VISITS Design-Tech Company

Policy on Protection of Personal Information


Established on June 1st, 2015
Revised on October 1st, 2018
VISITS Technologies Inc.
Representative Director, Masaru Matsumoto


1. Policy of Personal Information Protection
VISITS Technologies Inc. (“VISITS Technologies”, “we” or “us”) fully recognizes its social responsibilities to protect all personal information handled, and to follow all laws and regulations on the protection of individuals’ rights and personal information. We hereby declare that, in order to comply with the following policy, we will establish a management system to protect personal information and the company will continuously make improvements while keeping up with trends in IT technologies, social changes and business environments etc. The Policy described below applies to all personal information collected from individuals in Japan.

  1. 1. We collect, use and provide personal information only to the extent that it is necessary for our legitimate business operation, and recruiting and management of human resources. We will not use Personal information beyond the extent that is necessary for these specified purposes of use. We will take measures to prevent usage for purposes other than the aforementioned purposes.
  2. 2. We comply with laws, regulations, guidelines and other standards as stipulated by the government.
  3. 3. We will invest business resources which reflect the business and continuously improve the security system of personal information gathered, so that reasonable preventive and precautionary security measures can be taken against risks of leakage, loss and damages. In case of an accident, prompt corrective measures will be taken.
  4. 4. We will respond appropriately and promptly to complaints and/or consultations regarding the handling of personal information in a sincere manner.
  5. 5. We will review management systems to protect personal Information in a timely and appropriate manner, with consideration to changes in the business environments, so that we can continuously facilitate improvements to the system. This policy shall be distributed to all employees, and shall be available to anyone at any time by publication on publicly accessible mediums such as on our website and in pamphlets etc.

VISITS Technologies Inc. (“VISITS Technologies”, “we” or “us”) fully recognizes its social responsibilities to protect all personal information we handle, and we follow all the laws and regulations on protection of individuals’ rights and personal information. We hereby declare that in order to embody the following policy, we establish a management system to protect personal information and the whole company of us will continuously make improvement while always recognizing the trends of IT technologies, changes of social necessities and business environments etc. The Policy described below applies to all personal information we collect from individuals in Japan.

  1. 1. We collect, use and provide personal information only to the extent necessary for our legitimate business operation, and recruiting and management of human resources. We never use Personal information beyond the extent necessary to achieve specified purposes of use. We will take measures to prevent usage for the purposes other than the specified ones.
  2. 2. We comply with laws, regulations, guidelines stipulated by the government and other standards.
  3. 3. We will invest business resources which reflect the reality of the business and continuously improve the security system for persona information, so that we can take reasonable and precautionary security measures against risks of leakage, loss and damages of personal information and we can prevent such an event. In case of an accident, we will take corrective measures promptly.
  4. 4. We will make appropriate responds to complaints or consultation on handling personal information in a prompt and sincere manner.
  5. 5. We will review the management system to protect personal Information timely and appropriately in considering changes of environments surrounding us, so that we can continuously facilitate improvements of the system.

This policy shall be distributed to all employees, and shall be available to anyone at any time by publication on publicly accessible mediums such as on our website and in pamphlets etc.

[Inquiries]
Please contact us if you have any inquiries regarding this Policy:
Personal Information Inquiry Desk
VISITS Technologies Inc.
Address: Yusen Building 2F, 2-3-2 Marunouchi, Chiyoda-ku, Tokyo, 100-0005
E-mail: info@vis-its.com TEL: +81-3-6434-5441
(open from 10 a.m. to 5 p.m. during weekdays except holidays or year-end/year beginning period)

2. Public Announcement on Personal Information

■Handling of Personal Information
  1. 1. Purpose of use of the personal information we collect directly from you in writing (including those on website and via email etc.):
    We will inform you of the purpose of use in writing in prior to such collection.
  2. 2. Purpose of use of the personal information that we collect in a manner other than that described in the previous provision:
    Categories Purpose of use
    Personal information of individuals Management of use history
    Responding to customer inquiries
    Personal information of contact person(s) for business partners Confirmation of orders (correspondence records etc.)
    Personal information of job applicants via recruitment websites. Employment selection

CategoriesPurpose of use
Personal information of individualsManagement of use history
Responding to customer inquiries
Personal information of contact person(s) for business partnersConfirmation of orders (correspondence records etc.)
Personal information of job applicants via recruitment websites.Employment selection


