Privacy Policy

Neural Group Inc.
Representative Director: Michitake Shigematsu
Established: October 1, 2018
Last revised: February 27, 2025

Personal Information Protection Policy

1. Basic Policy on the Protection of Personal Information
Neural Group Inc. (hereinafter referred to as the “Company”) recognizes the protection of personal information as a social responsibility in providing various AI-based services. In accordance with the Privacy Policy established by the Company, we exercise the utmost care in collecting and handling personal information.

2. Definition of Personal Information
In this Privacy Policy, “personal information” means information relating to a living individual that falls under either of the following categories.

Information that can identify a specific individual by a name, date of birth, or other description contained therein {meaning any matter stated or recorded in a document, drawing, or electromagnetic record (a record created by electronic, magnetic, or other means that cannot be perceived by the human senses), or expressed using voice, movement, or any other method (excluding an individual identification code)} (including information that can be readily cross-checked against other information and thereby identify a specific individual).
Information containing an individual identification code.

Examples of Personal Information

The individual’s name
Date of birth; contact details (address, residence, telephone number, and email address); position within a company;
Or information concerning affiliation, when combined with the individual’s name
Visual information from which the individual can be recognized, such as information recorded by security cameras
Audio recordings that can identify a specific individual, such as recordings containing the individual’s name
An email address that can identify a specific individual
Information that could not identify a specific living individual at the time of acquisition but to which new information is subsequently added,
Or that, as a result of cross-checking, can identify a specific living individual
Publicly available information that can identify a specific individual, including information in official gazettes, telephone directories, staff directories, statutory disclosure documents (such as annual securities reports), newspapers, websites, and social media

3. Acquisition of Personal Information
When acquiring personal information, the Company specifies the purpose of use and acquires the information through lawful and appropriate means.

To provide more convenient services, the Company may collect information about access to and use of the services it provides. Such information may include cookies and similar technologies.

4. Use of Personal Information
The Company uses acquired personal information within the scope of the purpose of use stated at the time of acquisition. If personal information is jointly used with a third party, the Company will notify or publicly announce that fact, the items of personal information to be jointly used, the scope of joint users, and the name of the party responsible for management. If the handling of personal information is outsourced to a third party, the Company will exercise necessary and appropriate supervision over that third party to ensure the proper use of personal information.

5. Restrictions Based on the Purpose of Use
The Company uses acquired personal information only to the extent necessary to achieve the purpose of use. The Company establishes and implements procedures for taking necessary measures to prevent use outside the stated purpose (use for other purposes). If personal information is used outside the scope of the purpose of use, the Company will obtain the individual’s prior consent. However, this does not apply in the following cases.

(1) When required under the Act on the Protection of Personal Information or other laws and regulations
(2) When necessary to protect a person’s life, body, or property and it is difficult to obtain the individual’s consent
(3) When particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the individual’s consent
(4) When the Company must cooperate with a national government agency, local public body, or a party entrusted by either in carrying out affairs prescribed by law, and obtaining the individual’s consent may impede the performance of those affairs

6. Provision of Personal Information to Third Parties
Except as provided by the Act on the Protection of Personal Information or other laws and regulations, the Company will not provide personal information to a third party without the individual’s prior consent. When providing personal information to a third party, the Company will properly fulfill the verification and record-keeping obligations prescribed by the Act on the Protection of Personal Information.

7. Management of Personal Information
To the extent necessary to achieve the purpose of use, the Company maintains personal information accurately and up to date, manages it securely, including through necessary and appropriate supervision of employees who handle it, and implements necessary and appropriate information security measures to prevent loss, alteration, leakage, and similar incidents. The Company also endeavors to delete without delay any personal information that is no longer required.

8. Compliance with Laws, Government Guidelines, and Other Standards
The Company complies with the Act on the Protection of Personal Information and related laws and regulations, applicable guidelines, and the standards of organizations to which it belongs.

9. Continuous Improvement of the Personal Information Protection Management System
The Company implements and maintains a management system for protecting personal information, reviews it periodically, and endeavors to continuously improve it.

10. Contact Information
If you wish to request notification of the purpose of use, disclosure, correction, addition or deletion, suspension of use, erasure, or suspension of provision to third parties regarding your personal information held by the Company, or if you have any other inquiry, complaint, or request for consultation, please contact the “Personal Information Inquiry Desk” below.

