Our Policy regarding Personal Information
Today, the rapid development and proliferation of information technologies as symbolized by the Internet have substantially increased the volume of information we receive. The Internet is now inseparable from corporate activities and our personal lives. At the same time, however, there is a growing risk that any information that identifies individuals, such as names, addresses and phone numbers (“personal information”) may be illegally leaked into the network. Under these circumstances, we understand that it is our social responsibility to appropriately use and protect personal information. We are committed to ensuring that all of our employees are aware of this responsibility and actively work on to protect personal information.
In addition, from the standpoint as a digital content production company, we strongly encourage our clients to take necessary measures to protect personal information if they use or acquire personal information on their websites.
Personal Information Protection Policy of Mitsue-Links Co., Ltd.
We have established the following basic policy to ensure that all personal information we collect are appropriately used and protected, and that all our employees, including those in its management team, understand and observe the intention of this basic policy.
- 1. Definition of personal information
- We define personal information as all information, including personal identification numbers, that can be used to identify individuals.
- 2. Personal information management framework
- We set up a framework necessary to manage personal information and appoint a personal information manager. We also separately appoint a customer service manager and an internal audit manager to ensure the transparency of the framework.
- 3. Personal information purpose of use, scope of use, deletion and correction etc.
- We only acquire personal information to the extent necessary to provide our services. When we acquire such information, we will provide advance notification of why we are acquiring such personal information, how we use that information, as well as contact details for information related inquiries. We only use the acquired personal information within the scope agreed with you at the time of collection. For further information, please refer to the “Purpose of personal information use” below. We may modify, update or delete personal information obtained from you, if there is any change to your personal information (e.g., a change in address), or if you wish to have your personal information deleted.
- If this applies to you, please contact us at firstname.lastname@example.org.
- 4. Discretionary provision of personal information
- Provision of personal information to us is voluntary, however, as services may be dependent on information provided, if certain information is withheld, we may be unable to provide all or part of the requested services.
- 5. Acquisition of personal information under an outsourcing agreement
- When we provide information processing services under an outsourcing agreement that involves the provision of personal information, we will set out and adhere to the clauses of confidentiality, subcontracting, sharing of responsibility at the time of accidents, returning and deleting of personal information at the expiration of the agreement, and so on.
- 6. Provision of personal information to a third party
- We do not provide acquired personal information to third parties without obtaining the consent of the person concerned, nor do we provide personal information to third parties under the opt-out provision as defined in Article 23, Paragraph 2 of the Personal Information Protection Act. However, the following are exemptions to the above:
- when required by law;
- in cases where necessary for the protection of human life, health or property, and it is difficult to obtain the concerned person's consent;
- in cases where necessary for the improvement of public health or to promote the sound development of children, and it is difficult to obtain the concerned person's consent;
- in cases where cooperation is required with national or local public entities or individuals commissioned by a public agencies to perform administrative functions prescribed by law and obtaining the concerned person’s consent produces a likelihood that execution of the concerned administrative function may be affected.
- 7. Consignment of personal information
- We may outsource the handling of personal information to the extent necessary to achieve the purpose of use. When we do consign personal information, we ensure that consignee corporations or individuals have in place a personal information protection system at an equivalent or higher level than our own, and, then, we only entrust information within the scope of the purpose of use. By doing this, we seek to ensure the safe management of personal information.
- 8. Disclosure of personal information
- We will not disclose your personal information to a third party without your consent. In case we entrust a third party to process personal information, we will strictly supervise its operations by concluding an agreement that prohibits it from divulging or offering of the information to another party. If you wish to obtain your personal information we have collected, please contact us at the address below.
- 9. Security measures
- We implement rigorous security measures to protect your personal information from various threats. Our security system is constantly reviewed and maintained to prevent unauthorized access, loss, misuse, destruction, leakage, and alteration of the information. We also focus on preventing human errors to protect your personal information by providing educational activities for our employees.
- 10. External educational activities
- From the standpoint as a digital content production company, we encourage our clients who are planning to develop a website to be aware of the importance of protecting personal information and suggest specific protective measures. In this way, we are committed to promoting the sound use of the Internet.
- 11. Legal compliance and the continuous improvements on the personal information management framework
- We observe applicable law, regulations, guidelines and other official standards concerning personal information while regularly reviewing and improving our initiatives described above. However, we will disclose your personal information to comply with legally enforceable requests from courts, police departments, consumer centers, or other comparable authorities.
