Personal Information Privacy Policy

Imagine Global Care Co., Ltd. recognizes that the protection and proper management of personal information is an important social responsibility. We hereby establish the following Privacy Policy and will implement and maintain it accordingly.

1. The Company shall clearly define the purposes of use and appropriately acquire, use, and provide personal information for the promotion and operation of its healthcare, pharmacy, education, and resort businesses. Personal information obtained shall be used only within the scope of the stated purposes, and measures shall be taken to prevent use beyond such purposes.
2. The Company shall comply with all applicable laws and regulations concerning the handling of personal information, including Specific Personal Information, as well as guidelines established by the government and other relevant standards.
3. When outsourcing all or part of the handling of personal information entrusted to us, the Company shall select corporations and individuals that meet our required management standards, execute appropriate agreements, and implement proper supervision and management measures.
4. The Company shall implement sufficient security management measures and corrective actions against risks such as leakage, loss, damage, or destruction of personal information.
5. The Company shall appropriately respond to requests from individuals regarding disclosure and other inquiries concerning their personal information entrusted to us.
6. The Company shall establish a contact point for complaints and consultations and will respond sincerely and promptly.
7. The Company shall continuously review and improve its Personal Information Management System. The Company's Personal Information Management System conforms to the Japanese Industrial Standard JIS Q 15001.

Established: March 20, 2010

Revised: January 6, 2026

Imagine Global Care Co., Ltd.

