Privacy Policy
Prometech Software, Inc. (the “Company”) understands the importance of protecting personal information, and will observe the Act on the Protection of Personal Information (the “Act”) and endeavor to handle and protect personal information in an appropriate manner in accordance with this Privacy Policy (the “Privacy Policy”). Unless otherwise expressly provided for herein, the defined terms in the Privacy Policy shall have the same meaning as defined in the Act.
1. DEFINITION
In the Privacy Policy, personal information shall mean “personal information” defined in paragraph 1 of Article 2 of the Act.
2. PURPOSE OF USE
The Company shall use personal information for the following purposes:
- Provision of the Company’s products or services;
- Notifications and responses to customer inquiries, with respect to the Company’s products or services;
- Announcement regarding the Company’s products or services, etc.;
- Dealing with breach of the Company’s terms of use, policy, etc. (the “Terms”), with respect to the Company’s products or services;
- Notifications of amendment to the Terms of the Company’s products or services;
- Improvement of the Company’s products or services and development of new products or services, etc.;
- Employment management and internal procedures of the Company (this shall apply to personal information of the Company’s directors, auditors and employees);
- Shareholders management and procedures required by applicable laws such as Companies Act (this shall apply to personal information of shareholders, holders of share options etc.);
- Creation of statistics data which is processed so that no particular individuals shall be identified, in connection with the Company’s services or products; or other purposes related to the above purposes.
3. CHANGE OF PURPOSE OF USE
The Company may change the purpose of use of personal information to the extent that the purpose of use after the change is reasonably deemed related to the original purpose of use. When the purpose of use has been changed, the Company shall notify the person identified by personal information (the “Principal”) of, or publicly announce the purpose of use after the change.
4. RESTRICTION ON USE
The Company shall not use personal information, without the consent of the relevant Principal, beyond the scope necessary for the achievement of the purpose of use, unless permitted by the Act or other laws or regulations; provided, however, that this provision shall not apply if:
- the use of personal information is based on laws and regulations;
- the use of personal information is necessary for the protection of the life, body or property of an individual and it is difficult to obtain the consent of the relevant Principal;
- the use of personal information is specially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the relevant Principal; or
- the use of personal information is necessary for cooperating with a national government, a local government, or a person or entity entrusted thereby in executing the affairs prescribed by laws and regulations and acquisition of the consent of the relevant Principal may impede the execution of the affairs concerned.
5. PROPER ACQUISITION
5.1
The Company shall acquire personal information by a proper means, and shall not acquire it by a deception or other wrongful means.
The Company shall acquire personal information by a proper means, and shall not acquire it by a deception or other wrongful means.
5.2
The Company shall not acquire special care-required personal information (as defined in Paragraph 1 of Article 2 of the Act) without obtaining in advance a Principal’s consent except:
The Company shall not acquire special care-required personal information (as defined in Paragraph 1 of Article 2 of the Act) without obtaining in advance a Principal’s consent except:
- in case of any of the items of Article 4;
- in cases where the special care-required personal information is being made available to the public by a Principal, a government organization, a local government, a person set forth in each Item of Paragraph 1 of Article 76 or other persons prescribed by rules of the Personal Information Protection Commission;
- in cases where the Company acquires externally obvious special care-required personal information by visual observation or by photographing; or
- in cases where the Company acquires special care-required personal information in the manner which does not fall under provision to a third party pursuant to the proviso to Article 7.1.
6. SECURITY CONTROL
The Company shall sufficiently and appropriately supervise the Company’s employee to ensure the security control of personal information against the risk of loss, destruction, alteration or leakage. When the Company entrusts a third party with the handling of personal information in whole or in part, the Company shall sufficiently and appropriately supervise the third party to ensure the security control of personal information.
7. PROVISION TO A THIRD PARTY
7.1
The Company shall not provide personal information to a third party without the prior consent of the relevant Principal, unless the disclosure falls under any of Items of Article 4; provided, however, that the following cases shall not be regarded as the provision to a third party:
The Company shall not provide personal information to a third party without the prior consent of the relevant Principal, unless the disclosure falls under any of Items of Article 4; provided, however, that the following cases shall not be regarded as the provision to a third party:
- Cases where the Company provides a third party with personal information for the purpose of entrusting handling of personal information within the scope necessary for the achievement of the purpose of use;
- Cases where personal information is provided as a result of the succession of business in a merger or otherwise; or
- Cases where personal information is used jointly with others in accordance with the provisions of the Act.
