Privacy Policy

Rules

The Company will comply with laws, ordinances, government guidelines, and other regulations regarding the handling of personal information.

1. Definition of Personal Information

The Company defines “personal information” as information about living individuals (name, date of birth, and other personally identifiable information) as defined in the Act on the Protection of Personal Information (APPI) in addition to e-mail addresses, credit card information, and other information used in connection with a specific individual and information relating to personal attributes (e.g., age, income, interests, and family structure) associated with personal information.
Should the APPI or other applicable laws and regulations be amended, the definition of “personal information” shall be applied accordingly.

2. Acquisition of Personal Information

The Company shall acquire and handle the following information under strict control. The Company shall not receive personal information other than that listed below:

1. Personal information of customers and business partners (hereinafter referred to as “the Customer”)

   1-1: Personally identifiable information such as name, e-mail address, date of birth, department, and job title of the Customer

   1-2: Information about individuals, such as information entered or otherwise transmitted by the Customer using the Service (clap history data, point redemption by users on this website, and search history data)

   1-3: Names of departments under supervision of managers

2. Personal information obtained in relation to inquiries, etc.
3. Personal information of applicants for employment (including internships)
4. Personal information of shareholders
5. Personal information of executives, employees, temporary workers, etc.

Appropriate Acquisition of Personal Information

The Company shall acquire personal information in an appropriate manner and will never obtain such information through deception or other wrongful means.

3. Purpose of Use of Personal Information

The Company shall use personal information for the following purposes:

1. Personal information specified in 2.1 above
   • Business communication, execution of transactions and contracts, and other administrative functions
   • Communication of information on events and seminars and other communications
   • Provision and improvement of different services operated by the Company (hereinafter referred to as the “Service”)
2. Personal information specified in 2.2 above
   • Responses to inquiries, provision of materials, and other communications
3. Personal information specified in 2.3 above
   • Notification of job offers, selection results and employment, and other communications
4. Personal information specified in 2.4 above
   • Management of shareholders such as preparation of shareholder registry in accordance with the Companies Act and other applicable laws and regulations
   • Provision of benefits and implementation of other measures for shareholders
5. Personal information specified in 2.5 above
   • Workforce and labor management
   • Reports pursuant to the Companies Act and applicable laws and regulations

Changes to Purpose of Use of Personal Information

The Company shall modify the purpose of use of personal information only to the extent deemed reasonably relevant and shall notify or publicly announce any such modification to the individual concerned.

4. Provision of Personal Information

Shared Use

The Company shall share personal information obtained from the Customer as described below and shall provide personal information to the parties specified below for shared use.

1. Types of personal information to be shared
   • Personal information specified in 2-1 above
   • Information about the Customer’s personal relationships (including, but not limited to, the existence or absence of personal connections and the details thereof, as well as information about parties involved in projects in which the Customer participates) extracted from external services (i.e., services provided by Microsoft Teams and other business operators and linked to the Service) linked to the use of the Service
2. Scope of shared use
   • Companies with which the Customer is affiliated
3. Information users’ purpose of use
   • Display on the Service
   • Analysis of the information described in (1.) above to improve the quality of services
   • Provision of services, etc.
4. Name of the person responsible for the management of the above personal information
   • General Manager of Business Management Department at Unipos Inc.

Restrictions on Use of Personal Information

The Company never handles personal information beyond the scope necessary to fulfill the purpose of use without obtaining the prior consent of the individual who has provided such information, except as permitted by the APPI or other applicable laws and regulations, provided, however, that this shall not apply in the following cases:

• Cases where required by law
• Cases in which the use of personal information is necessary for the protection of the life, body, or property of an individual but it is difficult to obtain the consent of the individual
• Cases in which the use of personal information is particularly necessary for the improvement of public health or the promotion of the sound growth of children but it is difficult to obtain the consent of the individual to whom the information pertains
• Cases in which the handling of personal information is necessary for cooperating with a national government agency, a local government, or an individual or entity entrusted by either a national government agency or local government to execute affairs prescribed by law but obtaining the consent of the individual to whom said information pertains is likely to impede the execution of such affairs

Restrictions on Provision to Third Parties

1. The Company never provides personal information to third parties without obtaining the prior consent of the individual to whom the information pertains, except in cases where disclosure is permitted under the APPI or other applicable laws and regulations, provided, however, that this shall not apply to the following cases:
   • Cases in which the Company outsources all or part of the handling of personal information within the scope necessary for the fulfillment of the purpose of use
   • Cases in which personal information is provided as a result of the succession of business due to merger or other reasons
   • Cases in which the Company shares personal information with its group companies, business partners, or other entities, and the Company notifies the individual to whom the information pertains of or makes readily accessible to the individual in advance the types of personal information to be shared, the scope of shared use of the personal information, its purpose of use, and the name of the person responsible for managing the personal information
2. The Company never provides personal information to a third party in a foreign country without obtaining the prior consent of the individual to whom the information pertains, except as required by laws and regulations, etc.

Handling of Personal Information by Third Parties in Foreign Countries

When providing personal information to a third party in a foreign country, the Company shall obtain the consent of the individual to whom the information pertains to allow the provision of the information to the third party in the foreign country in advance.

1. Name of the foreign country: United States of America
2. Information regarding the system for the protection of personal information in the foreign country
   United States of America (federal government): https://www.ppc.go.jp/files/pdf/USA_report.pdf
3. Information on measures taken by the third party to protect personal information The following services comply with GDPR and take measures to protect personal information
   corresponding to the 8 principles of the OECD Privacy Guidelines.
   
   Service name：Mailgun(https://www.mailgun.com/)
   URL of the service’s privacy policy：https://www.mailgun.com/privacy-policy/
   Items of Information Provided：Personal information in 2-1 above
   Purpose of use：Sending emails to customers, etc.
   
   Service name：Azure OpenAI Service(https://azure.microsoft.com/en-us/products/cognitive-services/openai-service/)
   URL of the service’s privacy policy：https://privacy.microsoft.com/en-us/privacystatement
   Items of Information Provided：Personal information in 2-1 above
   Purpose of use：Improving the posting experience

5. Your Rights

Disclosure of Personal Information

When individuals request the Company to disclose their personal information in accordance with the provisions of the APPI, the Company will disclose their personal information as soon as they are identified as the individual to whom the information pertains. To request disclosure of personal information, please contact us. However, we may not disclose all or part of the information in the following cases. Those wishing to request the disclosure of their personal information should be informed that a fee (3,000 yen per request) will be charged for the disclosure of personal information.

• Cases in which there is a risk of harm to the life, body, property, or other rights or interests of the individual to whom the information pertains or to a third party
• Cases in which the disclosure of personal information is likely to cause significant hindrance to the proper conduct of the Company’s business
• Cases in which the disclosure of personal information may violate laws and regulations

Modification of Personal Information

Should an individual request the Company to make corrections, additions, or deletions (hereinafter referred to as “modifications”) to his/her personal information in accordance with the provisions of the APPI the Company shall, after the individual who has made the request is identified as the person to whom the information pertains, promptly conduct the necessary investigation within the scope necessary to fulfill the purpose of use. Based on the results of this investigation, the Company shall make the necessary modifications to the personal information and notify the individual of such modifications. (Should the Company decide not to make such modifications, the individual will be notified to that effect.) However, this shall not apply in cases where the Company is not obligated to make such modifications under the APPI or other applicable laws and regulations. To request modifications of personal information, please contact us.

Suspension of Use, etc. of Personal Information

In cases where an individual requests suspension of use or deletion (hereinafter referred to as “suspension of use, etc.”) of his/her personal information in accordance with the provisions of the APPI the Company shall proceed with suspension of use, etc. of the personal information once the individual who made the request is identified as the person to whom the information pertains and notify the individual to that effect, provided, however, that this shall not apply in cases where suspension of use, etc. is not an obligation of the Company under the APPI or other applicable laws and regulations. To request suspension of use, etc. of personal information, please contact us. In addition, all stored data of the personal information described in 2-1 above will be deleted upon the termination of the service agreement.

6. Behavioral Targeting Advertising

The Company may acquire information related to the behavioral history of users (hereinafter referred to as “Information”) for the purpose of creating advertisements that match the interests and preferences of Internet users. In addition, in order to deliver advertisements that are most appropriate for its customers, the Company uses a behavioral targeting advertising service based on cookies.

Cookies

The Company uses cookies on its website and in its advertising service. This page describes the purpose of the advertising service, who is subject to cookies, the purposes for which cookies are used, and how to opt-out of cookies.

List of persons or organizations who will handle the cookie information

• Google LLC
• Yahoo Japan Corporation
• Facebook Japan Co., Ltd. (FacebookUPPA)
• Facebook Japan Co., Ltd. (Instagram)
• Kyocera Communication Systems Co., Ltd. (KANADE)
• Smart News Co., Ltd.
• Twitter Japan Co., Ltd.

Information Obtained by Cookies

Information collected by the Company and previously listed persons or organizations are as follows:

• IP address
• User agent
• Browsing history (including but not limited to URL, page title, and referrer)
• Cookie ID

Opt Out of Other Companies’ Services

• Distribution of targeting advertisements using other companies’ services
• Advertising identifiers for each device
• Entrustment of analysis of user information to third-party companies

Visit the following link for details on opting out of other companies’ services.

https://www.unipos.co.jp/privacypolicy/optout.html(Japanese Only)

Collection and Use of Access Logs on the Company’s Website

The Company’s website collects access logs (history) of all website visitors. These access logs are used for site marketing, server operation, and statistical analysis to improve the usability of the Company website and are not used for any other purposes. The websites listed below are subject to the collection and use of access logs:

• https://www.unipos.co.jp/
• https://blog.unipos.co.jp/
• https://hr-media.unipos.co.jp/
• https://pr.unipos.co.jp/
• https://unite.unipos.co.jp/
• https://mailmagazine.unipos.co.jp/
• https://unipos.me/ja/
• https://blog.unipos.me/
• https://article.unipos.me/
• https://media.unipos.me/
• https://navi.unipos.me/
• https://event.unipos.me/
• https://support.unipos.me/
• https://sdgs.unipos.me/
• https://campaign.unipos.me/（Various landing pages deployed under the left domain）

7. Security Control Measures

Security

The Company recognizes that it has a social responsibility to strictly protect information assets, including personal information and information assets important for corporate activities (such as personal information of employees, not only those in employment relationships but also directors, auditors, and temporary workers). All employees are committed to protecting information assets in accordance with the following basic information security policy:

• The Company uses industry-standard SSL encryption when transferring personal information entered by users to servers to prevent third parties from stealing personal information and ensure the safe storage and use of the personal information of users entrusted to the Company.
• To protect its information assets from any threats, the Company has established an information security management system and performs company-wide information security management as an organization.
• The Company establishes regulations and implements physical and technical measures based on the information security policy to ensure confidentiality, integrity, and availability and to address security risks.
• The Company regularly educates directors, employees, and relevant contractors on the necessity of information security and compliance with the information security policy and other rules and regulations to ensure their thorough understanding and compliance.

Safe Management of Personal Information and Supervision of Subcontractors

The Company exercises the necessary and appropriate supervision over its employees to ensure the safe management of personal information and prevent divulgence, destruction, and falsification of personal information. When the Company outsources all or part of the handling of personal information, it provides the necessary and appropriate supervision to ensure that the subcontractor manages the personal information safely.

When handling personal information in a foreign country, the Company will implement safety management measures based on our understanding of the systems for personal information protection in the said country.

8. Continuous Improvement

The Company will review its handling of personal information from time to time and strive for continuous improvement and may change the Privacy Policy as necessary. Any changes will be notified to users or published on this website.

9. Personal Information Manager

The following person shall be responsible for the management of personal information entrusted to the Company:

Personal Information Manager: General Manager of Business Management Department

Contact Information

For inquiries regarding the Company’s privacy policy, please use the following contact information:

〒150-0001
Aoyama Oval Building 7F, 5-52-2 Jingumae, Shibuya-ku, Tokyo, Japan
Unipos Inc.
Privacy Policy Department
Email: info@unipos.co.jp

July 1, 2006
Unipos Inc.
Yuzuru Tanaka, Representative Director, President and CEO

Note:
This document has been translated from the Japanese original for reference purposes only. In the event of any discrepancy between this translated document and the Japanese original, the original shall prevail.