Privacy Policy

Personal Information Protection Policy

Xpotential (hereinafter referred to as “the Company”) provides professional services and develops and provides applications to support the sustainable growth of sales organizations and human resources through sales enablement. In the course of these efforts, we have established the following personal information protection policy (privacy policy) with the aim of appropriately managing and protecting the personal information we receive from individuals, and by establishing a system for protecting personal information and ensuring that all of our employees are aware of the importance of protecting personal information and their efforts to do so, we take responsibility to meet the trust of those who provide us with personal information.

1. Acquiring, Using and Providing Personal Information

When acquiring personal information, the Company shall limit the purpose of personal information acquisition so as not to exceed the limit necessary to achieve the purpose of acquisition, taking into consideration the nature, structure, and scale of our business.
Furthermore, the information shall be acquired through legal and fair means.

The Company may outsource the handling of personal information with the aim of providing better service.
In this case, an outsourcing contractor who is known for appropriate handling of personal information (Hereinafter referred to as “Subcontractor”) shall be selected, and necessary matters such as management of personal information, confidentiality, prohibition of re-provision, etc. shall be decided in an entrustment agreement, etc., and appropriate management shall be performed.

The Company shall not disclose or provide personal information (excluding personal numbers) to third parties other than Subcontractors without the consent of the individual, except when disclosure is required by law or when requested by a court, police, or other public institution.

2. Compliance with Laws, Regulations, and Standards

In carrying out the duty of handling personal information, the Company shall comply with laws and regulations concerning the protection of personal information, the “Personal Information Protection Management System (JISQ15001),” the guidelines set forth by the government, and other standards, and shall take the utmost care while handling of personal information in accordance with the items stipulated in the Company’s internal rules.

3. Management of Personal Information

The Company shall appoint a personal information protection manager to appropriately manage personal information and strive to prevent it’s leakage to outside parties.
The Company shall take appropriate information security measures for prevention and correction in order to prevent leakage, damage or loss of personal information due to unauthorized access, computer viruses, etc.

4. Complaints and Consultation regarding Personal Information

In the event when a complaint or request for consultation from an individual regarding the handling of personal information is received, the Company shall respond to the complaint or request without delay, except in cases where the handling of personal information would significantly hinder the execution of the Company’s duty or may harm the life, body, property, or other interests of the individual.
In the event when an individual requests the correction or deletion of his or her own personal information, the Company shall check the information without delay. In this case, if a correction or deletion is necessary, it shall be made without delay.

5. Establishment and Continuous Improvement of Management Systems for Personal Information Protection

The Company shall build and implement a management system for the protection of personal information by establishing rules and systems to ensure appropriate handling, and shall continue to improve these systems.

Enactment: February 22, 2020
Final Revision: January 1, 2024
Xpotential Inc.
Takahiro Yamashita, CEO

Handling of Individual Information

1. Acquiring Personal Information

When acquiring personal information, the Company shall clearly define, notify and/or announce the purpose of use, acquire no more than the information required to achieve that objective and acquire that information through legal and fair means.
Furthermore, in the event personal information is acquired from the individual directly in writing, a notification shall be issued in order to obtain the consent of the individual.

2. Use of Personal Information

Personal information shall be used within the scope of the purpose for which the consent of the person has been obtained. In addition, the Company shall take measures to ensure that personal information is not used for any other purpose.
If the need to use the information for other purposes arises, consent of the individual shall be obtained for such use, except when permitted by law.

The Company shall use personal information for the following purposes.

Information on Customers Interested in Our Services and Events

・To respond to requests for information materials and inquiries, and to provide information regarding our services,
events, and seminars (including providing information tailored to your interests and needs by analyzing information
such as our website browsing information)
・ To manage the operation of events and seminars
・ To utilize the information as statistical data in a form that does not identify individuals

Customer and Business Partner Information
・Information on customers interested in our services and events
・To respond to requests for information materials and inquiries, and to provide information regarding our services,
events, and seminars (including providing information tailored to your interests and needs by analyzing information
such as our website browsing information)
・To manage the operation of events and seminars
・To utilize the information as statistical data in a form that does not identify individuals
・To communicate with customers and business partners, to execute contracts, to request performance, etc.
・To provide, manage, and operate our services

Information on Candidates and Applicants for Employment
・ For employment selection and communication

Employee Informationmation
・ To communicate on business, exchange information, manage attendance, payroll, evaluations, benefits, safety and health and other labor management, and fulfill other obligations stipulated in labor-related laws, tax-related laws, social welfare-related laws and regulations, etc.
・ For receipt, performance, and management of various procedures stipulated in internal regulations
・ For notification and reporting to government agencies, participating organizations, etc.
・ For communication in case of emergency

If we use personal information for purposes other than those listed above, we will notify or publicly announce the purpose of use at the time of acquisition of the personal information, as necessary, in accordance with the relevant laws and regulations.

