Article 1 (Personal Information)

In this Policy, the terms below have the meanings as defined below.

1. “Personal Information” in this Policy means “Personal Information” as defined in Article 2, paragraph 1, of the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003; “Personal Information Protection Act” or “PIPA”); and therefore, means information which can identify a specific living individual by name, date of birth or other description contained in such information; or which includes a code that can identify a specific individual.　
2. “Personal Information Database” means “personal information database or the equivalent” as defined in Article 16, paragraph 1, of PIPA, which is a collective body of information comprised of personal information and is systematically organized so as to be searchable for particular personal information using a computer.
3. “Personal Data” means “personal data” as defined in Article 16, paragraph 3, of PIPA, which is personal information compiled in a personal information database or the equivalent.
4. “Retained Personal Data” means “personal data the business holds” as defined in Article 16, paragraph 4, of PIPA, which is personal data that the Company has the authority to disclose; to correct, add or delete content from; to cease to use; to erase; or to cease to provide to a third party.

Article 2 (Purpose of Use of Personal Information)

We may acquire and use Personal Information of Users of our Solutions within the scope necessary for the following purposes. If we seek to use such Personal Information beyond the following purposes, we will obtain the prior written consent of the Users whose Personal Information is concerned:

1. to hold business meetings;
2. to provide information and contact customers or business partners;
3. to carry out tasks entrusted by customers or business partners;
4. to perform contracts concluded with customers or business partners;
5. to respond to inquiries from customers or business partners;
6. to perform the Solutions (the “Solutions”);
7. to improve and refine the Solutions, or to develop new solutions;
8. to notify Users of new functions or updated information of the Solutions, campaigns, and our other solutions (including via e-mails, flyers, and other direct mails);
9. to inform maintenance of the Solutions or important news regarding the Solutions;
10. to answer comments and questions regarding the Solutions (including to confirm Users identification);
11. to report to Users the situation regarding the use of the Solutions;
12. to request Users to answer any questionnaires and questions regarding the Solutions or to attend events, or to report the answers of such questionnaires and questions or results of such events to such Users;
13. to conduct research on and provide analysis of the history of the Solutions and to utilize the results of such research and analysis for the improvement and development of the Solutions and to deliver any promotional materials;
14. upon the approval or application by the Users, to provide Personal Information to third parties, including companies participating in an event that we hold; and
15. to identify Users who have violated the Terms of Use or who intend to use the Solutions for unlawful or illegitimate purposes, and to block their use of the Solutions.
16. Recruitment activities and personnel and safety management after recruitment within our company;
17. Other related tasks;

Article 3 (Management and Protection of Personal Information)

We will carefully and closely manage Personal Data and will not disclose or provide such Personal Data to any third parties without the prior written consent of Users whose Personal Data is concerned, except in the following circumstances and shall take precautional and correctional measures to an illegal access to Personal Data, risks of loss, destruction or leakage of Personal Data considering a security perspective:

1. if such disclosure of Personal Information is necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of such person;
2. if such disclosure of Personal Information is necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person whose Personal Information is concerned;
3. if such disclosure of Personal Information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by such state organ or local government in executing the affairs required by laws and regulations, and if obtaining the consent of the person whose Personal Information is concerned is likely to hinder the execution of such affairs; and
4. (d) if it is permitted by laws and regulations.

We will take preventive and corrective measures against risks resulting from any unlawful access to Personal Information, or any loss, destruction, falsification, or leakage of Personal Information.

Article 4 (Entrustment of Personal Data Handling)

We may entrust an individual or a business operator to handle Personal Data in whole or in part. In such case, we will examine their eligibility sufficiently, obligate such individual or business operator to maintain confidentiality obligations by contract, and will perform the necessary and appropriate supervision over such individual or business operator.

Article 5 (Disclosure of Retained Personal Data)

Users may request the Company to disclose Retained Personal Data held by Us in accordance with the procedures separately prescribed by the Company. Upon receiving such request from the Users, We will disclose such Retained Personal Data to the Users without delay; provided, however, if the following would be applicable, We may decide not to disclose whole or part of the information, in which case we will send a notification to that effect without delay.

1. if such disclosure is likely to harm the life, body, property, or other rights or interests of such User or any other third parties;
2. if such disclosure is likely to hinder the proper execution of our business; and
3. if such disclosure may result to violation of any laws and regulations.

Article 6 (Correction of Retained Personal Data)

1. If Retained Personal Data of Users held by us is false, the Users may request that we make the correction of, the addition to, or the deletion of such Retained Personal Information (“Correction”) in accordance with procedure separately prescribed by the Company.
2. If we receive the request as stipulated in the immediately preceding paragraph, We will conduct necessary research without delay, and if the result of such research finds any ground, Correction will be made to such Retained Personal Data without delay.
3. If we makes any judgment as to whether to implement the Correction in accordance with the immediately preceding paragraph, We will notify the Users of such judgment without delay.

Article 7 (Discontinuation of Retained Personal Data Use)

1. Any Users may request that we cease to make the utilization of, make the erasure of, or cease the third-party provision of, Retained Personal Data held by us (“Cessation”), in accordance with procedures separately prescribed by the Company.
2. Upon request as stipulated in the immediately preceding paragraph, We will conduct necessary research without delay. If we consider as a result of such research that such request is well-grounded, we will implement Cessation of such Retained Personal Data without delay; provided, however, that if such Cessation is unduly expensive or is otherwise difficult to implement and alternative measures to protect the rights and interests of the Users are available, then we will take such measures instead.
3. If we reach any conclusion as to whether to implement Cessation in accordance with the immediately preceding paragraph, We will notify the Users of such conclusion without delay.

Article 8 (Procedures for Amending Privacy Policy)

We will review the content of this Policy appropriately and endeavor to improve this Policy. The content of this Policy can be amended unless otherwise stipulated in laws, regulations, and this Policy. The amended Policy will be valid when notified to all Users or uploaded on our website in accordance with our procedures.

Article 9(Compliance with Laws, Regulations and Norms)

We will comply with the laws and regulations in Japan and other rules that are applicable to the use of Personal Information we retain.

Article 10 (Response to Complaints and Consultations)

We will respond to any complaints from Users and will provide consultation to any User whose Personal Information is concerned as to the handling of his or her Personal Information. We will respond properly and promptly to any request for disclosure, correction, addition, deletion, refusal of use or provision regarding Personal Information.

Article 11 (Security Measures)

As to Personal Information provided by Users to the Company shall be protected from illegal access, lost, destruction, falsification, leakage and other issues through organizational, physical, personal and technical measures such as restricting access to Personal Information files, recording access logs, and taking security measures to prevent illegal access from outside. If, by chance, any leakage and other incidents are occurred, we will make report to relevant authorities in accordance with PIPA and relevant guidelines, and as per instructions to be given by the authorities, will take required measures to avoid an occurrence of similar incidents or the same type of incidents. Please refer to the “Security Measures for Personal Information” attached for details.

Article 12 (Address, Name of Representative and Personal Data Protection Officer)

Address, name of representative and name of the personal data protection officer of the Company are:

Address: 5th floor of Shimbashi Yanagiya bldg., Shimbashi 1-16-6, Minato-ku, Tokyo
Representative: Naoki Watarai
Personal Data Protection Officer: Naoki Watarai

Article 13 (Customer Desk)

For inquiries concerning our policy of handling of Personal Information, please contact us as below at:

Customer Desk of digzyme Inc.
5th floor of Shimbashi Yanagiya bldg., Shimbashi 1-16-6, Minato-ku, Tokyo
Inquiry form: https://www.digzyme.com/contact