Privacy Policy

table of contents

  1. Basic efforts
  2. Provision of personal information to a third party through opt-out procedures
  3. Handling of personal information of people in the European Economic Area (EEA)

XNUMX. XNUMX.Basic efforts

FRONTEO Inc. and its subsidiaries and affiliates (collectively, the Company) recognize the importance of personal information and personal numbers, and are implementing the following measures regarding the handling of information.

  • We have a manager in the department that handles personal information and personal numbers, and manage this information appropriately.
  • We will acquire personal information using legal and fair means only with the consent of the person and to the extent necessary to achieve the purpose.
  • We handle personal information only within the scope of the following purposes of use.For the use of personal information by opt-out procedure, please refer to "Providing personal information to a third party by opt-out procedure" below.
    1. Purpose of use of personal information obtained by methods other than direct writing
      • In order to properly carry out the outsourced work when outsourced
        Personal information of recruitment applicants obtained via the recruitment site
          a.For contacting those who wish to provide information on recruitment and for recruitment selection
        To license the outsourcer to use the service within the scope stipulated in the terms of service of the following outsourcee that outsources personal information management.
    2. Purpose of use of personal information subject to disclosure
      • Your personal information
          a.To provide, bill and pay for the products and services we have ordered
          b.For various information, support, questionnaire sending and collection regarding our products and services
          c.For shipping gifts such as campaigns
          d.For identity verification and response when making inquiries
        Personal information of business partners
          a.For contact regarding transactions, etc.
          b.For identity verification and response when making inquiries
        Personal information regarding inquiries and complaints
          a.To confirm, answer, and respond to inquiries and complaints to our company
        4Shareholder's personal information
          a.To secure the exercise of rights as a shareholder, contact, and send IR materials
        Personal information of our recruitment applicants and employees (including temporary staff and retirees)
          a.For contacting those who wish to provide information on recruitment and for recruitment selection
          b.For employee personnel / labor management and welfare
        For other purposes for which the person has agreed in advance

    However, this does not apply in the following cases i to iv.


     I.According to laws and regulations
    Ii.When it is necessary to protect the life, body or property of the person or a third party and it is difficult to obtain the consent of the person
    Iii.When there is a risk of significant hindrance to the proper implementation of our business
    Iv.When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent of the person.

  • Regarding personal numbers, we will use and provide information after obtaining information using lawful and fair means only within the scope of use stipulated by laws and regulations and third-party organizations designated by laws and regulations.However, this does not apply in the following cases v to vi.
  • Ⅴ.For financial institutions to pay money in the event of a catastrophic disaster, etc.
    Ⅵ.When it is necessary to use an individual number to protect the life, body or property of a person

  • If we change the purpose of use of personal information, we will notify the person or announce the changed purpose of use. (Excluding cases i to iv above).
  • We will not disclose or provide personal information to any third party other than our company without the consent of the individual. (Excluding cases i to iv above)
  • We will not share personal information with third parties other than our company without obtaining the consent of the person.
  • In order to provide better services to our customers, we may outsource part of our business and entrust personal information and personal numbers to the outsourced business.In this case, we will select a contractor that fully meets the security standards, conclude a contract for information protection, and thoroughly manage and supervise the contractor.In the unlikely event that a business is subcontracted, we will take similar measures.
  • We use the services of the following contractors to manage personal information.Depending on the terms of service of the outsourcer, personal information may be used for the purpose of improving / developing the outsourced service / system, the possibility of re-disclosure to the outsourced group companies, and other purposes stipulated in the terms of use. It may be used.If you do not wish to use the following outsourced services, please refer to the next section and take the procedure to suspend the provision to a third party.If you complete the procedure, we will stop providing the target personal information to the outsourcer and promptly take appropriate measures such as deletion.
  • At our company, disclosure, correction, addition, deletion, suspension / deletion of use, suspension of provision to third parties (hereinafter referred to as "disclosure, etc.") from the person or his / her agent We will respond to your request.When requesting disclosure, etc., please specify the matters subject to disclosure, etc., and then contact the requesting party using the following request method.
 