Personal Information Inquiry Desk: Personal Information Protection Manager, Executive Officer (CFO)
Email inquiries: contact@neural-group.com

Handling of Personal Information

1. Purposes of Use of Personal Information Acquired by the Company
The Company acquires the following personal information by proper and fair means.
(1) Personal information acquired by means other than directly from a written document

Image and video data acquired in the course of work commissioned to the Company
-To create analytical and statistical data in providing the Company’s services
Image and video data provided to the Company as a third party
Image and video data acquired from publicly available information
Image and video data captured on public roads, in parking lots, warehouses, offices, common areas of apartment buildings, and similar locations
-To create statistical data related to the Company’s services in a form that does not identify individuals
-To help improve the accuracy of and develop functions for the Company’s technologies, products, or services, and to develop new services
※When estimated information analyzed from image data is acquired, the image data is discarded after analysis without being acquired or stored.
※Image data is acquired for analysis and research and development and is not intended to identify passersby or other persons. The image data may incidentally and inseparably include information such as the faces and behavior of passersby or other persons, but it will not be used for any purpose other than those stated above.

(2) Personal information subject to disclosure requests

Personal information concerning contractors and service providers
Personal information concerning the employment management of all Company personnel
Personal information concerning applicants seeking employment with the Company
Personal information concerning persons who make inquiries
Personal information concerning users of the Company’s services

2. Handling of Information That May Be Acquired in Connection with the “Smart-kun” Dashboard Camera Application Service
In providing services through the “Smart-kun” dashboard camera application (hereinafter referred to as the “Application”), the Company uses information that cannot identify an individual, such as feature points in images captured by the camera when the Application is activated (hereinafter referred to as “Vehicle Information, etc.”). Vehicle Information, etc. is used mainly to determine road conditions, pedestrians, distances to surrounding vehicles and other objects, and similar matters for the purpose of improving the accuracy of and developing functions for the Application, and is not intended to identify users of the Application, passengers, or people passing by (hereinafter referred to as “Passersby, etc.”). Vehicle Information, etc. acquired by the Company may incidentally include information concerning the faces or behavior of Passersby, etc.; however, except where required by law, such information will not be used for any purpose other than the purposes of use for Vehicle Information, etc. stated below. Acquired information will be promptly deleted once the purpose of use has ended.

Purposes of Use of Vehicle Information, etc.:

Provision of services through the Application; improvement of accuracy and development of functions; other modifications; and operation and maintenance
Consideration and development of the Company’s businesses other than this service
Creation and provision of aggregated and analyzed statistical data, attribute information, and similar information (including provision to third parties; the same applies below)
Provision of traffic information and information concerning roads, terrain, structures, weather, and other environmental conditions

Details regarding the acquisition of Vehicle Information, etc. in this service are as follows.

Acquisition period for Vehicle Information, etc.: From June 2020 until termination of this service

3. Handling of Information That May Be Acquired in Connection with the Digital Signage Advertising Service
In providing its digital signage advertising service, the Company acquires and uses information that cannot identify an individual, such as feature points in images captured by AI cameras or by the digital signage advertising service incorporating such cameras (hereinafter referred to as “Viewer Information, etc.”). Viewer Information, etc. is used to understand how people passing by (hereinafter referred to as “Passersby, etc.”) view digital signage advertisements and to improve the accuracy of and develop functions for AI software; it is not intended to identify Passersby, etc. Viewer Information, etc. acquired and used by the Company includes information concerning the faces and behavior of Passersby, etc. (in each case limited to information that cannot identify an individual); however, except where required by law, such information will not be used for any purpose other than the purposes stated below. Acquired information will be promptly deleted once the purpose of use has ended.

Purposes of Use of Viewer Information, etc.:

Provision of the digital signage advertising service; improvement of accuracy and development of functions; other modifications; and operation and maintenance
Consideration and development of the Company’s businesses other than this service
Creation and provision of aggregated and analyzed statistical data, attribute information, and similar information

Details regarding the acquisition of Viewer Information, etc. in this service are as follows.
Acquisition period for Viewer Information, etc.: From October 2021 until termination of the digital signage advertising service; planned acquisition location: apartment buildings where the digital signage advertising service is installed

4. Handling of Information That May Be Acquired in Connection with AI Function Development
In providing AI for estimating personal attributes, the Company acquires and uses images captured by AI cameras. The acquired images are used internally to improve the accuracy of and develop functions for AI software and are not intended to identify Passersby, etc. At the time of recording, a notice is displayed to Passersby, etc. stating that recording is in progress, and any request to delete acquired images will be handled in accordance with this Privacy Policy. This AI function development is conducted primarily for use in digital signage advertising services in order to provide viewers with better advertisements. Except where required by law, the images will not be used for any purpose other than those stated below. The acquired images will not be provided to third parties. Acquired information will be promptly deleted once the purpose of use has ended.

Purpose of Use:

Accuracy evaluation and function development for AI that estimates personal attributes; other modifications; and operation and maintenance (no provision to third parties)

Details regarding the acquisition in this matter are as follows.
Acquisition period for Viewer Information, etc.: From October 2021 until termination of the digital signage advertising service; planned acquisition location: Tokyo

5. Outsourcing of Acquired Personal Information
The Company may outsource the handling of some acquired personal information. The Company evaluates its contractors in accordance with Company standards.

