COTOBA DESIGN, Inc. (“Company”) acknowledges the significance of the protection of personal information. The Company is therefore committed to properly handling and protecting personal information in compliance with the Act on the Protection of Personal Information of Japan (“PPI Act”) and the Company’s Privacy Policy as follows. Unless otherwise specified herein, the terms used in this Privacy Policy have the same meanings as set forth in the PPI Act.
In this Privacy Policy, “Personal Information” means personal information as defined in Article 2, paragraph (1) of the PPI Act.
The Company may utilize Personal Information for the purposes specified below.
(1) Sending the Company’s brochures, guide books or other information materials or responding to inquiries to those who have contacted the Company
(2) Responding to applicants or candidates in the context of the Company’s recruiting activities
(3) Activities incidental to or associated with any purpose described above
The Company may change the purpose of utilizing specific Personal Information within a scope that is reasonably determined to pertain to the pre-changed purpose. Such change, if any, will be communicated to the individual who is identified or may be deduced from the Personal Information in question (“Individual”) or publicly announced.
Except as otherwise permitted under the PPI Act or any other relevant laws of Japan, the Company will not handle any Personal Information beyond the range necessary for achieving a specific purpose without obtaining the Individual’s consent. However, the foregoing will not apply in any of the following cases.
(1) When the Company needs to utilize the Personal Information based on relevant laws
(2) When the Company needs to utilize the Personal Information for the purpose of protecting the life, body or property of humans in such a situation where it is difficult to obtain the Individual’s consent
(3) When the Company needs to utilize the Personal Information specifically for the purpose of improving public health or promoting the sound growth and development of children in such a situation where it is difficult to obtain the Individual’s consent
(4) When the Company needs to cooperate with the national or any local government or its designated person in the conduct of certain public affairs specified by applicable laws, which conduct might be adversely affected if the Company obtained or attempted to obtain the Individual’s consent
5.1 The Company is committed to acquiring Personal Information properly. The Company will never use any fraudulent or improper means for such acquisition.
5.2 Except in the cases specified below, the Company will never acquire any sensitive Personal Information (meaning “special care-required personal information” defined in Article 2, paragraph (3) of the PPI Act) without obtaining the Individual’s prior consent.
(1) When the Company needs to acquire sensitive Personal Information based on relevant laws
(2) When the Company needs to acquire the sensitive Personal Information for the purpose of protecting the life, body or property of humans in such a situation where it is difficult to obtain the Individual’s consent
(3) When the Company needs to acquire the sensitive Personal Information specifically for the purpose of improving public health or promoting the sound growth and development of children in such a situation where it is difficult to obtain the Individual’s consent
(4) When the Company needs to cooperate with the national or any local government or its designated person in the conduct of certain public affairs specified by applicable laws, which conduct might be adversely affected if the Company obtained or attempted to obtain the Individual’s consent
5.3 When receiving Personal Information from a third party, the Company will confirm the points listed below pursuant to applicable guidelines of the Personal Information Protection Commission (an external bureau of the Cabinet Office of Japan). However, the foregoing will not apply if the Personal Information is provided in any case as described in Section 4 above or if the Personal Information is received in a situation described in the second sentence of Section 7.1 where providing Personal Information to a third party without obtaining the Individual’s prior consent is not prohibited.
(1) The personal name or entity name and address of the third party, and the name of the third party’s representative if it is a corporation (or the third party’s representative or administrator if it is an organization without legal personality and is required to have a representative or administrator under its charter)
(2) Circumstances under which the third party has acquired such Personal Information
The Company is committed to providing necessary and appropriate supervision over its personnel in order to control risks of loss, corruption, unauthorized modification, leaks or other misuse of Personal Information and to safeguard Personal Information. If the Company outsources the whole or any part of its operations for handling Personal Information, the Company will provide the necessary and appropriate supervision over the outsourcing partner(s) to ensure their proper implementation of security control measures for Personal Information.
7.1 Except in the cases listed in Section 4, the Company will not provide any Personal Information to a third party without obtaining the Individual’s prior consent. However, each of the cases listed below does not constitute a case referred to in the preceding sentence where providing Personal Information to a third party without obtaining the Individual’s prior consent is prohibited.