■Announcement on matters related to personal information to be disclosed
As to the personal information subject to disclosure held by the Company, notification of the purpose of use from the person or his agent, disclosure, correction of content, addition or deletion, suspension of use, erasure, and suspension of provision to third parties (Hereinafter referred to as “Disclosure Request”) will be handled in the following manner.

a) Company Name
VISITS Technologies Inc.

b) Personal information protection manager
Name of Manager:Kenichi Hikita
Department:Corporate Department
Contact information: Email: info@vis-its.com  TEL:+81 3 6434 5441

c) Purposes of use of personal information to be disclosed
Categories Purpose of use
Personal information of individuals Provision of user support
Management of use history
Advertisement of our services
Responding to inquiries
Personal information of contact person(s) for business partners Confirmation of orders (correspondence records etc.)
Our employees Management of labor, business operation, health and security of employees
Personal information of job applicants Contacting job applicants and management of employment selection
Specific Personal Information For the purpose of use stipulated in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures

CategoriesPurpose of use
Personal information of individuals Provision of user support
Management of use history
Advertisement of our services
Responding to inquiries
Personal information of contact person(s) for business partnersConfirmation of orders (correspondence records etc.)
Our employeesManagement of labor, business operation, health and security of employees
Personal information of job applicants to usContact to job applicants and management of employment selection
Specific Personal InformationFor the purpose of use stipulated in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures


d) Contact information for complaints on handling the personal information to be disclosed.
Personal Information Inquiry Desk
VISITS Technologies Inc.
Address: Yusen Building 2F, 2-3-2 Marunouchi, Chiyoda-ku, Tokyo, 100-0005
E-mail: info@vis-its.com TEL: +81-3-6434-5441
(open from 10 a.m. to 5 p.m. during weekdays except Japanese national holidays and year-end/new-year period)

e) Authorized personal information protection organization
We are a member of the following authorized personal information protection organization.
You can file complaints regarding our handling of personal information to the following.

JIPDEC
Complaint consultation office on personal information protection
Address: Roppongi First Building 12F, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
TEL: +81-3-5860-7565 / 0120-700-779 (for domestic call only)
[Note: This is not contact information for inquiries on our products and services.]

f) Procedures for Disclosure Request of personal information to be disclosed
1) Department to which a Disclosure Request should be made
Please send your Disclosure Request to the Personal Information Inquiry Desk stated above.

2) Procedures for Disclosure Request
(i) Upon receipt of your request, we will send you a designated form titled “request letter for personal information to be disclosed” by postal mail.
(ii) Please send back a completed request letter to the above-mentioned Personal Information Inquiry Desk, in the case of request by representatives, together with a document which indicates that the requesting person is a representative of the person concerned, and a postal money order (yuubin kawase) for the amount of procedural fees (only in the case of requesting notice of purposes of use and disclosure).
(ii) Upon receipt of the above-mentioned request letter, for the purpose of identity verification, we will contact you in order to confirm identification information (e.g. telephone number and date of birth) registered with us.
(iv) In principle, our responses will be made in writing to the person concerned (a letter by postal mail).

3) Documents which indicates that the requesting person is a representative in the case of requests by representatives
If the person making the Disclosure Request etc. is a representative of the person concerned, please enclose i) a document to prove representation is being made, and ii) a document to prove the representative’s identity. The permanent address information included in each document should only show the prefecture of domicile and the following address information (City, Town etc.) is to be blacked out. Similarly, ensure that Personal Identification Numbers are also blacked out on documents provided.

(i) Documents to Prove Representation

Power of Attorney (original copy)


Copy of one of the documents listed below:
- Certified copy of the entire family register
- Certificate of residence (relationship to be described)
- Other formal document which proves legal representation


Copy of one of the documents listed below:
- Registration certificate of the adult ward register
- Other formal documents which prove legal representation

(ii) Document to prove representative’s identity
- Driving license
- Passport
- Health insurance card
- Certificate of residence
- Basic resident register card
4) Procedural fee for notification of purpose of use or request for disclosure
1000 JPY per request
(Please enclose a postal money order (yuubin kawase) together with the request form etc.)


