Privacy Policy for Recruitment Activities

1. Collection of Personal Information

The definition of personal information used in this policy is the definition outlined in Article 2 (1) of the Act on the Protection of Personal Information (Act No. 57 of 2003, “Personal Information Protection Act”). In order to fulfill the purpose defined in Section 2, Mercari Group collects applicants’ personal information, including the following, from applicants, recruitment agencies, and third parties subcontracted for background checks, etc.

1. name, age, address, date of birth, phone number, email address, educational background, professional background, certifications, current income, expected income, and other information;
2. any information included in documents the applicant provides to Mercari Group when applying to recruitment activities, including but not limited to resume, curriculum vitae, application form, or survey;
3. any communication between Mercari Group and the applicant in any form, such as face-to-face, email, or phone calls (including but not limited to communication regarding interviews);
4. any information Mercari Group collects during screening procedures such as background checks and reference checks in the candidate screening process; and
5. the applicant’s history of application to and participation in recruiting activities, as well as screening results.

The personal information collected by Mercari Group may include information related to the applicant’s gender, health, nationality, etc. (collectively, “sensitive information”). Provision of sensitive information is optional, and Mercari Group will only collect sensitive information with the applicant’s prior consent. Sensitive information collected from applicants will only be used to the extent necessary for improving Mercari Group’s recruitment processes, including enhancement of diversity in recruitment, ensuring suitability of work (assignments, etc.) and health in Mercari Group, and supporting applicants in obtaining necessary visas and/or work permits.

2. Purpose of Use of Personal Information

Mercari Group uses personal information collected from applicants to the extent necessary for recruiting activities at Mercari Group. This information is used for

1. evaluating the qualifications of applicants in recruitment screenings at Mercari Group (including background checks, reference checks, and any other screening procedures);
2. improving Mercari Group’s recruitment processes, including enhancement of diversity in recruitment;
3. ensuring suitability of work (assignments, etc.) and health in Mercari Group;
4. supporting applicants in obtaining necessary visas and/or work permits;
5. providing information to applicants regarding employment opportunities, events, etc. by Mercari Group;
6. improving Mercari Group’s employment opportunities, events, etc., and measuring satisfaction;
7. contacting applicants regarding recruitment activities;
8. managing information about applicants; and
9. other purposes incident to recruitment activities, such as calculating statistics for use in future hiring plans.

With the exception of cases recognized by law, Mercari Group will not use the personal information of applicants for purposes other than the above. In the event that Mercari Group uses personal information of applicants to a level exceeding the extent necessary to fulfill the purposes above, Mercari Group will only do so after obtaining the applicant’s consent.

3. Provision of Personal Information to a Third Party

Mercari Group will not provide the personal information of an applicant to a third party without obtaining the consent of the applicant, except if

1. pursuant to laws and regulations;
2. it is necessary in order to protect a human life, body, or fortune, and when it is difficult to obtain the applicant’s consent;
3. it is particularly necessary in order to enhance public health, and when it is difficult to obtain the applicant’s consent; or
4. it is necessary to cooperate in work pursuant to laws and regulations performed by a national or local government organization or another party entrusted to do such work, and when there is a possibility that obtaining the applicant’s consent would interfere with the performance of those affairs.

The third parties Mercari Group provides information to may include third parties in foreign countries as defined in the Personal Information Protection Act.

4. Entrusting of Information to a Third Party to Handle Personal Information

Within the extent necessary to fulfill the purposes in Section 2, Mercari Group may entrust all or some of the handling of personal information to a subcontracted third party. In this case, Mercari Group will thoroughly examine the third party to determine that it meets the third party selection standards defined by Mercari Group, and execute a contract with the third party ensuring that all personal information will be suitably managed.The subcontracted third parties may include third parties in foreign countries as defined in Article 24 of the Personal Information Protection Act, such as overseas cloud service providers. In this case, Mercari Group may provide personal information only to the extent necessary to carry out the subcontracted work.

5. Joint Use of Personal Information

Within the extent necessary to fulfill the purposes in Section 2, Mercari Group jointly uses the collected personal information between companies in Mercari Group.

1. Information jointly used:
   • Personal information as set out in Section 1
2. Scope of parties using this information:
   • Mercari Group as set out in the introduction of the Policy, as well as its overseas subsidiarie
3. Purpose of joint use:
   • Mercari, Inc. (for details regarding inquiries, please see Section 9)
     Please check the following link for information on Mercari, Inc., such as its location and representative.
     https://about.mercari.com/en/about/company/

6. Management and Security of Personal Information

Mercari Group securely stores personal information collected from applicants in servers in an environment inaccessible to general users, and strives to prevent unauthorized access, loss, destruction, alteration, or leakage of data.

In the event that recruitment screening results in an applicant joining the company, Mercari Group treats the personal information collected from that applicant as employee information, and stores and manages the applicant’s personal information in accordance with Mercari Group’s internal regulations. In the event that an applicant does not join the company, Mercari Group stores the applicant’s personal information for a certain period of time to the extent necessary for the purposes of improving Mercari Group’s recruitment processes, providing information to applicants regarding employment opportunities and events by Mercari Group, etc.

7.Disclosure, Correction, and Suspension of Use of Personal Information

If an applicant requests that their personal information be disclosed (including disclosure of records stating to which third parties their data has been shared), edited, added to, deleted, erased, or that its use or provision to third parties be suspended (collectively, “disclosure, etc.”), Mercari Group will respond to that request appropriately in accordance with relevant laws and regulations. If you wish to request disclosure, etc. of use of your personal information, please contact the person in charge of this at Mercari Group via the contact information in Section 9.

