1\uff0e\tWhen handling Personal Information, our company complies with all laws, governmental guidelines, and other standards related to the handling of personal information and personally identifiable information. To protect all the Personal Information we handle, we will also create a personal-information management system that conforms to the Japanese Industrial Standard Personal-information protection management system – Requirements (JIS Q15001).
\n2\uff0e\tWhen acquiring or using Personal Information, we will specify its purpose of use and never handle it in a way that exceeds the scope required to achieve that stated purpose of use. We will also take the appropriate steps to ensure that Personal Information is not used beyond its specified purpose of use.
\n3\uff0e\tExcept where required by law, we will never provide the Personal Information we acquire to a third party without first obtaining consent from the owner of that information. And even if we obtain consent from the owner, we will not provide Personal Information to a third party beyond the scope permitted by law.
\n4\uff0e\tWe may sometimes entrust the handling of Personal Information to a third party. In such cases, we will properly manage that third party as needed in accordance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures and the Act on the Protection of Personal Information.
\n5\uff0e\tTo strictly maintain the privacy of our customers, we will create guidelines for properly handling data that has been processed so that it cannot be used to identify an individual or reconstructed into the original Personal Information (anonymized data).
\n6\uff0e\tUpon receiving complaints or inquiries related to our handling of Personal Information, we will quickly investigate and respond to them in good faith within a reasonable time period.
\n7\uff0e\tTo ensure that the Personal Information we acquire is properly managed, we will enact and regularly update organizational, personnel, physical, and technical safety measures that prevent its loss, destruction, or unauthorized disclosure.
\n8\uff0e\tWe will continue to review our management system for protecting Personal Information based on social changes as we work to improve our protection of Personal Information.<\/p>\n
Created: October 1, 2004
\nLatest Revision: May 18, 2017<\/p>\n
MTI Ltd.
\nToshihiro Maeta, Representative Director<\/p>\n
Contact:<\/strong> Personal-Information Protection Supervisor\n<\/p>\n \n1. Purpose of use for personal information<\/strong> (1) Business details (2) Purpose of use 2. Purpose of use for individual numbers and personally identifying information<\/strong> (1) Business details (2) Purpose of use 3. Purpose of use for Pseudonymously Processed Information<\/strong> 4. Joint usage<\/strong> 5. Provision to a third party<\/strong> 6. Outsourcing<\/strong> 7. Use of anonymized data<\/strong> 8. Disclosing, revising, or ceasing provision of registered information<\/strong> (1) Retained personal data However, if any of the conditions in items a) through d) below apply, the personal information or PII is not considered retained personal data. In addition, there may be cases in which we are unable to comply with Requests due to the Protection Act, the Numbers Act, or other laws or guidelines.<\/p>\n \u3000a)\tIf publicizing the existence or nonexistence of the personal information or PII could cause harm to the life, health, or property of its owner or a third party (2) Procedure for submitting Requests (3) Verifying the owner\u2019s identity 9. Details of the system for handling personal information and the measures being taken<\/strong> (Organizational security management measures) (Personal security management measures) (Physical security management measures) (Technical security management measures) (Understanding the external circumstances) 10. Disclaimer<\/strong> \u3000a)\tIf a user discloses personal information or PII to another user via a service feature of our company or one of our outsourcers or through some other method 11. Miscellaneous<\/strong> 12. Verifying the usage agreements for each service<\/strong> 13. Changes to this document or the Privacy Policy<\/strong> 14. Point of contact for inquiries<\/strong>
\nMTI Ltd.
