Specifically, in order to enable our clients to use our service with confidence, all employees will comply with the laws concerning the handling of personal information, the guidelines or other norms developed by the government, and the requirements of the personal information protection management system (JIS Q 15001: 2017), while making sure to take reasonable safety or preventative measures such as developing internal regulations to avoid risks including unauthorized access to personal information, leakage, loss and destruction of personal information.
As to the personal information used for in our business, employment, and personnel management, we will acquire, utilize and provide the information in an appropriate manner and will not use the information beyond the intended purpose. Also, necessary manners to achieve such goals will be taken.
We will establish internal regulations to handle the complaints and inquiries concerning the handling of personal information and internal regulations, in order to respond promptly and sincerely to complaints and inquiries. Besides we will make sure all of our executives and employees are fully informed of the information mentioned above. We will also improve our company’s personal information protection management system if necessary, and continually improve the personal information protection management system in light of the business environment.
Date of Enactment：Dec. 01, 2016
Date of the last revision：Feb. 25, 2019
Akane Kinoshita, Representative Director
１. What is “personal information”
“Personal information” refers to the information that clients enter during the process of using this service (e-mail address, etc.), as well as opinions, requests, complaints, content of inquiries and other information incidentally obtained in the processes listed above, which can be used to identify specific individual by combining these pieces of information in its original form or when combined with other information.
２. About the acquisition of personal information
We acquire personal information only in a legal and fair manner and will not acquire personal information against the will of the client. Also, even when we collect personal information from a third party, we will make sure to confirm whether the personal information to be acquired is properly obtained by the information provider.
３. Purpose of using personal information
We will use the acquired personal information only for the following purposes. In addition, we will take necessary measures to prevent the use beyond the intended purpose, and handle the personal information appropriately.
1. For the provision of this service
2. To verify the identity of the client or his proxy
3. To communicate with customers or to provide various free information by e-mail
4. To customize the information on this service, the service itself or the content of advertisements based on the client’s age, occupation, sex, hobby etc.
5. For marketing (survey, questionnaire, etc.), data analysis or research and development of this service
6. To conduct work related to transactions with clients
7. To exercise the rights or fulfill the obligations under laws and or contracts with the client
8. Prohibition of insider trading or other illegitimate trade practices
9. Other work aimed at proper and smooth transactions with clients
４. Provision of personal information to a third party
We will not disclose/provide the personal information of clients to a third party without the client’s consent. However, in the following cases, personal data may be disclosed/provided without the client’s consent.
1. Based on laws and ordinances
2. In cases where it is necessary for the protection of the life, body or property of a person and it is difficult to obtain the consent of the client
3. In cases where it is particularly necessary for improving public health or promoting the healthy development of children and it is difficult to obtain the consent of the client
4. In cases where it is necessary for us to cooperate with a national institute, a local public entity or an individual entitled by the above organizations to carry out work prescribed by laws and regulations, and it is difficult or significantly hindered to obtain the consent of the client
5. About the supervision of contractor
When the personal information obtained from our clients is to be handled by our contractor, we will conduct a strict investigation on the contractor and will conduct necessary and appropriate supervision in order to protect confidential information. We may deliver information to the contractors with whom the Non-Disclosure Agreement are signed, by telephone, DM, e-mail or other means, under the supervision of our company.
6. About Cookies
1. We have currently contracted with several online partners to manage and optimize our Internet operations and communications. In addition, we measure the effectiveness of advertisements and how our clients are using this service, while using the support service of the marketing company to provide our clients with better service. Therefore, we use Web beacon and Cookies provided by the marketing company on this service.
2. The types of information we collect from our clients include IP address, domain name, information such as referrers, viewed pages, etc. With this information, it is possible to identify the web pages or services which the clients are most interested in the pages you liked and viewed but such information does not expose client’s identity and does not violate client’s privacy. In addition, although the information on this service is collected through the service provided by the marketing companies on MC, we are in charge of managing how the data is handled.
7. Disclosure/Correction/Use termination/Deletion of personal information
１. It is possible to disclose, correct, delete or terminate the use of your personal information at any time after the client logs onto this service. Regarding other information, we will conduct a research on the request of our clients without any delay, and correct/terminate the use of/delete the information if there is any reason considered necessary.
However, part or all of the information may not be disclosed under the following situations:
1） When there is a risk of harming the life, body, property or other rights and interests of the client or a third party
2） When there is a risk of a significant hindrance to the proper implementation of our business
3） In case of violating other laws and ordinances
2. Procedure of personal information disclosure on request
1) If you want to request for “notice of the purpose of use”, “disclosure”, “correction, addition or deletion”, “refusal of use or provision” (hereinafter referred to as “disclosure etc.”), please contact 9 [Personal information inquiry counter].
However, please note that we do not respond to requests for disclosing the personal information other than what is listed in “2)”. Personal Information to be disclosed can only be used for no other purpose than carrying out the commissioned work.
2) “Personal information subject to disclosure” includes:
(1) Personal information of client acquired by all types of our business (not including the personal information acquired via providers and outsourcers of the business entrusted to us)
(2) Personal information on our clients
(3) Personal information on employment management of all employees of our company
(4) Personal information on potential employees willing to join us
(5) Personal information on those who have made inquiries to us
3) Application for request for information disclosure
To request for information disclosure, please contact the “personal information inquiry
helpline“,and fill out the necessary information on our designated document in case you require us to notify the purpose of use, or disclose, correct, add or delete the personal information.
4) We will verify your identity before handling your request for information disclosure. In some cases, we might ask you to send a copy of your official certificate by E-mail to make the confirmation.
※ A proxy letter for confirmation will be necessary for the application made by a proxy. In addition, in the case of appointing a proxy, it is necessary to submit a copy of the official certificate of both the appointing party and the proxy. In addition, we do not accept any requests for disclosure by telephone, e-mail, fax, etc. So please submit your request in a way that is possible to get shipping records, such as simple registered mail.
※ For the application made by the attorney-in-fact of the minor or adult ward, an official certificate is needed to confirm the validity of proxy.
5) For disclosure request etc. (“Notification of purpose of use” or “Request for information disclosure”), we will charge a fee up to 1,000 yen. We will contact you separately if the fee exceeds 1,000 yen.
8. About inquiries concerning the handling of personal information
For inquiries, complaints, and consultation concerning the handling of personal information, please contact our “Personal Information Inquiry Counter”.
Finatext Inc. Personal Information Inquiry Counter
Manager for protection of personal information：Director and CFO／COO
E-mail address：Email firstname.lastname@example.org