Privacy Policy

Chalk Digital was founded in San Diego, USA with the idea of ​​”making the information about lunch menus written in chalk on cafe blackboards more widely available by utilizing digital tools such as social media.” Chalk Digital’s mission is to continue to take on new challenges in the mobile era while working with our partners to provide the best solutions to our customers and clients, in order to meet the trust and expectations of our customers and clients through marketing support and solution services for individuals and small business operators.

Based on these expectations, we recognize that the personal information of our customers and clients is entrusted to us by their own will for use for specific purposes, and that one of the challenges we face is to store that personal information safely and use it in a way that respects the will of our customers.

We declare that we will comply with this personal information protection policy (Privacy Policy) (hereinafter referred to as “this Policy”), always keep the following items in mind, and do our utmost to protect the personal information of our customers and clients.

(Compliance with laws and regulations)

1. When handling personal information (meaning “personal information” as defined in the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”), the same applies below), we will comply with laws and regulations, including the Personal Information Protection Act, national guidelines, and other standards.

(Use within the scope of the intended purpose)

1. We will specify the purpose of use as specifically as possible, and will only handle personal information within the scope of the purpose of use that has been clearly stated or publicly announced, except when we obtain the prior consent of the individual, or when exceptions are permitted by law.

(Indication and public announcement of purpose of use)

1. We will endeavor to clearly indicate necessary information such as the purpose of use, scope of joint users, and contact point for inquiries in advance, and obtain consent before acquiring personal information.
2. We may receive information related to customers (personal information) from third parties, such as identifiers and behavioral history, link that information with personal information held by our company, and use it for the purposes of use specified in advance. We will handle that information appropriately as personal information.

(Personal information of minors)

1. When there is a possibility that we may collect personal information from a child under the age of 15, we will take special care in handling the personal information of minors, such as by explicitly requesting consent from a parent or guardian before providing the information.

(Safety control measures)

1. We will endeavor to keep the personal information we hold accurate and up-to-date within the scope of the intended use, and will take necessary and appropriate safety control measures and corrective measures in accordance with the current state of technology to protect against leakage, loss, or damage.

(Supervision of contractors)

1. We may entrust the processing of personal information we have received to a third party within the scope of the purpose of use. We select these third parties after confirming that they have a sufficient level of security for personal information, and we provide necessary and appropriate supervision through contracts, etc.

(Provision to third parties)

1. Except in cases permitted by law, we will not provide personal information to third parties other than the joint users specified at the time of acquisition without the consent of the individual. In addition, we will use the opt-out system (Article 23, Paragraph 2 of the Act on the Protection of Personal Information) and will not provide personal information to third parties without the consent of the individual.

(Request for Disclosure, etc.)

1. The procedures for making requests for disclosure, correction, deletion, suspension of use, and suspension of provision (collectively referred to below as “disclosure, etc.”) of user information based on the Personal Information Protection Act are as follows. Requests made by the individual’s legal representative or a representative appointed by the individual will also be handled in the same manner as below.

(1) Please sign and seal the request form (hereinafter referred to as the “Request Form”), enclose a copy of your resident card (issued within 30 days prior to the request date) and postage stamps equivalent to the delivery confirmation postage, and send it by registered mail. The mailing address is as follows:
——————————————————————–
1-1-3 Marunouchi, Chiyoda-ku, Tokyo 100-0005 Nippon Life Insurance Marunouchi Garden Tower 3F
Business Airport Tokyo
Chalk Digital Co., Ltd.
——————————————————————–
(2) After sending the request form, a copy of your resident card and postage stamps equivalent to the delivery confirmation postage, we will confirm your identity by contacting the contact information you provided. We will only respond to requests for disclosure, etc. if we can confirm that the user information, etc. is the same as the requester and that you are the person in question.
(3) If we are unable to verify your identity, if we do not possess the user information that is the subject of your request, or if disclosure is not required by the Personal Information Protection Act or other laws and regulations, we will not respond to your request for disclosure and will notify you to that effect.
(4) We will charge a fee of 700 yen for each request for disclosure of personal information.

