Privacy Policy (Survey and Product/Service Activities)
erubu Co., Ltd. (Hamamatsu City, Shizuoka, Japan) (“we,” “us,” or the “Company”) adopts and complies with this Privacy Policy (the “Policy”) jointly with NWU Inc. (G.K.) (Chiyoda, Tokyo, Japan) and hub Co., Ltd. (Shizuoka City, Shizuoka, Japan) (together, the “Service Partners”).
We recognise the importance of protecting personal information and handle it lawfully and fairly in accordance with Japan’s Act on the Protection of Personal Information (APPI), other applicable laws and guidelines, and our internal rules.
Definitions
“Parties” means the Company and the Service Partners acting together.
“Activities related to the Product/Service” broadly include surveys, product development, and sales undertaken by the Parties.
Scope
This Policy applies whenever the Parties handle personal information or similar data in connection with Activities related to the Product/Service.
What We Collect and How We Collect It
We collect the following information from customers—survey panel registrants, seminar participants, newsletter subscribers, and product purchasers—by lawful and fair means. We do not collect or use information for additional purposes without consent.
Email communications are sent only with clear prior consent and in compliance with Japan’s Act on Regulation of Transmission of Specified Electronic Mail; unsubscribe requests are honoured promptly.
Categories of Personal Information
Panel registrants:
name, address, employer, phone number, fax number, email address, survey responses
Seminar participants
name, address, employer, phone number, fax number, email address, survey responses
Newsletter subscribers
name, email address, survey responses
Product purchasers
name, address, employer, delivery address, phone number, fax number, email address, survey responses
Application forms / business cards, etc.
name, address, employer, phone number, fax number, email address, any other items stated on the document or card, survey responses
How We Use Personal Information
We use personal information only for the purposes below:
Administration of contracts related to the Product/Service
Research and development to improve the Product/Service
Communications related to the Product/Service; distribution of newsletters, direct mail, and various notices
Service improvement, new service development, and marketing
Conducting campaigns, surveys, panel studies, and interviews
Confirming and responding to opinions and inquiries about the Product/Service
Governance, Security, and Retention
We strive to keep personal information accurate and up to date and respond, as appropriate, to requests for correction.
Security measures: We maintain strict internal rules for handling personal information and ensure they are followed.
Workforce oversight: Employees handle personal information under rigorous internal procedures.
Processor oversight: When outsourcing, we select processors that meet our requirements and supervise them appropriately.
Incident response: In the event of a breach, we will notify Japan’s Personal Information Protection Commission and affected individuals as required by law.
Retention and deletion: We retain personal information for five (5) years after the purposes are achieved and then delete it appropriately. If information becomes unnecessary earlier, it is deleted without delay.
Sharing with Third Parties
We do not provide personal information to third parties without prior consent, except where:
required by laws or regulations.
necessary to protect life, body, or property and obtaining consent is difficult.
particularly necessary for improving public health or promoting the well-being of children and obtaining consent is difficult.
cooperation with national or local authorities (or their designees) is required by law and obtaining consent could impede such operations; or
we have announced or disclosed in advance that third‑party provision may occur, the items of data, the means or methods of provision, and the right to request cessation of such provision.
Not considered third‑party provision:
sharing with service providers within the scope necessary to achieve the stated purposes.
provision in connection with a business succession due to merger or other reasons.
joint use where we notify—or make readily available—*the items jointly used, the scope of joint users, purposes of use, and the name of the party responsible for management.
Requests to Access, Correct, or Suspend Use
For requests to access, correct, or suspend the use of retained personal information, we respond in accordance with our prescribed procedures. Details are provided individually via the contact point below.
Contact
For questions about the Product/Service or this Policy, please contact:
Personal Data Protection Desk, erubu Co., Ltd.
info [at] erubu.co.jp
*Replace “[at]” with “@” when sending an email.
Cookies and Effectiveness Measurement
We may conduct effectiveness measurement for surveys. We primarily rely on opt‑in consent for non‑essential cookies and similar technologies. Where cookies or similar technologies are used, we follow widely recognized standards—including the EU GDPR and other applicable laws, regulations, and guidelines.
When measurement is performed with your consent, results are handled in aggregated (statistical) form and are not used to identify individuals. During processing, certain identifiers (e.g., IP addresses or cookie IDs) may be handled for measurement; in such cases, we obtain consent or provide appropriate controls consistent with applicable requirements.
Effective Date: October 25, 2025