Privacy policy

This policy describes how Fenrir Inc. (“We”, “Us” or “Our”) and its affiliates collect and use personal information. This policy applies to Our corporate site, to the relevant websites or services We operate, or to all users who contact Us directly or indirectly. However, this does not apply where other privacy policies are applied separately on related websites or services.

If you contact Us through a service provided by other companies, We will manage the received information in accordance with this privacy policy, provided, however, that the privacy policies which are separately effective between the user and the services provided by other companies will apply to the use of the services thereby.

1) Collection, Purpose of Use, and Grounds for Use of Personal Information

We receive the following information from users (the “Personal Information”) by lawful and fair means. The Personal Information of the user will be used only for the purpose of use notified to the user at the time of provision thereof or within the scope of the purpose of use listed below, and will not be used for any other purpose without the user’s prior consent, and will not be used in any way that may encourage or induce an illegal or unjust act. In addition, the personal information will be deleted immediately when its use is no longer necessary.

1.Information We Collect

We collect the following information. The details of the information to be collected are shown as examples in the right columns.

Access information
  • IP address.
  • Device information. (device and application identification numbers, Internet service providers, mobile carriers)
  • Browser information.
  • Web browsing status (URL of the access destination, search information) and the status of opening and clicking emails.
  • Operating system and system configuration information.
  • Time stamp information.
  • Cookie information.
Requests for proposals and various inquiries
  • Contents of inquiry.
  • Company name and department name.
  • Address.
  • Name.
  • Contact information.(e-mail address and telephone number)
Recruitment-related information
  • Personal attribute information. (address, name, date of birth, etc.)
  • Academic background, work experience, etc.

2.Purpose of use of collected information (the “Purpose of Use”)

Promotion and sales activities
  • Procedures for using Our affiliated services.
  • Information on Our products, services, and seminars.
  • Dispatch and provision of products and premiums.
  • Request for cooperation in investigations in questionnaires, etc.
  • Investigation and analysis of the contents of the provided questionnaires, etc.
  • Survey and analysis of services usage.
Response to inquiries
Responding to various inquiries.
Recruitment activities
  • Provision of employment information, etc. and communication to job applicants.
  • Management of recruitment work in Us.
Statutory procedures
  • Investigation and resolution of claims and disputes by Us or users concerning the use of Our services.
  • Provision to national agencies or local governments to which it is permitted by laws and regulations.

3.Grounds for Use of Collected Information

We will use the Personal Information based on one or more of the following grounds.

We collect the Personal Information of users based on the consent of the users. You have the right to withdraw your consent at any time.
Responding to user requirements
We collect the Personal Information of users when handling thereof is necessary in order to perform contracts and in order to perform the procedure in response to the requests of users prior to the conclusion of the contracts. Responding to requests from users includes responding to inquiries from users and recruitment activities.
Compliance with legal obligations
We collect the Personal Information of users in order to comply with the legal obligations that We must comply with.
Protection of important interests of users or third parties
We collect the Personal Information of users in order to protect the important interests of users and third parties. Important interests of users include the omission of the users’ re-entry effort, the display of the most appropriate contents for the users, and the display of advertisements according to the users’ interests.
Protection of the public interest
We collect the Personal Information of users to the extent necessary to protect the public interest.
Pursuit of the legitimate interests of us or third parties
We collect the Personal Information of users in order to pursue the Our legitimate interests or those of third parties. Our legitimate interests include preventing and detecting fraud in Our services and responding to it, providing customer support, conducting investigations and analyses to improve Our services or security, conducting direct marketing and engaging in recruitment activities.

4.Use of Cookie, etc.

We may use Cookie on the websites We operate and related websites. A Cookie is a text file stored on your computer system through the Internet browser. By using Cookie, you can save the usage history and entered information between the browser and the server when you use the websites on your computer. By using Cookie, you can optimize the contents and advertisements on Our website.
Users can disable Cookie settings through Our website by using the settings in the users’ Internet browsers.

5.Use of Analysis Tools

In relation to Our website, We have introduced services by other companies for Our marketing activities.
For further information, please review the privacy policies of each of the following companies.

2)Rights of Users

You have the following rights: The exercise of these rights and any inquiries, opinions, questions, complaint requests, and other handling of user information shall be made through the Inquiry Form.

1.Right of Information and Access

Users have the right to request explanations concerning the Personal Information We hold and how to use such information. We will also provide a copy of available data certifying the subjects of the request in response to any requests for access to the Personal Information processed by users.

2.Right of Correction

Users have the right to correct the inaccurate Personal Information of users and complete such information after taking into account the purpose of processing such information.

3.Right of Deletion

In certain cases, users have the right to request the deletion of their own Personal Information.

4.Right to Restrict Disposal

In certain cases, users have the right to restrict the processing of their own Personal Information.

5.Portability Rights

Users have the right to receive the Personal Information in a structured, generally used, machine-readable form and the right to transfer the Personal Information obtained in response to the consent or the request of the users, from Us to another administrator without being obstructed from the administrator. Specifically, when the user changes to a service that is different from the services provided by Us, the user is entitled to receive reusable Personal Information at the level of the text file data such as CSV or the data description languages such as JSON regarding the group of Personal Information provided by the user to Us.

