Last-Modified: August 17, 2020
We guarantee that the acquisition, processing, use and storage of data will be handled strictly in accordance with the personal data protection laws established in each country and region.
• Data that we may handle
There are three types of data related to individuals that we handle:
1. Personal information
Personal information that can identify an individual and may include:
- Phone number
- Email address
- Other personal information defined in the Act on the Protection of Personal Information.
This information is collected and utilized to the extent necessary for certain services and solutions we provide. Registration, collection, and utilization of information will be carried out with prior user agreement specifying the purpose. The Company will not use or use such personal information for any purpose other than those specified or agreed up to.
We may use automated communication systems, such as email, to update products, marketing activities, and support information. However, users can also opt out of marketing communications. By registering on the Pinmicro platform, users can create and edit their profiles.
2. Device location data
Information about an individual (user) obtained through a smart device (a generic term for information processing terminals such as smartphones and tablets) that contains location information (latitude, longitude, time, accuracy). The device location data we obtain is mobile advertising identifiers (ADID), Wi-Fi information (SSID/BSSID), beacon information, and IP information related to position information. Device location data basically cannot identify a specific individual on its alone, and does not fall under the “personal information” stipulated by the Act on the Protection of Personal Information unless it can be easily collated with other information to identify a specific individual.
The Company collects device location data for each service provided by the Company and uses it for the service. Registration, collection, and utilization of information will be carried out with prior user agreement specifying the purpose. We may use these device location data as a basis for providing reporting services for each service and solution we provide. In this case, we may also provide device location data to third parties, including our partners.
In principle, we do not use device location data in combination with personal information. In addition, we and third parties who provide data from us are prohibited from acting that may identify individuals using device locations.
When implementing measures that combine personal information and device location data by the Company and a third party that provides services and data from the Company, it is defined as personal information in a state including device location data (e.g., visitor registration using EventPlus and dynamic analysis at the relevant exhibition), and is used and provided with permission from an individual in accordance with the Act on the Protection of Personal Information.
The Company will comply with the Japanese Act on the Protection of Personal Information and other laws and regulations regarding the data held and possible by the Company, and will review the contents of this Policy as appropriate and strive to improve it.
• Personal information protection approach
We conduct business activities centred on IT solutions and product sales, infrastructure services, system integration, custom development solutions, outsourcing services, etc. Personal information acquired from customers through business activities and personal information of our employees (hereinafter “personal information”, including specific personal information) we recognize that it is an important social responsibility of the Company to ensure the protection of personal information.
Therefore, the Company will handle personal information acquired through its business activities in accordance with the following policy, and will provide “peace of mind” to customers and employees of the Company and fulfil its social responsibilities with regard to the protection of personal information.
1. Acquisition, use and provide of personal information
- We will acquire personal information by lawful and fair means.
- We will use personal information within the scope necessary to achieve the purpose of use.
- When providing personal information to a third party, we will get the consent of the person in advance.
- We will not use the acquired personal information for any other purpose.
- If there is a need for use for a purpose other than the purpose, we will use it after obtaining the re-consent of the new purpose of use.
2. Laws and regulations, guidelines established by the government, and other norms (hereinafter called “laws and regulations”)
3. We will always strive to grasp laws and regulations related to the business that handles personal information, and we will inform and comply with employees engaged in our business (hereinafter called “employees”).
4. Regarding the safe management of personal information
- In order to prevent various risks such as unauthorized access to personal information, leakage, loss, or damage of personal information, we will establish and maintain a system to take prompt corrective measures for the safe management of personal information.
- We will conduct inspections, promptly correct any violations or accidents discovered, and take preventive measures against weaknesses.
- We will thoroughly educate our employees on safety.
5. Complaints and Consultations
For complaints and consultations regarding the handling of personal information, we will establish a personal information inquiry desk, establish a system that can respond promptly, and respond in good faith.
6. About continuous improvement
- In order to protect personal information, the Company’s personal information protection management system monitors and audits the status of compliance with internal regulations, strives to discover violations, incidents, accidents, and weaknesses, and conducts reviews by management.
- We will reflect this in our management measures and internal regulations, and strive to continuously improve our personal information protection management system.
- For improvement, we will comply with laws and regulations and JIS Q 15001.
Established: June 1, 2020
CEO Mr. Tiby Kuruvila
7. Handling of Personal Information
In accordance with JISQ15001 requirements, the Company monitors the following contents.
1. Purpose of use when acquired outside of direct written acquisition from the person in question
Types of personal information
Purpose of use
Migration data retrieved from trading partners
For data migration work, etc.
2. Purpose of use of personal information subject to disclosure
Types of personal information
Purpose of use
Materials Information of those who have received a request or inquiry
Responding to inquiries and service guidance
Customer and Business Partner Information
Communication with customers and business partners, performance of contracts, claims for performance, etc.
Information about candidates and applicants
Recruitment screening, communication
Employment management such as human resources and general affairs
Product buyer information on the Store site
For product shipment, etc.
8. Procedures for requesting disclosure, etc.
Notification of the purpose of use, disclosure, correction of the content, addition or deletion, suspension of use, erasure, and suspension of the offer to a third party with regard to personal information subject to disclosure held by the Company from the person in question or his/her agent (hereinafter, “request for disclosure, etc.”) The procedures for responding to the following are as follows.
• Where to request disclosure, etc.
For requests for disclosure, etc., please attach the necessary documents to the request for disclosure of personal information, etc., and mail it. When mailing an invoice to us, please use a method that allows you to check the delivery record, such as delivery record mail or simple registered mail.
In addition, I would appreciate it if you could write “Request for disclosure of personal information etc. in red” on the envelope.
• Documents submitted in requests for disclosure, etc.
When requesting disclosure, etc., please fill out all prescribed matters in the request for disclosure of personal information, etc., and mail it to us.
• Identity confirmation
The Company will be collecting by telephone in order to confirm the identity of the requester, such as disclosure. However, if you cannot check by phone, you may be asked to present a copy of your driver’s license, resident card, health insurance card, etc.
• Request for disclosure, etc. by an agent
When delegating to an agent about requesting disclosure, etc., please enclose the following documents in addition to the request for disclosure of personal information, etc.
a. Documents (copy) to confirm the identity of the agent
- A copy of your driver’s license, resident card, or health insurance card.
- Please prepare a copy filled with domicile.
b. Power of attorney
- Please stamp the power of attorney by the person in question and attach the seal registration certificate of the seal.)
- If the agent is a legal representative such as a parent or authority, it is also possible to submit documents that show the relationship with the person in question instead of a power of attorney.
• Fees related to disclosure and requests for notification of purpose of use
- When requesting disclosure of personal information and notification of the purpose of use, a fee of 500 yen (tax included) will be charged for each request. Please enclose a postal money order of 500 yen in the submitted documents.
- Please bear the fee for the purchase of the postal money order and the postage to us.
- Please note that we will not be notified of the purpose of disclosure or use if the fee is insufficient or if the fee is not enclosed.
• How to respond to requests for disclosure, etc.
- We will respond in writing to the address on the invoice of the requester.
- Complaints about personal data held, other unknowns, complaints, consultations, etc.
- If you have any questions, please contact the following office.
Personal information inquiry desk
Y’S Coral Build 5F, 2-20 Kanda-Kaguracho,
Chiyoda-ku, Tokyo 101-0051
Fax:03-6265-6475 (24 hours)
Personal Information Protection Manager – Mr. Tiby Kuruvila