\nMail\uff1a privacy@mti.co.jp<\/p>\n
\nOur company uses the personal information we collect for the following business within the scope described below.<\/p>\n
\n Content business, healthcare business, other business (AI service, DX service, etc.), and related business<\/p>\n
\n\u3000a)\tTo appropriately and seamlessly provide our services to users who registered or applied for them, or to appropriately and efficiently operate those services
\n\u3000b)\tTo verify if someone is a genuine registrant of our membership-based services
\n\u3000c)\tTo send emails about new features, updated information, or campaigns related to the services we or third parties designated by our company provides
\n\u3000d)\tTo send products as winnings in various campaigns, or to provide services as winnings
\n\u3000e)\tTo manage user registration or usage history when entering agreements with corporate associations or other organizations regarding our company\u2019s services
\n\u3000f)\tTo identify and deny usage to individuals who have violated laws or our company\u2019s agreements or terms of use
\n\u3000g)\tTo allow users view, change, or delete their own registered information or view or change their usage terms
\n\u3000h)\tTo give one of our business partners the minimum personal information required to provide a service jointly offered by us and that partner in cases where a user will use one of those services
\n\u3000i)\tTo analyze data or create statistical documentation for the purpose of marketing or improving our services (the generated documentation or other data may be provided to other companies within our corporate group or to our business partners)
\n\u3000j)\tTo respond to inquiries or consultations from users
\n\u3000k)\tTo improve the quality or features of all our company\u2019s services (including services that a user has registered or applied for), or to research and develop new services
\n\u3000l)\tTo provide services or advertising tailored to a user\u2019s age, gender, occupation, or tastes
\n\u3000m)\tTo bill users for usage fees
\n\u3000n)\tTo contact users regarding our company\u2019s services
\n\u3000o)\tFor employment screening at our company
\n\u3000p)\tFor managing the employment of personnel
\n\u3000q)\tTo protect an individual\u2019s life, health, or property
\n\u3000r)\tFor crime or disaster prevention using surveillance cameras*
\n*Surveillance cameras are installed in our reception lobby and internal office areas to prevent crime and disasters. The data is erased after a designated period of time and is not used for any purposes other than crime or disaster prevention.
\n\u3000s)\tTo provide users with sales information or promotional items
\n\u3000t)\tTo fulfill entrusted business
\n\u3000u)\tTo improve response quality*
\n*Recording capability is installed on our phone system. The data is erased after a designated period of time and is not used for any purposes other than the above.<\/p>\n
\nOur company uses the individual numbers and personally identifying information (collectively, \u201cPII\u201d) we collect for the following business within the scope described below.<\/p>\n
\n\u3000a)\tFor tasks related to the taxes and social insurance of our company\u2019s employees and their dependents
\n\u3000b)\tFor tasks related to remuneration, fees, or down payments to companies we do business with
\n\u3000c)\tFor tasks related to the taxes and social insurance of employees within our corporate group (in cases where our corporate group entrusted us with the handling of such matters)
\n\u3000d)\tFor tasks related to remuneration, fees, or down payments to companies that our corporate group does business with (in cases where our corporate group entrusted us with the handling of such matters)<\/p>\n
\n\u3000a)\tPII belonging to our company\u2019s business contacts or those of our corporate group that we were entrusted with
\n\u3000\u3000\u30fbFor creating records related to the payment of remuneration, fees, down payments, or prize money
\n\u3000b)\tPII belonging to our employees or to employees of our corporate group that we were entrusted with
\n\u3000\u3000\u30fbFor creating tax withholding slips
\n\u3000\u3000\u30fbFor tasks related to the granting or exercising of stock options
\n\u3000\u3000\u30fbFor providing to an employee shareholders\u2019 association for the purpose of that organization creating payment records for its members
\n\u3000\u3000\u30fbFor health insurance or employee pension notifications, or applications or invoices
\n\u3000\u3000\u30fbFor unemployment insurance or occupational accident insurance notifications, applications or invoices, or creating certificates
\n\u3000c)\tPII belonging to spouses or relatives of our employees or those of our corporate group that we were entrusted with
\n\u3000\u3000\u30fbFor creating tax withholding slips
\n\u3000\u3000\u30fbFor health insurance or employee pension notifications<\/p>\n
\nOur company uses the Pseudonymously Processed Information for the following purpose described below.
