Privacy Policy

Last Modified: October 25, 2025

1. About This Policy
Kikutora Special Risks K.K. (“we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your information (“Personal Data”). Processing includes the collection, recording, organization, storage, adaptation, retrieval, use, disclosure, erasure, or destruction of Personal Data.

This Privacy Policy applies to all users of our website, platforms, and services, including applicants, vendors, suppliers, partners, and customers ("you" or "your").

2. Personal Data We Collect
Personal Data means any information that identifies you or could be used to identify you, such as name, address, phone number, email address, date of birth, occupation, government-issued identifiers, financial information, or images.

We may collect Personal Data in the following ways:

Directly from you: when you use our website, purchase our services, apply for a role, or otherwise interact with us.
Automatically from your device: including IP address, browser type, operating system, session data, geographic location, cookies, and device information.
From third parties: such as vendors, service providers, professional advisers, regulators, or authorized representatives.
You may also provide us with information about third parties. In doing so, you confirm that you have their consent to share such information with us.

3. How We Use Your Personal Data
We process Personal Data for the following purposes:

To provide and deliver our services and solutions.
To verify your identity.
To manage our business relationship with you.
To process payments and comply with tax or accounting obligations.
To handle inquiries, applications, complaints, or feedback.
To detect, prevent, and investigate fraud or misuse.
To comply with applicable legal or regulatory requirements.
To improve our services and security.
For marketing communications (digital or conventional), subject to your right to opt out at any time.

We rely on legal bases such as your consent, contractual necessity, legal obligations, and our legitimate interests when processing your Personal Data.
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4. Sharing Your Personal Data
We may share your Personal Data with:

Third-party service providers and agents engaged to perform functions on our behalf.
Professional advisers, regulators, or law enforcement when required.
Affiliates or partners where necessary to provide our services.
We will not sell or rent your Personal Data to third parties.

5. Cross-Border Data Transfers
Your Personal Data may be transferred to and processed in countries outside your place of residence. We will take appropriate measures to ensure your Personal Data is handled securely and in accordance with this Privacy Policy.

6. Your Rights
Depending on applicable laws, you may have the right to:

Access, correct, or update your Personal Data.
Withdraw consent to our processing of your Personal Data.
Request deletion of your Personal Data, subject to legal and contractual obligations.
Opt out of marketing communications.

Requests may be submitted in writing or by email (see Section 11). We may require reasonable time and verification before fulfilling your request.

7. Retention of Data
We retain Personal Data for as long as necessary to provide services, comply with legal obligations, resolve disputes, or enforce agreements. When no longer needed, we securely delete or anonymize your Personal Data.

8. Data Security
We maintain appropriate technical, organizational, and physical safeguards to protect your Personal Data. However, no system or method of transmission over the internet can be guaranteed 100% secure.

In the event of a data breach, we will notify you as required and take steps to minimize any potential impact.

9. Links to Third-Party Sites
Our website may contain links to external websites. We are not responsible for the privacy practices or content of those sites, and we encourage you to review their privacy policies.

10. Complaints
If you have concerns about how we handle your Personal Data, please contact us (see Section 11). We will address your concerns promptly and confidentially. If unresolved, you may contact the relevant regulatory authority in your jurisdiction.

11. Contact Information
KIKUTORA SPECIAL RISKS K.K.
1 Hachimancho, Ichigaya, Shinjuku-ku, Tokyo, Japan
Email: info@kikutorasr.com

12. Updates to This Policy ‍

We may update this Privacy Policy from time to time. Updates will be posted on our website with a revised effective date. Continued use of our services after updates take effect indicates your acceptance of the revised Privacy Policy.

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General Terms and Conditions of Service

Last Modified: October 25, 2025

Effective Date: October 25, 2025

These Terms govern the provision of all consulting and advisory services (“Services”) provided by Kikutora Special Risks K.K. (“Kikutora” or “Consultant”) to the Client identified in the applicable Letter of Engagement. These Terms apply to and bind the parties and their Affiliates, directors, officers, employees, contractors, and agents unless otherwise agreed in writing.

1. Definitions

“Affiliate” means an entity that controls, is controlled by, or is under common control with a party.
“Letter of Engagement” means the signed agreement, proposal, or document outlining Services, fees, and specific terms.
“Client” means the legal entity receiving Services, including its Affiliates, directors, officers, employees, and agents.
“Consultant” means Kikutora, including its Affiliates, directors, officers, employees, and agents.

2. Scope of Services

Services are provided as described in the relevant Letter of Engagement. Consultant performs such Services in a professional and diligent manner consistent with industry practices.

3. Fees and Payment

Fees and billing terms are defined in the Letter of Engagement.
Unless otherwise agreed, payment is due upon presentation of Consultant’s invoice.
Late payments may incur a 1.5% monthly interest or the maximum allowed by law.
Reasonable, pre-approved out-of-pocket and travel expenses for onsite work will be reimbursed by Client.

4. Confidentiality

4.1 Each party shall treat all Confidential Information as confidential and use it solely for the Services.

4.2 “Confidential Information” includes any non-public, proprietary, or sensitive information disclosed in any form.

4.3 Each party shall:

Take reasonable steps to protect confidentiality
Not disclose to third parties except necessary personnel
Notify the other party of unauthorized use or disclosure

4.4 Obligations do not apply to information that is public, known prior, independently developed, or legally required to be disclosed.

4.5 Upon termination or request, parties must return or destroy Confidential Information and certify destruction upon request.

5. Intellectual Property

Consultant retains ownership of all methodologies, tools, software, and materials used or developed. Deliverables are licensed to the Client for internal use only and may not be disclosed or transferred without written consent.

6. Client Responsibilities

Client shall:

Provide access to necessary personnel, systems, and information
Secure required authorizations or consents
Cooperate in good faith and act reasonably

7. Liability and Indemnity

Consultant’s liability is limited to fees paid.
Consultant is not liable for indirect or special damages.
Both parties indemnify each other for third-party claims due to misuse, legal breaches, or non-performance.

8. Termination

Either party may terminate with 14 days' notice if a breach is not cured. Client must pay for Services and approved expenses up to the termination date.

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9. Compliance and Ethics

Both parties must comply with all applicable laws. Consultant may withdraw if performing the Services would be illegal or violate obligations.

10. Governing Law and Dispute Resolution

These Terms are governed by Japanese law. Disputes will be settled by binding arbitration under JCAA rules in Tokyo, in English, with one arbitrator.

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11. Miscellaneous

These Terms and the Letter of Engagement constitute the entire agreement. Amendments require written agreement. No assignment without consent. Invalid provisions do not affect the remainder.

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