AtCoder Inc. (hereinafter referred to as “we”, “our”, or “us”) processes the personal data of our customers (hereinafter referred to as “Users”) including those who enter into competitive programming contests (hereinafter referred to as the “Contests”) and use related services (hereinafter referred to as the “Services”) such as recruitment support for software engineers, competency assessments, and skill tests provided on the AtCoder website (https://atcoder.jp/) (hereinafter referred to as our “Website”) in accordance with applicable data protection and privacy laws such as the Act on the Protection of Personal data, and other related laws, regulations, and guidelines (hereinafter referred to as the “Applicable Data Protection and Privacy Laws”).

Collection of Personal data

We collect the following personal data directly from Users. In cases where the processing of personal data is required pursuant to laws, regulations, or an agreement with a User, and if such personal data is not provided, we may not be able to provide the Services properly. We do not obtain personal data through third parties.

1. 1. E-mail addresses and country/region which are required to register for the Services, as well as your birth year, affiliation, and social media usernames, which are optional;
2. 2. Information registered by a User when participating in the Contests such as their name, age, prefecture of residence, or other information regarding the User’s location such as country and address, affiliation category, name of affiliated school and (expected) graduation date, name of affiliated company and job title, employment-related information such as intention and status of employment or job change, research content, usable programming languages, information necessary for the delivery of prizes such as address, and social media usernames;
3. 3. Information concerning whether or not the User has registered for or participated in the Contests, answer data, log data, and metadata related thereto, results of the Contests, rating, ranking, and, if applicable, team name and team members;
4. 4. Information concerning the application, participation, results, test serial codes, and payments relating to the skill tests held by us on our Website; and
5. 5. Information such as cookies and IP addresses automatically collected when using our Website.

To monitor changes in User access patterns and to improve our Website, the Website uses Google Analytics to perform access analysis. This is conducted by collecting access logs and issuing cookies in a manner that does not identify individuals.

For Google Analytics and Google’s privacy policy, please refer to the following links:

https://marketingplatform.google.com/about/analytics/terms/us/

https://policies.google.com/privacy?hl=en

Purpose of Use of Personal data

We will process the personal data of Users for the following purposes. Where required by the Applicable Data Protection and Privacy Laws, we will obtain the consent of the User for the use for such purposes.

1. To provide the Services;
2. To provide information regarding the Services;
3. In order for corporate sponsors of the Contests in which Users have participated to provide recruitment information to Users, verify application history, and conduct selection activities;
4. In order for companies to which Users have applied to provide recruitment information to such Users, verify application history, and conduct selection activities;
5. To customize information on the pages of the Services, the Services themselves, and the distribution of advertisements based on the age, occupation, gender, hobbies and preferences, etc. of Users;
6. To improve the Services, and for the development of new services, etc.;
7. To prevent the usage of the Services in a manner that violates the Terms of Use;
8. To ensure cybersecurity;
9. To create statistical data related to the Services which is processed in a manner so that individuals cannot be identified;
10. To use answer data posted on our Website by the Users through their use of the Services, or to provide such data to third parties such as AI developers, for the purpose of using it as training data, etc. for machine learning and the like;
11. To respond to inquiries from Users; and
12. To comply with laws and regulations.

Sharing of Personal data

We may share the personal dataof Users with the following third parties:

1. Service Providers : For the aforementioned purposes, we may share personal data with the providers of IT, system administration and hosting, and credit card payment processing services.
2. Sponsors : If a User participates in the Contests or applies for recruitment at companies, we may share such User’s personal data upon obtaining his or her consent.
3. AI Developers : With the consent from the User, we may share answer data posted to the Contests by such User, log data, and metadata related thereto, as well as any other data authorized by such User to be shared with third parties such as AI developers to be used as training data for machine learning and the like.

In such cases, we may provide personal data to third parties located outside Japan in accordance with the Applicable Data Protection and Privacy Laws. Information on the personal data protection systems in such foreign countries is as follows:

• Names of foreign countries The United States of America, the Republic of Korea, the People’s Republic of China
• Information on the systems for the protection of personal data in foreign countries. Please refer to the following links located at the website of the Personal Information Protection Commission of Japan.
• The United States of America: https://www.ppc.go.jp/files/pdf/USA_report.pdf
• The Republic of Korea: https://www.ppc.go.jp/files/pdf/korea_report.pdf
• The People’s Republic of China: https://www.ppc.go.jp/files/pdf/china_report.pdf
• Information on the measures for the protection of personal data taken by recipients

The third parties to whom personal data is provided have taken all measures corresponding to the eight principles set out in the OECD Privacy Guidelines (https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0188).

Retention Period of Personal data

We will not retain the personal data of Users beyond the period necessary for the aforementioned purposes of use of personal data or the period required by laws and regulations. When personal data is no longer necessary, we will delete the data promptly.

Right for Disclosure

We will, without delay, respond to the requests of Users for the disclosure of their personal data. However, we may refuse to disclose a User’s personal data, in whole or in part, in the following cases. If we decide not to disclose his or her personal data, we will inform the User of the same without delay.

1. Where disclosure may harm the life, body, property, or other rights and interests of Users or third parties;
2. Where disclosure may significantly interfere with the proper implementation of our business;
3. Where disclosure may violate other laws and regulations; or
4. Where we cannot confirm that the request for disclosure is made by the User himself or herself.

Right for Corrections, Addition, or Deletion

If a User requests us to correct, add, or delete the content of their personal data (hereinafter referred to as the “Corrections, etc.”) by reason of such personal data not being accurate or correct, we will conduct an investigation without delay after verifying the identity of the requesting User, and make the necessary Corrections, etc. within a reasonable period of time, except for cases where special procedures are stipulated pursuant to the provisions of other laws and regulations.

Right for Suspension of Use or Erasure

If a User requests us to suspend the use of or erase their personal data (hereinafter referred to as the “Suspension of Use, etc.”), we will conduct an investigation without delay after verifying the identity of the requesting User, and if it is found that there are reasonable grounds for the request, we will carry out the Suspension of Use, etc.

Precedence

We may establish separate privacy policies. In such cases, if there is any inconsistency between this Privacy Policy and such separate privacy policies, this Privacy Policy shall prevail to the extent of the inconsistency.

Revision to This Privacy Policy

We may revise this Privacy Policy in whole or in part. The notification of such revised Privacy Policy will be announced on our Website.

Inquiries

For comments, questions or complaints regarding our Privacy Policy, or other inquiries or requests regarding the processing of personal data, please contact us at the following address. Please also refer to the “Personal Information Protection Policy” [KP1.1]for the specific methods of making requests.

AtCoder Inc., Personal Information Complaints and Consultation Desk

E-mail: support[@]atcoder.jp

Head Office: 4-1-23 Shinjuku, Shinjuku-ku, Tokyo

Last Update: June 29th, 2026