6. Security Control Measures for Retained Personal Data
(1) Establishment of a Basic Policy To work as an organization to ensure the proper handling of personal data (including personal information acquired or to be acquired by the Company that is intended to be handled as personal data), the Company has established a basic policy (see the “Personal Information Protection Policy,” etc.).
(2) Establishment of Rules for the Handling of Personal Data
The Company has established handling rules concerning methods for handling personal data, the persons responsible and in charge, and their duties.
(3) Technical and Physical Security Control Measures

In areas where personal information is handled, the Company controls employee entry and exit and restricts devices that may be brought in, and implements measures to prevent unauthorized persons from viewing personal information.
The Company takes measures to prevent the theft or loss of devices, electronic media, documents, and similar items that handle personal information. When such devices or electronic media are carried, including within Company premises, the Company encrypts the devices or applies password controls.
The Company has introduced systems to protect information equipment that handles personal information from unauthorized external access and malicious software.

(4) Organizational Security Control Measures
The Company appoints a “Personal Information Protection Manager” as the person responsible for managing personal information and clearly defines the responsibilities and authority of personnel regarding the secure management of personal information.
The Company establishes internal rules and manuals concerning security controls, requires personnel to comply with them, and conducts appropriate audits of the status of compliance.

(5) Personnel Security Control Measures
The Company provides personnel with regular education and training concerning the secure management of personal information.

7. Requests for Disclosure and Other Actions Concerning Personal Information
The Company recognizes that individuals have the right to request notification of the purpose of use; disclosure of personal information or records of provision to third parties; correction, addition, or deletion of content; suspension of use; erasure; suspension of provision to third parties; and similar actions. Upon receiving such a request, the Company will respond promptly within a reasonable period and scope in accordance with the Act on the Protection of Personal Information and related laws and regulations.

Procedures for Responding to Requests for Disclosure and Other Actions
To request disclosure or other actions, please submit your request by postal mail in accordance with the procedure below. The Company may be unable to accept a request if it contains deficiencies or omissions. For each request for disclosure of personal information or notification of the purpose of use, an administrative fee of JPY 1,000 must be paid by bank transfer.
Personal information submitted through the “Request Form for Disclosure of Personal Information, etc.” will be used only to respond to the inquiry and for no other purpose.
　

When the Individual Makes the Request	To request disclosure or other actions, please prepare the following documents and send them by recorded-delivery mail. 1. Request Form for Disclosure, etc. Please download the above file and complete the required fields. 2. Identity Verification Documents A copy of a driver’s license, passport, health insurance card, or other document that verifies the individual’s name and current address.
When a Representative Makes the Request	If the person requesting disclosure or other actions is a statutory representative or a representative authorized by the individual, please enclose the applicable documents below in addition to those listed in the preceding section. 【For a Statutory Representative】 1. Document verifying statutory authority of representation A certified copy of the family register; if the representative is a person with parental authority, a copy of a health insurance card listing the dependent family member is also acceptable. 2. Document verifying the identity of the statutory representative A copy of a driver’s license, passport, health insurance card, or other document that verifies the representative’s name and current address. 【For an Authorized Representative】 1. Power of Attorney (attachment to the Request Form for Disclosure of Personal Information, etc.) Please download the above file and complete the required fields. 2. The individual’s certificate of seal registration (issued within the past three months) 3. Document verifying the identity of the authorized representative A copy of a driver’s license, passport, health insurance card, or other document that verifies the representative’s name and current address.
Mailing Address for Requests	Tokyo Midtown Hibiya, Hibiya Mitsui Tower 32F 1-1-2 Yurakucho, Chiyoda-ku, Tokyo 100-0006 Neural Group Inc. Attn: Personal Information Inquiry Desk

※For details regarding disclosure and other actions, please contact the Personal Information Inquiry Desk.

【Personal Information Inquiry Desk】

Name	Neural Group Inc.
Address	Tokyo Midtown Hibiya, Hibiya Mitsui Tower 32F 1-1-2 Yurakucho, Chiyoda-ku, Tokyo 100-0006
Personal Information Protection Manager	Executive Officer (CFO)
Contact	contact@neural-group.com

8. Accredited Personal Information Protection Organization
The Company is a covered business operator of the accredited personal information protection organization listed below. Complaints concerning a covered business operator’s handling of personal information may be submitted to the association.
※Please note that this is not a contact point for inquiries concerning the Company’s products or services.

(1) Name of the Accredited Personal Information Protection Organization
Japan Users Association of Information Systems (JUAS)
(2) Contact for Complaint Resolution
Complaint Consultation Office, Secretariat of the Accredited Personal Information Protection Organization
NBF Higashi-Ginza Square, 1-13-14 Tsukiji, Chuo-ku, Tokyo 104-0045, Japan TEL: 03-6264-1316
Hours: 10:00–16:00 (excluding Saturdays, Sundays, and public holidays)