Privacy Policy

The Privacy Policy is a translation from the Japanese version. In the event of any discrepancy or inconsistency between the English and Japanese versions, the Japanese version shall take precedence.
Click here for the Japanese version.

Gehirn Inc., hereinafter referred to as “Gehirn”, recognises that your personal information is entrusted to Gehirn for a specific purpose by your own will, based on their trust in Gehirn. In order to protect the personal information and to use it with respect for the user’s will, Gehirn has established the following policy on the appropriate handling of personal information.


1. Definition of Personal Information
Gehirn recognises that personal information means information about a living individual (name, date of birth, and other information that could identify a specific individual) as defined in the Act on the Protection of Personal Information, as well as information such as an e-mail address, user ID, password, etc., that could be used in connection with a specific individual; and school or company affiliation, gender, age, and other personal attributes that are integrated to one’s personal information.
2. Access and Location Information
Access information (hostnames, IP addresses, cookies, browser information, etc.) and location information are not considered personal information, because Gehirn cannot identify a specific individual based on this information alone. However, if this information is used in conjunction with the personal information mentioned above, it shall be deemed personal information.

Gehirn will disclose the purpose and method of use of cookies and IP address information on websites and services operated by Gehirn, even if they do not identify specific individuals. It is also possible to reject cookies by disabling them in the browsers settings. If the service cannot be accessed if cookies are disabled, Gehirn will make an announcement to that effect.
3. Compliance with laws and regulations
When handling personal information, Gehirn complies with the obligations set out in the Act on the Protection of Personal Information, and other laws and regulations concerning the protection of personal information, as well as the guidelines set out by the relevant ministers, and with this policy.
4. Use within the scope of the purpose of use
Gehirn will handle personal information only to the extent necessary to achieve the purpose of use specified in advance, except in cases where Gehirn has obtained your consent or the consent of your parent or guardian in advance, or where permitted by law. However, this does not apply to the following cases.
  • Where a risk of harm to life, health, property, or other rights and interests of the individual or a third party arises by notifying the purpose of use to the individual or announcement of such purpose.
  • Where it is necessary to cooperate with a national or local government in executing its legal duties, and where notifying the purpose of use to the individual or announcement of such purpose may hinder the execution of the said duties.
  • Where notifying the purpose of use to the individual or announcement of such purpose may harm the rights or legitimate interests of Gehirn.
5. Acquisition of Personal Information
When acquiring personal information, Gehirn will strive to specify the purpose of use, the scope of joint users, the contact point for enquiries, and any other necessary information, and obtain the individual’s consent in advance.
6. How we use your Personal Information
Gehirn will use the personal information it collects only for the following purposes.
  • To fulfil the contract between the individual and conduct our business
  • To resolve and reply to your enquiries, and for internal training purposes
  • For statistical recording in the event we collect opinions from a wide range of users
7. Personal Information of customers under the age of 15
Gehirn will make special consideration for the handling of personal information of users under the age of 15, e.g., to notify clearly in advance to ask such user to provide personal information upon the consent of a parent/guardian.
8. Security Measures
Gehirn will strive to keep the personal information we receive from the users accurate and up-to-date within the scope of the purpose of use, and will take the necessary and appropriate security measures in line with current technological standards to prevent unauthorised access, leakage or falsification of data, and will take corrective action if necessary.
9. Change in purposes of use of Personal Information
Gehirn will not change the purpose for which personal information is used beyond the scope in which it is reasonable to find that the changed purpose of use is appropriately relevant to the original purpose of use, and will notify the individual of the changed purpose of use, or will announce it.
10. Supervision of Contractors
In the event Gehirn outsources the handling of personal information in whole or part to third parties, Gehirn will conclude a confidentiality agreement with the outsourcing partner, or require agreement to terms and conditions stipulated by Gehirn, and will supervise such partner appropriately to achieve safe management of personal information.
11. Restrictions on the provision of personal information to third parties
Gehirn will not provide personal information to third parties without the prior consent of the individual or the parent/guardian of the individual, except in the following cases.
  • Where required by law and regulation
  • Where it is necessary to protect the life, health, or property of an individual, and it is difficult to obtain the consent of the individual concerned or the parent/guardian of the individual.
  • Where it is particularly necessary for the improvement of public health or the promotion of the sound growth of children or students, and it is difficult to obtain the consent of the individual concerned or the parent/guardian of the individual.
  • Where it is necessary to cooperate with a national or local government, or a person entrusted by such government in executing its legal duties, and obtaining the consent of the individual concerned may hinder the execution of the said duties.
  • Where the following information has been notified or announced in advance.
    • Provision of personal information to third parties is included in the purpose of use
    • Items of data to be provided to third parties
    • Means or methods of provision to third parties
    • Provision of your personal information to third parties will be suspended upon your request
However, none of the following cases are considered as a third party under this article.
  • When Gehirn outsources the handling of personal information, in whole or part, within the scope necessary to achieve the purpose of use.
  • Where it is necessary to protect the life, health, or property of an individual, and it is difficult to obtain the consent of the individual concerned or the parent/guardian of the individual.
  • Where it is particularly necessary for the improvement of public health or the promotion of the sound growth of children or students, and it is difficult to obtain the consent of the individual concerned or the parent/guardian of the individual.
  • Where it is necessary to cooperate with a national or local government, or a person entrusted by such government in executing its legal duties, and obtaining the consent of the individual concerned may hinder the execution of the said duties.
  • Where personal information is provided as a result of business transfer due to a merger or other reasons.
12. Access Analysis
The website and some of its services operated by Gehirn use Google Analytics to collect access data. Google Analytics uses cookies to collect information about you without identifying you personally. To find out more about how data is collected and processed by Google Analytics, please refer to the following URL.
https://policies.google.com/technologies/partner-sites
13. Responding to Comments and Inquiries
Gehirn will respond appropriately, in accordance with the provisions of the law and regulations, to any comments or inquiries regarding the disclosure, correction, suspension of use (introduction of products and services), erasure or other handling of personal information.
14. Contact Us
If you have any questions about Gehirn’s Privacy Policy, please contact us at the following address.

Gehirn Inc., Mgmt Dept.
7F Seki BLDG., 1-3-6 Kudankita, Chiyoda-ku, Tokyo, 〒 102-0073 Japan
Supplementary Provision
The Privacy Policy will come into effect from August 30th, 2019.