Date of enactment: 1 June 2014
Date of final revision: 1 December 2015
Uzabase, Inc. (hereinafter “the Company”) provides information infrastructure supporting decision-making in business activities. The Company is aware of its social responsibility in protecting personal information that it handles, protects individual rights and interests, and observes rules and regulations concerning personal information.
In order to realise the principles noted below, the Company shall build a personal information protection management system. The Company also hereby declares that the entire company will endeavour to continuously improve the system with constant awareness of the latest IT trends and changes in social requirements and business environment.
- Principle 1. The Company shall endeavour to specify the purpose for which personal information will be utilised. It will not handle personal information that is beyond the necessary scope to fulfil that purpose. The Company shall also take appropriate measures to achieve this.
- Principle 2. The Company shall observe laws, ordinances, state policies, and other rules and regulations concerning personal information management.
- Principle 3. The Company shall stipulate internal regulations concerning complaints and consultation requests regarding personal information management. The Company shall respond to such complaints and consultation requests swiftly and in good faith.
- Principle 4. The Company shall endeavour to take necessary and appropriate measures to ensure the security of personal information, including the prevention and correction of instances of personal information leakage, loss, and damage.
- Principle 5. The Company shall stipulate internal regulations concerning personal information protection and make appropriate revisions in a timely manner to promote constant improvements.
PrivacyMark System is a system set up to assess enterprises that take appropriate measures to protect personal information, in compliance with Japan Industrial Standards (JIS Q 15001:2006 [Personal Information Protection Management System – Requirements]). Enterprises that are assessed as qualified will be granted the right to display the “PrivacyMark” in the course of their business activities.
1．Definition of Personal Information
Nevertheless, in the event that Act No. 57 of the May 30 2003 Act on Protection of Personal Information (hereinafter referred to as “the Act”) and any of its relevant laws and ordinances are revised, the definition shall follow such revision(s).
2．Purpose of Personal Information Utilisation
The Company uses personal information for the purposes listed below. In cases where changes in the purpose of utilisation are necessary, the Company will issue a notification or make a public announcement regarding such changes in a timely manner.
- Personal information contained in employment contracts will only be used for the purpose of employment contract management.
- Personal information of employees will only be used for the purpose of employment and human resource management.
- Personal information of job applicants that is submitted to the Company will only be used for the purpose of applicant assessment. It should be noted that in the course of recruitment, the Company may receive job applicants’ personal information (e.g. past work experience) from employment agencies, however such personal information shall only be used for the purpose of recruitment and assessment, and will not be used for any other purposes.
- Personal information of clients will be used for the purpose of business contact and business development and progress.
- Personal information of subscribers to services that the Company operates and provides will be used for specified purposes in accordance with the terms and conditions of each service’s privacy policies.
3．Provision of Personal Information to a Third Party
The Company will not provide personal information to a third party except in the following circumstances:
- In cases where prior consent on such action has been obtained;
- In cases where such action is conducted in accordance with the Act and other laws and ordinances;
- In cases where such action is necessary in order to protect individuals from life threats, physical injuries, and property damage, and where there is difficulty in obtaining the Subject’s consent;
- In cases where personal information management is outsourced partially or wholly (including server storage) to an external enterprise in accordance with a business outsourcing contract, the Company will sign an agreement with the third party concerning personal information management and/or appropriately supervise the third party regarding security management of personal information;
- In cases where business succession as a result of a merger or acquisition, company split, business transfer, etc. has taken place.
4．Joint Utilisation of Personal Information
In order to provide better services, the Company will share and jointly utilise personal information with its affiliates as listed below under strict management and with appropriate security measures.
Affiliates allowed for personal information sharing are:
- NewsPicks, Inc.
- Uzabase Asia Pacific Pte. Ltd.
- Uzabase Hong Kong Limited
- Shanghai Uzabase Information & Technology Co., Ltd
5．Procedures for Consultation and Disclosure Requests Concerning Personal Information Management
If an individual has complaints and/or requests for disclosure, correction, and termination of use of their personal information, they should contact the Company through the following email address (firstname.lastname@example.org), and the Company will respond to such requests when the individual’s identity has been confirmed.
6．Procedures for Disclosure Requests
- Personal information that is disclosed by the Company (hereinafter referred to as “Personal Information subject to Disclosure”) refers to personal information as listed below that is either a collection of information systematically organised to be searched on a computer, or a collection of information systematically organised, classified, categorised, or coded in line with specific rules so that particular personal information can be searched easily, to which the Company is entitled with all rights including notification of the purpose of utilisation, disclosure of information, correction, addition, and/or deletion of content, termination of utilisation, elimination of information, and termination of provision to a third party as requested by the Subject.
- Personal information of customers that the Company acquires from each of its businesses (excluding personal information temporarily provided to the Company by suppliers and/or contractors in the case of business outsourcing);
- Personal information of clients;
- Personal information related to employment management of all employees;
- Personal information of job applicants; however, personal information such as past work experience of applicants that the Company acquires from employment agencies is excluded from Personal Information subject to Disclosure, and therefore the Company is unable to respond to requests for disclosure, etc. of such information;
- Personal information obtained through any enquiry to the Company.
- Those that request disclosure of Personal Information subject to Disclosure should submit an email enquiry to email@example.com and provide necessary information in a written format designated by the Company.。
- Such requests for disclosure should be confirmed and authenticated by the Subject. Under certain circumstances, the Subject may be asked to deliver copies of official documents for authentication.
7．Major Changes and Notifications
In case of major changes and notifications regarding personal information protection, the Company will make public announcements through its website and/or via other channels.
8．Revisions of the Principles
In order to constantly improve its personal information management, the Company may change and revise the Principles, under which circumstances the Company shall release the revised Policy on the company website that it operates.
When such revision requires customers’ consent under relevant laws and ordinances, the Company shall obtain such consent in a manner designated by the Company.
9．Personal Information Protection Supervisor
Uzabase, Inc. Executive Officer in Charge of Administration
Address: 10/F Ebisu First Square, 1-18-14 Ebisu, Shibuya-ku, Tokyo, Japan