
4. Management of Personal Information
The Company will implement appropriate management measures to prevent the loss, leakage, or unauthorized use of customers' personal information which the Company possesses.
5. Prohibition of Disclosure and Provision of Personal Information to Third Parties
Besides the exceptions listed below, the Company will not disclose or provide personal information to third parties without the consent of the customer. However, the following items from 4 to 6 will not apply when personal information is disclosed or provided to a third party located outside Japan (excluding cases where the third party has established a system in accordance with Article 28, Paragraph 1 of the Act on the Protection of Personal Information, or is located in a foreign country specified by the Personal Information Protection Commission rules).
(1) When it is necessary to protect a person's life, body, or property, and it is difficult to obtain the customer's consent.
(2) When it is particularly necessary to improve the public health or promote the healthy development of children, and it is difficult to obtain the customer's consent.
(3) When it is necessary to cooperate with national or local government agencies or those entrusted by them in carrying out the duties prescribed by law, and obtaining the customer's consent may hinder the performance of such duties.
(4) When it is necessary to entrust all or part of the handling of personal information within the scope necessary to achieve the purpose of use for the smooth operation of business.
(5) When personal information is provided in connection with the succession of business due to merger or other reasons.
(6) When personal information is jointly used with a specific individual, and the customer is notified in advance or placed in a state where it can be easily known about the items of personal information to be jointly used, the range of individuals who will jointly use the personal information, the purpose of use of those who will jointly use the personal information, and the name or title of the person responsible for managing such personal information.
(7) When otherwise permitted by law.
6. Joint Use
The Company will share data pertaining to personal information provided by customers (hereinafter "personal data") as follows.
(1) Items of Personal Data to be Shared
Attribute information such as name, date of birth, gender, address, telephone number, e-mail address, etc., payment-related information, information at the time of use of the Company’s Services (terminal identification ID, terminal OS information, usage, operation and setting information, cookie information, terminal location information: GPS location information, Wi-Fi location information, Bluetooth location information, etc.), number of share held, shareholder number, public information and other matters related to the attributes of the customer.
(2) Scope of joint users
(3) Purpose of Use of Personal Data
① To allow each joint user to provide various services linked with the Company’s Services (hereinafter referred to as "Related Services")
② To allow each joint user to conduct market research, improve the content of Related Services, or to develop and research new products and services
③ To allow each joint user to provide information on new features, updates, campaigns, etc. (including sending e-mails, flyers, and other direct mailings) for Related Services
④ To allow each joint user to contact you as necessary for maintenance, important notices, etc. related to Related Services
⑤ To allow each joint user to request users to cooperate with questionnaires, interviews, etc. concerning Related Services, to ask users to participate in various events, or to report the results of such events, etc.
⑥ To allow each joint user and advertising distributors, etc., to deliver advertisements (targeting advertisements) tailored to the customer’s interests and preferences, and to verify the extent to which the delivered advertisements align with the customer’s interests and preferences
⑦ To allow each joint user to resolve any trouble that may arise in the use or operation of related services
⑧ In case that the customer is a shareholder of the Company, in recognition of their status as shareholders of the Company by the Company and each joint user, to provide various benefits, and to implement measures to facilitate the relationship between the customer and the Company/joint users
(4) Name of the person responsible for the management of personal data
Name of Company: GENDA Inc.
Address: 1-9-1 Higashi Shimbashi, Minato-ku, Tokyo
Representative: Representative Director, President and CEO Nao Kataoka
7. Data Provision to Advertisement Distribution Providers (Including Provision to Third Parties Located Outside Japan)
In order to deliver optimal advertisements to customers, the Company may convert personal information received from customers (such as email addresses) into irreversible character strings (hashing), provide it to advertisement distribution providers, and deliver advertisements by matching this data with user information held by said providers (addressable advertising). Please refer to the appendix for information regarding the personal information protection systems of advertisement distribution providers located outside Japan.
8. Use and External Transmission of Offerwalls (Performance-Based Advertising)
(1) The Company implements an advertising system (hereinafter referred to as "Offerwall") through which customers can earn points as rewards by fulfilling specific conditions (such as installing targeted applications or achieving performance milestones). In this case, the Offerwall (excluding transition destination sites, applications, etc.) shall also be included within the Company's Services.
(2) When you use the Offerwall, the Company acquires and utilizes the following information (hereinafter referred to as "Additional Information"). Additional Information may include personal information.
- User ID (encrypted)
- Offer completion status and point acquisition history
- Performance details, such as installed applications, registered services, and completed surveys
- Log data regarding interactions with the offer, including offer displays, clicks, and completions
- Review results regarding the approval or rejection of performance achievements
(3) The Company utilizes the Additional Information for the following purposes:
- Provision of the Offerwall, granting of rewards, and management of usage status
- Verification and handling of reviews regarding performance approvals by advertisers
- Detection and prevention of fraudulent or unauthorized use, and investigation of system failures
- Effectiveness measurement and analysis of offers, and service improvement
- Customized display of offers tailored to user interests
(4) The Company may provide the Additional Information to the following third parties for the purpose of providing the Offerwall, and customers shall agree to this in advance:
- Advertisers providing the offers
- Advertising agencies and affiliate service providers handling the offers
- Offerwall operators
9. Disclosure of Personal Information
If you wish to request the disclosure of personal data concerning customers held by the Company (hereinafter "Retained Personal Data"), please contact us through the inquiry form on our company website. When the Company is requested to disclose Retained Personal Data by a customer, we will promptly disclose it to the customer. However, if the disclosure falls under any of the following, we may not disclose all or part of the data and will promptly notify the customer of the decision. In addition, a handling fee of 1,000 yen per item will be charged for the disclosure of Retained Personal Data.