7.2
Notwithstanding Article 7.1, except in cases set forth in each Item of Article 4,in cases where the Company provides personal information to a third party (excluding a person having a system conforming to standards prescribed by the rules of the Personal Information Protection Commission pursuant to Article 24 of the Act) in a foreign country (excluding those prescribed by the rules of the Personal Information Protection Commission pursuant to Article 24 of the Act),the Company shall obtain a Principal’s prior consent on the provision to a third party in a foreign country.
Notwithstanding Article 7.1, except in cases set forth in each Item of Article 4,in cases where the Company provides personal information to a third party (excluding a person having a system conforming to standards prescribed by the rules of the Personal Information Protection Commission pursuant to Article 24 of the Act) in a foreign country (excluding those prescribed by the rules of the Personal Information Protection Commission pursuant to Article 24 of the Act),the Company shall obtain a Principal’s prior consent on the provision to a third party in a foreign country.
7.3
When the Company provides personal information to a third party in accordance with the provisions of Article 25 of the Act, the Company shall make and keep a record of the provision.
When the Company provides personal information to a third party in accordance with the provisions of Article 25 of the Act, the Company shall make and keep a record of the provision.
7.4
When the Company receives the provision of personal information from a third party, the Company shall make confirmation required by Article 26 of the Act and make and keep a record of the confirmation.
When the Company receives the provision of personal information from a third party, the Company shall make confirmation required by Article 26 of the Act and make and keep a record of the confirmation.
8. DISCLOSURE
In cases where the Company is requested by a Principal to disclose the personal information under the Act, the Company shall, after confirming that the request is made by the principal, disclose the personal information to the Principal without delay (in cases where the Company does not have such personal information, the Company shall notify the Principal to that effect); provided, however, that this provision shall not apply to cases where the Company is not obliged to disclose such personal information under the Act or other laws or regulations.
9. CORRECTION, ETC.
In cases where the Company is requested by a Principal to correct, add or delete the personal information under the Act on the ground that such personal information is contrary to the fact, the Company shall, after confirming that the request is made by the principal, conduct a necessary investigation without delay within the scope necessary for the achievement of the purpose of use, and on the basis of the result, correct, add or delete the personal information and notify the Principal to that effect (in cases where the Company decides not to make such correction, addition or deletion, the Company shall notify the Principal to that effect); provided, however, that this provision shall not apply to cases in which the Company is not obliged to make such correction, addition or deletion under the Act or other laws or regulations.
10. DISCONTINUANCE OF THE USE, ETC.
In cases where the Company is (i) requested by a Principal to discontinue using or to erase the personal information under the Act on the ground that such personal information is being handled beyond the purpose of use publicly announced in advance or has been acquired by a deception or other wrongful means, or (ii) requested by a Principal to discontinue providing the personal information under the Act on the ground that such personal information is provided to a third party without the Principal’s consent, and where it is found that the request has a reason, the Company shall, after confirming that the request is made by the principal, discontinue the use of or erase the personal information, or discontinue the provision of the personal information, without delay and shall notify the Principal to that effect; provided, however, that this provision shall not apply to cases in which the Company is not obliged to make such discontinuance of use or erasure, or discontinuance of provision, under the Act or other laws or regulations.
11. HANDLING OF ANONYMOUSLY PROCESSED INFORMATION
11.1
When the Company produces Anonymously Processed Information, the Company processes personal information in accordance with standards prescribed by the rules of the Personal Information Protection Commission. The "Anonymously Processed Information" means the information as defined in Paragraph 9 of Article 2 of the Act which is limited to those constituting Anonymously Processed Information database etc. as defined in Paragraph 10 of Article 2 of the Act.
When the Company produces Anonymously Processed Information, the Company processes personal information in accordance with standards prescribed by the rules of the Personal Information Protection Commission. The "Anonymously Processed Information" means the information as defined in Paragraph 9 of Article 2 of the Act which is limited to those constituting Anonymously Processed Information database etc. as defined in Paragraph 10 of Article 2 of the Act.
11.2
When the Company produces Anonymously Processed Information, the Company takes action for the security control of such information in accordance with standards prescribed by rules of the Personal Information.
When the Company produces Anonymously Processed Information, the Company takes action for the security control of such information in accordance with standards prescribed by rules of the Personal Information.
