개인정보 처리방침 / Privacy Policy

이 법적 문서의 한국어 정식 번역은 아직 준비되지 않았습니다. 전문 법률 번역이 완료될 때까지 아래에 영어 원문(정본)을 표시합니다.

This Privacy Policy explains how Waholi (operated by benstaydev — the "operator") handles personal information in connection with the Waholi job-advertising board, in accordance with Japan's Act on the Protection of Personal Information (個人情報保護法, "APPI"). Waholi is a job-advertising platform (募集情報等提供事業), not a placement service.

1. What we collect

• Account data: email address, hashed password (argon2id — we never store the plain password), chosen role (seeker / employer), language preference, email-verified status, and (if you sign in with Google) a Google account identifier and the email Google returns.
• Seeker profile: display name, declared nationality, declared visa type, declared Japanese level, short bio, and location preference. These are self-declared — we do not verify them.
• Employer profile: company name, description, address, prefecture/city, contact email, contact phone, optional website and logo.
• Applications: the job applied to, your optional message, and a snapshot of your declared visa type and Japanese level at the time you apply.
• Résumé files: only if and when the résumé-upload feature is enabled. At MVP it is off, and no résumé file is collected. When enabled, résumés are stored as access-controlled files (not public).
• Activity & technical data: saved jobs and job alerts you create. For security and abuse-prevention, your IP address is processed transiently — used as a short-lived in-memory key for rate-limiting and sent to Google reCAPTCHA on protected forms. We do not store IP addresses in our application database. Standard web-server access logs may record request metadata (including IP) for a short period per ordinary server operation.

2. Why we use it (purpose of use — 利用目的)

We use personal information only to operate the job-advertising board, specifically to:

• create and secure your account, authenticate you, and verify your email;
• display job advertisements and let seekers search, save, and apply;
• deliver an application (with the declared snapshot) to the employer you apply to;
• send transactional email (verification, password reset, application received, status updated, listing expiring) and — only if you opt in — job-alert email;
• moderate content against our policy, handle reports, and prevent fraud and abuse (rate-limiting and bot checks);
• respond to enquiries and comply with law.

We do not use your data for algorithmic matching, candidate ranking, AI résumé screening, "recommended candidates," or profile-derived alerts — these are excluded by design. We do not sell personal information.

3. Disclosure to employers (the key consent point)

When you apply to a job, you disclose to that one employer: your application message, the declared visa/Japanese-level snapshot captured at apply time, and your declared profile details — your display name, nationality, visa type, Japanese level, and location preference. This sharing happens because, and at the moment, you choose to apply: submitting the application is your consent to that disclosure. We state this in this Policy and on your profile page (where it notes your declared details are shared with an employer only when you apply). We do not disclose your details to employers you have not applied to, and we do not broadcast applications. If résumé upload is enabled and you attach a résumé to an application, that résumé is likewise disclosed to that employer.

Employers may use the application data they receive only to evaluate that application and contact you about it, and must handle it in accordance with APPI (see the Terms). Once an employer has lawfully received your application, the operator cannot retract what the employer already holds.

4. Third-party processors (委託先・サービス提供者)

We use the following service providers to operate Waholi. Each receives only the data needed for its function:

• Sakura Internet (さくらインターネット) — hosting (Japan). The application and database run on a Sakura VPS in Japan; personal data is stored in Japan.
• Amazon Web Services — Amazon SES — transactional & alert email (Tokyo, ap-northeast-1). Recipient email addresses and message content are processed to send mail. Configured in the Tokyo region to keep email processing in Japan.
• Google — reCAPTCHA — bot/abuse prevention. On certain forms, Google reCAPTCHA processes technical signals and your interaction to distinguish humans from bots, subject to Google's privacy policy.
• Google — Google Sign-In (OAuth) — optional login. If you choose to sign in with Google, Google authenticates you and returns a Google account identifier and your email, subject to Google's privacy policy.
• Stripe — billing — only if/when paid employer features are enabled. If an employer purchases a paid feature, Stripe processes the payment. Card details are handled by Stripe, not stored by Waholi. (No billing is active at launch.)

For operational error alerts we may send PII-redacted error information to a Slack channel used only for ops monitoring; these alerts must never carry application or résumé content.

