SomniQ Co., Ltd. (hereinafter referred to as “the Company”) has established the following Privacy Policy (hereinafter referred to as “this Policy”) regarding the handling of participant information, including personal information of participants, in projects operated by the Company (hereinafter referred to as “this Project”).
1. Basic Policy
Regarding the handling of personal information obtained, we will comply with the Act on the Protection of Personal Information, guidelines and other regulations concerning the protection of personal information, and other relevant laws and regulations concerning the protection of personal information.
2. Participant information to be collected and methods of collection
In this policy, “Participant Information” means information related to the identification of a participant, their activity history on communication services, and other information generated or stored on the participant’s smartphone, PC, or other device in relation to the participant or the participant’s device, which is collected by the Company in accordance with this policy.
The participant information that our company will collect in this project will be as follows, depending on the method of collection:
(1) Information to be provided by participants
The following information is required from participants in order to participate in this project:
* Name * Email address * Nickname * Other information that participants will enter into the input form specified by our company
(2) Information that we collect when participants take part in this project
* Empathy information (practice data from the Empathy app)
Our company may collect information regarding access to and use of the website introducing this project. This includes the following information:
* Device information * Log information * Cookies and anonymous IDs * Location information
3. Purpose of use
3-1. Participant information will be used for the operation of this project as stipulated in 3-2, and may also be used for other purposes as stipulated in 3-3.
3-2. The specific purposes for which participant information related to the operation of this project will be used are as follows:
(1) To provide ongoing support, advice, guidance, and respond to inquiries regarding this project;
(2) To take action against actions that violate our participation terms, privacy policy, etc. (hereinafter referred to as “Terms, etc.”) regarding this project;
(3) To notify participants of changes to the Terms, etc. regarding this project;
(4) For purposes incidental to the above purposes of use.
3-3. Other purposes of use besides those described in 3-2 above are as follows:
Purpose of use
(1) To create statistical data in a form that does not identify individuals in connection with our projects.
* Practice data * Device information * Log information * Cookies and anonymous IDs * Location information
4. Management of personal information
Our company will strictly adhere to the following principles regarding the management of personal information obtained from users.
(1) Ensuring the accuracy of information
We strive to ensure that the personal information we collect is always accurate and up-to-date.
(2) Security Management Measures
Our company has established strict handling procedures for the organizational management of personal information in accordance with internal regulations, and we thoroughly implement handling and strict operation in accordance with these regulations.
(3) Supervision of contractors responsible for managing personal information
When outsourcing the management of personal information, we will only entrust it to contractors in accordance with our company regulations and will ensure that it is managed appropriately.
5. Methods of notification, publication, or obtaining consent, and methods for requesting discontinuation of use.
5-1. The following participant information will be collected only after obtaining the participant’s consent.
• Audio data in practice
5-2. Participants may request the cessation of the use of all or part of their participant information by making the prescribed settings for this project. In this case, we will promptly cease the use of such information in accordance with our established procedures. However, for certain items of participant information, their collection or use is a prerequisite for this project, and we will only cease their collection if the participant withdraws from this project using the method prescribed by us.
6. Third party provision
Our company will not provide personal information of participants to third parties without the prior consent of the participant, except in cases where disclosure is permitted under the Personal Information Protection Act or other laws and regulations. However, this shall not apply in the following cases:
(1) When our company entrusts all or part of the handling of personal information to a third party to the extent necessary to achieve the purpose of use;
(2) When personal information is provided in connection with the succession of a business due to merger or other reasons;
(3) When it is necessary to cooperate with a national or local government agency or a party entrusted by them in carrying out duties stipulated by law, and obtaining the participant’s consent would hinder the performance of such duties;
(4) In other cases permitted by the Personal Information Protection Act or other laws and regulations.
7. Disclosure of personal information
When a participant requests disclosure of their personal information in accordance with the Personal Information Protection Act, we will verify that the request is from the participant themselves and then disclose the information to the participant (we will notify the participant if such personal information does not exist). However, this does not apply if we are not obligated to disclose the information under the Personal Information Protection Act or other laws and regulations.
8. Correction and suspension of use of personal information, etc.
8-1. If a participant
requests (1) correction of their personal information based on the provisions of the Personal Information Protection Act on the grounds that the personal information is not true, or (2) suspension of use of their personal information based on the provisions of the Personal Information Protection Act on the grounds that it is being handled beyond the scope of the publicly announced purpose of use or that it was collected by fraudulent or other improper means, we will verify that the request is from the participant themselves, conduct the necessary investigation without delay, and based on the results, correct or suspend the use of the personal information and notify the participant accordingly. If we decide not to correct or suspend the use of the personal information based on reasonable grounds, we will notify the participant accordingly.
8-2. If a participant requests the deletion of their personal information, and we determine that we are obligated to comply with the request, we will verify that the request is from the participant themselves, delete the personal information, and notify the participant accordingly.
8-3. If, under the Personal Information Protection Act or other laws and regulations, we are not obligated to correct, or cease the use of, the provisions of the preceding two paragraphs shall not apply.
9. Contact Information
For comments, questions, complaints, or any other inquiries regarding the handling of participant information, please contact the following office.
Address: SomniQ Co., Ltd. , Tomiyama Building, 1-3 Kanda Jimbocho, Chiyoda-ku, Tokyo 101-0051, Japan
Inquiry
Email: info@empatheme.org
10. Procedure for changing the Privacy Policy
Our company will periodically review the operational status of our handling of participant information and strive for continuous improvement, and may change this policy as necessary. If changes are made, we will notify participants. However, if the changes involve content that requires participant consent under the law, we will obtain participant consent through our prescribed method.
Last updated: 2025.8.14