\n\u3000a)\tTo develop and improve our products and services
\n\u3000b)\tTo analyze for health promotion research
\nIn case the Pseudonymously Processed Information is used for purposes other than those listed above that are beyond the scope reasonably determined to be relevant to the original purpose, we will clarify and publicly announce the purpose of its use.<\/p>\n
\nWe may jointly use the personal information our company collects together with one of our business partners within the scope required to achieve the purposes of use described above in cases where we or another company within our corporate group provides a joint service in conjunction with that business partner. In such cases, we will inform the personal information\u2019s owners of the exact data that will be shared; the scope and purpose of the joint usage; the names and titles of the people in charge of the protection of personal information at the organizations that will jointly use the personal information; and the acquisition method. In accordance with law, we will not jointly use PII.<\/p>\n
\nWe will not provide personal information to a third party (including those located overseas; same below) without obtaining consent from its owner, except in cases prescribed by the Act on the Protection of Personal Information (the \u201cProtection Act<\/strong>\u201d) or other laws.<\/p>\n
\nWe may disclose personal information or PII to a third-party outsourcer for the purpose of completing tasks that include the handling of such information within the scope required to achieve the purposes of use described above. In such cases, we will properly manage and oversee the outsourcer so that it does not leak the personal information or PII.<\/p>\n
\nWe may use data that includes personal information that has been processed so that it cannot identify an individual and cannot be restored to its original unprocessed state (\u201cAnonymized Data\u201d), upon publication of relevant items included in such information. When providing Anonymized Data to a third party, we will publicize the items being provided and the provision method while declaring the Anonymized Data to the third party.<\/p>\n
\nWithin the scope allowed by the Protection Act and the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the \u201cNumbers Act<\/strong>\u201d), we accept requests from individuals to disclose their retained personal data or PII, to notify them of its purpose of use, to revise it (for instance, in cases where it conflicts with reality), or to cease usage or provision to a third party (collectively, \u201cRequests<\/strong>\u201d). See below for the procedure for submitting a Request. If you require more specific information, please submit an inquiry using the contact information provided later. Note that a processing fee of \u00a52,500 is required for Requests related to the disclosure of personal information or PII or the notification of its purpose of use.<\/p>\n
\nRetained personal data is the \u201cretained personal data\u201d described in the Protection Act (essentially a systematically arranged assembly of personal data that our company has the authority to disclose, correct, append or delete, discontinue the use of, erase, and discontinue the provision of to a third party). <\/p>\n
\n\u3000b)\tIf publicizing the existence or nonexistence of the personal information or PII could encourage or induce illegal or improper acts
\n\u3000c)\tIf publicizing the existence or nonexistence of the personal information or PII could endanger national security, harm the relationship of mutual trust between Japan and other nations or international organizations, or create a disadvantage in negotiations with other nations or international organizations
\n\u3000d)\tIf publicizing the existence or nonexistence of the personal information or PII could obstruct public order or safety, such as by hindering investigations or the prevention or suppression of crime<\/p>\n
\n\u3000a)\tTo submit a Request, first contact us using the information below.
\n\u3000b)\tWe will then mail the personal information\u2019s owner or their legal representative our designated forms for Request for Disclosure or Purpose of Use of Personal Information, Request for Revision of Personal information, and Request for Discontinuing the Use of Personal Information, as well as a Power of Attorney form (in cases where a legal representative has been established).
\n\u3000c)\tAfter the owner or their legal representative has completed the forms, please return them to us. Please enclose documentation to confirm identification along with the forms.
\n\u3000d)\tWe will then send a Notification of the Disclosure of Personal Information in accordance with the Request.
\n\u3000e)\tAs noted above, there may be cases in which we are unable to comply with a Request for legal reasons.<\/p>\n
\n\u3000a)\tDocuments that verify the owner\u2019s identity
\n\u3000\u3000\u30fbA copy of a driver\u2019s license
\n\u3000\u3000\u30fbA copy of a passport
\n\u3000\u3000\u30fbAn official copy of a family register
\n\u3000\u3000\u30fbA copy of a Certificate of Insurance for health insurance
\n\u3000\u3000\u30fbA copy of a national pension book
\n\u3000\u3000\u30fbOther official documents that can be used to verify the owner\u2019s identity
\n\u3000b)\tRequests submitted by the owner
\n\u3000\u3000\u30fbIf submitting a form of photo identification such as a driver\u2019s license or passport, please submit a copy of one of the two such documents. (Otherwise, you will generally need to provide at least two forms of identification.)
\n\u3000c)\tRequests submitted by a legal representative
\n\u3000\u3000If the Request is being submitted by a voluntary proxy or by the legal representative of a minor or adult dependent, please submit the following documentation in addition to that listed above.
