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Privacy Policy

Privacy Policy

In order to properly manage personal information, we will establish a personal information protection policy, construct a personal information protection management system, and strive for its implementation.

The term “personal information” as used in this policy shall mean any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you.

For the purposes of the EU General Data Protection Regulation 2016 (the “GDPR”) Djinn Mentor K.K. is the controller of personal information and responsible for our website (the “Site”).

Acquisition and Provision of Personal Information

  • When collecting personal information, the purpose of use is specified in advance, and to the extent necessary to achieve the purpose, it will be done after obtaining the consent of the person in an appropriate manner
  • When using personal information, we will take measures to ensure that it is not used beyond the extent that is necessary in order to achieve the specified purposes
  • If it is necessary to provide personal information, we will do so after obtaining the person’s consent

Purpose of using appropriate personal information

We will use your personal information for the following purposes:

  • To confirm your identity
  • To respond to your questions and provide related customer service
  • To detect and prevent fraud or other financial crime
  • To monitor and protect the security of our information, systems and network
  • For internal business intelligence purposes, to conduct research, product development and enhancement
  • With your explicit consent, to inform you of changes made to our Site and other services
  • With your explicit consent, to conduct marketing and commercial activities and to market relevant offers and promotions to you
  • To ensure that content from our Site is presented most effectively for you and your computer
  • To enable you to search for information on our Site
  • To improve our Site
  • To enable us to deliver our services to you


From time to time, we may send out emails for promotion purposes to announce our services, functions, researches, news, promotions, contests, and events. Our users may opt out of receiving these emails. We may use a third-party service provider to send out emails or to communicate smoothly with our users. For a smoother communication, we may share information, such as your email address, to the service provider for this limited purpose only.

Provision to third parties

Djinn Mentor does not provide personal data held to third parties without obtaining consent except in the following cases.

  • Based on the law
  • Our professional advisors such as auditors, accountants and lawyers, etc.
  • Companies that provide services to help us with our business activities, such as data storage, maintenance services, database management, and payment processing
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets
  • We may seek to acquire other businesses or merge with them—if a change happens to our business then the new owners may use your personal information in the same way as set out in this Policy

Where personal information relating to European based individuals is shared with a third party located in a non-EU country that has not received an adequacy decision by the European Commission, we rely on appropriate safeguards, such as the European Commission-approved Standard Contractual Clauses and EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, to transfer the data.

We are an international company headquartered in Japan. We also work or may work with third party service providers in different countries (for example, cloud providers, web hosting, help-desk software providers, payment processors). Therefore, your information may be transferred outside of the European Economic Area (EEA) and stored, or processed in other countries (including Japan and the United States of America), as part of our business operations. By using our Site, you consent to any transfer of your information to these locations. Where personal information is transferred from the European Economic Area to a country that has not received an adequacy decision by the European Commission, we rely on appropriate safeguards, such as the European Commission-approved Standard Contractual Clauses and EU-U.S. Privacy Shield Framework, to transfer the information.

Compliance with laws and regulations

In handling personal information, ChallengeHub observes Japanese laws and regulations that apply to the protection of personal information.

About the handling of sensitive personal information and sensitive information.

Djinn Mentor will only use information regarding disabilities (personal information requiring consideration) and health care, based on the consent of the person concerned, and ensuring proper operation. There is no acquisition, use or offer to a third party for any other purpose.

Safety measures

In order to protect personal information, Djinn Mentor will take the best and most appropriate measures to prevent improper access, loss, destruction, falsification, or divulgence of personal information.

Regarding HTTP Cookies

Like many websites, we use HTTP cookies to make our Site more convenient to our users.

HTTP cookies are small pieces of data that are transferred between a web server and your web browser, and stored on your computer or mobile device as a file.

We mainly use HTTP cookies for the following purposes.

  • When you use the service, you do not need to enter a password every time
  • On our Site and services, we use HTTP cookies to deliver personalized experiences to our users

You may disable the function of HTTP cookies by choosing the browser’s configuration. Please note that this may result in you not being able to use all or part of the services on our Site.

SSL (Secure Socket Layer)

ChallengeHub uses SSL (Secure Socket Layer) to encrypt the personal information that you provide in order to prevent external third parties from intercepting it.

Your European privacy rights

For European residents only. We collect and process personal information about you only where we have a legal basis for doing so under applicable data protection law, including under the GDPR. The legal bases will depend on the purpose for which we process your personal information. This means we collect and use your personal information only where:

  • We need it to provide the services, including to operate the Site, provide customer support and personalized features and to protect the safety and security of the Site
  • It satisfies a legitimate interest (which is not overridden by your rights and interests), such as for research and development, to market and promote the Site and to protect our legal rights and interests
  • You give us consent to do so for a specific purpose
  • We need to process your personal information to comply with a legal obligation
  • If you have consented to our use of personal information about you for a specific purpose, you have the right to change your mind at any time

We may use your email address to send you newsletter or marketing emails. We will ask for your consent in line with the applicable law when you first provide your personal information. You can opt out by following the unsubscribe instructions included in these emails, or you can contact us using the Contact page on our Site.

In certain circumstances, you have rights under the GDPR in relation to your personal information.

  • Request access to your personal information: you may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making
  • Request correction of your personal information: you may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you
  • Request erasure of your personal information: you may have the right to request that personal information held about you is deleted
  • Request restriction of processing your personal information: You may have the right to prevent or restrict processing of your personal information
  • Request transfer of your personal information: You may have the right to request transfer of personal information directly to a third party where this is technically feasible

Where you believe that we have not complied with our obligation under this privacy policy or European data protection law, you have the right to make a complaint to an EU Data Protection Authority, such as the Irish Data Protection Commission.

Dealing with complaints and consultations

Djinn Mentor respects the right of the person in relation to personal information, when asked by the person to disclose, correct, add or delete information, stop using it, delete it, and stop providing it to a third party. If there is a complaint or consultation, we will respond appropriately and promptly within the reasonable scope.

Continuous improvement of personal information protection management system

The personal information protection management system of Djinn Mentor will continuously improve as it adapts to the results of regular audits, the change of laws and regulations, and changes in the social environment.

Policy History

  • Enacted: 23 December, 2019