Privacy Policy
SOFTBRAIN Co.,Ltd. (hereinafter referred to as SOFTBRAIN) [T1] and its group companies acknowledge the importance of protecting personal information in an advanced information society and shall protect personal information in accordance with the following policy.
1. Collection of Personal Information
In this policy, personal information is all data that we obtain about clients at the time of application and during the provision of the service, including any personally identifiable information (this includes any information that can be collated with other information and thereby used to identify that specific individual) such as company name, department name, job title, address, name, telephone number, e-mail address, IP address and customer ID (except cases where such information provision infringes the secrecy of communication).
SOFTBRAIN and its group companies collect personal information by lawful and fair means.
When obtaining personal information from the individual, SOFTBRAIN and its group companies shall clarify the purpose of use of such personal information (hereinafter referred to as “purpose of use”). However, we may omit the indication of the purpose of use in the following cases.
- - When personal information is provided in a business meeting or business card exchange with a sales representative of SOFTBRAIN and its group companies
- - When receiving a business card at any event, fair, or seminar, etc.
- - When personal information is provided by the individual through various forms on this website
In these cases, except when the person involved refuses, the information may be used to introduce products and services of SOFTBRAIN and its group companies and offer various information by e-mail as well as for marketing activities including face-to-face sales.
2. Use of Personal Information
SOFTBRAIN and its group companies use collected personal information to the extent necessary to fulfill the following purposes.
(1) Personal information we collect from clients
- - To provide products and services of SOFTBRAIN and its group companies
- - To provide information about products and services that SOFTBRAIN and its group companies handle
- - To maintain an environment where the products and services of SOFTBRAIN and its group companies can be used safely and securely
- - To operate and manage the products and services of SOFTBRAIN and its group companies
- - To handle information and inquiries regarding the products and services of SOFTBRAIN and its group companies
- - To conduct surveys, collect data, improve, and conduct research and development on the products and services of SOFTBRAIN and its group companies
- - To make necessary contact between the client and SOFTBRAIN and its group companies
- - To respond to violation of the Terms & Conditions, Policy, etc. of SOFTBRAIN and its group companies regarding the products and services of SOFTBRAIN and its group companies (hereinafter referred to as “Terms & Conditions, etc.”)
- - To notify you of changes to the Terms & Conditions and other relevant documents regarding the products and services of SOFTBRAIN and its group companies
- - For the purpose agreed upon between the client and SOFTBRAIN and its group companies
(2) Personal information we collect from our employees, their dependent spouse, and applicants
- - For labor management, operations management, health management, safety management, etc.
- - For purposes of use stipulated by law
- - For recruitment processes
- - For other purposes associated with the above
3. Joint Use
When using personal information jointly with a third party or entrusting a third party with the handling of personal information, SOFTBRAIN and its group companies shall conduct a thorough investigation of the third party and exercise appropriate supervision to ensure that they maintain confidentiality.
SOFTBRAIN and its group companies shall jointly use personal information as follows.
a. Parties with which SOFTBRAIN jointly uses information
- Our group companies
b. Personal information to be jointly used
- Same as described in “1. Collection of Personal Information”
c. Purposes of joint use
- Same as described in “2. Use of Personal Information”
d. Person in charge of managing protection of personal information to be jointly used
- Chief Information Security Officer: General Manager, Director, SOFTBRAIN Co., Ltd.
4. Disclosure of Personal Information to a Third Party
SOFTBRAIN and its group companies shall not provide personal information without obtaining the prior consent of the individual except under the circumstances set forth below.
- - When providing personal information about participants to co-organizers for various events, fairs, and seminars jointly organized by other companies
- - When providing contract information of our clients to providers of products and services upon billing for usage fees for the products and services
- - When deemed necessary for protecting the rights, assets, and services of a third party and SOFTBRAIN due to violation of the service terms, etc.
- - When based on laws and regulations
- - When it is particularly necessary for the maintenance of public health, and it is difficult to obtain the individual’s consent
- - When it is necessary to cooperate with the execution of the legally prescribed affairs of national or local government, and obtaining the individual’s consent is likely to interfere with the execution of the affairs
- - When it is necessary for the protection of human life, human health, or property, and it is difficult to obtain the individual’s consent
5. Measures for Managing the Security of Personal Information
SOFTBRAIN and its group companies take the following measures to prevent leakage, loss, or damage of personal information and for other appropriate safety management of personal information.
