Basic Policy for the Protection of Personal Information
In conducting its staffing and other businesses, for Startups, Inc. deeply acknowledges that customers’ personal information is an important element of privacy. We respect customers and will respond to their expectations of and trust in us by handling customers’ personal information in the course of our operations in compliance with all applicable laws and regulations related to personal information and with our internal rules established for the protection of personal information, as well as by striving for the appropriate protection of personal information by developing an appropriate organizational structure.
Acquisition, Use, and Provision of Personal Information
We will specify the purposes for which personal information will be used within the scope of our business activities, and will acquire, use, and provide personal information in a fair and appropriate manner to the extent necessary to achieve such purposes. We will also take measures to prevent personal information acquired by us from being used for unintended purposes.
Compliance with Laws, Regulations, and Norms
We strive for the appropriate protection of personal information by complying with all applicable laws and regulations, all applicable guidelines established by the national government, and other norms and social order related to personal information.
Appropriate Management of Personal Information
We are fully aware of the risks of unauthorized access to, or tampering with, or loss, destruction, leakage, etc. of, personal information handled by us, and we will implement reasonable safety measures and will take appropriate corrective actions in the event of any problem.
Response to Inquiries
We will appropriately respond to any inquiries about personal information handled by us from persons to whom such personal information relates, such as requests for disclosure, correction, or suspension of use, or filing of complaints.
We have developed management rules and systems for the protection of personal information, which will be thoroughly applied by all our employees and will be regularly revised in an effort to ensure continuous improvement.
Handling of Personal Information
for Startups, Inc. (the “Company”) will handle personal information of users who use the services provided by the Company (collectively, the “Services”), as follows.
The definitions of terms used herein are in accordance with the Act on the Protection of Personal Information (the “APPI”) and all relevant laws and regulations.
1. Compliance with Relevant Laws, Regulations, Guidelines, etc.
2. Acquisition of Personal Information
The Company will acquire personal information by lawful and appropriate means to the extent necessary for its operations. The information to be acquired by the Company includes the following:
(1) Information entered by users when they apply for a subscription to the Services (name, address, date of birth, e-mail address, telephone number, gender, etc.)
(2) Information collected by the Company in cases where users use a terminal or mobile terminal when using the Services (terminal identifier, mobile terminal identifier, IP address, location information, etc.)
3. Intended Uses of Personal Information
The Company will use personal information within the scope of the following intended uses or the intended uses that are obvious from the situation in which the personal information was acquired, and the Company will not use personal information for any other purpose without the consent of the user or unless permitted by law:
(1) Receiving applications for subscriptions to the Services.
(2) Contacting users when providing the Services.
(3) Confirming the identity of, and otherwise managing, users of the Services.
(4) Signing contracts related to the Services.
(5) Sending offers of employment or new jobs from the Company’s clients to users of the Services.
(6) Managing and improving the Services.
(7) Providing information on renewals of the Services, promotional information on the Services, and other information related to the Services.
(8) Conducting questionnaire surveys related to the Services.
(9) Creating statistics and conducting various marketing research.
(10) Responding to inquiries about the Services from users.
(11) Resolving problems related to the Services.
(12) Exercising the Company’s rights related to the Services, including conducting billing and payment activities.
(13) Developing new services by the Company.
(14) Other activities necessary for the appropriate and smooth performance of all services provided by the Company, including the Services.
4. Outsourcing the Processing of Personal Data
The Company may outsource all or part of the handling of personal information to an outside entity(ies) in order to facilitate the Company’s operations and to provide better services. However, personal information entrusted with such outside entity(ies) will be limited to the minimum necessary information to perform the outsourced services.
5. Provision of Personal Data to Third Parties
The Company will not provide any personal data to any third party except: (i) in the case set forth in the preceding article; (ii) with the prior consent of the user; (iii) where permitted by law; or (iv) in other cases specified below:
(1) In cases where the Company provides personal data to an employer in the course of provision of the Services.
(3) In cases where the Company discloses personal information when transferring shares in the Company or carrying out a merger or other reorganization, or a business transfer, or any other transaction similar to any of the above, or when conducting research or negotiations prior to any of the above transactions.
6. Management of Personal Data
(1) Ensuring data accuracy
The Company will keep personal data accurate and up-to-date to the extent necessary to achieve the intended uses and will strive to delete any personal data that the Company no longer needs to use.
(2) Safety management measures
The Company will provide supervision necessary and appropriate for the prevention of leakage or loss of, or damage to, personal data and for other safety management of personal data.
(3) Supervision of employees
When allowing its employees to handle personal data, the Company will provide necessary and appropriate supervision by ensuring that the proper handling of personal information is thoroughly known to all such employees and by providing appropriate training to them.
(4) Supervision of contractors
When outsourcing the handling of personal data, the Company will select as the contractor a partner which has taken appropriate safety management measures, and the Company will provide necessary and appropriate supervision to such contractor.
(5) Use of statistically processed data
Based on personal data provided to the Company, the Company may create statistical data which has been processed to make individuals unidentifiable. The Company is entitled to use such statistical data without any restriction.
(2) Any user who wants to disable cookies may do so by changing the settings of his/her browser. However, disabling cookies may prevent normal use of the Services.