3. Global Policy on Handling of Personal Information

The Policy described below applies to all personal information we collect. Personal information here means the same as Data Protection Regulation (“GDPR”), which is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

■Name and address of controller of personal information
Personal Information Inquiry Desk
VISITS Technologies Inc.
Address: Yusen Building 2F, 2-3-2 Marunouchi, Chiyoda-ku, Tokyo, 100-0005
E-mail: info@vis-its.com TEL: +81-3-6434-5441

■Personal information we may collect

•  your contact information, such as full name and email address;
•  your username and password;
•  your work title, department information and other information related to your work or organization;
•  the content, communications and other information you provide when you use our services, including when you sign up for an account, create or share content, and message or communicate with others;
•  billing information;
•  information that you provide when you or your organization contact or engage our support regarding the Service.
•  job applications and related information when you apply for a job with us; and
•  when you use our online services, we also store cookies to provide user-friendly online service according to your previous visit to our website.

■How we use your personal information

Your personal information will be collected and handled by us for the following purposes:
•  Procedures for registration of use of the Service;
•  Provision of the Service;
•  Delivery of notices, etc. in connection with the use of the Service;
•  Surveys and monitor campaign etc. for improvement of the Service;
•  Provision of support and response to inquiries in relation to the use of the Service;
•  Provision of information about services of VISITS Group; and
•  Inspection of registration with false information and application for commercial or fraudulent use which are prohibited under the terms of use as well as confirmation of details of the application based thereon.
■Our use of your information as described above is permitted by applicable data protection law because it is:
• Necessary for our legitimate interests in pursuing the purposes set out above, and such interests in each case not being overridden by your privacy interests;
•  In some cases, necessary to meet our legal or regulatory responsibilities, such as disclosures to authorities, regulators or government bodies; or
•  In some cases, necessary for the performance of a task carried out in the public interest and, when we use special categories of personal information, necessary for establishing. exercising or defending legal claims or where the processing relates to personal information manifestly in the public domain; or
•  In limited circumstances, processed with your consent which we obtain from you from time to time.
•  We will keep your personal information for the period required in order to meet our legal or regulatory responsibilities under Japanese laws and regulations. Upon expiration of such period, we will dispose of your personal information promptly unless it is necessary in relation to contractual and other processual purposes..


■Sharing with third parties
we never disclose your personal information to third parties unless we have obtained your consent or required to do so under laws and regulations.
■IP addresses and cookies

We collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns and does not identify you or any individual.
For the same reason, we obtain information about your general internet usage by using a cookie file which is stored on your device. Cookies help us to improve our website and to deliver a better and more personalized content. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the storing of cookies. This will remove all details from the cookie. However, if you select this setting you may be unable to access certain parts of our website or use certain functionality.


■Transfer of your data

Your personal information can be transferred to and/or processed in one or more countries such as Japan. The transfer of personal information to Japan or the other countries other than Member State of European Union can be on the basis of an adequacy decision by the European Commission or Standard Contractual Clauses (“SCC”) we may enter from time to time. For details of the adequacy decision related to Japan, please refer to the website of European Union (https://ec.europa.eu/info/law/law-topic/data-protection_en)
.
■Your rights. How you can access, correct and delete your personal information
Under applicable data protection laws, you have the following rights:

•  Right to access and obtain a copy of your personal information.
•  Right to correct your personal information: If you can demonstrate that the personal information we hold about you is not correct, you can ask that this information is updated or otherwise corrected.
•  Right to be forgotten/have data deleted: In certain circumstances you have the right to have your personal data deleted.
•  Right to restrict or object to the processing of your data: In certain circumstances you have the right to obtain restriction of the processing of your personal information, or to object on certain processing thereof on grounds relating to your particular situation.
To exercise your rights, you can contact us at the following address: info@vis-its.com. .
To the extent our processing of your personal information is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of such withdrawal.
You can also lodge a complaint about our processing of your personal information with the data protection authority of the Member State of the European Union of your habitual residence, of your place of work, or of an alleged infringement of your rights.

■Changes to this Policy
The terms of this Policy may change from time to time. We shall publish any material changes to this Policy through appropriate notices either on this website or contacting you using other communication channels.

■Contact
Questions, comments and requests regarding this Policy are welcomed and should be addressed to personal information Inquiry Desk stated above.