Privacy Policy

Proxy Watcher Inc. (the “Company”)

 

 

The company has established this “Privacy Policy” to ensure the proper handling of personal data in accordance with the “Act on the Protection of Personal Information” (Act No. 57 of 2003). 

 

1 About the Company

 

Proxy Watcher Inc.

Address: 11F KANDA SQUARE, 2-2-1 Kanda Nishiki-cho, Chiyoda-ku, Tokyo 101-0054, Japan

CEO: Koh Matsuki

 

2 Compliance with relevant laws and regulations

 

We will handle personal data appropriately in compliance with the Act on the Protection of Personal Information and other laws and regulations, as well as the guidelines of the Personal Information Protection Commission and other guidelines.

 

3 Definition of Personal Information

 

The term “personal information” shall mean information pertaining to the identification of users, action history on communication services, and other information generated or accumulated in connection with users or their terminals, which is collected by the Company.

 

4 Acquisition and Use of Personal Information

 

When acquiring personal information, the Company shall publicly announce or notify the purpose of use (including public announcement through these Guidelines), and shall not use personal information for any purpose other than that for which it was collected. In addition, when acquiring personal information directly from the person concerned in a contract or other document (including electromagnetic records), we will clearly state the purpose of use in advance and acquire the information in a lawful and fair manner. We will use personal information appropriately within the scope necessary to achieve the purpose of the collection of the said personal information.

 

5 Purpose of Use of Personal Information

 

We will use personal information for the following purposes

 

 (1) Personal information related to customers

 

Purpose of use

Identification and personal authentication of customers

・Provision and shipment of products related to services in which the customer has participated

 

・Responding to, confirming, and recording customer inquiries, consultations, complaints, repairs, and support evelopment of products and improvement and enhancement of other servicesmprovement and enhancement of the customer experience in digital services (including but not limited to websites, mobile applications, etc.) provided by the Company

 

To advertise and provide information on our products and services through letters, e-mails, etc. (*1 and *2)

 

・Providing our products and services to customers in a safe manner. This includes detecting users who are violating the Terms of Use and notifying such users, as well as investigating, detecting, and preventing fraud, unauthorized access, and other illegal activities that abuse the services, etc., and responding to such activities.

 

(*1) Analyze information obtained from customers, such as website browsing history, to provide services, distribute advertisements, etc.

 

(*2) “Cookie” is a technology that records and manages the information of customers who use the Company’s website on their computers and application software. (*2) The Company’s website may use cookies to make it more convenient for customers to use the website.

 

(2) Personal information concerning business partners (or their officers and employees in the case of corporate customers)

 

Purpose of use

To contact, execute contracts, and conduct business negotiations as necessary in the course of business.

To manage business partner information.

 

(3) Personal information concerning applicants for employment and recruiting activities

 

Purpose of use

To contact and provide information to applicants for recruitment and recruiting activities, and for other uses necessary for recruitment and recruiting activities.

 

 (4) Personal information concerning employees

 

Purpose of use

Business communication

Payment of compensation (wages, bonuses, benefits, etc.), the performance of personnel and labor management, and provision of benefits

Health management

 

Any change in the purpose of use shall not exceed the scope that is reasonably considered to be relevant to the purpose of use before the change. In addition, prior consent shall be obtained from the customer if personal information is to be used for any purpose other than those listed in this policy.

 

6 Joint Use of Personal Information

We will share the personal information of our customers as follows

 

(1) Items of personal information

Customer’s address, name, postal code, telephone number, fax number, e-mail address, etc.

 

 (2) Scope of joint use

In order to provide better services to our customers, we may link (and/or share) personal data with partner companies. The information to be shared is limited to items necessary for the business of the Company, and will not be used for any other purposes.

 

 (3) Purpose of use

Personal data will be jointly used within the scope of the purposes of use of “personal data concerning customers” described in 4 (1) above.

(4) Name, address, representative, etc. of the company responsible for the management of personal data

 

The Company will be responsible for the personal data to be jointly used. For the Company’s address and representative, please refer to 1 above.

 

 For inquiries regarding joint use, please contact the following

Personal Information Protection Consultation Contact: Koh Matsuki

 

Contact Information

 11F KANDA SQUARE, 2-2-1 Kanda Nishiki-cho, Chiyoda-ku, Tokyo 101-0054, Japan

 Personal Information Protection Consultation Service, Proxy Watcher Inc.

Phone number 080-4395-8529

Hours: Monday-Friday (excluding national holidays and year-end and New Year holidays) 10:00-12:00, 13:00-17:00

 

 

7 Provision of Personal Information to Third Parties

We will not provide personal information entrusted to us to third parties except in the following cases

・When we have obtained the prior consent of the customer

・When the Company outsources the handling of personal information within the scope necessary to achieve the purpose of use

・When the provision of personal information is required by law.

・When it is necessary for the protection of the life, body, or property of an individual, it is difficult to obtain the customer’s consent.

・When it is especially necessary to improve public health or to promote the sound growth of children (below the age of 20), and it is difficult to obtain the customer’s consent

・Cases in which the handling of personal information is necessary for cooperating with national or local governments in the execution of their legally prescribed duties, and in which obtaining customer consent is likely to impede the execution of such duties

・When the information is provided to the parties listed in the scope of joint users in 5. above

 

8 Concerning Safety Control Measures

The company takes necessary and appropriate security control measures for the management of personal data, including the prevention of leakage, loss, or damage. In addition, we will exercise necessary and appropriate supervision over our employees and contractors (including subcontractors, etc.) who handle personal data. (2) The Company will take necessary and appropriate measures to ensure the security of personal data. The security control measures for personal data are specifically stipulated in a separate “Personal Information Handling Regulations”, the main contents of which are as follows. 

 

(Formulation of Personal Information Protection Guidelines)

– In order to ensure the proper handling of personal data, the Company has established these guidelines (Personal Information Protection Guidelines) regarding “compliance with relevant laws, regulations, guidelines, etc.” and “contact points for handling questions and complaints.

(Establishment of Rules for Handling Personal Data)

– For each stage of acquisition, use, storage, provision, deletion/disposal, etc., the Company has established “Rules for Handling Personal Information,” including handling methods, responsible persons/persons in charge, and their duties.

(Organizational Safety Control Measures)

– In addition to appointing a person responsible for handling personal data, the Company clarifies the employees who handle personal data and the scope of personal data handled by such employees. A liaison system is in place for employees and employees who handle personal data.

– Regular self-inspections of the status of personal data handling are conducted, as well as audits by other departments and outside parties.

 (Personnel Safety Control Measures)

– Regular training is provided to employees on points to keep in mind regarding the handling of personal data.

– Items concerning the confidentiality of personal data are stipulated in the employment regulations.

(Physical security control measures)

– In areas where personal data is handled, the Company controls employee access to rooms and restricts the equipment, etc. that employees may bring into such areas, and has implemented measures to prevent unauthorized persons from viewing personal data.

– Measures are taken to prevent theft or loss of equipment, electronic media, and documents that handle personal data, as well as to prevent personal data from being easily discovered when such equipment, electronic media, etc. are transported, including within the business site.

(Technical safety control measures)

– Access control is implemented to limit the scope of persons in charge and the personal information databases, etc. handled.

– A mechanism is in place to protect the information system handling personal data from unauthorized external access or unauthorized software.

(Outsourcing the handling of personal information in foreign countries)

We handle personal information only in Japan, and do not acquire, operate, or entrust the handling of personal information in foreign countries.

 

9 Requests for Disclosure of Personal Information

When we receive a request for reference, correction, suspension of use, deletion, etc., of personal information, we will promptly respond to the request after confirming the identity of the customer in accordance with the prescribed procedures. If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at the inquiry desk indicated in Section 9 below.

 

10 Contact for Inquiries

If you have any questions or complaints regarding our handling of your personal data, please contact us at the following address.

 

(1) Address

11F KANDA SQUARE, 2-2-1 Kanda Nishiki-cho, Chiyoda-ku, Tokyo 101-0054, Japan

Personal Information Protection Consultation Office, Proxy Watcher, Inc.

Koh Matsuki

(2)Telephone number: 080-4395-8529

Hours: Monday through Friday (excluding national holidays and year-end and New Year holidays)

10:00 – 12:00, 13:00 – 17:00

 

11 Amendment and/or Change of this policy

The Company reserves the right to amend and/or change any or whole of this policy without prior notification to any parties in concern. 

 

12 Date of enactment and revision of privacy policy

Enacted: September 1, 2022