MotiTune Privacy Policy
Attuned K.K. CEO: Casey Wahl VORT Akihabara IV 2F 1-7-8 Kanda Sudacho, Chiyoda-ku, Tokyo 101-0041 Japan
Attuned K.K. (the "Company") provides "MotiTune" (the "Service"), a cloud-based service that presents questions to the Company's customers (the "Customers") and enables Customers themselves to analyze and utilize the results of their responses for purposes such as self-understanding and career development. The Company respects the privacy of Customers and handles Personal Information appropriately and with due care.
1. Relationship to Other Policies and Terms
The Company handles Personal Information in accordance with: • this MotiTune Privacy Policy; and • the Company's internal information security and privacy policies, as updated from time to time. This Privacy Policy should be read together with the MotiTune Terms of Service. In the event of any inconsistency, the Terms of Service govern contractual matters, and this Privacy Policy governs privacy-related matters.
2. Definitions
As used in this Policy, the following terms have the meanings set forth below, unless otherwise specified. Personal Information Information relating to a living individual that can identify a specific individual (including name, contact information, identifiers, or other descriptions), or information that can be easily collated with other information to identify a specific individual. Customer Data All information provided, input, transmitted, uploaded, or generated by a Customer in connection with the Service, including survey responses, answers to questions, text data, conversation logs, metadata, settings, account information, and, where applicable, audio data. Outputs Analysis results, scores, reports, visualizations, feedback, and other deliverables generated or provided through the Service. Statistical Information Information created by processing and aggregating Customer Data so that no individual or specific Customer can be identified.
3. Privacy Contact
The Company does not appoint a dedicated Data Protection Officer. For all inquiries regarding Personal Information, please contact: Privacy Contact: Casey Wahl (CEO) Company: Attuned K.K. Email: team@attuned.ai Address: VORT Akihabara IV 2F 1-7-8 Kanda Sudacho, Chiyoda-ku, Tokyo 101-0041 Japan
4. Personal Information We Collect
Depending on how the Service is used, the Company may collect and process the following categories of Personal Information: a. Account and Contact Information Names, email addresses, and user identifiers. b. Service Usage and Technical Data Login records, access logs, IP addresses, browser or device information, timestamps, and usage metadata. c. Survey, Questionnaire, and Conversation Content Survey responses, free-text answers, chat or conversation content submitted to the Service, and related metadata. d. Support and Communications Inquiries, support requests, and communications with the Company. e. Website Data (Cookies and Analytics) Cookies, similar technologies, and analytics-related data collected through the Company's websites.
5. Purposes of Use
The Company uses Personal Information only to the extent necessary to: 1. Provide, operate, and maintain the Service; 2. Enable access control, authentication, and account management; 3. Generate Outputs; 4. Perform billing, payment processing, and contract administration; 5. Respond to inquiries and communicate with Customers; 6. Deliver newsletters and service-related announcements to Customers; 7. Improve, develop, and maintain the Service, including AI features, models, and algorithms; 8. Create and use Statistical Information for service improvement, research, marketing, public relations, and publication in media, provided that no individual or specific Customer can be identified; 9. Ensure security, prevent fraud or abuse, and comply with legal obligations. Note: The Service provides insights for human consideration and is not intended to be used as solely automated decision-making that produces legal or similarly significant effects on Customers.
6. Legal Basis for Processing (EEA/UK Customers)
For Customers residing in the EEA or the United Kingdom, the Company processes Personal Information based on one or more of the following legal bases, as applicable: • Performance of a contract; • Legitimate interests (such as service improvement, security, and prevention of abuse); • Consent, where required by applicable law.
7. Disclosure to Third Parties and Outsourcing
The Company does not sell Personal Information. Personal Information may be disclosed or entrusted to third parties only in the following cases: 1. Service Providers and Subprocessors Cloud hosting providers, security vendors, analytics providers, customer support tools, and other vendors necessary to provide and operate the Service, subject to appropriate contractual and security safeguards. 2. Legal Requirements Where disclosure is required by applicable laws, regulations, or lawful government requests. 3. Business Transfers In connection with a merger, acquisition, reorganization, or transfer of business.
8. International Data Transfers
Personal Information may be processed and stored in Japan and in other countries where the Company or its service providers operate. Where required by applicable law, the Company implements appropriate safeguards for cross-border data transfers.
9. Data Retention and Deletion
The Company retains Personal Information and Customer Data for as long as necessary to provide the Service and for legitimate business purposes. • Personal Information and Customer Data are not automatically deleted upon termination of the Individual Agreement. • Deletion or anonymization is performed only upon an explicit written deletion request from the Customer, within a reasonable and operationally feasible period. • The Company may continue to retain Personal Information or Customer Data where necessary for legal compliance, dispute resolution, audits, security, backups, or other legitimate business purposes. • Statistical Information may be retained indefinitely.
10. Customer Rights
Customers may have rights under applicable law to request access, correction, addition, deletion, or restriction of use regarding their Personal Information. Customers may submit such requests directly to the Company. Please direct requests to the contact details set out in this Privacy Policy.
11. Security Measures
The Company implements reasonable and appropriate technical and organizational measures to protect Personal Information against unauthorized access, loss, destruction, tampering, or leakage, including encryption in transit and at rest (such as SSL/TLS), access restrictions, and internal policies. However, complete security cannot be guaranteed.
12. Cookies and Analytics
The Company's website may use cookies to improve usability and analyze usage. Where cookies are linked to identifiable information, they may be treated as Personal Information. The Company may use analytics tools such as Google Analytics. For details, please refer to: https://policies.google.com/technologies/partner-sites The Company's website also uses Leadfeeder's company identification tool (loaded via sc.lfeeder.com) for business-to-business marketing purposes. It uses the cookies "_lfa" and "_lfa_*" (retention period: 1 year) to identify visiting companies. Some marketing or analytics vendors may provide opt-out mechanisms, such as: https://app.retention.com/optout
13. Amendments to This Privacy Policy
The Company may revise this Privacy Policy from time to time to reflect changes in the Service, legal requirements, or operational practices. Material changes will be notified by posting on the Service or by other appropriate means. Where required by applicable law, the Company will obtain Customer consent.
14. Inquiries
For questions, requests, or complaints regarding this Privacy Policy or the handling of Personal Information, please contact: Privacy Contact: Casey Wahl (CEO) Company: Attuned K.K. Email: team@attuned.ai Address: VORT Akihabara IV 2F 1-7-8 Kanda Sudacho, Chiyoda-ku, Tokyo 101-0041 Japan
Supplementary Provisions
Enacted: September 1, 2026