(Administrator and contact details)

1. Please contact the following for any inquiries or questions regarding this policy and the handling of personal information.
   Contact: Personal Information Protection Manager
   Email address:  info-jp@chalkdigital.com

(Continuous improvement of internal systems)

1. In order to properly handle the personal information entrusted to us, we will strive to continually strengthen and improve our internal systems, including reviewing this policy, through the establishment of internal regulations, employee education, and the implementation of appropriate audits.

(Changes to this Policy)

1. We may change the contents of this policy in accordance with the provisions regarding changes to standard terms and conditions in the Civil Code. If we change this policy, we will notify you of the changed content of the policy and the effective date by posting it on our website, etc.

Date of enactment: April 17, 2018
Date of change: June 27, 2018
Date of change: February 1, 2025
Chalk Digital Co., Ltd.
Personal information protection manager

Personal information protection efforts (items to be disclosed pursuant to Article 32 of the Personal Information Protection Act)

We will make the personal information we handle available to you as follows:

1. Personal information handling business

Chalk Digital Co., Ltd.
1-1-3 Marunouchi, Chiyoda-ku, Tokyo Nippon Life Marunouchi Garden Tower 3F
Business Airport Tokyo
CEO Craig Hagopian

2. Purpose of use of retained personal data

The purposes for which personal information is used by our company are as follows:

i. Information of customers using Chalk Digital services

1. To provide our services (including providing services and displaying advertisements according to the usage status of our services, etc.)
2. Responding to inquiries from customers and clients
3. To send and distribute information about our services and solutions, as well as products and services handled by our company, our shareholders (including our US headquarters), our group companies, and those entrusted with sending advertisements to our company, and to send and distribute direct mail, etc. (by email, post, courier service, etc.)
4. To request consent when we use personal information and history information in the future
5. Disclosure of information from our company to our partners and use of such information by our partners within the scope of the consent of our partners from customers and clients in order to provide affiliated services
6. Other uses within the scope of consent obtained from customers and clients

ii. Personal information of those who contact us

1. To improve our customer service attitude, etc.
2. To accurately understand the content of inquiries and communications and respond to them.
   *If you are notified of the purpose of use individually, the purpose of use will be in accordance with that notification.

３．Procedures for disclosure of retained personal data

Please refer to the “Request for Disclosure, etc.” section of our separate “Personal Information Protection Policy (Privacy Policy).”

４．Contact point for complaints regarding the handling of retained personal data

For inquiries regarding the handling of personal data held, please contact the following
: Person in charge: Personal Information Protection Manager
Email address: info-jp@chalkdigital.com

5. Overview of safety control measures

The following is an overview of the security measures we have taken:

i. Formulation of basic policies

1. Establishing a basic policy to ensure the proper handling of personal information

ii. Establishment of rules regarding the handling of personal information

1. Establish basic procedures for handling personal information when acquiring, using, storing, etc.

iii. Organizational security control measures

1. The person in charge will confirm that personal information is being handled in accordance with the established handling procedures.
2. Establish a reporting and communication system from employees to the person in charge

iv. Personnel security measures

1. Regular training is provided to employees regarding important points regarding the handling of personal information.
2. Matters concerning confidentiality of personal information are included in the work regulations

v. Physical safety control measures

1. Implement measures to prevent personal information from being easily viewed by anyone other than employees who handle personal information and the person in question.
2. Measures will be taken to prevent theft or loss of devices, electronic media, documents, etc. that handle personal information, and measures will be taken to prevent personal information from being easily identified when carrying such devices, electronic media, etc., including when moving within the workplace.

vi. Technical safety control measures

1. Clarifying the devices that can handle personal information and the employees who handle those devices, and preventing unnecessary access to personal information
2. Implement a mechanism to protect information systems that handle personal information from unauthorized external access or malicious software.

vii. Understanding the external environment

1. When handling personal information in a foreign country, we will understand the systems for protecting personal information in that foreign country and implement safety control measures.