Privacy
Privacy Policy
Effective YYYY-MM-DD Last revised YYYY-MM-DD
This page is a draft. Items in red are not yet settled and will be finalised following review of our practices and legal confirmation. The Japanese text is authoritative.
LLAYOS Institute of Sapientia (“we”) treats the protection of personal information handled in the course of our business as a responsibility we owe to society, and complies with the Act on the Protection of Personal Information and other applicable laws and guidelines.In this policy, “personal information” means personal information as defined in Article 2(1) of that Act.
Part 1 — Our policy
1. How we obtain personal information, and why
We obtain personal information by lawful and fair means, and use it only within the following purposes.・ To answer enquiries・ To provide and operate our services and to perform contracts・ To improve service quality, produce statistics, and improve machine learning models (processed so that individuals cannot be identified)・ To run and announce seminars, training and other events・ To send information about our products and services by email or post・ To conduct recruitment, contact applicants, and administer employment・ To meet legal obligations and to exercise or defend our rightsWe will obtain consent in advance before using it beyond these purposes.
2. Special care-required personal information
Except where the law permits, we do not obtain special care-required personal information such as race, creed or medical history without prior consent. In recruitment we take care not to obtain such information beyond what the work requires.
3. Security and supervision of employees
We take necessary and appropriate measures to prevent leakage, loss or damage of personal information, and train the employees who handle it. The measures themselves are set out in Part 2, item 7.
4. Compliance
We comply with the Act on the Protection of Personal Information, other applicable laws, and the guidelines issued by the authorities.
5. Changes to this policy
We may change this policy in response to changes in law or circumstances. A changed policy takes effect when posted on our website. We will give clear notice on our website of any significant change.
Part 2 — How we handle personal information
Published under Article 32(1) of the Act on the Protection of Personal Information and Article 10 of its Enforcement Order.
1. Our name, address and representative
Name: registered corporate name (confirm the registered name for LLAYOS Institute of Sapientia)Address: postal code addressRepresentative: title and namePersonal information manager: title Kou Suzuki
2. What we collect, and why
When you contact us, request materials, apply to join us or use our services, we collect your name, company, department, job title, email address, telephone number, and information arising from your use of each service. The purposes are those set out in Part 1, item 1.
3. Outsourcing
We may outsource all or part of the handling of personal information to the extent necessary to achieve those purposes. Where we do, we select the contractor after appropriate assessment and supervise them through contract and other necessary and appropriate means.
4. Provision to third parties
We do not provide personal data to third parties without prior consent, except where:・ required by law;・ necessary to protect a person’s life, body or property and consent is difficult to obtain;・ specially necessary for public health or the sound growth of children and consent is difficult to obtain;・ cooperation with a public authority performing a statutory duty is required and consent would impede that duty.The following recipients are not third parties for this purpose under the Act: contractors handling data within the purposes above; successors to the business on merger or similar; and parties with whom data is used jointly after prior notice or where the fact is readily accessible.
5. Provision to third parties in foreign countries
To provide our services and run our business we may entrust personal data to, or provide it to, third parties located outside Japan, including contractors abroad. Where we do, we obtain prior consent and take the measures the law requires.The countries and purposes currently involved are:・ United States: processing by AI models and online search (Anthropic PBC, OpenAI, L.P., Google LLC, Tavily Inc., Exa Labs Inc.)・ Czech Republic: web data acquisition platform (Apify Technologies s.r.o.)・ Malaysia: hosting of the website and enquiry data (Hostinger International Limited)Information about the data protection regime in those countries and the measures those third parties take is available on request from the contact in item 9.
6. Joint use
We do not currently use personal data jointly with any other party. If joint use begins, state the items, the scope of parties, their purposes, and the party responsible for management
7. Security measures we take
・ Basic policy: we maintain this policy and internal rules to ensure proper handling.・ Organisational: we appoint a person responsible, define which employees handle which data, maintain means of checking how it is handled, and maintain a reporting line for any breach of law or internal rule.・ Personnel: we train employees regularly on handling personal information, and confidentiality obligations are set out in our work rules and in signed undertakings.・ Physical: in areas where personal information is handled we control entry and exit and restrict the devices brought in, and we prevent viewing by unauthorised persons.・ Technical: we apply access control to the systems that handle personal data, limiting both the people and the databases involved, and we maintain protection against unauthorised access and malicious software.・ External environment: we handle personal data using cloud services in the United States, the Czech Republic and Malaysia. We understand the data protection regime in each and take the measures necessary for secure handling.
8. Requests for disclosure and related rights
You or your agent may ask us to notify you of the purpose of use of retained personal data; to disclose it (you may specify disclosure by electromagnetic record or another method); to correct, add to or delete its contents; to suspend its use or erase it; to stop providing it to third parties; and to disclose records of third-party provision.How to make a request:・ Contact us at item 9 and we will send our request form.・ Return the completed form with a copy of identification. For a request by an agent, please also include a power of attorney and the agent’s identification.・ We will verify your identity and respond without delay as the law requires. Where the method you specified is not feasible, we will disclose in writing.Fee: no fee is charged for notification of purpose of use or for disclosure. If a fee is introduced, state the amount hereWhere the law so provides we may be unable to comply in whole or in part; if so we will tell you promptly and explain why.
9. Contact and complaints
For questions about this policy, complaints about our handling of retained personal data, and the requests in item 8:entity name Personal Information Deskpostal code addressTelephone: 000-0000-0000 (weekdays 10:00–18:00)Email: privacy@llayos.com (to be opened)We maintain the arrangements needed to handle complaints appropriately and promptly.
10. Cookies and data sent to external services
As things stand our website uses no third-party analytics or advertising services, and no information is sent from your device to any third party. Fonts, images and other assets are all served from our own servers.If analytics or any other external service is introduced, record the service, the provider, the information sent, our purpose and the provider’s purpose here at the same time it goes live