Privacy Policy

1. Business operator information

The name, address, and representative of the business operator handling personal information are as follows.

The Company may entrust part of its sales support operations for the Service — including sales support, referrals, application guidance, and first-line response — to ENKA株式会社 (ENKA Co., Ltd.).

2. Personal information protection manager and contact point

For inquiries about this Policy, and for requests concerning retained personal data — including disclosure, correction, suspension of use, deletion, and other requests — please contact the desk above or use the contact form on our website.

3. Information we collect

The Company may collect or handle the following information to the extent necessary for providing the Service, opening accounts, accepting applications for use, contract screening, verifying identity and authority, preventing unauthorized use, billing, support, ensuring security, and otherwise operating the Service.

3.1 Information the Company collects itself

1. Company name, organization name, municipality name, department name, contact person's name, and job title
2. Email address, phone number, and address
3. Login ID, account information, and authentication credentials
4. Contract details, application details, plan information, billing information, and payment information
5. Details of inquiries, document requests, business meetings, and support interactions
6. Usage history, operation logs, and access logs for the Service
7. IP address, browser information, device information, cookies, and other identifiers
8. Information that users enter, register, or upload in the Service's admin console
9. Records relating to account-opening procedures, including email verification, pressing of the application button, consent checkboxes, and payment registration
10. Consent logs, including the versions of the Terms of Service, Privacy Policy, Legal Notice under the Act on Specified Commercial Transactions, fee terms, and other contractual conditions agreed to, the date and time of consent, and the contents of the consent
11. Information necessary for contract screening, including identity, employment status, authority, purpose of use, ability to pay, and prevention of unauthorized use
12. Where the Company requests additional verification: identity verification documents, certificates of registered corporate matters, materials confirming the contact person's employment, powers of attorney, materials confirming decision-making authority, materials confirming the purpose of use, and other materials the Company deems necessary
13. Other information necessary for providing, contracting, billing, screening, supporting, and operating the Service

3.2 Information handled under entrustment from users

1. End users' names, phone numbers, addresses, email addresses, and other information obtained in the course of calls or inquiries
2. Call audio and recording data
3. Transcription data
4. Call summaries
5. Sentiment analysis results
6. Call history, response history, tags, notes, and statuses
7. Orders, reservations, inquiries, consultations, complaints, cancellations, applications, and other call content
8. FAQs, knowledge bases, scripts, prompts, and other configuration information that users register in the Service
9. Other information that users handle through the Service

3.3 Special care-required personal information

Depending on how the Service is used, call content may include medical history, disabilities, medical care, welfare, criminal victimization, administrative consultations, living circumstances, and other sensitive information, or information that may constitute special care-required personal information under Japan's Act on the Protection of Personal Information (APPI).

When handling such information through the Service, users shall, at their own responsibility, take the necessary measures required by law, including providing required explanations, obtaining consent, notifying or publicly announcing purposes of use, limiting the scope of collection, and managing access permissions.

The Company handles such information within the scope entrusted to it by users.

4. Purposes of use

The Company uses the information it collects or handles for the following purposes.

4.1 Purposes of use for information the Company collects itself

1. To provide, operate, maintain, and manage the Service
2. To accept applications for the Service, verify identity, issue accounts, and manage contracts
3. To confirm that the applicant is the person concerned or a person with legitimate authority
4. To screen registered information, billing information, contact person information, purposes of use, and other application details
5. To prevent false applications, impersonation, unauthorized applications, unauthorized use, nuisance calls, and other inappropriate use
6. To calculate fees, bill, process payments, confirm receipt of payment, and handle unpaid amounts
7. To respond to inquiries, document requests, consultations, support, and service failures
8. To review usage of the Service, improve its quality and features, and develop new features
9. To ensure security, prevent unauthorized use, detect failures, and manage logs
10. To provide information, proposals, and important notices about the Service and related services
11. To conduct marketing, analysis, and sales activities based on users' consent or applicable law
12. To respond to acts that violate laws, terms, or contracts
13. To respond to disputes, inquiries, complaints, claims, and audits, and to keep records, report, disclose, and otherwise respond as required by law
14. To respond as required under the Telecommunications Business Act and other applicable laws, to handle communications properly, to prevent unauthorized use, to respond to communication failures, and to otherwise respond as necessary for providing the Service

4.2 Purposes of use for consent logs and application records

The Company uses consent logs and application records for the following purposes.

