Personal Information Protection Policy
The Company has established this Personal Information Protection Policy to work as an organization to ensure the proper handling of personal data based on the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the “Personal Information Protection Act”).
1 Company name, address, and representatives
Suncall Corporation
14, Umezunishiura-cho, Ukyo-ku, Kyoto
Tadao Otani, Representative Director
Tadashi Nara, Representative Director
2 Compliance with related laws and regulations, guidelines, etc.
The Company will handle personal data properly in compliance with laws and regulations including the Personal Information Protection Act as well as the guidelines including those of the Personal Information Protection Committee.
3 Acquisition and use of personal information
The Company will publish or give notice of the purposes of use (including publishing in accordance with this Policy) when acquiring personal information, and when acquiring personal information stated in an agreement or other document (including electromagnetic records) directly from the individual in question, the Company will expressly indicate the purposes of use in advance and acquire it by legitimate and fair means.
The Company will use personal information properly within the scope necessary for achieving the purposes of use.
4 Purposes of use of personal information
The Company will use personal information for the following purposes:
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(1) Personal information of users of this website
[Purposes of use]
- To receive opinions and feedback;
- To respond to inquiries and requests for materials;
- To conduct market research and develop new products and services;
- To give notice of events, seminars, and campaigns;
- To offer an email delivery service or send publications, etc.;
- To provide information on products and services handled by the Company or its partners;
- To perform confirmation work in accounting audits;
- To analyze acquired information including browsing histories and provide information on new products and services;
- To identify and authenticate users;
- To send products and invoices;
- To respond to, confirm, and record inquiries, consultations, complaints, repairs, and provide support;
- To develop products and improve and enhance services;
- To improve and enhance user experience in digital services provided by the Company (e.g. websites and mobile applications);
- To advertise and provide information on products, services, campaigns, etc. by invitation letter, email, or similar means (*1, *2);
- To deliver behavioral targeting advertisements using advertisement delivery service providers including Google (*3, *4);
- To analyze the attribute information, behavior histories, etc. acquired by the Company to understand users' interests, preferences, etc. (*2); and
- To safely provide the Company's products and services. The above includes discovery of and notification to users violating the Terms of Use, and investigation, detection, and prevention of fraud, unauthorized access, or other dishonest acts by misusing services, etc., as well as response to the above.
*1 The Company will analyze the information acquired from you, including website browsing history and purchase history, to provide services and deliver advertisements.
*2 The Company may use the information acquired from third parties, such as your interests, browsing history, etc. linked to your personal information already held by the Company. In such cases, the Company will acquire agreement from you in advance, and use that information within the scope of the purposes of use listed above.
*3 A cookie is a technology for recording and managing information of users of a website on computers or application software. The Company website uses cookies to provide greater convenience to you.
*4 The Company website uses Google Analytics, a service provided by Google LLC, to understand your visits to the Company website.
The Google Analytics service used on the Company website enables Google LLC to collect, record, and analyze your visit history to the Company website based on the cookies issued by the Company.
The Company receives the analysis results from Google LLC to help it better understand your visits to the Company website.
Your information that is collected, recorded, and analyzed by Google Analytics contains no information that can be used to identify specific individuals. That information is managed by Google LLC in accordance with their privacy policy.
You can disable Google Analytics using your browser’s add-on settings to stop your information from being collected by the Company using Google Analytics. To disable Google Analytics, change your browser’s add-on settings by downloading and installing the Google Analytics Opt-out Browser Add-on from the Google LLC opt-out add-on download page. If you disable Google Analytics, Google Analytics for all other websites you visit will also be disabled, but it can be enabled again by resetting the browser add-on. For the terms of service of Google Analytics, please visit the Google Analytics site, and for the privacy policy of Google LLC, please visit the Google LLC site.
Google Analytics Terms of Service
http://www.google.com/analytics/terms/us.html
Google Privacy Policy
http://www.google.com/intl/en/policies/privacy/
Google Analytics Opt-out Browser Add-on
https://tools.google.com/dlpage/gaoptout?hl=enThe Company website uses BowNow, MA (marketing automation) software provided by Cloud CIRCUS Inc. to analyze the usage of its website.
When an end user visits the Company’s web page with tracking codes (codes set up in a website or web application for acquiring information of and analyzing access by end users who visited the website or used the web application, which are linked to this software) set up, their online behavior history information is collected with the use of the functions of this software.
This behavior history information does not contain information that can be used to identify specific individuals, such as names or e-mail addresses, but when acquired by the Company, it may be combined with the end user’s lead information, such as their name, from the software and become personally identifiable information.
For the Terms and Conditions of BowNow and the Privacy Policy and the Basic Security Policy of Cloud CIRCUS Inc., please refer to the following URLs, respectively.
BowNow Terms and Conditions
https://cloudcircus.jp/dcms_media/other/BowNow_terms.pdf
Cloud CIRCUS Inc. Privacy Policy
https://cloudcircus.jp/privacy/
Cloud CIRCUS Basic Security Policy
https://mtame.co.jp/security/ - To deal with the need to contact you for some other reason
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(2) Personal information on the Company’s trading partners (or in the case of a corporation, its officers and employees)
[Purposes of use]
- To make necessary business contacts, execute contracts, conduct business negotiations, etc.; and
- To manage trading partner information
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(3) Personal information on the Company’s shareholders (or in the case of a corporation, its officers and employees)
[Purposes of use]
- To exercise rights and perform obligations under the Companies Act; and
- To manage shareholders, including preparation of records under various laws and regulations
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(4) Personal information on job applicants collected in the recruitment and employment processes
[Purposes of use]
- For communication with and information provision to job applicants in the recruitment and employment processes, and other uses necessary for the recruitment and employment processes
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(5) Personal information on the Company’s employees
[Purposes of use]
- For business communications to the Company’s employees;
- For payment of compensation (wage, bonus, allowances, etc.) to the Company’s employees, performance of personnel and labor management, and provision of benefits; and
- For healthcare of the Company’s employees
5 Joint use of personal information
The Company will jointly use the personal information of users of this website as follows:
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(1) Items of personal information
Your address, name, zip code, telephone number, fax number, e-mail address, product purchase history, etc.
