{# SPDX-License-Identifier: AGPL-3.0-or-later #}
{# SPDX-FileCopyrightText: 2023 JWP Consulting GK #}
<h1>Privacy Policy</h1>
<p>
    JWP Consulting GK (hereinafter referred to as "the Company") is intent on
    protecting the privacy of any user of the Company's website(s) and the
    Company’s service(s) (hereinafter collectively referred to as “Website,
    Etc.”) (such a user is hereinafter referred to as “User”) with respect to
    handling the Personal Information, etc. in the Website, Etc. The Company
    would like the User to read this privacy policy (hereinafter referred to as
    "Privacy Policy") carefully and thoroughly before using the Website, Etc.
</p>
<h2>Article 1 (Definitions)</h2>
<p>The terms used in the Privacy Policy are defined as follows:</p>
<ol type="1">
    <li>
        <p>
            "Personal Information" means any personal information under the
            Personal Information Protection Law, i.e., any information about a
            living individual that includes a name, date of birth, address,
            telephone number, contact information, or any other description
            that identifies a specific individual or includes a personal
            identification code.
        </p>
    </li>
    <li>
        <p>
            "Personal Information Database, Etc." means a personal information
            database, etc. under the Personal Information Protection Law, i.e.,
            a collection of information containing Personal Information that is
            systematically organized so that specific Personal Information can
            be retrieved by using a computer, and any other one specified by a
            Cabinet Order.
        </p>
    </li>
    <li>
        <p>
            "Personal Data" means any personal data under the Personal
            Information Protection Law, i.e., any Personal Information that
            constitutes Personal Information Databases, Etc.
        </p>
    </li>
</ol>
<h2>Article 2 (Scope of the Privacy Policy)</h2>
<ol type="1">
    <li>
        <p>
            The Privacy Policy shall be applied between the Company and the
            User with respect to the handling of Personal Information, etc. in
            the Website, Etc.
        </p>
    </li>
    <li>
        <p>
            In case the EU General Data Protection Regulation (GDPR) and its
            related national laws are applicable, the Company’s GDPR Privacy
            Policy (hereinafter referred to as "GDPR Privacy Policy") shall
            apply in addition to the Privacy Policy.
        </p>
    </li>
    <li>
        <p>
            In case of any discrepancy between the Privacy Policy and the GDPR
            Privacy Policy, the GDPR Privacy Policy shall prevail.
        </p>
    </li>
</ol>
<h2>Article 3 (Method of Collecting Personal Information)</h2>
<p>
    The Company may ask the User to provide any Personal Information or collect
    any Personal Information when the User uses the Website, Etc. In addition,
    the Company may obtain any Personal Information from any third parties with
    whom the Company collaborates.
</p>
<h2>Article 4 (Purpose of Using Personal Information)</h2>
<p>
    The purposes for which the Company uses any Personal Information are as
    follows:
</p>
<ol type="1">
    <li>
        <p>
            To provide, maintain, protect, and improve the Website, Etc. such
            as by accepting registrations, verifying the identity of any User,
            calculating usage fees, etc.;
        </p>
    </li>
    <li>
        <p>
            To notify the public of any information regarding the contents of
            the Website, Etc. any updates thereof, any events and campaigns
            thereof, and any changes, etc. to any terms and conditions thereon;
        </p>
    </li>
    <li>
        <p>To respond to any notice or inquiry regarding the Website, Etc.;</p>
    </li>
    <li>
        <p>
            To respond to any violation of the Company's terms and conditions
            or other rules and regulations concerning the Website, Etc.;
        </p>
    </li>
    <li>
        <p>To compile any statistical data on the use of the Website, Etc.;</p>
    </li>
    <li>
        <p>
            To plan, draft or implement any future activities related to the
            Website, Etc.;
        </p>
    </li>
    <li>
        <p>To perform identity authentication when logging in or after logging in while using the Website, Etc.;</p>
    </li>
</ol>
<h2>Article 5 (Provision to Third Party)</h2>
<ol type="1">
    <li>
        <p>
            The Company will not provide any Personal Information to any third
            party without the prior consent of the User, except in the
            following cases:
        </p>
        <ol type="i">
            <li>
                <p>In case of being required by laws and regulations;</p>
            </li>
            <li>
                <p>
                    In case it is necessary for the protection of life, body,
                    or property of an individual and it is difficult to obtain
                    the User’s consent;
                </p>
            </li>
            <li>
                <p>
                    In case it is especially necessary to improve public health
                    or to promote the sound growth of children and it is
                    difficult to obtain the User's consent; or,
                </p>
            </li>
            <li>
                <p>
                    In case it is necessary to cooperate with a national
                    agency, a local government, or an individual or entity
                    entrusted by either a national agency or local government
                    to execute affairs prescribed by the laws and regulations,
                    and obtaining the User's consent is likely to impede the
                    execution of such affairs.