<Request method for disclosure of personal information>

Those who can request disclosure, etc.
Principal, legal representative and voluntary representative
How to accept
Please have the necessary documents ready and mail them to the billing address.
Required documents
    Disclosure request form (free format. Request details, name, address, telephone number are required items)
    Identity verification documents (a copy of any one of the driver's license, resident's card, passport and other documents issued by public institutions)

    If the request is made by a voluntary or legal representative, please attach the following documents.

    Proxy right confirmation document

    <In the case of legal representative> A copy of documents such as a copy of the family register that can confirm the legal representative right

    <In the case of a voluntary agent> Power of attorney (with the person's seal) and the person's seal registration certificate (within 3 months after issuance)

    4Identity verification documents for agents (a copy of any one of the driver's license, resident's card, passport and other documents issued by public institutions)
Fees
Free (However, the cost of mailing documents for requesting disclosure etc. will be borne by the requester)
Billing
108-0075-12 Konan, Minato-ku, Tokyo 23-XNUMX Meishan Takahama Building
FRONTEO Inc. Personal Information Manager
Other notes

<Regarding identity verification documents and proxy rights verification documents>
If there is a registered domicile, medical record, etc., please delete the relevant part before mailing.

<When we cannot respond to disclosure, etc.>
Please note that we cannot respond to requests for disclosure, etc. in the following cases.
In that case, we will notify you that we will not be able to respond to your request for disclosure, etc., clearly stating the reason.

    When it cannot be confirmed that the requester for disclosure, etc. is the person or agent of the retained personal data
    When the subject of request for disclosure, etc. does not correspond to retained personal data
    When there is a risk of harming the life, body, property or other rights and interests of the person or a third party
    4When there is a risk of significant hindrance to the proper implementation of our business
    When it violates other laws and regulations

<Purpose of use of personal information acquired in response to a request for disclosure, etc.>
Personal information acquired in connection with a request for disclosure, etc. shall be handled only within the scope necessary for disclosure, etc.
The submitted documents will not be returned.
After completing the response to the request for disclosure, etc., we will properly manage and dispose of it.

 

  • In order to ensure the accuracy of the content of personal data, we will endeavor to manage personal information and personal numbers in an accurate and up-to-date state within the scope of the purpose of use.
  • We will comply with applicable laws and norms regarding personal information and personal numbers held by us, and will review and improve our efforts in handling personal information, such as strengthening internal safety management measures.
  • For complaints and inquiries regarding the handling of personal information and personal numbers, please contact the following.


108-0075
12-23-XNUMX Konan, Minato-ku, Tokyo Meishan Takahama Building
FRONTEO Inc. Personal Information Manager
Email Address



In addition to personal information and personal numbers, we also have a service that handles your important information.Since we handle such important information, we are implementing the following measures.

  • Regarding the installation and operation of our data analysis laboratory, we limit the number of people who have the authority to enter and leave the laboratory within the company.
  • We have installed a system that requires vein authentication when entering and leaving our data analysis laboratory, and we collect logs for entering and leaving each fingerprint registrant.
  • We have installed a low-light surveillance camera in our data analysis laboratory to record and store entry and exit to our data analysis laboratory and access to analysis PC booths and servers 24 hours a day.
  • We use our forensic hardware for all our PCs to acquire and maintain the data in the HDD on a regular basis.



 

XNUMX. XNUMX.About the provision of personal information to a third party by opt-out procedure

We will provide personal information to a third party by opt-out procedure only within the scope of the following purposes of use.

  • Purpose of use provided by a third party
  • For risk compliance surveys such as risk analysis in the supply chain, research on academic research, research on public policy, research on product development / research, the target researcher, the organization to which the researcher belongs / participates, and others. Provides information on the relationship with researchers and organizations.In addition, when providing paper information, we will provide author information that accompanies the paper.

  • Information source
  • Government agencies, educational institutions, private companies (companies involved in the procurement and distribution of goods, pharmaceutical-related companies, companies that own and use R & D functions), and other corporations that wish to analyze and investigate.・ Individual

  • Source of information
  • Article search / public websites on the Internet (limited to websites that publish author information and articles with the consent of the author of the article).

  • Information processing method
  • In order to maintain the information that we hold and manage in our database, we collate and compare the information that we already have with the newly acquired information, and update processing such as correction of changed data and addition of new data. to hold.At this time, for example, if there are different notations for one person's name or organization name, the name identification process that unifies to the predetermined notation is also included.

  • Proper acquisition of information
  • We have obtained it by an appropriate method in accordance with the guidelines of the Personal Information Protection Law established by the Personal Information Protection Commission.

  • Items of personal data provided to third parties
  • Paper title, author name, organization, country / region to which the organization belongs, email address

  • How to provide to a third party
  • ① Provided by e-mail
    (XNUMX) Provided by media such as optical discs and paper
    ③ Provided through services on the Internet that can only be viewed by contract users

  • Procedure for suspending provision to a third party
  • We will stop providing your personal information to third parties at your request by mail or e-mail contact method.


 

108-0075
12-23-XNUMX Konan, Minato-ku, Tokyo Meishan Takahama Building
FRONTEO Inc. Personal Information Manager
Email Address



 

XNUMX. XNUMX.Handling of personal information of people in the European Economic Area (EEA)

Regarding the handling of personal information of those located in the European Economic Area (EEA) to which the European General Data Protection Regulation (GDPR) applies, in addition to our "Handling of Personal Information", this "European Economic Area (EEA) EEA) Handling of personal information of residents ”(hereinafter referred to as“ this handling policy ”) applies.In addition, if the content specified in the former conflicts with the content specified in the latter, the latter provision shall take precedence.

  1. Term definition

    The definitions of terms in this handling policy are as follows.

    • Applicable privacy legislation
    • Applicable privacy legislation, including the General Data Protection Regulations (GDPR) and related national enforcement laws

    • EEE
    • Member States of the European Union and countries under the European Economic Area (EEA) agreement

    • Our company
    • FRONTEO Inc.
      12-23-XNUMX Konan, Minato-ku, Tokyo Meishan Takahama Building

    • Personal Data
    • Directly or by reference to an identifier such as a name, identification number, location data, online identifier for an identified or identifiable natural person (“Site User”), or by reference to multiple elements. Information that can be indirectly identified

    • Processor
    • Natural persons or legal entities, public institutions, departments or other organizations that handle personal data on behalf of administrators

    • Manager
    • Natural persons, corporations, government agencies, and others who determine the purpose and means of processing personal data, alone or in collaboration with others.

    • third party
    • Natural persons or legal entities, public institutions, departments or other organizations other than site users, administrators, processors, and those who are authorized to handle personal data under the direct approval of the administrator or processor.

    • Processing restrictions
    • Mark archived personal data to limit its processing in the future

    • processing
    • It shall be available for collection, recording, editing, composition, record keeping, modification or modification, search, reference, use, disclosure by transmission, distribution, or otherwise, whether by automatic means or not. Performing operations on personal data or a group of personal data, such as aligning or combining, limiting, erasing or destroying

    • Profiling
    • Analyzing or predicting certain personal aspects associated with a natural person, in particular aspects of the natural person's ability to perform, financial condition, health, personal preferences, interests, credibility, behavior, location and mobility. Automatic processing of personal data in any form, consisting of the use of personal data to do so

    • Consent of the person
    • Freely given, specified, and pre-explained, means an unambiguous, unambiguous indication of the site user's intent, thereby allowing the site user to make a statement or express positive action. Express your consent to the handling of personal data related to you

    • Our site
    • https://www.fronteo.com/

  2. Scope of application of this handling policy

      a.It applies to individual use by users of our site and processing of personal data through our site to which applicable privacy laws and regulations apply.Our company is the administrator of this process.

      b.Our site may contain information from third parties (eg hyperlinks, banners, etc.).We do not control the information of these third parties and we are not responsible for the compliance of applicable privacy laws by third parties.We ask that users of our site carefully read the privacy policy of the third-party websites they visit.

  3. The purpose of use of personal data acquired and held by the Company and the basis for legal handling based on the EU General Data Protection Regulation (GDPR) are as follows.

      a.Business partner: For business with us and related communication.Based on the consent of the person (GDPR Article 6a) or legitimate interests (GDPR Article 6f)

      b.To respond to inquiries from the person himself / herself.Based on the consent of the person (GDPR Article 6 a) or legitimate interests (GDPR Article 6 f)

  4. Personal data we collect

    We may collect the following personal data from users of our site.

      a.Name and address

      b.Email Address

      c.Username and password

      d.IP address

      e.Cookie

      f.Employment information, resume

    We do not collect sensitive personal data such as passport information or health data through our site except as provided by applicable privacy laws.

  5. Purpose of data processing

    We collect personal data when the following actions are taken by users of our site.As stated in this Handling Policy, we will only process your personal data in accordance with applicable privacy laws.

      a.When registering on our site

      b.When applying for employment through our site

      c.When using our site

    We collect and process personal data only for the purposes described below.

      d.Customers / Business partners: To fulfill contracts or respond to requests from users of our site before concluding a contract

      e.Customer Service: For inquiries about products and services, notification of important information, and response to complaints

      f.Marketing: For sending gifts such as various information about our products, services and events, conducting questionnaires, campaigns, etc.

      g.Shareholders: To secure the exercise of rights as a shareholder, respond to inquiries and inquiries, and send IR materials

      h.Recruitment applicants: For contacting those who wish to provide information on recruitment and for recruitment selection

  6. Third country relocation

    When we provide personal data to our companies, contractors or subcontractors, it may involve transfer outside the EEA.We will only transfer personal data to a third party located outside the EEA if at least one of the following applies:

      a.Transfer to a country where the European Commission deems the level of protection of personal data appropriate (GDPR Article 45)

      b.Transfer to a contractor who has signed a data transfer contract that includes standard contract clauses designated by the European Commission (GDPR Article 46, Paragraph 2)

      c.Transfers that fall under the exceptions stipulated in Article 49, Paragraph 1 of GDPR

  7. Holding period

    We will store personal data for an appropriate period as stipulated by relevant laws and regulations.Personal data that has passed the storage period and no longer needs to be handled will be properly deleted in accordance with company regulations.

  8. Change registration information

    When there is a request for disclosure, correction, addition, deletion, suspension of use, or deletion of personal data, confirm that the person making the request is the person or the person who has been delegated by the person. We will respond in an appropriate manner.
    (Handling of personal information described in <Request method for disclosure of personal information>)
    Inquiries regarding the above requests and other personal data will be accepted at each contact point.If you do not know the person in charge, please contact the following.


    108-0075
    12-23-XNUMX Konan, Minato-ku, Tokyo Meishan Takahama Building
    FRONTEO Inc. Personal Information Manager
    Email Address



    If you are located in the EEA area, you can make the following requests for your personal data in addition to the requests for the items listed.

    • Disclosure (access)
    • correction
    • Erase
    • Handling restrictions
    • Data portability
    • Opposition
    • Withdrawal of consent
  9. Opposition to the supervisory authority

    Persons located within the EEA have the right to appeal to the competent supervisory authority (available at the URL below) regarding the processing of their personal data.
    http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

  10. Contact information for the data protection officer

    Billing
    108-0075-12 Konan, Minato-ku, Tokyo 23-XNUMX Meishan Takahama Building
    Person in charge of FRONTEO DPO Co., Ltd.
    Email Address

  11. Last updated: (Jan.2021, 12)

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