Directors Co., Ltd.
Takumi-Challenge Programme Privacy Notice
Supplementary to the Directors Co., Ltd. Privacy Policy
Directors Co., Ltd. (hereinafter referred to as “the Company”, “we”, “us”, or “our”) recognizes that it is a social responsibility to properly handle personal information and thoroughly protect personal information, and complies with laws and regulations, national guidelines, and other regulations related to the handling of personal information, including Japan's Act on the Protection of Personal Information (APPI) and India's Digital Personal Data Protection Act 2023 (DPDPA).
This notice applies specifically to the Takumi-Challenge programme (hereinafter, “the Programme”) and sets out how we handle the personal information of everyone who registers for or takes part in it, including candidates, referrers, and university contacts (hereinafter, “you” or “the individual”). It supplements, and does not replace, our general Privacy Policy referenced above, which continues to apply to our other business activities.
1. Acquisition of Personal Information
In connection with the Programme, the Company will identify the purpose of use of personal information and, within the necessary scope, acquire personal information through lawful and fair means. The categories of personal information collected through the Programme are as follows.
| Personal Information Collected | When Collected | Purpose |
|---|---|---|
| Name, email address, phone number, candidate type | Registration | Account creation, communication, login |
| University, degree, GPA, academic branch, year of study | Registration | Eligibility verification and initial screening |
| Resume | Profile submission | AI-assisted screening of project quality and skills |
| AI Interview responses and transcript | AI Interview stage | Assessing specificity, personal ownership, motivation maturity, depth of reflection, and role fit |
| Video and audio recording of the AI Interview | AI Interview stage | Human review, scoring, and quality assurance |
| Official university email or ID document | Eligibility verification | Confirming enrolment or graduation status |
| LinkedIn or GitHub URL (where provided) | Profile submission | Additional, optional professional or technical context |
| Innovation Challenge submission | Challenge stage | Human evaluation and judging |
| Evaluation scores and reviewer notes | All stages | Shortlisting and Candidate Evaluation Report preparation |
| Referral information | Referral activity | Referral tracking and any associated recognition |
| Website and communication usage data | Throughout | Channel attribution and platform performance measurement |
2. Purpose of Use of Personal Information
The Company uses personal information acquired through the Programme only to the extent necessary to achieve the following purposes.
- Registration, account management, and eligibility verification for the Programme
- AI-assisted screening, including the AI Interview, used to generate an initial score and shortlist; this score does not by itself determine advancement, and does not carry forward into later scoring stages
- Human review of AI Interview results, Innovation Challenge submissions, and final interviews
- Preparation of Candidate Evaluation Reports for internal review by the Directors hiring panel
- Where the candidate has given separate, explicit consent, sharing of shortlisted candidate profiles and Candidate Evaluation Reports with participating Japanese partner companies for interview scheduling and offer decisions (see Section 3)
- Communication regarding the individual's status at each stage of the Programme
- Contract conclusion, performance, and transaction management relating to any resulting internship or employment offer
- Provision of information about the Company's business, services, recruitment, and events
- Improvement of the Programme website, communications, and service content
- Where the candidate has separately opted in, retention in a talent pool for consideration in future Programme cycles
- Responses based on requests from laws and administrative agencies
Automated decision-making: AI-assisted tools contribute to initial scoring and ranking only. A human reviewer always examines low-confidence or flagged results, and a human panel always makes the final interview and offer decision. No decision to reject or advance a candidate is made by an automated system alone.
3. Provision of Personal Information to Third Parties
Except as permitted by the Personal Information Protection Act, the DPDPA, or other relevant laws and regulations, the Company will not provide personal information to third parties without the individual's consent. For the Programme specifically, this includes the following disclosure.
Where a candidate is shortlisted, and only where the candidate has given separate, explicit consent at the shortlisting stage, their evaluation scores and Candidate Evaluation Report may be shared with participating Japanese partner companies for the purpose of candidate evaluation, interview scheduling, and internship or employment offer decisions. This consent is not bundled with the general registration consent in Section 1. Raw AI Interview video is not shared with partner companies; only the transcript, scores, and reviewer notes are included in the Candidate Evaluation Report. A candidate who does not give this consent remains eligible for the Directors-internal hiring track but will not be considered for company-matching until consent is given.
The Company does not sell personal information, and does not pass candidate profiles to any third-party platform, including Talendy or GSJTI, as a matter of course. Any sharing beyond what is described in this notice will be separately disclosed to the individual.
4. Entrustment of Personal Information
The Company may outsource the handling of personal information to external parties within the scope necessary to achieve the purposes set out in Section 2, including cloud hosting providers, email delivery tools, and AI evaluation service providers. In such cases, the Company requires the entrusted party to properly manage personal information, and such parties process personal information only on the Company's instructions. A current list of Programme service providers handling personal information is available on request.
5. Cross-Border Transfer of Personal Information
Because the Company is based in Japan and the Programme actively invites participation from individuals based in India, personal information collected through the Programme may be processed and stored in both India and Japan, and may be accessed by authorised Company personnel and approved service providers in either country. The Company applies appropriate safeguards to any such cross-border transfer, consistent with the DPDPA and applicable Japanese requirements.
6. Video Data Safety Protocols
The AI Interview stage of the Programme involves recording the individual's voice and, where applicable, video. The following safeguards apply specifically to this category of personal information.
6.1 Consent Before Recording
Recording does not begin until the individual has given explicit, separate consent on a dedicated consent screen, distinct from general acceptance of the Programme terms of use and from the registration consent in Section 1. Individuals are informed before the interview starts that an AI system will ask the questions and generate an initial score.