                </p>
            </li>
        </ol>
    </li>
    <li>
        <p>
            Notwithstanding the preceding paragraph of Article 5.1, a person to
            whom any Personal Information is provided in the following cases
            shall not be considered a third party:
        </p>
        <ol type="i">
            <li>
                <p>
                    In case the Company outsources all or part of the handling
                    of the Personal Information within the scope necessary to
                    achieve the purpose of use;
                </p>
            </li>
            <li>
                <p>
                    In case the Personal Information is provided as a result of
                    the succession of business due to merger or other reasons;
                    or,
                </p>
            </li>
            <li>
                <p>
                    In cases the Personal Information is used jointly with a
                    specific person or entity, and the Company notifies or make
                    easily available to the User such joint use, the items of
                    the Personal Information to be jointly used, the scope of
                    the joint users, the purpose of use by such joint users,
                    the name and address of the person responsible for managing
                    the relevant Personal Information, and in the case of a
                    corporation, the name of its representative in addition to
                    the above information.
                </p>
            </li>
        </ol>
    </li>
</ol>
<h2>Article 6 (Provision to a Third Party Located in a Foreign Country)</h2>
<ol type="1">
    <li>
        <p>
            The Company may provide any Personal Information to any third party
            in the following foreign country(s)(any country or region outside
            of Japan) in connection with the provision of the Website, Etc.;
        </p>
        <ul>
            <li>
                <p>Germany,</p>
            </li>
            <li>
                <p>The Netherlands,</p>
            </li>
        </ul>
    </li>
    <li>
        <p>
            Any third party in the foreign country(s) to which the information
            is provided in the preceding paragraph of Article 5.1 complies with
            the protection regulations regarding the protection of the Personal
            Information in that foreign country(s). The Company would like the
            User to refer to the following for any details of the systems
            concerning the protection of the Personal Information in such
            foreign country(s):
        </p>
        <ol type="i">
            <li>
                <p>
                    GDPR (EU)
                    <a href="https://www.ppc.go.jp/enforcement/infoprovision/EU/">https://www.ppc.go.jp/enforcement/infoprovision/EU/</a>
                </p>
            </li>
        </ol>
    </li>
</ol>
<h2>Article 7 (Supervision of Subcontractors)</h2>
<p>
    The Company may entrust the handling of any entrusted Personal Information
    to any third party to the extent necessary for the provision of the
    Website, Etc. and for the achievement of safe and sound use by the User.
    These third parties will be selected after confirming that they have
    adequate security standards for the handling of the Personal Information,
    and will be supervised as necessary and appropriate through contracts and
    other means.
</p>
<h2>Article 8 (Security Control Measures)</h2>
<p>
    The Company implements the following security control measures to ensure
    the proper handling of the Personal Data:
</p>
<ol type="1">
    <li>
        <p>
            to establish a basic policy regarding compliance with relevant
            laws, regulations, guidelines, etc., and a contact point for
            handling questions and complaints;
        </p>
    </li>
    <li>
        <p>
            to establish basic handling methods when acquiring, using, and
            storing the Personal Data, etc.;
        </p>
    </li>
    <li>
        <p>
            to establish a person responsible for the handling of the Personal
            Data and a reporting and communication system for the person
            responsible;
        </p>
    </li>
    <li>
        <p>
            to provide any confidentiality of the Personal Data in internal
            rules, etc.;
        </p>
    </li>
    <li>
        <p>
            to implement measures to ensure that the Personal Data cannot be
            easily accessed by anyone other than employees who are authorized
            to handle the Personal Data and the individual concerned; and,
        </p>
    </li>
    <li>
        <p>
            to implement mechanisms to protect equipment that handles the
            Personal Data from unauthorized external access or unauthorized
            software.
        </p>
    </li>
</ol>
<h2>
    Article 9 (Disclosure, Correction, Suspension of Use, etc. of Personal
    Information)
</h2>
<p>
    In case the User requests the Company to disclose, correct, add, delete,
    stop using of, or disclose records of provision to third parties of, the
    User's Personal Information in accordance with the Personal Information
    Protection Law (hereinafter collectively referred to as "Disclosure,
    Etc."), the Company will endeavor to process the request appropriately and
    promptly in accordance with the Law after confirming the identity of the
    User. The Company would like the User to contact the following for
    inquiries regarding the Disclosure, Etc. of User's Personal Information.
    The fee of 1,000 yen per a request will be charged for the Disclosure, Etc.
    of the Personal Information.
</p>
<h2>Article 10 (Contact for Inquiries)</h2>
<p>
    The Company would like the User to contact the following for the
    Disclosure, Etc. as specified in the preceding article of Article 9 or for
    any other inquiries regarding the Privacy Policy:
</p>
<p>
    Name (business operator handling the Personal Information): JWP Consulting
    GK
</p>
<p>Representative: Justus Wilhelm Perlwitz, Senior Partner</p>
<p>
    Address: Shimokitazawashinkosha Bldg. Room 305 Kitazawa 2-37-3 Setagaya
    City, Tokyo-to
</p>
<p>E-mail: hello@jwpconsulting.net</p>
<h2>Article 11 (Revision)</h2>
<p>
    The Company may revise the Privacy Policy as it deems necessary, and the
    User hereby consents to such revisions in advance. Any changes to the
    Privacy Policy shall become effective upon posting on the Website, Etc.
</p>
<h2>Supplementary Provisions</h2>
<ul>
    <li>Established as of December 26, 2023</li>
    <li>Updated as of April 12, 2026</li>
</ul>
<p>JWP Consulting GK</p>