Privacy Policy
Hello, Yaponiya! Ukraine

Version:
Supersedes:

v2.0 (March 2026)
v1.0 (9 February 2026)

1) Who we are (controller)

People Cloud, Inc. (“People Cloud”, “we”, “us”) is the data controller responsible for the processing of personal data described in this Privacy Policy.

Privacy / compliance focal point (contact):

This website and application process support a UNIDO-supported feasibility study and related training activities. UNIDO supports the project, but People Cloud operates this application process and is responsible for data protection.

2) What this policy covers

This policy applies to personal data you provide when you:
‍
- apply to our Business Development / Project Manager program;
- participate in practical Japanese lessons; and
- interact with us about the program and (if you choose) career support / partner introductions.

3) What data we collect

We aim to collect only what is necessary for application screening, program delivery, reporting obligations, and (if you opt in) career support.

A) Application and profile data

- Name and surname
- Age (integer)
- Email address
- Telegram / messenger handle
- Citizenship
- Current location (and “other” free field if applicable)
- Gender: Female / Male / Non-binary / Prefer not to say (collected for aggregated reporting; not used for selection)
- Education level; university and specialization; specialization category
- Years of experience
- English level; Japanese level
- Professional summary (project example, role, achievements)
- Motivation statement
- How you heard about the program
- CV file upload (English or Japanese)

B) Compensation-related data

- Current salary range (mandatory; collected as ranges, not exact amounts)

C) Administrative and communications data

- Messages you send us; interview scheduling information; onboarding information (if selected); and basic participation status (e.g., selected / not selected; attendance and completion status where applicable).

Important note about sensitive data

Please do not include passport/ID numbers, full home address, medical/health information, or other sensitive personal data in your CV or free-text fields.

4) How we use your data (purposes)

We process your data for the following purposes:

5) Legal basis

People Cloud is based in Japan and follows applicable Japanese requirements, including the Act on the Protection of Personal Information (APPI). We use GDPR principles voluntarily as a best-practice benchmark, without waiving jurisdictional defenses. Where Ukrainian data protection requirements apply to activities in Ukraine, we aim to comply with those applicable requirements as well, including Law of Ukraine "On Personal Data Protection" (No. 2297-VI).People Cloud is based in Japan and follows applicable Japanese requirements. We use GDPR principles voluntarily as a best-practice benchmark, without waiving jurisdictional defenses. Where Ukrainian data protection requirements apply to activities in Ukraine, we aim to comply with those applicable requirements as well.

As a practical basis for processing:
- Application processing / program delivery: necessary to handle your request to apply and participate (GDPR Art. 6(1)(b) benchmark; APPI §17–18 purpose specification).
- UNIDO reporting / audit evidence: necessary for project accountability and compliance obligations, using minimized data (GDPR Art. 6(1)(f) benchmark — legitimate interest; APPI §18 use within stated purpose).
- Career support / partner introductions: based on your explicit opt-in consent (Career Support Consent Form).
- Future-opportunity retention: based on your explicit opt-in consent (Career Support Consent Form, item 3).
- Identifiable media capture: based on your explicit consent (Media Consent Form).
- System integrity: operational necessity for protecting systems and evidence.

A full legal basis mapping across GDPR, APPI, and Ukrainian law is set out in the project’s Data Protection Impact Assessment (DPIA Report, Section 7).

6) Your choices at application and during the program

When you apply, you will be asked to confirm:

‍(1) Required: “I have read and accepted the Privacy Policy and agree to the processing of my data for application screening and program delivery.”
(2) Optional: “I consent to People Cloud storing my profile after the selection process and sharing it with partner companies for potential employment opportunities.”

If you did not tick the optional checkbox, we will not use your data for partner introductions or longer-term retention for future opportunities.

If you are selected for the program, you may additionally be asked to sign:

- Career Support Consent Form: covering career guidance, partner-company introductions, and future-opportunity retention (optional; does not affect program participation).
- Media Consent Form: covering identifiable screenshots, photographs, and recordings during project activities (optional; does not affect program participation).

7) Who we share data with

We do not sell your personal data. We may share limited personal data with:

A) Entrusted Parties / project partners
Service providers supporting People Cloud operations under confidentiality and security obligations, limited to what is operationally necessary. These include SAMI Japan Inc. and Monstarlab Omnibus Inc., supervised in accordance with APPI requirements.Service providers supporting People Cloud operations under confidentiality and security obligations, limited to what is operationally necessary.

‍B) Cloud-based service providers (processors)
We use cloud-based tools to collect and store data and run operations, including Airtable (forms/database) and Google Workspace (email/storage/collaboration), and hosting providers used to operate the website where applicable. These providers process data on our instructions for the purposes described in this Policy.
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C) UNIDO
Only where required for reporting and supporting evidence, and typically in minimized/necessary form.

‍D) Partner companies (only if you opt in)
Only if you provide explicit opt-in consent (via the Career Support Consent Form), we may share your name, email address, professional summary, CV, and language levels with partner companies in Japan or their Ukraine offices for potential employment opportunities. Your salary range, gender, and other application data will not be disclosed to partner companies.

‍E) Beetroot Academy
If you participate in Beetroot Academy training, you may register directly on Beetroot’s platform. Beetroot operates as an independent controller for its own platform environment. Where People Cloud discloses selected-participant contact details to Beetroot or receives attendance/completion information from Beetroot, this is governed by a data-sharing protocol and limited to what is necessary for administration and reporting.

8) International transfers

People Cloud operates from Japan, and applicant data may be stored in, accessed from, or processed in Japan and other locations where our service providers operate. Japan has been recognized by the EU as providing an adequate level of data protection. Where data is accessed cross-border, we apply appropriate safeguards (restricted access, confidentiality, encryption, and security controls) consistent with our DPIA and security package.

9) Storage and security

We limit access to authorized personnel and entrusted parties with an operational need. We apply reasonable administrative and technical safeguards, including role-based access control, encryption in transit and at rest, multi-factor authentication, and activity logging. Details are set out in the project’s Minimum Security Schedule.

10) Retention

We retain data only as long as necessary for the purposes described above.

Selected participants: retained for the program period and for audit/accountability needs consistent with the project’s documentation requirements (seven-year baseline from the end of the Grant Agreement), in a minimized form where possible.

‍Non-selected applicants:
- If you opted in (optional checkbox): we may retain your profile to contact you about future opportunities and to share with partner companies as described, for up to 24 months. You may withdraw this consent at any time.
- If you did not opt in: we retain your application data for a limited period to manage the selection process and related inquiries, then delete it within a reasonable timeframe.

11) Your choices and rights

You can:

- request access to or correction of your data;
- request deletion of your data (including non-selected applicant records);
- withdraw consent for career support / partner introductions at any time by emailing ukraine@people-cloud.jp with the subject line “WITHDRAW CAREER CONSENT”;
- withdraw consent for identifiable media capture at any time by emailing ukraine@people-cloud.jp with the subject line “WITHDRAW MEDIA CONSENT”.

Withdrawal does not affect processing already performed before withdrawal.

12) How to contact us

For privacy requests (access, correction, deletion, withdrawal) or questions:

This Privacy Policy forms part of the data protection framework established under Output 3 (Activity 1: Compliance Plan; Activity 2: DPIA, security measures, and consent/privacy templates) of the hello, yaponiya! Ukraine feasibility study.