6.2 Storage
Interview recordings and transcripts are stored on the Company's own infrastructure and are not stored with a third-party HR platform. Where an established external AI provider is used to generate a transcript or a score, data is sent to that provider for processing only and is not retained by that provider as a system of record.
6.3 Access
Access to interview recordings is limited as follows.
- Named Company reviewers, for the purpose of scoring or reviewing a flagged or low-confidence case
- Participating Japanese partner companies, limited to the transcript and score only, where the candidate has been shortlisted and has given the separate consent described in Section 3
- Company technical staff, only where required to resolve a confirmed technical failure
Interview recordings are never made public and are never used for any purpose outside the Programme evaluation process described in this notice.
6.4 Technical Safeguards
- Encrypted storage and encrypted transmission between the individual's device and Company servers
- Role-based access permissions, so that only authorised reviewers can open a given recording
- Audit logging of every access to interview recordings and every manual score override
- Auto-save at each question, so a technical interruption does not affect earlier answers
6.5 Technical Failures and Retry Policy
If a session is interrupted by a confirmed technical failure, verified by system logs, the individual may resume within 24 hours, and a support contact is provided immediately. One retry is permitted in this circumstance. A retry is not offered where an individual would simply prefer to give a different answer.
6.6 Retention of Video Data
Interview recordings and transcripts are retained in accordance with the defined periods in Section 8. Individuals may request deletion of this data at any time in accordance with Section 9, subject to the exceptions described there.
7. AI-Assisted Screening
Application materials, including the resume, academic information, and AI Interview responses, may be processed using automated evaluation tools to assist with initial screening and ranking. Consistent with the Takumi-Challenge selection philosophy, the AI Interview is assessed primarily on the specificity of a candidate's examples, their personal ownership of the experiences they describe, the maturity of their stated motivation, the depth of genuine reflection in their answers, and their fit with the role track applied for. Automated tools assist with scoring and ranking only. Any interview result with low confidence, or any flagged response, is reviewed by a named Company reviewer before a shortlisting decision is made, and a reviewer may override an automated score with a documented reason. Final progression decisions at the Innovation Challenge and final interview stages are made entirely by human reviewers.
8. Secure Management and Retention of Personal Information
The Company will implement necessary and appropriate security management measures to prevent unauthorized access, leakage, loss, or damage to personal information collected through the Programme. Defined retention periods are as follows.
| Candidate Status | Retention Period |
|---|---|
| Active candidate, current cycle | Retained through the end of the Programme cycle (November 30, 2026), plus 90 days for administrative closure |
| Not shortlisted or not selected, no talent pool opt-in | Deleted within 90 days of the end of the Programme cycle |
| Not shortlisted or not selected, opted into talent pool | Retained for 24 months from the date of opt-in, or until the candidate withdraws consent, whichever is earlier. Renewal consent will be requested before expiry |
| Finalist | Retained for 24 months from finalist confirmation, to support future company matching, renewable with the candidate's consent |
| Offer accepted | Retained in line with standard employment and statutory record-keeping requirements; the exact period will be confirmed with Japan-side legal counsel and stated in the employment contract |
| Consent records | Retained for the same period as the associated candidate record, plus 12 months, to allow the Company to demonstrate consent history for audit purposes |
When personal information is no longer needed for these purposes, the Company either irreversibly anonymises it or securely destroys it.
9. Disclosure, Correction, and Suspension of Use of Personal Information
When the Company receives a request from the individual regarding the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to third parties regarding the personal information we hold, we will confirm that the request is from the individual or their authorised representative and respond in accordance with applicable law. This includes, for individuals based in India, the rights available under the DPDPA:
- The right to confirm what personal information the Company holds and how it is used
- The right to receive a copy of the personal information submitted
- The right to correct inaccurate or incomplete personal information
- The right to request deletion where the Company no longer has a valid ground to retain the information
- The right to withdraw consent, where processing is based on consent, without affecting processing already carried out
- The right to raise a grievance regarding the handling of personal information
The Company will respond to such requests within 30 days. If an individual is not satisfied with the Company's response, they may raise the matter with the Data Protection Board of India or the relevant authority in their place of residence, in addition to any rights available under Japanese law.
10. Age and Eligibility
The Programme is intended for participants aged 18 years and above. By registering, individuals confirm that they are 18 or older. The Company does not knowingly collect personal information from individuals under 18 through the Programme. If it comes to the Company's attention that a registrant is under 18, their account and associated data will be removed.
11. Use of Cookies and Access Information
On the Programme website, the Company collects information such as cookies, IP addresses, and browsing history, including through Google Analytics (GA4), Meta Pixel, and UTM tracking parameters, to attribute registrations to the correct outreach channel, monitor usage, investigate technical issues, and improve site content. This information may be used as statistical data that does not identify individuals. Where required, the Company will request consent before activating non-essential tracking technologies, and individuals may manage their preferences through browser settings or the cookie controls on the website.
12. Referral Programme
Where an individual takes part in the Programme's referral scheme, the Company collects the information needed to attribute a referral, including the referrer's name. Where a referral leaderboard is used, the referrer's name may appear on it. Consent given at the point of joining the referral scheme covers this use. Individuals may opt out of leaderboard visibility by contacting the Programme office set out in Section 13.
13. Inquiries Regarding Personal Information
For inquiries, complaints, consultations, or requests for disclosure regarding the handling of personal information under our general Privacy Policy, please contact:
Directors Co., Ltd.Personal Information Protection Manager: Daijiro Miura
Email: info@directors.jp
For Programme-specific privacy inquiries from India, including requests relating to the AI Interview, video data, or Candidate Evaluation Reports, please contact:
Takumi-Challenge Programme OfficeEmail: krishank@directors.jp
14. Changes to This Notice
The Company may change this notice as necessary. Where appropriate, registered candidates will be notified directly of any material change.