Applicants may not request disclosure, etc. of use of personal information that meets either of the conditions below:

1. Information in relation to the screening process at Mercari Group
2. Information in relation to evaluation at Mercari Group, such as the results of screening

If an applicant wishes to correct any personal information that they sent to Mercari Group using the registration form, they may do so by re-sending the registration form with the corrected personal information.

8. Changes to this Policy

Mercari Group strives to improve this Policy appropriately. This Policy may be updated to reflect changes in laws and regulations, the necessity of recruitment activities, etc.

9. Inquiries

Inquiries regarding this Policy, including Section 7, should be sent to Mercari Group using the contact information below.

18F Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku, Tokyo 106-6118 Address to: Hiring Representative, Mercari, Inc.
Email address: jobs(at)mercariapp.com
(Please replace (at) with the @ symbol.)

1. Type, Purpose, and Legal Basis for Collecting Personal Data

The main source of personal data is your application with us. In case a recruitment agency is involved in the recruitment process, we may have received the personal data from the agency.

For the purposes of the Applicable Laws in which the concepts of “Controller” and “Processor” are defined, we are the “Controller” of personal data described in this Global Privacy Policy.

We have set out below a description of all the ways we plan to process the various categories of your personal data. We also describe the legal basis under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), etc. for each processing of personal data as a reference. Please note that the legal basis may vary depending on the jurisdiction, and if the legal basis specified in the table below does not apply in your jurisdiction, we will process your personal data based on an alternative legal basis permitted under the Applicable Laws, such as obtaining your consent to this Global Privacy Policy or obtaining your separate consent. 

2. Processing Security Measures

We make efforts to keep your personal data in accurate and up-to-date condition, and take the necessary and appropriate security control measures in order to protect your personal data against unauthorized access, tampering, leakage, loss, and damage.

3. Provision of Personal Information to a Third Party

We may provide your personal data to the following persons and entities in order to achieve the purposes of processing the personal data: 

• Mercari, Inc. (US), Merpay, Inc., Mercoin, Inc., and our other affiliated companies;
• Entities that provide us with infrastructure to conduct the Recruitment Activities. This includes not only online services, translation tools, and other infrastructure providers, but also immigration consultants, moving companies, and other third parties involved in processing visa and work permit applications, relocations, and other services;
• Counterparties of substantial business transactions, such as a sale or transfer of company assets, merger, or consolidation; and
• Third parties to which we disclose your personal data in order to comply with applicable laws and regulations; handle legal processes and litigation; respond to requests from public authorities; address national security, law enforcement, and other issues of public concern; protect our rights, or the rights of the Applicants, or other third parties; seek available remedies; investigate fraud; protect our business, etc.

When we provide your personal data to third parties, we put appropriate measures in place in accordance with the Applicable Laws.

4. International Transfer

We may transfer your personal data to countries other than your country including Japan or the United States, which may have a lower level of data protection than your country. When providing personal data to third parties outside your country, we take the necessary measures therefor, such as obtaining consent and concluding data transfer agreements, etc., in accordance with the Applicable Laws. 

In the event that the GDPR applies to the processing of your personal data, we will protect your personal data based on an adequacy decision regarding the transfer of your personal data to Japan and other countries where an adequacy decision has been given or by entering into Standard Contractual Clauses (Article 46(2) of the GDPR) regarding the transfer of your personal data outside the European Economic Area. If you would like to review the Standard Contractual Clauses, please contact us as set out in Section “10. Inquiries” below.

5. Retention Period

We retain your personal data for a standard period of five years, including for the purpose of considering potential future job opportunities that may be relevant to you. If there has been no contact with you during this five-year period, we will delete your personal data. If you choose to object to the retention of your personal data for future job opportunities, we will delete your personal data immediately following the completion of the Recruitment Activities. However, we will retain your personal data beyond such period in cases where we are required to do so by the Applicable Laws.

6. Your Rights

In some countries, you have certain rights as a data subject under the Applicable Laws. To the fullest extent permitted by the Applicable Laws, you may have the following rights:

• The right to access your personal data;
• The right to correct your inaccurate or incomplete personal data; 
• The right to delete your personal data;
• The right to restrict the processing of your personal data; 
• The right to object to our processing of your personal data on the basis of our legitimate interest;
• The right to withdraw your consent;
  *Please note that the legality of the processing of your personal data based on consent granted before such withdrawal of consent is not affected by such withdrawal of consent.
• The right to refuse direct marketing or to refuse profiling done for that purpose if your personal data is being processed for direct marketing purposes; and
• The right to data portability. 

If you or your agent wishes to exercise your rights in accordance with the Applicable Laws, please contact us as set out in Section “10. Inquiries” below.

In addition, you may have the right to lodge a complaint with the relevant supervisory authority under the Applicable Laws. 

7. Cookies

We use cookies and other similar mechanisms (collectively, “cookies”) to collect certain data about you while you are browsing websites in order to distinguish you as a user for the duration of your visit and when you return to our websites.

8. Contact Information

If you would like to exercise your rights under the Applicable Laws; if you have comments, questions, or concerns; or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact us using this contact form.

9. Changes

We will review our processing of personal data as appropriate and may revise this Global Privacy Policy. If we make any revisions, we will inform you by displaying them on our website, by other appropriate means, or by notifying you directly.

10. Inquiries 

For inquiries regarding personal data, please contact the below or in the contact form in Section 8. “Contact Information”:

18F Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku, Tokyo 106-6118

Address to: Hiring Representative, Mercari, Inc.
Email address: jobs(at)mercariapp.com
(Please replace (at) with the @ symbol.)