Privacy Policy

1. About This Policy

本方針について

Exentive G.K. ("Exentive," "we," "us") is a Tokyo-based executive search and recruitment firm licensed under Japan's Employment Security Act. We are committed to handling all personal information responsibly and in full compliance with Japan's Act on the Protection of Personal Information (個人情報の保護に関する法律, "APPI") and its 2022 amendments.

This policy explains what personal information we collect, why we collect it, how we use and protect it, and the rights you have in relation to that information. It applies to two groups:

• Candidates: individuals who contact us regarding job opportunities, submit resumes, or otherwise engage with us in connection with placement services.
• Clients: companies and their authorised representatives who engage Exentive to assist with recruitment mandates.

If you have any questions about this policy or how your information is handled, please contact us using the details in Section 8.

2. Information We Collect from Candidates

求職者から収集する情報

When you engage with Exentive as a candidate, we may collect the following categories of personal information:

• Contact details: name, email address, telephone number, current address.
• Professional background: resume/CV, employment history, educational qualifications, professional licences or certifications.
• Compensation information: current and expected salary, bonus structures, and benefits preferences (provided voluntarily by you).
• References: names and contact details of professional references you provide.
• Sensitive personal information (要配慮個人情報): where relevant to a role (e.g., language proficiency level, nationality for visa eligibility) and only with your explicit consent.

We collect this information directly from you, from your resume or application materials, and occasionally from third parties such as professional reference providers, only with your prior consent.

3. How We Use Candidate Information

求職者情報の利用目的

We use your personal information strictly for the following purposes (利用目的):

• Evaluating your suitability for specific roles and presenting your profile to relevant client companies, always with your prior consent before any disclosure.
• Communicating with you about opportunities, the status of your candidacy, and our services.
• Maintaining internal records of placement activities as required by our recruiting licence.
• Complying with legal obligations, including reporting requirements under Japan's Employment Security Act.

We will not use your information for any purpose beyond those listed above without first notifying you and, where required, obtaining your consent.

4. Disclosure of Candidate Information to Third Parties

第三者への情報提供

We will not share your personal information with any client company or third party without your explicit prior consent. Specifically:

• Before presenting your profile to a prospective employer, we will describe the opportunity to you and obtain your agreement to proceed.
• We do not sell, rent, or trade personal information under any circumstances.
• We may share information with trusted service providers (e.g., secure cloud storage providers) who process data solely on our behalf and are contractually bound to appropriate confidentiality and security obligations.
• We may disclose information where required by law, a court order, or a regulatory authority.

All third parties who receive personal information from Exentive are subject to appropriate data handling obligations consistent with APPI.

5. Candidate Rights Under APPI

APPI に基づく求職者の権利

You have the following rights with respect to your personal information held by Exentive:

• Access (開示請求): You may request a copy of the personal information we hold about you.
• Correction (訂正): You may request that inaccurate or incomplete information be corrected.
• Deletion (削除): You may request deletion of your information where it is no longer necessary for the purposes for which it was collected, subject to any legal retention obligations.
• Suspension of use (利用停止): You may request that we stop using your information in certain circumstances.
• Withdrawal of consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us using the details in Section 8. We will respond within a reasonable time and in accordance with APPI requirements.

6. Information We Collect from Clients

クライアントから収集する情報

When your company engages Exentive to provide recruitment services, we collect personal information relating to your authorised representatives and contacts, including:

• Business contact details: name, job title, corporate email address, telephone number.
• Mandate information: job descriptions, role requirements, organisational details, and hiring criteria shared with us in the course of an engagement.
• Feedback and evaluation: information you share regarding shortlisted candidates during the interview and selection process.

This information is collected to perform our recruitment services and to maintain our business relationship with you. It is held and used in accordance with the contractual terms agreed between Exentive and your company.

Please note that APPI primarily governs the handling of personal information of natural persons. Client contacts whose personal data we hold are entitled to the same access and correction rights described in Section 5.

7. Data Security and Retention

情報の安全管理と保存期間

Exentive takes the security of personal information seriously and implements appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration.

Personal information is retained only for as long as necessary to fulfil the purposes set out in this policy, or as required by applicable law. Candidate records are typically retained for a period of up to three (3) years from the date of last contact or placement, after which they are securely deleted. Shorter or longer retention periods may apply based on legal requirements or specific circumstances.

Where personal information is processed or stored outside Japan, we ensure that appropriate cross-border transfer safeguards are in place consistent with APPI Article 24 requirements.

8. Contact and Complaints

お問い合わせ・苦情の申し出

If you have questions about this policy, wish to exercise your rights, or have a concern about how your personal information has been handled, please contact us:

We will acknowledge your enquiry promptly and aim to resolve any concerns within a reasonable timeframe. If you are not satisfied with our response, you may lodge a complaint with Japan's Personal Information Protection Commission (個人情報保護委員会, PPC).

9. Changes to This Policy

本方針の変更

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Any material changes will be communicated via our website. The effective date at the top of this document will be updated accordingly. Continued use of our services following any such update constitutes acceptance of the revised policy.