11.3
When the Company produces Anonymously Processed Information, the Company discloses to the public the categories of information relating to an individual contained in the Anonymously Processed Information pursuant to rules of the Personal Information Protection Commission.
When the Company produces Anonymously Processed Information, the Company discloses to the public the categories of information relating to an individual contained in the Anonymously Processed Information pursuant to rules of the Personal Information Protection Commission.
11.4
When the Company provides the Anonymously Processed Information (including Anonymously Processed Information produced by the Company and provided by third parties. The same shall apply hereinafter except as otherwise provided for in the Privacy Policy) to a third party, the Company discloses to the public the categories of information concerning an individual contained in Anonymously Processed Information to be provided to a third party and its providing method, and states to the third party explicitly to the effect that the information being provided is Anonymously Processed Information in advance pursuant to rules of the Personal Information Protection Commission.
When the Company provides the Anonymously Processed Information (including Anonymously Processed Information produced by the Company and provided by third parties. The same shall apply hereinafter except as otherwise provided for in the Privacy Policy) to a third party, the Company discloses to the public the categories of information concerning an individual contained in Anonymously Processed Information to be provided to a third party and its providing method, and states to the third party explicitly to the effect that the information being provided is Anonymously Processed Information in advance pursuant to rules of the Personal Information Protection Commission.
11.5
In handling Anonymously Processed Information, the Company shall, in order to identify a principal concerned with personal information used to produce the Anonymously Processed Information, neither (i) collate the Anonymously Processed Information with other information, nor (ii) acquire information relating to those descriptions etc. or individual identification codes deleted from the personal information and information relating to a processing method carried out pursuant to the provisions of Paragraph 1 of Article 36 of the Act in connection with Anonymously Processed Information provided by third parties.
In handling Anonymously Processed Information, the Company shall, in order to identify a principal concerned with personal information used to produce the Anonymously Processed Information, neither (i) collate the Anonymously Processed Information with other information, nor (ii) acquire information relating to those descriptions etc. or individual identification codes deleted from the personal information and information relating to a processing method carried out pursuant to the provisions of Paragraph 1 of Article 36 of the Act in connection with Anonymously Processed Information provided by third parties.
11.6
The Company shall make efforts to (i) take necessary and appropriate measures for the security control of Anonymously Processed Information and necessary action to ensure the proper handling of Anonymously Processed Information such as dealing with a complaint about the handling of Anonymously Processed Information, and (ii) to disclose to the public the contents of such measures.
The Company shall make efforts to (i) take necessary and appropriate measures for the security control of Anonymously Processed Information and necessary action to ensure the proper handling of Anonymously Processed Information such as dealing with a complaint about the handling of Anonymously Processed Information, and (ii) to disclose to the public the contents of such measures.
12. USE OF COOKIES AND OTHER TECHNOLOGIES
Cookies or similar technologies may be used in the Company’s service. Google Analytics may also be used in the Company’s service with such technologies. Such technologies and Google Analytics help the Company to recognize the status of use of the Company’s service, etc. and contribute improvement of the service. When a user intends to disable cookies, the user may disable cookies by changing the web browser’s settings. Please note that when cookies are disabled, a part of the service may be unavailable.
Google Analytics’ system to collect and process data may be confirmed on the website of Google Analytics as following URL.
www.google.com/policies/privacy/partners/
Google Analytics’ system to collect and process data may be confirmed on the website of Google Analytics as following URL.
www.google.com/policies/privacy/partners/
13. CONTACT
With respect to requests for disclosure, etc., comments, questions, complaints and other inquiries regarding the handling of personal information, please contact the following.
113-0033 Hongo Daiichi bldg. 8F, 3-34-3, Hongo Bunkyo-ku, Tokyo
Prometech Software, Inc. corporate planning department
E-mail:web@prometech.co.jp
Please note that the Company shall receive the contacts from 10:00 to 17:00 on weekdays.
Prometech Software, Inc. corporate planning department
E-mail:web@prometech.co.jp
Please note that the Company shall receive the contacts from 10:00 to 17:00 on weekdays.
14. CONTINUOUS IMPROVEMENT
The Company shall endeavor to review timely the status of the operation regarding handling of personal information and to improve such operation continuously. The Company may amend this Privacy Policy as necessary.
Effective as of March 6, 2017
Revised as of March 23, 2020
Revised as of March 23, 2020