(1) When the Company provides the Personal Information, to the extent necessary for achieving the specified purposes of its utilization, to a third party acting as an outsourcing partner who undertakes the whole or part of the Company’s operations for handling Personal Information
(2) When the Personal Information is provided in the context of business succession due to a merger or on other grounds
(3) In the event of joint utilization of the Personal Information pursuant to Section 8
7.2 Notwithstanding Section 7.1, if the Company intends to provide any Personal Information to a third party (excluding those who are recognized as operating a framework conforming to the standards specified in applicable guidelines of the Personal Information Protection Commission pursuant to Article 24 of the PPI Act) in a foreign country (excluding those designated under applicable guidelines of the Personal Information Protection Commission pursuant to Article 24 of the PPI Act), the Company will obtain the Individual’s prior consent to such provision to the foreign third party, except in the cases specified in Section 4.
7.3 If the Company has provided any Personal Information to a third party, the Company will create and maintain a record on such provision pursuant to Article 25 of the PPI Act.
7.4 If the Company intends to receive any Personal Information from a third party, the Company will conduct necessary confirmation and create and maintain a record on such confirmation pursuant to Article 26 of the PPI Act.
If any Personal Information is to be jointly utilized, the Company will conform to the following conditions and the Personal Information to be jointly utilized may be provided solely to the users specified below.
(1) Categories of Personal Information that can be jointly utilized
None
(2) Scope of users other than the Company’s personnel who are authorized to jointly utilize the Personal Information
None
(3) Purposes of utilization by the authorized users described above
None
(4) Name of the person responsible for controlling the joint utilization
COTOBA DESIGN, Inc.
If an Individual requests the Company to disclose his/her Personal Information pursuant to applicable provisions of the PPI Act, the Company will disclose the requested information to the Individual without delay after confirming that such request is based on the Individual’s intention (or inform the Individual that the Company does not retain the requested information, where applicable). However, the foregoing will not apply if the Company is not obligated to make disclosure under the PPI Act or any other relevant laws of Japan.
If an Individual requests the Company to correct, add or delete any data related to his/her Personal Information pursuant to applicable provisions of the PPI Act on the grounds that his/her Personal Information retained by the Company is incorrect, the Company will investigate the situation to the extent necessary for achieving the specified purposes of utilization without delay after confirming that such request is based on the Individual’s intention, and then the Company will correct, add or delete the Personal Information based on the investigation findings and inform the Individual of such correction, addition or deletion (or inform the Individual that the Company has decided not to carry out any correction, addition or deletion, where applicable). However, the foregoing will not apply if the Company is not obligated to carry out correction, addition or deletion under the PPI Act or any other relevant laws of Japan.
In the case where an Individual requests the Company to cease its utilization of his/her Personal Information or to delete the same pursuant to applicable provisions of the PPI Act on the grounds that his/her Personal Information is handled beyond the scope of utilization publicly announced by the Company in advance or has been acquired through any fraudulent or improper means, or requests the Company to stop providing his/her Personal Information to any third party pursuant to applicable provisions of the PPI Act on the grounds that it is provided without his/her consent, if the Company determines that such request is well-founded, the Company will cease its utilization or provision of the Personal Information or delete the same without delay after confirming that such request is based on the Individual’s intention, and the Company will inform the Individual of such cessation or deletion. However, the foregoing will not apply if the Company is not obligated to cease its utilization or provision of the Personal Information or delete the same under the PPI Act or any other relevant laws of Japan.
The Company may use cookies and similar technologies in its services. Such technologies help the Company understand the status of access to and interaction with the Company’s services and improve the quality and functionality of those services. Users who wish to disable cookies can block cookies by changing their web browser settings. However, disabling cookies may result in loss of some functionality and features in the Company’s services.
Those who wish to ask for disclosure, etc. of their Personal Information, convey opinions, file complaints, or make inquiries about the handling of Personal Information in any other respect are requested to send messages to the Company in its prescribed online contact form.
The Company will review its operations for handling Personal Information from time to time and endeavor to improve such operations on an ongoing basis. As necessary, the Company may appropriately revise this Privacy Policy.
Established as of August 17, 2017