1. To confirm the fact that a user has agreed to the Terms of Service, the Privacy Policy, the Legal Notice under the Act on Specified Commercial Transactions, the fee terms, and other conditions displayed by the Company
2. To confirm account opening, contract formation, and the applicant's identity and authority
3. To respond to disputes concerning applications, contracts, fees, cancellation, suspension of use, and other matters relating to the Service
4. To prevent false applications, impersonation, unauthorized applications, unauthorized use, and other risks
5. To retain records required by law, terms, contracts, and internal administration

4.3 Purposes of use for information handled under entrustment from users

1. For AI-powered inbound calls, outbound calls, responses, and answer generation
2. To connect, record, store, transcribe, summarize, and analyze calls
3. To display, search, and manage call history, inquiry history, and response history
4. For sentiment analysis, tagging, report creation, and dashboard display
5. To respond based on the FAQs, knowledge bases, scripts, and prompts configured by users
6. To notify, escalate to, hand over to, and support users
7. To maintain the Service, respond to failures, and ensure security
8. For quality improvement, accuracy improvement, verification, and testing permitted under contracts with users
9. For the proper handling of communications, prevention of unauthorized use, response to failures, and other responses necessary for providing the Service under the Telecommunications Business Act and other applicable laws

The Company handles information entrusted to it by users within the scope of the entrusted purposes, in accordance with its contracts with users, this Policy, and applicable law.

5. Pre-account-opening screening and additional verification

For the safe provision of the Service, prevention of unauthorized use, proper use of communications, fee collection, and verification of identity and authority, the Company may, before or after opening an account, review application details, registered information, purposes of use, payment information, consent logs, access logs, and other necessary information.

If, in light of the application details, registered information, purpose of use, payment method, usage, or other circumstances, the Company reasonably determines that there is doubt about identity, authority, the accuracy of registered information, or the legality or safety of the purpose of use, the Company may request that the prospective user or user submit identity verification documents, certificates of registered corporate matters, materials confirming the contact person's employment, powers of attorney, materials confirming decision-making authority, materials confirming the purpose of use, and other materials the Company deems necessary.

If a party does not comply with such verification, or if the Company reasonably determines that providing the Service is inappropriate, the Company may refuse to open an account, restrict use of the Service, suspend the account, terminate the contract, or take other necessary measures.

The Company uses information obtained in connection with the above screening and additional verification for contract management of the Service, verification of identity and authority, prevention of unauthorized use, billing, ensuring security, dispute response, legal compliance, and other purposes necessary for providing the Service.

6. Secrecy of communications and handling of call information

In providing the Service, the Company handles the secrecy of communications appropriately, in accordance with the Telecommunications Business Act and other applicable laws.

The Company does not use call content, communication history, or other information relating to communications for purposes other than the intended ones, except where required by law, where the user consents, or where necessary for providing the Service, maintenance, responding to failures, preventing unauthorized use, ensuring security, or otherwise carrying out legitimate business operations.

When using the Service to record, transcribe, summarize, analyze, or otherwise process calls, users shall, at their own responsibility, notify end users of recording, notify or publicly announce purposes of use, obtain necessary consent, and take other measures required by law or operational practice.

7. AI processing and transmission to external services

To the extent necessary to provide the Service, the Company may use external services for speech recognition, speech synthesis, natural language processing, AI response generation, transcription, summarization, analysis, telephone communication infrastructure, cloud storage, payment, authentication, access analytics, and other functions.

External services may include the following categories.

1. Voice AI processing services
2. Generative AI and natural language processing services
3. Telephone and communication infrastructure services
4. Cloud infrastructure and data storage services
5. Payment and billing management services
6. Email delivery and inquiry management services
7. Access analytics and measurement services

When using external services, the Company transmits information only to the extent necessary to achieve the purposes of use and exercises necessary and appropriate supervision over subcontractors and external service providers.