3. Measures Taken for The Safe Management of Personal Information

Based on the personal information protection policy in accordance with JIS Q 15001, we have established personal information protection rules and regulations, and are operating a personal information protection management system. In addition, we have implemented safety control measures for the actual handling of personal information from four perspectives: organizational, personnel, physical, and technical.
For more information on safety control measures, please contact the following our inquiry desk.

4. Restrictions on Provision to Third Party

The Company shall appropriately manage personal information provided to the Company and shall not disclose or provide personal information to third parties, except in the following cases.

 ・If an individual has given the consent
 ・When it is necessary to protect the life, body, or property of an individual, and it is difficult to obtain the consent of the individual
 ・When it is necessary to disclose the information in accordance with the laws and regulations

5. Voluntariness and results of providing personal information

Provision of personal information to the Company is at the discretion of the individual. However, in the event some or all of the necessary personal information is not provided, it may not be possible to provide the response, etc. described in the purpose of use in an appropriate manner.

6. Notification of Purpose of Use, Disclosure, Correction, Addition, Deletion, Suspension of Use, Elimination, Suspension of Provision to Third Parties, etc. of Personal Information

In the event when individual wish to request notification of purpose of use, disclosure, correction, addition or deletion, suspension of use, elimination, or suspension of provision to a third party, disclosure of third party records (hereinafter “Disclosure”), please contact our inquiry desk. After confirming individual’s identity, the Company will respond without delay.

 Procedures Required to Request for Disclosure, etc.
 The Company shall disclose personal information to the individual based on the request made by the individual as long as it does not hinder appropriate execution of the Company’s duty. In that case, the individual’s identity shall be confirmed using the method predetermined by the Company.
 If the personal information disclosed to the individual is found to be inaccurate, the Company shall immediately correct it. In addition, if individual requests that the Company stop using personal information, the Company shall immediately stop using it.

 Sending Requests for Disclosure
 [Inquiry Desk] for “7.Correspondence Regarding Complaints and Consultation”

7. Correspondence Regarding Complaints and Consultation

If you have any complaints or questions regarding this Privacy Policy (Personal Information Protection Policy), please send your name, address, and return e-mail address (for e-mail inquiries), as well as a document describing the content of your inquiry, by e-mail or by post to the address provided below.

The Company shall use the personal information of the person making the inquiry only for the purpose of replying to the inquiry.

8. Handling of Personal Information on the Website

We may use “Cookie” and “IP address” on our website (hereinafter “Our site”) for the following purposes.

・ To identify and resolve the causes of problems or failures that may occur on our servers
・ To improve the content of Our site, e-mails, etc.
・ To customize the contents of Our site and e-mails for individual users.
・ To use your browsing history, survey results, etc. for marketing activities for services that you have registered your personal information for in advance
・ To distribute advertisements and promote our products
・ To utilize the information as statistical data in a form that does not identify individuals.

“Cookie” is a mechanism that stores the usage history, input contents, and other information sent and received between Internet browsing software (browser) and the server as a file on the customer’s computer when the customer uses a web page. If you have set your browser to allow the sending and receiving of Cookie, the Company may retrieve the Cookie stored on your computer and link the collected behavioral history to your personal information. In addition, the Company may refer to Cookie stored on the customer’s computer via third parties to whom the Company outsources the delivery of advertisements, etc., or via web pages other than Our site, to deliver advertisements for the Company’s products and to conduct advertising, etc. You may set your browser to allow Cookie, refuse Cookie, or notify you when Cookie is received. Please note that if you choose to reject Cookie, you may not be able to use some of the services provided by the Company.

“IP address” is a number that can identify the computer accessing the server (it cannot identify the user of the computer).

Use of “Google Analytics”
The Company may use Google Analytics to monitor the usage of Our site, which uses first-party Cookie to collect information about access to Our site without identifying you personally. The collection and use of access information is governed by the Google Analytics Terms of Service and the Google Privacy Policy.
For more information about Google Analytics, please visit the following site. (Google Analytics is a trademark of Google LLC.)


[Inquiry Desk]
Xpotential Inc.
3-28-5 Axle Ochanomizu #211 Kanda-Ogawamachi, Chiyoda-ku Tokyo, Japan 101-0052
Personal Information Protection Manager
Shinya Umeno, Director