Personal Information Protection Policy
Goodpatch Inc. (the “Company”) and Goodpatch Group companies (including the Company, the “Group”), realizing that personal information is the essential property of an individual, has stated the following policies on treatment of personal information to appropriately collect and use that information, to comply with laws and ordinances related to personal information, and to prevent and cure leakage of personal information, and will take the greatest care in control and use of personal information. Any collection of personal information by linked sites or any other entities is not covered by this Personal Information Protection Policy.
Article 1 (Appropriate Collection and Purpose of Use)
When obtaining personal information, the Group will identify the purpose of use as much as possible and collect personal information by lawful means to the extent necessary to achieve the purpose. Personal information shall be used within the scope of the purpose of use for which you have given consent. The Company will establish and implement procedures to take necessary measures to prevent personal information from being used for other purposes.
Article 2 (Appropriate Control and Protection)
Personal information will be strictly controlled, and appropriate measures will be taken to prevent and cure unauthorized access, loss, destruction, falsification, and leakage of personal information.
Article 3 (Response to Complaints and Consultations Request)
If you have any complaints or seek consultation regarding personal information in the Company’s possession, please contact the “Inquiry Counter in Charge of the Handling of Personal Information” so that the Company can respond thereto.
Article 4 (Continuous Improvement of the Personal Information Protection Management System)
The Group will establish, implement, maintain, and improve the personal information protection management system.
Article 5 (Amendment)
The Group may amend the whole or part of this Personal Information Protection Policy. Any material amendment shall be announced on the Company’s website.
Article 6 (Contact Point for Personal Information Protection Policy)
Goodpatch Inc.
VORT Shibuya south 2nd Floor,
3-3 Uguisudanicho, Shibuya-ku, Tokyo
Email: privacy@goodpatch.com
Date of enactment: April 24, 2014
Date of last revision: September 1, 2022
Goodpatch Inc.
Representative Director Naofumi Tsuchiya
Handling of Personal Information
When providing the services “Prott” operated by the Company (hereinafter the “Services” and including all derivative services of the Company using the name of Prott), the Company will handle personal information collected and used by it as follows.
1.Purpose of Use
The Company will collect personal information for the following purpose of use. Notwithstanding the following, if the purpose of use is separately specified at the time of collection, the Company may use personal information for that specified purpose as well. The provision of personal information to the Company is voluntary. If you do not provide the Company with the necessary information, you may not be able to use the Services.
Basic purposes of use
- to make contact with you
- to verify your identity and otherwise respond to inquiries
Purposes of use of personal information collected in connection with transactions with the Company and the Services in general
- to provide the Services
- to provide notices and send questionnaires regarding the Services that are currently provided or under consideration for future provision
- to help improve the Services and develop new services
- to select in drawings and deliver prizes or products
- to transmit advertising information sponsored by the Company or any other third party
- to create statistical data regarding the use of the Services
- to prevent any use in breach of the Terms of Service
Purposes of use of personal information collected in connection with seminars, events, etc.
- to provide information regarding seminars and events
- to operate and manage seminars and events
Purpose of use of personal information collected in connection with e-mail newsletter membership registration
- to deliver e-mail, such as various e-mail newsletters and information
- to provide notices and send questionnaires regarding the Services that are currently provided or under consideration for future provision
- to help improve the Services and develop new services
- to provide information regarding seminars and events
- to select in drawings and deliver prizes or products
- to transmit advertising information sponsored by the Company or any other third party
- to create statistical data regarding the use of the Services
2. Entrustment
The Company may entrust the whole or part of the personal information it collected to outsourcing entities to the extent required to achieve the purpose of use. In such a case, the Company will fully examine the eligibility of such outsourcing entities, set forth confidentiality provisions when executing a contract with them, and provide any necessary and appropriate supervision to them.
3.Provision to Third Party
The Company will not disclose or provide any data to any third party except when:
- prior consent is given by you
- it is based on laws and ordinances
- any breach of the Terms of Service for the Services or other Company’s services should occur and there are sufficient reasons for determining the disclosure of the personal information is necessary to protect the Company’s rights, property, and services.
- it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain your consent
- it is especially necessary for improving public health or promoting the sound growth of children and it is difficult to obtain your consent
- it is necessary for cooperating with a national or local authority or an entity entrusted by it in executing the affairs prescribed by laws and ordinances, and obtaining your consent is likely to impede the execution of such affairs
- any succession of the Company’s business, including the provision of personal information, is made due to any merger, company split, transfer of operations, or other reasons
4. Joint Use
The Company may jointly use any personal information with the Company’s business cooperators in providing the Services. In such a case, the Company will, in advance, publish the items of personal information used jointly, the scope of the joint users, the purpose for which the personal information is used jointly, and the name of the person responsible for the management of the personal information that is used jointly.
5. Use by Minors under 18
If you are under 18 and provide personal information, please do so with the consent of your custodian.
6. Procedures for Disclosure
The Company will respond without delay to your request for notice of the purpose of use, disclosure, correction, addition, or deletion of contents, discontinuance of the use, erasure, and discontinuance of provision to a third party (hereinafter “Disclosures”) of (your) personal information.
