Privacy Policy

Recognizing the importance of protecting personal information, the Company shall strive to protect personal information in accordance with the following policy.

1. The Company shall acquire personal information in a legal and fair manner to the extent necessary after specifying the purposes of using it as clearly as possible.
2. The Company shall use personal information within the scope of the purposes of use indicated at the time it is acquired only to the extent necessary for executing the business.
3. The Company shall not provide personal information to any third party without the prior consent of the person providing the personal information, except as provided by law. If the Company jointly uses personal information with a third party, or entrusts a third party to handle personal information, the Company shall conduct a thorough investigation of such third party and provide proper supervision to ensure that confidentiality is maintained.
4. In handling personal information, the Company shall appoint a person responsible for managing personal information and make every effort to manage it appropriately, such as by preventing the unauthorized access, loss, destruction, alteration, and unauthorized disclosure, etc. of said personal information.
5. The Company acknowledges that persons providing personal information have the right to request the disclosure, correction, stopping of use, deletion, etc. of their own personal information, and if such request is made, shall promptly respond to it to a reasonable extent.
6. The Company shall comply with laws, regulations, and norms applicable to personal information, as well as endeavor to review and improve its efforts as mentioned above from time to time.

The Company shall process customers’ personal information as shown below (where 'process' means any work or series of work performed with personal information or a set of personal information, whether or not by automated means, and where 'work' means acquiring, recording, editing, structuring, storing, modifying, changing, restoring, referencing, using, disclosing through transfer, disseminating, and otherwise preparing said personal information to make it possible to disseminate, arrange, combine, restrict, delete, and/or destroy it. The same applies hereinafter.) The personal information that the Company processes shall be, but is not necessarily limited to:

Name; contact information (address, telephone number, e-mail address, etc.); business information (company name, department name, title, etc.); inquiry details; request details; content of contract; IP address; cookie information; and information related to the Web access history of the Company and its business partners.

Since such information needs to be provided by customers in order for the Company to provide its services to customers, customers who do not provide it may not be able to use its services.

The purposes of use for which the Company acquires personal information from customers, etc. are as specified below. The Company shall use personal information for the purposes of use specified below based on the consent of customers, etc., unless otherwise permitted by law. Customers, etc. may withdraw such consent at any time. (If the Company acquires personal information for purposes of use different from those specified below, the Company shall separately notify or publicly announce such purposes.)

• To provide information such as product and event information and sale to customers
• To analyze data and behavior as necessary for marketing activities, and information provision and sales activities based on the results of those analyses
• To request answers from customers to various questionnaires
• To answer various inquiries
• To conduct other overall customer management
• To place orders and make contact with business partners
• To settle accounts with business partners
• To conduct other overall business partner management
• To report and notify public offices, various industry groups, and so on
• To make contact with, and send materials to, stockholders
• To recruit Company employees and screen job applicants for employment
  (The purposes of use of the Company’s employees' information shall be notified or publicly announced separately.)

To accomplish the purposes of use specified above, the Company may provide customers’ personal information to third parties including the Company’s subsidiaries or distributors, such as agencies, or the Company’s contractors, such as cloud vendors or services operation companies.

Since the third parties to whom the Company provides customers’ personal information may include those located in countries outside Japan or the EU (including, without limitation, the U.S., China, South Korea, Singapore, Thailand, India, and Malaysia. The same applies hereinafter.), and customers shall agree to the following matters in addition to the provision of personal information to the third parties by agreeing to this personal information policy.

• In countries outside the EU in which third parties are located, the same data protection laws as the EU have not been developed and many of the rights that are granted to subjects' data in the EU are not granted.
• Customers’ personal information shall be provided and processed for the purposes of use specified above.
• Customers’ personal information shall be provided to third parties outside Japan or the EU.

Additionally, if the Company provides the personal information of customers located in the EU to third parties in countries outside the EU, the Company shall ensure that adequate measures will be secured to protect the customers’ personal information through the execution of the Standard Contractual Clauses under the EU General Data Protection Regulation, etc.

The website operated by the Company (the “Company Website”) uses Google Analytics, which is a service of Google Inc., to understand the status of visits by customers to the Company Website. By the use of Google Analytics on the Company Website, Google Inc. collects, records, and analyzes customers’ visit history for the Company Website based on cookies issued by the Company. The Company receives the results of such analysis from Google Inc. and can understand the status of visits by customers to the Company Website. Customer information that is collected, recorded, and analyzed by Google Analytics does not include any information that could identify a specific individual. Moreover, such information is managed by Google Inc. pursuant to its privacy policy. For details of said privacy policy, please see the following web page.

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

The Company shall strive to keep personal information up to date, and in the case of erroneous or missing personal information, to correct it. In addition, when the purposes of use of personal information are accomplished, the Company shall promptly destroy it.

In order to prevent unauthorized access to, and unauthorized disclosure, etc. of, personal information, the Company shall comprehensively evaluate and determine the risk of breaches of personal information after considering the type of personal information, its sensitivity, the degree of impact on customers including economic and mental damages in the case of an unlawful breach of personal information, and shall take the necessary and appropriate human, systematic, and technical safety control measures according to the risk of breach of personal information, as well as make every effort to improve ordinary security by establishing a process for examining and correcting such safety control measures if needed.

With respect to the personal data held by the Company, the persons providing said personal data may make a request for disclosure, etc. (disclosure, correction, stopping of use, deletion, and data portability), and file a complaint to the extent permitted by applicable law. If such request or complaint is made, the Company shall respond to it within a reasonable period of time in accordance with applicable law. The Company shall accept such requests and complaints at the contact for inquiries concerning personal information, stated below. In the procedures for responding to a “request for disclosure, etc.,” the Company shall confirm the identity of such requester.
* Please note that the Company cannot accept any requests or complaints made by directly visiting the Company.

When acquiring personal information from customers under the age of 16, the Company shall always obtain the consent of their parents or legal guardians. The Company would like to ask customers under the age of 16 to ensure that their parents or legal guardians confirm the content of this personal information policy, and that the parents/legal guardians, not the customers themselves, accept it before the customers use the Company's services. Additionally, if a parent of a customer under the age of 16, or other persons find that the customer accepted this personal information policy without the parent’s confirmation and consent and is using the Company's services, please notify the contact for inquiries stated below.

Generally, the Company does not use customers’ personal information for the purpose of automated decision making.

If a customer has a complaint about the handling by the Company of personal information, the customer may file the complaint with the regulatory authority having jurisdiction over the country or region in which the customer is located under the provisions of applicable laws.

For inquiries concerning the handling by the Company of personal information, please send them to the following contact:

E-mail address: hrs.privacy.7z@hirose-gl.com

Established: April 1, 2016
Revised: April 1, 2018