\n\u3000\u3000\u30fbAt least two forms of documentation proving the identity of the representative (a copy of a driver\u2019s license, a copy of a passport, an official copy of a family register, a copy of a Certificate of Insurance for health insurance, a copy of a national pension book, or another official document that can be used to verify the representative\u2019s identity)
\n\u3000\u3000\u3000*If submitting a form of photo identification such as a driver\u2019s license or passport, please submit a copy of one of the two such documents.
\n\u3000\u3000\u30fbOne form of documentation proving that the representative has the legal authority to act as the owner\u2019s proxy (a power of attorney containing the certificate of seal impression of the owner, an official copy of a family register, a copy of a Certificate of Insurance for health insurance, or a Certificate of Registered Matters)
\n\u3000\u3000\u3000Note: Please redact information regarding permanent residences from any documentation provided for the purposes of identity verification.<\/p>\n
\nWe take technical and organizational security measures strictly to manage the retained personal data.<\/p>\n
\nIn addition to appointing a person in charge of the handling of personal data, we have clarified the employees who handle personal data and the scope of personal data handled by such employees and have established a reporting system for the person in charge when facts or signs of violations of laws or rules are detected.
\nWe conduct periodic self-inspections and annual internal audits of the handling of personal data.<\/p>\n
\nWe conduct periodic training for our employees on the points of concern regarding the handling of personal data.
\nWe have included sections regarding the confidentiality of personal data in our employment regulations.<\/p>\n
\nIn the designated areas where personal data is handled, we restrict the access of employees and the devices they bring in, and we take measures to prevent unauthorized persons from accessing personal data.
\nWe encrypt the devices that handle personal data.<\/p>\n
\nWe implement access control to limit the scope of the person in charge and the personal information database to be handled.
\nWe have implemented a system to protect information systems that handle personal data from unauthorized access from outside or unauthorized software.<\/p>\n
\nWe select primarily Japanese domestic service providers when we outsource personal data.
\nWe outsource personal data to overseas companies for cloud storage in some cases (including simple data storage). In such cases, we fully understand the regulations regarding the protection of personal information in those countries and outsource to companies that have a system in place for the protection of personal information.
\n* Outsourcing internal personal data to overseas
\nMicrosoft Japan Office365 (Japan\/USA\/South Korea\/Malaysia\/Singapore)
\n*Outsourcing customer personal data to overseas
\nUSA \/ Vietnam \/ South Korea
\n(Reference)
\nPersonal Data Protection Acts Overseas
\nUSA<\/a>\u3000Vietnam<\/a>\u3000South Korea<\/a>\u3000Malaysia<\/a>\u3000Singapore<\/a><\/p>\n
\nAlthough our company appropriately manages its services in accordance with laws and our own internal regulations to prevent the unauthorized disclosure of personal information or PII, we assume no legal responsibility if a problem occurs due to a third party acquiring such information in the following cases.<\/p>\n
\n\u3000b)\tIf the information\u2019s owner is identified from data entered into one of our company\u2019s services by another user
\n\u3000c)\tIf information leaks because a user utilized a site advertised within one of the services provided by our company
\n\u3000d)\tIf any other information leak occurs through no fault of our company<\/p>\n
\nIf a user does not provide us with information that is current and accurate, they may be unable to receive the appropriate service.<\/p>\n
\nSince the information contained in this document may be appended or modified through the usage agreements and individual confirmation screens for each service in order to fit the specifics of those services, be sure to also verify the information in those service-specific agreements and confirmation screens.<\/p>\n
\nWe may review our management of the various forms of personal information and modify this document or the Privacy Policy without prior notice in order to maintain a suitable level of protection or to comply with changes in laws or other regulations. We will notify our customers of the modified content of this document or the Privacy Policy by posting the information on our website and within our services. After doing so, we will handle all information (including that which was collected prior to the modifications) in accordance with the modified policies, within the limits recognized by law. The changes to this document or the Privacy Policy will go into effect at the point in time they are posted on our website and within our services.<\/p>\n
\nWe will establish a point of contact for receiving user inquiries related to our handling of personal information and PII. <\/p>\n
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