Policy on the Handling of User Information in the Bernal Search Service
Bernal, Inc. (the "Company") sets out this Policy on the Handling of User Information in the Bernal Search Service (this "Policy"), describing how we handle user information in connection with "Bernal" (the "Service"), the search intelligence we provide.
1. Company information
| Name | Bernal, Inc. |
|---|---|
| Representative | Kazuo Ikeda |
| Contact | Please see our Contact page |
2. Overview of the Service
The Service is a search engine installed via an embedded tag on a publisher's (client's) website. We operate the Service on the client's instruction, and information arising from its use is, as a rule, processed self-containedly within our own systems (we do not re-share or sub-contract it to any third party).
3. Information we collect
In providing the Service, the information we collect is as follows.
| Search terms | Words or phrases a user enters into the Service's search box |
|---|---|
| Anonymous ID | A randomly generated identifier stored in the browser's localStorage (contains no name, membership details or other identifying information) |
| Session ID | A randomly generated identifier stored in the browser's sessionStorage (cleared when the tab is closed) |
| Page URL | The URL of the page on which the search box is installed |
| Usage event data | Search executions, the number of results shown, articles clicked and their position, display of and clicks on related articles, and timestamps |
IP address and browser information (User-Agent) reach our servers as an inherent feature of how data is transmitted over the internet, but are not stored in our database.
The anonymous ID and session ID above are both randomly generated identifiers. We do not link them to a name, email address or any other information capable of identifying an individual.
Our system is technically capable of linking search logs to a client's own member IDs, but we do not currently use this capability to store data in that way. Should a client implement this in future, this would no longer apply, and we would notify the client concerned individually.
4. How we collect it
Information is collected automatically, in the user's browser, through the Service's programme (tag), when a user interacts with the search box.
5. Purpose of use
- To provide the Service (search functionality)
- To improve search accuracy
- To produce usage reports for clients (such as popular keywords and click-through rates)
We do not use this information beyond the purposes above.
6. External transmission (Article 27-12 of the Telecommunications Business Act)
When a user views or interacts with a page on which the Service's tag is installed, the following information is sent to our servers (the recipient).
| Information transmitted | Search terms, anonymous ID, session ID, page URL, usage event data (search executions, number of results shown, clicks, ranking, timestamps, etc.) |
|---|---|
| Name of recipient | Bernal, Inc. |
| Purpose of transmission | To provide the Service (search functionality), to improve search accuracy, and to produce usage reports for clients |
We do not link the information transmitted to anything beyond what is described in Section 3.
7. Retention period
Raw data: we have not currently set a retention period, and do not carry out deletion.
Aggregated data: we do not store aggregated data separately; it is calculated afresh from the raw data each time it is shown in our dashboard.
[A retention period will be set in due course, and this Policy updated accordingly.]
8. Disclosure to third parties
Except where required by law, we do not disclose the information we collect to any third party. Nor do we sub-contract any part of the Service's operation (we use no sub-processors).
We do use an external vendor for the development and maintenance of the systems behind the Service; the safeguards covering that arrangement are set out in Section 10, under "Technical safeguards."
9. About cookies
The Service (search widget): The Service does not itself use cookies or any similar device identifier, and none are sent.
This website (bernal-inc.com): Our corporate website uses Google Analytics, an analytics tool provided by Google, to understand how the site is used and to help us improve it. Google Analytics collects information via cookies, but this does not include information capable of identifying you by name. This use of cookies is enabled only if you consent via the banner shown when you visit the site; if you do not consent, no measurement takes place. Information collected is managed by Google in accordance with Google's own Privacy Policy. For details of Google Analytics' terms and privacy practices, please see Google's Privacy Policy. You can also opt out of measurement using the Google Analytics Opt-out Browser Add-on.
10. Security measures
To prevent the leakage, loss or damage of the information we handle, and to maintain its security more generally, we take the following measures.
| Organisational safeguards | We have established a policy for handling data (this Policy), and have put in place in advance a reporting and escalation process for when a data breach occurs or is suspected. |
|---|---|
| Personnel safeguards | Access to data is limited to those who need it for their work. As our team grows, any expansion of who may access data happens only after we have agreed confidentiality undertakings with, and provided data-handling training to, the individuals concerned. |
| Physical safeguards | Data relating to the Service is managed in data centres operated by a domestic (Japanese) cloud provider, and we also control access to the work devices we use, to prevent unauthorised viewing by third parties. |
| Technical safeguards | Data is encrypted both at rest and in transit, and we apply access controls such as IDs and passwords, together with measures to prevent unauthorised access. Where we sub-contract the development or maintenance of our systems, we enter into an agreement with the vendor imposing confidentiality obligations and prohibiting use beyond the agreed purpose, and we structure the work so the vendor has no direct access to production data. |
11. Changes to this Policy
This Policy may be changed without notice, to reflect changes in the law or other circumstances. Any change takes effect from the moment it is published on this page.
12. Enquiries
For enquiries about this Policy, please contact us via our Contact page.