(1) If there is a risk of harming the life, body, property or other rights and interests of the customer or a third party.
(2) If there is a risk of significantly hindering the proper implementation of the Company's business.
(3) If it violates other laws and regulations.
10. Correction and Deletion of Personal Information
If the Retained Personal Data of a customer is found to contain incorrect information, we will correct or delete the data in accordance with the procedures established by the Company upon request from the customer. If the Company determines that it is necessary to respond to the customer's request in the preceding paragraph, we will promptly correct or delete the Retained Personal Data and notify the customer of the action.
11. Suspension of Use of Personal Information, etc.
If a customer requests the suspension or deletion of the use of personal information (hereinafter "Suspension of Use, etc.") based on any of the following items, the Company will promptly conduct the necessary investigations and, based on the results, suspend or delete the use of personal information in accordance with the law and notify the customer of the action. However, if there is a large cost associated with the Suspension of Use, etc., or if it is difficult to suspend or delete the use of personal information for any other reason, we will take alternative measures necessary to protect the customer's rights and interests.
(1) If personal information is being handled beyond the scope of the stated purpose of use.
(2) If personal information was obtained by fraudulent means.
(3) If personal information is being used in a way that promotes or induces illegal or unfair acts.
(4) If the Company no longer needs to use the customer's personal information.
(5) If there is a leak, loss, or damage (hereinafter "Leakage, etc.") of personal information containing sensitive information, or if there is a risk of such occurrence.
(6) If there is a risk of financial damage due to the Leakage, etc. of personal information that may be used fraudulently.
(7) If a Leakage, etc. of personal information that may have been committed for an unauthorized or fraudulent purpose has occurred or is suspected to have occurred.
(8) If a Leakage, etc. of personal information involving more than 1,000 data subjects has occurred or is suspected to have occurred.
(9) If there is a risk that the rights or legitimate interests of customers may be harmed by the handling of said personal information.
12. Handling Complaints and Consultations
The Company will promptly and appropriately respond to inquiries and complaints regarding the handling of personal information by our customers. We will also promptly and appropriately respond to requests from customers regarding disclosure, correction, addition, deletion, use, or refusal of personal information.
13. Inquiries
For inquiries and consultations regarding the handling of personal information by the Company, please use the contact form on this Website.
Disclaimer
The Company does not provide any guarantees regarding the legality, accuracy, usefulness, morality, reliability, appropriateness, safety, or copyright clearance of the information posted on this website. The information posted on this website is only accurate as of the time of posting and may not correspond to actual information over time. In addition, we may change, modify, or delete the contents or URLs on this website without notice. We are not responsible for any damages resulting from these actions.
Third-party websites linked to or from this website are not under our management, and we are not responsible for any damages resulting from the content or use of those third-party websites.
Copyright
Unless otherwise noted, all information posted on this Website, etc., including but not limited to text, graphics, logos, images, and software, is copyrighted by the Company or the original authors, or other rights holders. Except for personal use or use otherwise permitted under copyright law, you are prohibited from copying, modifying, distributing, or using this information without prior permission from the Company.
Amended on October 5, 2026
Amended on December 9, 2025
Amended on February 13, 2025
Amended on June 17, 2024
Appendix
Entrusted Party
① Braze, Inc.
【The name of the country where the third party is located】
The United States of America
【The name of the service utilized by the Company】
Braze
【The personal information protection system in the country of location】
https://www.ppc.go.jp/files/pdf/USA_report.pdf ※Japanese only
【Measures taken by the third party for the protection of personal information】
All measures corresponding to the Eight Principles of the OECD Privacy Guidelines have been implemented.
【The terms and conditions of the third party】
https://www.braze.com/company/legal/privacy
Third-Party Recipient
② Google LLC
【The name of the country where the third party is located】
The United States of America
【The name of the service utilized by the Company】
Google Customer Match
【The personal information protection system in the country of location】
https://www.ppc.go.jp/files/pdf/USA_report.pdf ※Japanese only
【Measures taken by the third party for the protection of personal information】
All measures corresponding to the Eight Principles of the OECD Privacy Guidelines have been implemented.
【The terms and conditions of the third party】
https://policies.google.com/privacy?hl=en-US
③ Meta Platforms, Inc.
【The name of the country where the third party is located】
The United States of America, Ireland
【The name of the service utilized by the Company】
Custom Audiences
【The personal information protection system in the country of location】 ※Japanese only
The United States of America: https://www.ppc.go.jp/files/pdf/USA_report.pdf
Ireland: https://www.ppc.go.jp/enforcement/cooperation/cooperation/EU-DPA/
【Measures taken by the third party for the protection of personal information】
All measures corresponding to the Eight Principles of the OECD Privacy Guidelines have been implemented.
【The terms and conditions of the third party】
https://www.facebook.com/privacy/policy/
④ X Corp.
【The name of the country where the third party is located】
The United States of America
【The name of the service utilized by the Company】
Custom Audiences
【The personal information protection system in the country of location】
https://www.ppc.go.jp/files/pdf/USA_report.pdf ※Japanese only
【Measures taken by the third party for the protection of personal information】
All measures corresponding to the Eight Principles of the OECD Privacy Guidelines have been implemented.
【The terms and conditions of the third party】
https://x.com/en/tos
⑤ TikTok Pte. Ltd.
【The name of the country where the third party is located】
Singapore
【The name of the service utilized by the Company】
Custom Audiences
【The personal information protection system in the country of location】
https://www.ppc.go.jp/files/pdf/singapore_report.pdf ※Japanese only
【Measures taken by the third party for the protection of personal information】
All measures corresponding to the Eight Principles of the OECD Privacy Guidelines have been implemented.
【The terms and conditions of the third party】
https://www.tiktok.com/legal/page/us/privacy-policy/en