(1) Formulation of the basic policy and establishment of regulations regarding the handling of personal information
- - Comply with all laws and regulations related to personal information protection, publish this policy for continuous improvement, specify handling procedures and the responsibility structure for each step including obtaining, using, and providing personal information, and establish inside rules
(2) Institutional measures for managing the security of personal information
- - Appoint a person responsible for handling personal information, clarify employees handling personal information and the scope of personal information handled by the employees, and establish a reporting system for the person responsible when obtaining knowledge of any facts or indications of violation of laws and handling regulations
- - Conduct regular self-inspection of the handling of personal information and conduct audits by other departments and a third party
(3) Personnel measures for managing the security of personal information
- - Conduct regular training regarding considerations for handling personal information for employees
- - Include matters regarding the confidentiality of personal information in the work rules
(4) Physical measures for managing the security of personal information
- - Perform access control for employees and restrict the equipment to be brought into the areas where personal information is handled, and take measures to prevent access to personal information by unauthorized persons
- - Take measures to prevent theft or loss of equipment, electronic media, and documents that contain personal information and to ensure that personal information is not easily revealed when carrying such equipment, electronic media, etc.
(5) Technological measures for managing the security of personal information
- - Apply access control and limit the persons in charge and the scope of personal information database to be handled
- - Introduce a system to protect information systems that handle personal data from unauthorized external access or unauthorized software
(6) Identification of the external environment
- - When storing personal information outside of Japan, take measures for managing the security of personal information after understanding the personal information protection system in the country
6. Disclosure, Correction, Discontinuance of the Utilization, and Erasure of Personal Information
SOFTBRAIN and its group companies acknowledge that the individual has the right to request disclosure, correction, discontinuance of the utilization, erasure, etc. of his or her own personal information, which is recognized under the Act on the Protection of Personal Information, and shall promptly respond without objection or delay if such requests are made. If you have any questions or concerns regarding the handling of personal information by SOFTBRAIN and its group companies, please contact the following contact point:
Personal Information Consultation Office SOFTBRAIN Co., Ltd.
privacy@softbrain.co.jp
7. Organization and System
SOFTBRAIN and its group companies shall appoint a person in charge of managing protection of personal information and implement appropriate management of personal information.
Person in charge of protection management of personal information
Chief Information Security Officer: General Manager, Director, SOFTBRAIN Co., Ltd.
SOFTBRAIN and its group companies shall conduct training for executives and employees regarding the protection of personal information and proper management methods and strictly enforce the proper handling of personal information in daily business activities.
8. Establishment, Implementation, Maintenance, and Improvement of Compliance Program
To implement this Policy, SOFTBRAIN and its group companies shall establish a Compliance Program (including this Policy, Personal Information Handling Regulations, and other regulations and rules), implement it by ensuring that all employees of SOFTBRAIN and its group companies and other people involved are fully aware of it, and maintain and continuously improve it.
9. Cookies
SOFTBRAIN and its group companies may send cookies to a client’s computer through each service. A cookie is a mechanism that stores website access history, data entry and other information on a client’s computer as a file. If the browser of a client is set to allow the sending and receiving of cookies, SOFTBRAIN and its group companies may obtain the cookies stored in the client’s computer and link the collected action history to personal information. SOFTBRAIN and its group companies use cookies to improve service convenience for clients and to obtain and analyze statistical data, and other purposes.
Additionally, SOFTBRAIN and its group companies use third-party companies’ advertisement services for optimal advertisement distribution. Cookies used in this service do not contain any information that would identify or recognize individuals, are used only for effective advertisement distribution and access analysis for advertisement distribution, and are not used for other purposes. To confirm the usage of action history information by third-party companies and to opt out of cookies sent by third-party companies, please refer to the privacy policies of the third-party companies providing advertisement services.
Established on October 13, 2004
Revised on October 19, 2022
Hirofumi Toyoda
CEO, SOFTBRAIN, Co., Ltd.