When making a request for Disclosures, please contact the Company by e-mail or telephone. The Company will send a “Request for Disclosures of Personal Information” to the designated contact address. Upon receipt, please follow the procedure below to send the request by mail to the “Inquiry Counter in Charge of Handling of Personal Information”. The Company may not be able to accept your request if there is deficiency or insufficiency in it. For the request for disclosure of personal information or notification of the purpose of use, an administrative fee of 1,000 yen will be charged for each request by postage stamps.
When you make a request by yourself
To make a request for Disclosures, please prepare the following documents and send them by certified mail.
- Request for Disclosures of Personal Information
Please fill in the required information.
- Identity verification documents
A copy of a document that can verify your name and current address, such as driver’s license, passport, or health insurance card.
When your agent makes a request
If a person making a request for Disclosures is a legal representative or an agent privately appointed by you, please enclose the following documents in addition to the documents specified in the preceding paragraph.
[In the case of a legal representative]
- Documents confirming that a legal representative is legally authorized to represent you
A copy of the family register or, if a legal representative is a person with parental authority, a copy of the health insurance card showing their dependents is also acceptable.
- Documents to confirm the identity of a legal representative
A copy of a document that can verify the name and current address of a legal representative, such as driver’s license, passport, or health insurance card.
[In the case of a privately appointed agent]
- Power of Attorney (documents attached to the Request for Disclosures of Personal Information)
Please fill in the required information.
- A certificate of a seal impression of your seal (issued within the last 3 months)
- Documents to confirm the identity of a privately appointed agent
A copy of a document that can verify the name and current address of the agent, such as driver’s license, passport, or health insurance card.
The personal information collected by the Company through the “Request for Disclosures of Personal Information” will be used only to respond to inquiries and will not be used for any other purpose.
7. Personal information security management
The Company takes the following security measures against the risk of leakage, loss, or damage, etc., of personal information.
- Organizational security management measures
- The Company has appointed a control manager for the handling of personal information and operates a personal information protection management system centered on the control manager.
- The Company has established regulations regarding the handling of personal information for each stage of personal information acquisition, usage, storage, provision, deletion, and removal, etc.
- The Company conducts regular audits on the handling status of personal information.
- Human security management measures
- The Company holds periodic employee training concerning the handling of personal information.
- The Company requires new employees to sign a pledge of confidentiality at the time of hiring.
- Physical security management measures
- The Company imposes personnel access controls on areas where personal information is handled and takes measures to prevent the viewing of personal information by unauthorized personnel.
- The Company takes measures to prevent theft or loss of personal information handling devices, electronic media, and documents, etc., and uses encryption or password protection while such devices, electronic media, and documents, etc., are in transit.
- Technical security management measures
- The Company imposes access control measures on systems and services used by the Company to limit the viewing of personal information to the minimum necessary personnel.
- The Company has introduced mechanisms to protect personal information handling systems from unauthorized external access or unauthorized software.
- Checking on external environments
- When personal information handling is outsourced, service providers are screened in accordance with the Company’s established selection criteria and are required to sign a non-disclosure agreement.
- When personal information handling occurs in a foreign country including the EU, security management measures are taken after acquiring an understanding of the personal information protection regulations in the country concerned.
8. Disclaimer
The Company shall assume no liability whatsoever if you reveal your personal information to third parties using any feature of the Services or any other means and you become identifiable by that information which you disclosed on the Services.
9. Creation and Use of Statistical Data
The Company may create, based on the personal information collected, statistical data processed so that no individual is identifiable. With regard to such creation and use of personally unidentifiable statistical data, the Company may do so without any restriction.
10. Collection and Use of Attribute Information/Action History
- In order to render the Company’s services and advertising content more suitable to visitors, the Company can acquire and use information as exemplified below, which enables no individual identification. The Company may link the following information with personal data and use such linked information for analysis to improve our services. For the same purpose, the Company may provide information to advertisers, information providers, and service providers, etc.
Examples: Cookies, logs, accessed URLs, content, User ID, action history such as citation order, device information such as terminal individual identification information, and attribute information such as visitor gender, occupation, and age, etc.
- In order to understand the visit and usage status of visitors to the Company’s website, the Company uses Google’s access analysis tool “Google Analytics” and other tools (collectively, “Tools, etc.”). This tool uses cookies to collect visitor data, which is anonymized and identifies no individual visitors. A visitor can refuse this data collection function by disabling cookies. Visitors are requested to check their browser settings for information. Data collected by Google Analytics is managed based on Google’s terms of service and privacy policy. Visitors are requested to refer to the “Google Analytics Terms of Service” and “Google Privacy & Terms” pages for information. The Company may link the following information which is acquired by Tools, etc. with personal data and use such linked information for analysis to improve our services. For the same purpose, the Company may provide information to advertisers, information providers, and service providers, etc.
Examples: Cookies, logs, accessed URLs, content, User ID, action history such as citation order, device information such as terminal individual identification information, and attribute information such as visitor gender, occupation, and age, etc.
11. Contact Point
With respect to the handling of personal information, the Company will endeavor to respond appropriately to your inquiries,complaints, and consultations. To make any inquiries about the handling of personal information by the Company, please contact the following:
Goodpatch Inc.
VORT Shibuya South 2nd Floor, 3-3 Uguisudanicho, Shibuya-ku, Tokyo
Contact point for inquiries regarding the handling of personal information
Personal Information Protection Manager: Toshiyuki Makishima
Email: privacy@goodpatch.com
Date of last revision:
September 1, 2022