1. Collection of Personal Information
We collect information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we will collect, and have collected in the last twelve (12) months, the following categories of Personal Information from our consumers:
|A. Identifiers.||Real name, postal address, company name, department name, job title, unique personal identifier, online identifier, internet protocol address, email address or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Name, address, and telephone number.|
|C. Internet or other electronic network activity information.||Browsing history, search history, and information regarding a consumer’s interaction with the internet / websites.|
We obtain your Personal Information listed above directly or indirectly from you in our relationship with you, including, without limitation, when you: (i) access our webpage (http://tomorrowaccess.com/); (ii) receive services from us; and (iii) communicate with us for inquiries or contact us.
2. Purposes of Use of Personal Information
We may use the Personal Information for one or more of the following business purposes indicated below:
- to provide the consulting services and other services to consumers;
- to respond to inquiries from consumers;
- to perform, monitor and enforce contracts concluded between the consumers and the Company;
- to provide notification of information related to the consulting services and other services or notification of other related information to consumers (including to notify consumers of changes to the services); and
- to serve advertisements to consumers on our website and/or third-party websites and applications.
We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.
3. Sharing or Disclosure of Personal Ianformation
We may share or disclose your Personal Information to a third party for business or commercial purposes.
When we disclose Personal Information to service providers for business or commercial purposes, we enter into a contract that describes such purposes and requires the service providers to both keep that Personal Information confidential and not use it for any purpose other than performing the contract.
In the preceding twelve (12) months, we have shared or disclosed Personal Information to the following categories of third parties for business or commercial purposes:
- Service providers, including CRM tool vendors and advertising companies.
If you are a Japanese resident, we will only provide your Personal Information to third parties (including third parties outside of Japan) after satisfying the requirements stipulated in the Act on the Protection of Personal Information of Japan (the “APPI”).
4. Details of System for Obtaining Personal Information and Security Control Measures
In handling Personal Information, we will take appropriate security control measures and establish a system that is necessary and appropriate for the protection of Personal Information. We will also continue to provide guidance and education to all employees regarding the protection of Personal Information.
If you want to know any further information about our system for obtaining Personal Information and our security control measures, please contact us as described in Section 8 (Contact Us) below.
5. Sales of Personal Information
We have not sold any Personal Information in the preceding twelve (12) months.
6. Your Rights and Choices under the Applicable Law
Depending on your jurisdiction, in accordance with applicable law, you may have several rights in relation to our processing of your Personal Information, which may include requesting access to, correcting or deleting your Personal Information. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from us.
If you are a California resident, the California Consumer Privacy Act of 2018 (the “CCPA”) provides consumers who are residents of California with specific rights regarding Personal Information. The following parts in this Section describe your CCPA rights and explain how to exercise such rights.
（1）Access Right to Specific Information
You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your Personal Information over the past twelve (12) months from the time of your request. Once we receive and confirm your verifiable consumer request, we will disclose any or all of the following information to you:
- The categories of Personal Information we collected about you;
- The categories of sources for the Personal Information we collected about you;
- Our business or commercial purposes for collecting or selling that Personal Information;
- The categories of third parties with whom we share or sell that Personal Information;
- The categories of Personal Information sold by each third party who sold Personal Information;
- The categories of Personal Information disclosed for business or commercial purposes; and
- The specific pieces of Personal Information we collected about you.
As stated above in Section 5 (Sales of Personal Information), we have not sold any Personal Information in the preceding twelve (12) months.
（2）Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise other rights provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with legal obligations; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We have not sold and will not sell any Personal Information collected from consumers.
We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
（5）Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 8 (Contact Us).
Only you, or a natural person or business entity registered with the California Secretary of State to conduct business in California that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative thereof (i.e., passports, driver’s licenses, etc.); and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.
If you are a Japanese resident, you have the right to make a request for notification of purposes of use, disclosure, correction, suspension of use, suspension of provision to a third party, deletion, etc. of Personal Information, etc., based on the provisions of the APPI. We will promptly respond to such requests to the extent that we are obliged to do so under the APPI and other laws and regulations, after confirming that the request is made by yourself. When making a request, please send the request to the contact details listed in Section 8 (Contact Us) below, with your identification documents attached thereto.
We will review and improve the contents of the above items regarding the handling of your Personal Information as appropriate. When changes are made to this Policy, an update notice will be posted on our website and will be effective as of the date posted.
If you have any questions or comments about this Policy or the ways in which we collect and use your information described above, or wish to exercise your rights described in Section 6 (Your Rights and Choices under the Applicable Law), please do not hesitate to contact us at: