table of contents
- Basic efforts
- Provision of personal information to a third party through opt-out procedures
- 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 acquired by means other than direct writing
- ①In order to properly carry out the outsourced work when outsourced
- ②Personal information of recruitment applicants obtained via the recruitment site
- For contacting those who wish to provide information on recruitment and for recruitment selection
- ③To 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
- (XNUMX) Personal information of customers
- To provide, bill and pay for the products and services we have ordered
- For various information, support, sending and collecting questionnaires regarding our products and services.In addition, to provide various information (including third-party service information) that the Company deems beneficial to customers who are interested in the above products and services.
- Grasping of event participants such as seminars, various clerical communications related to events, communications for follow-up after events, and information on sponsored events (e-mail newsletter).To understand who is registered as a member of our content site.To provide information using materials and videos on our content site.
- For shipping gifts such as campaigns
- For identity verification and response when making inquiries
- (XNUMX) Personal information of business partners
- For contact regarding transactions, etc.
- For identity verification and response when making inquiries
- ③Personal information related to inquiries, complaints, etc.
- To confirm, answer, and respond to inquiries and complaints to our company
- ④Personal Information of Shareholders
- To secure the exercise of rights as a shareholder, contact, and send IR materials
- ⑤Personal information of job applicants and employees (including temporary staff and retirees) of our company
- For contacting those who wish to provide information on recruitment and for recruitment selection
- For employee personnel / labor management and welfare
- ⑥ For other purposes with the prior consent of the individual
- 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.
- Adobe (Please refer to the URL below for terms of service)
https://www.adobe.com/content/dam/cc/jp/legal/terms/enterprise/pdfs/GeneralTerms-JP-2020v1.1.pdf - Salesforce (For terms of service, please refer to the following URL)
https://www.salesforce.com/jp/company/legal/sfdc-website-terms-of-service/
- Adobe (Please refer to the URL below for terms of service)
- 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 | ①Disclosure request form (free format. Request details, name, address, telephone number are required items) ②Identity 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. ③Proxy 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> <When we cannot respond to disclosure, etc.> ②When the subject of request for disclosure, etc. does not correspond to retained personal data ③When 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 ⑤When it violates other laws and regulations <Purpose of use of personal information acquired in response to a request for disclosure, etc.> |
- 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.
12-23-XNUMX Konan, Minato-ku, Tokyo Meishan Takahama Building
FRONTEO Inc. Personal Information Manager
E-mail 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.
12-23-XNUMX Konan, Minato-ku, Tokyo Meishan Takahama Building
FRONTEO Inc. Personal Information Manager
E-mail 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.
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
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.
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)
Personal data we collect
We may collect the following personal data from users of our site.
a.Name and address
b.E-mail 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.
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
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
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.
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
E-mail 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
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.htmContact 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.
E-mail Address
Last updated: (Jan.2023, 6)