President & CEO: Hiroki Kinoshita

Handling of Personal Information by the Company

1. Purpose of Use of Personal Information
   1. Purpose of Use of Personal Information Subject to Disclosure Obtained Directly from the Individual Through Written Forms, Websites, Email, Fax, or Similar Means, and Personal Information Subject to Disclosure Obtained Directly from the Individual by Telephone or Other Non-Written Means
      1. Personal Information of Customers
         • To deliver products and provide paid or unpaid services to customers.
         • To bill customers for products and services.
         • To confirm and communicate regarding the delivery of ordered products and related after-sales services.
         • To provide customers with information regarding services and products that the Company believes may be beneficial to them (including those of affiliated companies) by telephone, postal mail, email, or other means. However, if the customer does not wish to receive such information, the Company will promptly discontinue such communications upon request.
         • For marketing activities, sales promotions, surveys, and service improvements conducted by the Company.
         • To respond to customer requests, inquiries, complaints, and consultations regarding the Company.
         • To prepare and use statistical data in a form that does not identify individuals for marketing and other analytical purposes.
         • To record telephone conversations for quality improvement, staff training, and the accurate confirmation of inquiries and responses.
         • To provide family members of enrolled students with information regarding activities and daily life within the educational facilities through recorded video and photographic images (Personal Information Not Subject to Disclosure).
      2. Personal Information of Business Partners
         • To contact business partners and send materials, etc. in connection with the Company's business activities.
      3. Personal Information of Job Applicants and Employees
         • In relation to the Company's recruitment activities, to contact applicants and send recruitment-related documents and information, and to use such information as the basis for recruitment screening and selection.
         • To conduct personnel management for employees hired by the Company, including employment administration, employee benefits, retirement procedures, and the creation and management of emergency contact information (including family information).
      4. Information (Video and Photographic Images) Recorded Within Educational Facilities (Personal Information Not Subject to Disclosure)
         • To provide family members of enrolled students with information regarding activities and daily life within the educational facilities. Such information shall be provided only to the family members of enrolled students.
         • To inform the general public about services provided by the educational facilities, including through websites, brochures, social media, and other promotional materials. Prior consent shall be obtained from the individual or the parent/guardian before any external publication or use.
      5. For Purposes for Which Prior Consent Has Been Obtained from the Individual
   2. Purpose of Use of Personal Information Not Subject to Disclosure Obtained by Means Other Than Directly from the Individual Through Other Companies' Websites, etc.
      1. Personal Information of Customers
         • To confirm and communicate regarding the delivery of ordered products and related after-sales services.
         • To respond to customer requests, inquiries, complaints, and consultations regarding the Company.
         • For marketing activities, sales promotions, surveys, and service improvements conducted by the Company.
         • To prepare and use statistical data in a form that does not identify individuals for marketing and other analytical purposes.
   3. Purpose of Use of Personal Information Not Subject to Disclosure Obtained by Means Other Than Directly from the Individual, Except Through Other Companies' Websites, etc.
      1. To appropriately perform entrusted operations in cases where business operations have been outsourced to the Company.
2. Provision to Third Parties
   1. In order to deliver advertisements that are more relevant to customers, and for the purposes of advertisement delivery, effectiveness measurement, analysis, and related activities, the Company may provide personal data to the following business partners (including those located in foreign countries) with the consent of the customer.
      1. Recipients
         • Meta Platforms, Inc.
         • Google LLC
         • LY Corporation
      2. Personal Data to Be Provided: Hashed email addresses, telephone numbers, dates of birth, and customer identification numbers (processed into a format that cannot be restored to the original personal data and obtained directly by the Company).
   2. In addition to the above, the Company will not provide acquired personal information to third parties except where the consent of the individual has been obtained or where required by laws and regulations.
   3. The Company may provide personal data in cases that constitute joint use pursuant to Article 27, Paragraph 5 of the Act on the Protection of Personal Information.
3. Joint Use of Personal Information
   The Company shall jointly use acquired personal information (including information acquired in the past) as follows.
   1. Scope of Parties for Joint Use
      • Tokyo Pharmaceutical Co., Ltd. (an affiliated company of the Company)
      • Life Plus General Incorporated Association (business partner)
   2. Purpose of Joint Use
      To provide information regarding products and services offered by each company (including distribution through direct mail, email, social media, etc.), to provide information regarding campaigns, events, and monitor recruitment, to propose medical and health-related services and products, and to provide after-sales support and respond to inquiries.
   3. Items of Personal Information Subject to Joint Use
      Name, customer ID (a unique ID used to identify customers), address, telephone number, fax number, email address, purchase history, point-related information, browsing history, date of birth, gender, inquiry information, processed information derived from the personal information listed above, and other information necessary to achieve the purposes described above.
   4. Person Responsible for the Management of Personal Information
      The following entity shall be responsible for the management of personal information to be jointly used.
      Imagine Global Care Co., Ltd.
      Roppongi KS Building 8F, 3-16-12 Roppongi, Minato-ku, Tokyo 106-0032 Japan
4. Outsourcing of Personal Information Handling
   The Company may outsource the handling of personal information within the scope necessary to achieve the purposes of use described above. In such cases, the Company shall exercise necessary and appropriate supervision over the outsourcing contractor to ensure the safe management of personal information.
5. Complaints and Consultations Regarding Personal Information
   For complaints and consultations regarding the handling of personal information, please contact the "Inquiry Desk."
6. Inquiry Desk
   For requests regarding disclosure, etc. of personal information, as well as complaints and consultations, please contact the following:
   Personal Information Customer Consultation Desk
   Roppongi KS Building 8F, 3-16-12 Roppongi, Minato-ku, Tokyo 106-0032 Japan
   +81-3-5549-2814
   (9:00–18:00, excluding weekends, national holidays, and the New Year holidays)
   E-mail: support@imagine-gc.com
   Please note that inquiries are not accepted in person at our office.
7. Requests for Disclosure, Correction, etc. of Personal Information
   The Company accepts requests for notification of the purpose of use of personal information, disclosure, correction, addition or deletion of content, suspension or deletion of use, suspension of provision to third parties, and disclosure of records of provision to third parties (hereinafter collectively referred to as "Disclosure, etc."). For the contact point for requests for Disclosure, etc., please refer to the "Personal Information Complaints and Consultation Desk" below.
8. Voluntary Provision of Personal Information
   Whether or not to provide personal information to the Company is at the discretion of the individual. However, please note that if the required information is not provided, the Company may be unable to enter into contracts or provide services.
9. Handling of Credit Card Information
   If payment by credit card is requested, the entered credit card information shall be handled as follows.
   • Purpose of Use: To process payment for purchased products and services
   • Name of the Entity Acquiring the Information: Imagine Global Care Co., Ltd.
   • Recipient of the Information: GMO Payment Gateway, Inc.
   • Retention Period: The Company does not retain such information in any form.
10. Safety Management Measures
    The Company implements the following measures for the safe management of retained personal data after understanding the external environment.
    1. Organizational Safety Management Measures
       The Company has implemented necessary measures regarding the establishment of organizational structures, operation in accordance with rules governing the handling of personal data, establishment of methods for confirming the handling status of personal data, establishment of systems for responding to leakage incidents, and the review and improvement of safety management measures.
    2. Human Safety Management Measures
       The Company provides employees with regular training regarding matters to be observed in the handling of personal data. In addition, the Company obtains written pledges containing confidentiality obligations regarding personal data.
    3. Physical Safety Management Measures
       The Company has implemented necessary measures regarding the management of areas where personal data is handled, prevention of theft of equipment and electronic media, prevention of leakage when transporting electronic media, and the deletion and disposal of personal data, equipment, and electronic media.
    4. Technical Safety Management Measures
       With respect to information systems, the Company has implemented necessary measures regarding access control, identification and authentication of users, prevention of unauthorized external access, and prevention of information leakage associated with the use of information systems.