The specific names of external services, the information transmitted, the purposes of use, opt-out methods, and other details are published in the Cookie and External Transmission Policy separately established by the Company or in notices within the Service.

8. Provision to third parties located in foreign countries

When the Company provides personal data to a third party located in a foreign country, it takes the necessary measures in accordance with applicable law, including providing the required information, obtaining the person's consent, and supervising subcontractors.

However, there may be entrustments that do not constitute provision to a third party located in a foreign country under the APPI, or cases handled by other methods permitted by law.

The Company publishes, as necessary, the countries where external services are provided, their personal information protection systems, the protective measures taken by such third parties, and other matters required by law, in this Policy, the Cookie and External Transmission Policy, or individual notices.

9. Provision to third parties

The Company does not provide personal data to third parties without the person's consent, except in the following cases.

1. When required by law
2. When necessary to protect a person's life, body, or property and it is difficult to obtain the person's consent
3. When particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the person's consent
4. When it is necessary to cooperate with a national government agency, a local government, or a party entrusted by either in performing affairs prescribed by law, and obtaining the person's consent could impede the performance of those affairs
5. When entrusting all or part of the handling of personal data to the extent necessary to achieve the purposes of use
6. When providing personal data in connection with a merger, corporate split, business transfer, or other business succession
7. In cases of joint use where the matters required by law have been notified to the person in advance or made readily accessible to the person
8. In other cases permitted by law

10. Supervision of subcontractors

The Company may entrust all or part of the handling of personal information to external businesses to the extent necessary to achieve the purposes of use, including providing the Service, sales support, application guidance, customer support, billing, payment, maintenance, support, data processing, cloud storage, AI processing, provision of telephone communication infrastructure, screening assistance, verification of identity and authority, and prevention of unauthorized use.

Subcontractors may include ENKA株式会社, cloud service providers, telephone and communication infrastructure providers, AI-related service providers, payment providers, support tool providers, and other businesses necessary for providing the Service.

The Company exercises necessary and appropriate supervision over subcontractors, through contracts or other means, to ensure the secure management of personal data.

11. Sales support by ENKA株式会社

ENKA株式会社 may, under entrustment from the Company, conduct sales support operations for the Service, including sales support, referrals, application guidance, and first-line response.

ENKA株式会社 may handle inquiry information, business meeting information, contact person information, information necessary to assist with applications, information necessary for pre-account-opening screening, and other information necessary for sales support and screening assistance, within the scope of the sales support operations entrusted by the Company.

If ENKA株式会社 uses personal data beyond the scope entrusted by the Company for its own purposes — such as its own sales, marketing, or customer management — the necessary arrangements will be made in accordance with law, such as joint use, provision to third parties, or the person's consent.

12. Joint use

At present, if the Company is to jointly use personal data with ENKA株式会社 or other third parties, it will do so after notifying the person in advance of the following matters or making them readily accessible to the person.

1. The fact that personal data will be used jointly
2. The items of personal data to be used jointly
3. The scope of the parties who will jointly use the data
4. The purposes of use of the parties who will jointly use the data
5. The name, address, and representative's name of the party responsible for managing the personal data

Where joint use is not conducted, the statements on joint use in this article do not mean that joint use is being carried out.

13. Use for AI training

The Company may use call audio, transcriptions, call summaries, inquiry content, and other personal data handled under entrustment from users for providing, maintaining, and troubleshooting the Service and for improving its quality and accuracy, based on its contracts with users.

If the Company uses a user's individual call data or personal data for additional training or retraining of AI models, creation of evaluation data, or similar purposes, the Company will obtain the user's consent or a separate agreement as necessary, in accordance with law and its contracts with users.

The Company may use information that has been statistically processed, aggregated, or anonymized so that individuals cannot be identified, for quality improvement, feature improvement, statistical analysis, research and development, creation of sales materials, and other business purposes of the Company. However, where restricted by law or individual contracts, the Company will follow those provisions.