5. Cross-border transfer (外国にある第三者への提供)

Our default is to keep personal data in Japan (hosting and email processing are in Japan, the latter in the Tokyo region). Some providers above (Google for reCAPTCHA / Sign-In, Stripe for billing) are operated by entities outside Japan and may process limited data outside Japan under their own safeguards. We do not transfer personal data to third parties outside these listed providers.

6. Retention

We keep personal information only as long as needed for the purposes above or as required by law. Our target retention periods are:

• Account & profile data: kept while your account is active; our policy is to delete/anonymize accounts after 24 months of inactivity (no login). You can request deletion at any time (§7).
• Applications & declared snapshots that an employer lawfully received: target retention of up to 12 months after the application; dissociated from a deleted seeker account as described in §7.
• Job-alert consent records (that you opted in, and when): kept while the alert is active and for at least 1 month after the last alert email sent for it (per 特定電子メール法 guidance) — unless you delete your account or the alert sooner, which removes them earlier (§7).
• Web-server access logs (may include IP): about 90 days for abuse prevention, then rotated. Rate-limit state is in-memory only and not persisted. The operational action log (audit_log) keeps only non-identifying action records.

These are the operator's stated target periods and current policy; automated enforcement of the dormancy and application windows is being implemented, and in the meantime you may exercise deletion at any time via §7. We retain data longer only where law requires (e.g. tax/accounting records for paid billing), and may adjust these periods to comply with law.

7. Your rights and deletion (data-subject requests / DSAR)

Under APPI you may request access to, correction of, suspension of use of, or deletion of your personal information. You can:

• edit your profile and account settings directly in the app;
• contact us at support@waholi.jp for any access / correction / suspension / deletion request (seeker or employer). This is the guaranteed channel and always available; we action verified requests as required by law;
• delete your seeker account yourself where the self-service deletion flow is enabled (the DELETE /api/seeker/account endpoint). This in-app self-delete is feature-gated and may not be available at launch — when it is unavailable, use the support channel above. When it runs, it removes your seeker profile, saved jobs, job alerts, sessions, federated-login links, and any résumé file, and anonymizes your account record (your email is scrubbed and the account is disabled).

We are honest about the limit on deletion: because an employer may already have lawfully received an application from you, those received application messages/snapshots are retained for the stated retention window and dissociated from your account, then purged on schedule — we cannot promise instant erasure of what an employer already holds.

Deletion propagates to backups on the next backup cycle (not instantaneously). We will respond to verified requests within a reasonable period as required by law.

8. Security

We protect personal information with measures including: argon2id password hashing; httpOnly/Secure/SameSite session cookies with per-session CSRF protection on every state-changing action; object-level authorization (you can only access your own data; an employer sees only their own listings' applicants); rate limiting; user content stored and rendered as escaped plain text (no HTML/scripts); access-controlled, non-public file downloads (when résumés are enabled); and secrets kept out of source control. No system is perfectly secure. If a reportable breach occurs, we will follow our breach-response process and applicable APPI notification duties.

9. No minors

Waholi is for adults. You must be at least 18. Working-holiday visas are issued only to adults, and Waholi is not intended for, and does not knowingly collect personal information from, anyone under 18. If we learn we have collected data from a minor, we will delete it.

10. Cookies

We use a strictly-necessary session cookie to keep you logged in and to protect against CSRF. Third-party providers above (e.g. Google reCAPTCHA / Sign-In) may set their own cookies when you use those features, subject to their policies.

11. Operator, changes and contact

• Personal-information handling business operator (個人情報取扱事業者): benstaydev (Waholi). Registered operator name and postal address: <operator legal name & postal address — MUST be filled before this Policy is published>. (Publishing this Policy without the operator's real name and address would not satisfy APPI Art. 32 — this is a hard launch prerequisite, tracked with the legal review and the same registered details used for the email sender identity.) The operator's name and address are also disclosed on request under APPI.
• Contact for privacy matters, the publication of retained-personal-data details, and data-subject (access / correction / suspension / deletion) requests: support@waholi.jp.
• We may update this Policy; the "last updated" date above reflects the current version.

Waholi is a job-advertising platform. We do not verify the identity, legitimacy, or legal/visa status of employers or job seekers — verify independently.