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(2) Scope of joint users
The Company may use your personal information jointly with its subsidiaries, affiliates, etc. within the scope of the purposes of use listed in 4 above. In such case, the Company ensures the prevention of leaks by joint users by executing confidentiality agreements or other methods.
For subsidiaries and affiliates, please see the Offices page.
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(3) Purposes of use
The Company will jointly use such personal information within the scope of the purposes of use listed in 4-(1) “Personal information on users of this website” above.
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(4) Name, address, and representative of the company responsible for the management of personal data
The Company will be responsible for the personal data used jointly. For the address and the representatives of the Company, please see 1 above.
For inquiries about joint use, please contact the following:
- [Personal Information Protection Consultation Service]
- General Affairs Department
- [Contact]
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Personal Information Protection Consultation Service (General Affairs Section Manager),
General Affairs Department, Suncall Corporation
14, Umezunishiura-cho, Ukyo-ku, Kyoto 615-8555 Japan
Tel.: +81(75)881-8111
Hours for acceptance of inquiries: 9:00 a.m. to 11:00 a.m. and 1:30 p.m. to 4:00 p.m.
Monday to Friday (excluding national holidays and year-end and New Year holidays)
6 Third-party provision of personal information
The Company will not provide your personal information it received to a third party except in the following cases:
- (i)If your prior consent is obtained
- (ii)If the Company entrusts the handling of the personal information to an outside contractor within the scope necessary for achieving the purposes of use
- (iii)If the Company is requested to provide the personal information based on laws and regulations
- (iv)If such provision is necessary for the protection of the life, body, or property of a person and it is difficult to obtain your consent
- (v)If such provision is particularly necessary for the improvement in public health or the promotion of sound development of children, and it is difficult to obtain your consent
- (vi)If it is necessary to cooperate with a national or local government in the execution of the clerical duties prescribed by laws and regulations, and obtaining your consent may affect the execution of the relevant duties
- (vii)If the information is provided to a person within the scope of the joint users listed in 5 above
7 Matters regarding security control measures
The Company will undertake security control measures necessary and appropriate for the management of personal data, including leak, loss, and damage prevention measures. It will additionally exercise necessary and appropriate supervision over its employees and contractors (including subcontractors). The detailed security control measures for personal data are specified separately in the Personal Information Management Regulations, whose main contents are as follows:
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(Establishment of Personal Information Protection Policy)
- To ensure the appropriate handling of personal data, the Company has established these Personal Information Protection Guidelines regarding compliance with relevant laws, regulations, and guidelines as well as the contact points for inquiries and complaint handling.
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(Establishment of regulations regarding handling of personal data)
- The Company has established the Personal Information Management Regulations for the handling methods, the managers and persons in charge, and their duties, etc. for the respective stages of acquisition, use, storage, provision, and deletion or disposal.
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(Organizational security control measures)
- The Company has appointed a personal data handling administrator, defined the employees who handle personal data and the scope of the personal data handled by such employees, and developed a system to report to the administrator of any fact or sign of a violation of the Personal Information Protection Act and the Personal Information Management Regulations.
- The Company implements regular self-inspections and audits of the handling of personal data by other departments or outside persons.
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(Human security control measures)
- The Company implements regular training for employees on specific points of note regarding the handling of personal data.
- The Company provides matters regarding the confidentiality of personal data in the Work Rules.
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(Physical security control measures)
- The Company undertakes measures for areas where personal data is handled, including access control of employees, restrictions on devices brought in, and prevention of unauthorized access to personal data.
- The Company also undertakes measures to prevent theft and loss of devices, electronic media, documents, etc. used in handling personal data, as well as measures to prevent specific individuals subject to personal data from being easily identified while such devices, electronic media, etc. are carried about, including within the office.
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(Technical security control measures)
- The Company exercises access control to limit the scope of the persons in charge and the personal information database, etc. to be handled.
- The Company introduces systems for protecting the information systems used in handling personal data against unauthorized access from the outside or illegal software.
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(Entrustment of handling of personal information outside Japan)
- If the Company provides personal data to a third party outside Japan, the prior consent of the individual in question to the provision to a third party in the relevant foreign country must be obtained, except in special cases.
8 Contractor entrusted with handling of personal information outside Japan
The Company does not entrust the handling of personal information to any contractor outside Japan.
9 Request for disclosure, etc. of personal information
If requested for a referral, correction, suspension of use, or deletion of personal information, the Company will respond promptly upon confirming that it is from the individual in question in accordance with the prescribed procedure. If you have any questions regarding these Personal Information Protection Guidelines or wish to exercise your rights, please contact us using the contact information listed in 10 below:
10 Contact for inquiries
For inquiries and complaints about the handling of personal data by the Company, please contact the following:
- (i)Address
Personal Information Protection Consultation Service (General Affairs Section Manager),
General Affairs Department, Suncall Corporation
14, Umezunishiura-cho, Ukyo-ku, Kyoto 615-8555 Japan - (ii)Telephone number
+81(75)881-8111 - (iii)Hours for acceptance of inquiries
9:00 a.m. to 11:00 a.m. and 1:30 p.m. to 4:00 p.m.
Monday to Friday (excluding national holidays and year-end and New Year holidays)