6.Right of Objection

Users have the right to object to the protection of the public interest or to the processing (including profiling) of the Personal Information obtained for the purpose of pursuing the legitimate interests of Us or third parties.

7.Right Not to Receive Automated Decisions including Profiling

Users have the right to not be subject to a fully automated decision, including profiling, that (i) gives rise to a legal effect to you, or (ii) has a similar material impact on you. However, at this point, We have not made any fully automated decisions, including profiling, that (i) give rise to a legal effect or (ii) have a similar material impact on you, as we have not made any targeted advertisements with a high degree of infringement in light of the content and distribution of advertisements, the impact on users, or any other factors.

8.Right to Revoke Consent

Users have the right to revoke his/her consent at any time with regard to the Personal Information obtained based on his/her consent. However, this will not affect the legality of any process made based on such consent prior to the withdrawal of such consent.

3)Appropriate Management and Protection of Personal Information

We have introduced measures and an information security management system to properly manage and protect users’ Personal Information in accordance with the applicable laws and to prevent inappropriate loss, theft, unauthorized use, leakage, damage, and alteration thereof.
In the event of an incident such as a leak, we will notify users and report to the supervisory authority in accordance with the governing laws, regulations and related guidelines, and will take the necessary measures in accordance with the instructions of the supervisory authority.

4)Provision and Disclosure to Third Parties

We will not provide or disclose the Personal Information of users to third parties except in any of the following cases:

  • Cases where the user has given his/her consent to the disclosure of his/her Personal Information;
  • When providing or disclosing to subcontractors, etc. within the scope necessary for achieving the Purpose of Use;
  • In the event of joint use among Our group companies as follows (“Our Group Companies”) to the extent necessary to achieve the Purpose of Use.
    In order to facilitate the smooth execution of operations among Our Group companies, we may share the Personal Information of users among Our Group Companies within the scope of the Purpose of Use determined by Us. In such cases, We are responsible for the safe management of the Personal Information.
    (a)Items of the Personal Information that may be shared
    (i)Address, name, date of birth, etc. of the users
    (ii) Phone number and mail address
    (iii) IP address, device information, browser information, web browsing information, and Cookie information
    (b) Scope of Joint Users
    • Fenrir Inc. Chengdu
    • Fenrir Shanghai Inc.
    • DAQ Co. Ltd.
    • Bergmal Inc.
    (c)Purpose of Use by Joint Users
    Same as the Purpose of Use of the Personal Information stipulated in Article 1.
    (d)The name of the person responsible for the management of such Personal Information
    Fumio Awaji
    Chief Privacy Officer
    Fenrir Inc.
  • When disclosure or provision is permitted by applicable laws; or
  • Cases where the Personal Information is disclosed or provided as a result of business succession such as merger, company split or business transfer, etc.

5)Disclaimer for Third Parties

We are not responsible for any matters related to the acquisition of the Personal Information by third parties in any of the following cases:

  • When a user discloses his/her Personal Information to a third party at his/her own discretion;
  • In the event that the identity of the user has been identified unexpectedly based on the content of the inquiry received from the user;
  • When the Personal Information is provided by users and used by external websites linked from Our services; or
  • When, on the user’s responsibility, information that can identify a user is leaked due to the vulnerability of the network used by the user.

6)Administration on Outsourced Consignee

We may outsource the handling of the Personal Information to the extent necessary for the implementation of the Purpose of Use. In such cases, We will select a consignee who is recognized to properly handle the Personal Information. In addition, We will provide or disclose the Personal Information of users only to the extent necessary for implementing the Purpose of Use to the consignee. We will also ask the consignee to properly handle the Personal Information after concluding a confidentiality agreement with respect thereto, and periodically confirm and review the status of handling such information.


Fumio Awaji
Chief Privacy Officer
Fenrir Inc.

Address: Grand Front Osaka Tower B 14F, Ofukachou 3-1, Osaka City Kita-ku, Osaka Prefecture
Telephone Number : +81-6-6377-7606
Inquiry Form:

8)Governing Law

This policy will be construed and applied in accordance with the laws of Japan. In addition, the Osaka District Court or the Tokyo District Court will be the exclusive jurisdictional courts of the first instance for any dispute concerning this policy.

9)Review and Improve the Handling of Personal Information

We evaluate the handling of the Personal Information in a timely manner and will make continuous improvements. Therefore, this policy is subject to change. If there is any significant change, the content will be announced in an easy-to-understand manner to users.

Supplementary Provisions
Partial revision of Article 2 on September 5, 2005
Partial revision of Article 2 and 4, February 20, 2006
Revision on January 16, 2012
Full revision on April 1, 2016
Revision of Article 7 on September 21, 2017
Partial revision of Article 1 on December 19, 2017
Full revision on May 25, 2020
Partial revision of Article 4, July 01, 2021
Partial revision of Article 1,3,4 and 7, April 01, 2022