Established on October 17, 2002
Revised on July 12, 2023
Name and address of our Company, name of Representative
Address: Sumitomo Fudosan Shinjuku Grand Tower 33F, 8-17-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo
Representative: Masashi Takahashi, Representative Chairman
Purpose of Personal Information Use
We use personal information to:
(1) Conduct web content operation services, which include the following:
- a. Performance of commissioned work, including the processing of all or part of the personal information acquired from the commissioning party
- b. Management of registered information using web forms we operate
- c. Investigation and analysis on the results of user testing
- (2) Communicate with clients for quotations and meetings
- (3) Provide information on our services and respond to inquiries
- (4) Provide our services and respond to enquiries
- (5) Provide information on our Corporate Social Responsibility (CSR) activities and respond to enquiries
- (6) Provide information to shareholders and investors concerning our IR news and manage information of shareholders and shares
- (7) Send our email newsletters to the clients who have signed up for our newsletter
- (8) Provide information and notification to mass media concerning our PR activities
- (9) Provide information of our seminars, notification to participants, and service guidance to the clients who wish to have it
- (10) Recruit new employees and communicate with candidates
- (11) Manage our human resources
- (12) strengthen security, such as implementing office access controls and in-house video surveillance
For items (9),(10) and (11), we will again provide notification on our purpose of personal information use.
Items other than (1) fall under the category of personal information subject to disclosure.
Regarding personal information held by our company that is subject to disclosure, if you seek either notification of the use purpose, disclosure, correction, addition or deletion, suspension of use, cessation of provision to third parties, or a record of provision to third parties, then we kindly ask that you contact our Personal Information Manager via the communication methods listed at the foot of this page. In accordance with request particulars, we shall prepare and send a designated form via either post or email. Once completed, please return the form by post, together with documents that confirm your identity, or in person. Once your identity has been confirmed, we will proceed with the request.
- ※ Please note that we cannot respond to requests concerning information that, under Japan’s Act on the Protection of Personal Information, is not permitted to be disclosed. We thank you for your understanding.
Our Security Management Measures
- (1) Formulation of Basic Policy
- To ensure the appropriate handling of personal information, we have formulated a basic compliance policy in line with relevant laws, regulations, and guidelines, etc., as well as the establishment of a contact point for inquiries and complaints.
- (2) Establishment of Regulations regarding the handling of Personal Information
- For each stage of acquisition, use, storage, provision, deletion/disposal, etc., we have established personal information protection rules that outline the appropriate handling methods, responsible persons/persons in charge, and their duties, etc.
- (3) Organizational Security Control Measures
- We have designated a responsible person for the management of personal information, clarified the employees who deal with personal information, and defined the scope of personal information handled by such employees. Furthermore, if a violation of the law or personal information protection regulations is detected or any indication of such a violation is perceived, we have also established a system that facilitates reporting to the responsible person.
- The status of our personal information management systems is periodically inspected and audited by other departments and external parties.
- (4) Personnel security control measures
- We provide periodic training to employees on matters concerning the handling of personal information.
- We have included matters concerning the confidentiality of personal information in our employment regulations.
- (5) Physical Security Control Measures
- We have implemented measures to prevent the theft or loss of devices, electronic media, documents, etc. that handle personal information. Furthermore, we have taken measures to prevent personal information from being easily identified when transporting such devices, including within the office environment.
- (6) Technical Security Control Measures
- We have implemented access control measures to limit both the number of personnel dealing with personal information as well as the scope of personal information handled.
- We have introduced mechanisms to protect information systems that handle personal information from both unauthorized external access and unauthorized software.
- (7) Knowledge of External Environments
- In cases where personal information is to be handled in a foreign country, we implement security management measures based on our knowledge of personal information protecting protocols in the respective country.
- In cases where personal information is consigned to an external business entity, the respective entity is evaluated and appropriately supervised.
Comments, Complaints and Claims concerning Privacy
If you have any doubts about our compliance status with this privacy statement, please contact us at email@example.com. After reviewing your feedback, we will reply via e-mail and make every possible effort to take appropriate action.
Revisions to the Personal Information Protection Policy
If we use your personal information in a manner that differs from the statement that was effective at the time of acquisition, such an event will be posted here or notified to you by e-mail. You have the right to elect whether you allow us to use your personal information in a manner that differs from the statement on this website.
It is very important that you fully understand how we handle your personal information. If you have any comments or questions on the statement above, please do not hesitate to contact us:
Mitsue-Links Co., Ltd.
Attn: Personal Information Manager Tetsuji Yamashita
33F, Sumitomo Fudosan Shinjuku Grand Tower, 8-17-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo, 160-6133 JAPAN
- Accredited Personal Information Protection Organization to which we are a Target Business Entity, and Complaint Resolution Support Contact Information
- ※ Please note that the following organization is not a contact point for inquiries regarding our products and services.
- Accredited Personal Information Protection Organization
- Complaint Resolution Support
Certified Personal Information Protection Organization Secretariat
Roppongi First Building, 9-9 Roppongi 1-chome,
Minato-ku Tokyo, 106-0032 Japan