(3) In addition to the activities set forth in paragraph (1) above, the Company may acquire, by using Google Analytics, information on electronic communication terminals used by users when using the Services (terminal identifier, IP address, location information, cookies, usage logs, etc.) and may use such information to analyze personal information on users, to measure and analyze website usage using the results of such analysis of personal information, and to improve the relevant website. For details of Google Analytics and for opt-out, please visit: Google Analytics Terms of Service and How Google Uses Information from Sites or Apps That Use Our Services.
8. Response to Requests Related to Retained Personal Data
(1) Upon receipt from a user of a request for notification of the intended uses of retained personal data of the user, the Company will notify the user of such intended uses without delay except in the following cases:
(i) In cases where the intended uses of the retained personal data identifying the user is obvious.
(ii) In cases where the requested notification may impair the life, body, property or other rights or interests of the user or any third party.
(iii) In cases where the requested notification may impair any rights or legitimate interests of the Company.
(iv) In cases where the Company is required to cooperate with any agency of the national government or with any local government in the execution of any statutory affairs of such agency or local government and where the requested notification may hinder the execution of such affairs.
(2) Upon receipt from a user of a request for disclosure of retained personal data of the user, the Company will disclose such retained personal data to the user without delay except in the following cases:
(i) In cases where the requested disclosure may impair the life, body, property or other rights or interests of the user or any third party.
(ii) In cases where the requested disclosure may cause significant hindrance to the proper execution of the Company’s operations.
(iii) In cases where the requested disclosure would violate any law or regulation.
(3) Upon receipt from a user of a request for correction, addition or deletion of retained personal data of the user, the Company will conduct an investigation without delay and will take appropriate action based on the results of such investigation.
(4) Upon receipt from a user of a request for deletion or suspension of use of retained personal data of the user, the Company will take appropriate action if such request is found well-grounded.
9. Contact Point for Inquiries
for Startups, Inc.
36F Izumi Garden Tower
1-6-1 Roppongi, Minato-ku, Tokyo
11. Use of STARTUP DB by EU Residents
The Company provides the following supplementary provisions to Articles 1 through 10 above regarding personal information of users who use STARTUP DB, which is among the Services, from within the EU.
(1) Additional information on the acquisition of personal information
Of the information listed in Article 2 above, the Company will acquire: (i) names and e-mail addresses entered by users during membership registration, including cases where a user uses an account with a service provided by the Company-designated third party of the user’s choice; and (ii) information on electronic communication terminals used by users when using the Services. The Company uses Google Analytics for acquiring the information listed in (ii) above.
(2) Additional information on the intended uses of personal information and on statutory grounds
(i) The Company will handle personal information for the following purposes in order to perform contracts related to the Company’s provision of the Services to users:
a. Providing STARTUP DB and media information.
b. Authenticating members and providing a push notification service to subscribers thereof, in the case of users who are registered members.
c. All other acts incidental to any of the above.
(ii) The Company will handle personal information for the following purposes for the sake of the Company’s legitimate interests:
a. Taking security measures for, and resolving problems with, the system for STARTUP DB and otherwise maintaining, managing, and improving such system.
b. Creating statistics and conducting various marketing research.
(iii) The Company will handle personal information for the following purposes with the consent of the user:
a. Analyzing personal information on users using Google Analytics, measuring and analyzing website usage using the results of such analysis, and using such results to improve the relevant website.
(3) Information on recipients of personal information
The Company will transmit the information listed in (2)(ii) above to Google LLC in association with the Company’s use of Google Analytics. For details of Google Analytics and for opt-out, please visit: Google Analytics Terms of Service and How Google Uses Information from Sites or Apps That Use Our Services.
(4) Information on transmission to third countries
In connection with the handling of the information listed in (2)(ii), personal information may be transmitted to sites used by Google LLC (which may include sites in countries not recognized by the European Commission as having an adequate level of protection for personal information) in association with the Company’s use of Google Analytics. All users expressly consent to such transmission.
(5) Information on retention period
The Company will retain personal information until the Company receives a request for deletion of such information from the relevant member.
(6) Information on the rights of data subjects
Users may exercise against the Company: (i) the right to access, (ii) the right to correct, (iii) the right to delete, (iv) the right to limit the handling of, (v) the right to raise an object to the handling of, and (iv) the data portability right with respect to, personal information of their own in accordance with Chapter 3 of the GDPR. For conditions and procedures for the exercise of these rights, please contact the contact point.
(7) Information on the right to raise an objection to the handling of personal information
Users may raise an objection to the handling listed in (2)(ii) above. For conditions and procedures for the exercise of this right, please contact the contact point.
(8) Information on withdrawal of consent
Users may withdraw their consent to the handling specified in (2)(iii) and (5) above. For withdrawal procedure, please contact the contact point.
(9) Information on information to be mandatorily handled
In order for a user to complete membership registration and to receive members-only services, information on the name and e-mail address of the user must be handled.
(10) Information on the right to file an objection with supervisory authorities
Users have the right to file an objection with supervisory authorities in EU member countries.
(11) Information on changes to intended uses
for Startups, Inc.
Yuichiro Shimizu, Representative Director
Established on: September 1, 2016
Revised on : July 1, 2017
Revised on: June 14, 2018
Revised on: September 14, 2018
Revised on: June 14, 2019