14. Recording and transcription

The Service may record, transcribe, summarize, analyze, and otherwise process calls.

When using the Service to record, transcribe, summarize, or analyze calls with end users, users shall, at their own responsibility, notify end users of recording, notify or publicly announce purposes of use, obtain necessary consent, establish a contact point for inquiries, and take other measures required by law or operational practice.

The Company processes call data within the scope entrusted to it by users.

15. Security control measures

To prevent leakage, loss, damage, unauthorized access, unauthorized use, and other risks to personal data, the Company implements the following security control measures.

1. Establishing basic policies and related rules on the handling of personal information
2. Educating and supervising employees who handle personal information
3. Managing access rights to personal data and applying controls based on the principle of least privilege
4. Account management, authentication management, and log management
5. Encryption of communication channels and other technical security measures
6. Selecting, contracting with, and supervising subcontractors
7. Reporting, communication, investigation, containment, and recurrence prevention when incidents occur
8. Managing retention periods for personal data and deleting data that is no longer needed

To strengthen its information security management framework, the Company is preparing to obtain ISO/IEC 27001 and other third-party certifications relating to information security. However, as of the time this Policy is posted, this does not represent that the Company has already obtained any such certification.

Details of these security control measures will be provided without delay upon request from the person, to the extent that doing so does not compromise security.

16. Retention period

The Company retains personal information only for the period necessary to achieve the purposes of use, the period required under contracts, or the period for which retention is required by law.

Personal information that no longer needs to be retained is deleted, erased, anonymized, or otherwise appropriately processed within a reasonable period.

The specific retention periods for call data, deletion timing, availability of export, and other conditions are governed by the application screens, the admin console, the pricing table, individual contracts, or terms separately established by the Company.

Consent logs, application records, records relating to contract screening, records relating to billing, records necessary for compliance with the Telecommunications Business Act and other laws, and records necessary for dispute response may be retained for the period necessary for contract management, legal compliance, dispute response, prevention of unauthorized use, and other necessary purposes.

17. Cookies and external transmission

The Company's website may use cookies and other technologies for purposes such as maintaining login status, ensuring security, improving convenience, understanding usage, keeping application records, collecting consent logs, and preventing unauthorized use.

If the Company introduces external access analytics, advertising, measurement tags, or other mechanisms by which information is transmitted from users' devices to external businesses, the Company will publish the recipients, the information transmitted, the purposes of use, opt-out methods, and other necessary matters in the Cookie and External Transmission Policy.

For details on cookies and external transmission, please see the Cookie and External Transmission Policy separately established by the Company.

18. Requests for disclosure, correction, suspension of use, etc.

A person may, in accordance with law, request notification of the purposes of use, disclosure, correction, addition, deletion, suspension of use, erasure, suspension of provision to third parties, disclosure of records of provision to third parties, and other actions with respect to retained personal data held by the Company.

When making a request, we may ask you to submit documents prescribed by the Company to verify your identity.

The Company will respond within a reasonable period in accordance with law. However, the Company may be unable to respond to a request where a response is not required by law, where identity cannot be verified, where the request is deficient, or where there are other legitimate reasons.

Requests concerning end users' personal data handled under entrustment from users are, in principle, handled through the user that entrusted the data. If the Company receives an inquiry directly from an end user, it will respond in cooperation with the user as necessary.

19. Complaints and consultations

For complaints, consultations, and other inquiries regarding the Company's handling of personal information, please contact the following desk.

20. Accredited personal information protection organization

There is no accredited personal information protection organization of which the Company is a member (not applicable). If the Company joins one, its name and the contact point for complaint resolution will be posted on this page.

21. Changes to this Policy

The Company may change this Policy due to changes in law, changes to the Service, changes to external services, changes to the account-opening and screening flow, changes to the Company's telecommunications business notification, changes in the status of information security certifications, business needs, or other reasons.

When making material changes, the Company will announce them by posting on its website or by other appropriate means.

The revised Policy takes effect when posted on the Company's website, unless otherwise specified by the Company.