Personal Information Protection Policy

Established: November 1, 2009
Revised: February 21, 2023

In protecting all the personal information we handle, we protect the rights of the individual concerned and comply with laws and regulations related to personal information with a full awareness of our social responsibility in this area. Moreover, we state our commitment to establishing a system for managing protection of personal information in order to realize the policy set out below and making concerted efforts to continuously improve this system while being alert to the latest IT trends as well as changes in social requirements and the business environment at all times.

• We take measures to ensure that we only collect, use, and provide personal information within the scope required to legitimately conduct our business in the areas of support for digital transformation and support for staffing of IT personnel as well as recruitment of employees and human resource management, and that we do not handle personal information beyond the scope required to achieve the specific purpose of use.
• We comply with laws and regulations, guidelines stipulated by the national government, and other standards related to protection of personal information.
• To prevent the leak, loss, or damage of personal information and other risks by taking reasonable security measures, we continuously improve our personal information security systems by investing management resources that fit with our business circumstances. Furthermore, we take prompt corrective measures if such risks eventuate.
• We respond promptly, in good faith, and appropriately to complaints or inquiries related to our handling of personal information.
• We continuously review and improve the system for managing protection of personal information in a timely and appropriate manner based on changes in the environment surrounding the Company. We distribute this policy to all employees to ensure they are aware of it and make it accessible anytime to everyone via our website and in pamphlets, etc.

Handling of Personal Information

• Purpose of Use of Personal Information
  We clearly state the purpose of use whenever we collect personal information directly provided in writing by you. We do not handle personal information beyond the scope required to achieve the purpose of use without your consent, except when permitted under the Act on the Protection of Personal Information and other laws and regulations.

  Classification	Purpose of Use	Disclosure
  Personal information handled in work commissioned	For execution of work commissioned	N
  Inquiries about our services	For correspondence and follow-up on services for support for digital transformation and support for staffing of IT personnel	Y
  Our employees’ information	For management of personnel, work, health, and security related to employees	Y
  Inquiries about employment	For screening and employment of human resources	Y
  Webinar registrations	Administrative correspondence and follow-up related to webinars For information on our services (including distribution of online newsletters and e-mails summarizing blog information) For various announcements (products, services, exhibitions, seminars, etc.) and surveys from the companies that speakers/lecturers belong to	Y
  Inquiries about partnerships	For information on our services (including distribution of online newsletters and e-mails summarizing blog information) For correspondence on services for support for digital transformation and support for staffing of IT personnel	Y
  Inquiries about freelancer registrations	For correspondence on projects For information on our services (including distribution of online newsletters and e-mails summarizing blog information)	Y
  Partner engineers’ information	For skill inquiries, contracts, and invoicing procedures	N
  Personal information collected from people we meet at exhibitions, etc. or via our website, and personal information collected from the business cards of our business partners	For correspondence and follow-up on services for support for digital transformation and support for staffing of IT personnel For information on our services (including distribution of online newsletters and e-mails summarizing blog information) For information on events we are organizing, co-hosting, or participating in	Y
  Information collected through membership registrations	For correspondence and follow-up on services for support for digital transformation and support for staffing of IT personnel For information on our services (including distribution of online newsletters and e-mails summarizing blog information) For information on events we are organizing, co-hosting, or participating in	Y

  We will disclose information for which disclosure is required under the Act on the Protection of Personal Information, regardless of “Y” or “N” above.

• Voluntary Provision of Personal Information and Consequences if You Fail to Provide the Information
  Your provision of personal information to us is voluntary. However, please be aware that we may not be able to answer your inquiry if you do not provide us with the information.
• Use of Cookies, etc.
  To improve our services, we may collect information using cookies or web beacons, etc. on our website. Such information includes the number assigned when you visited our site, the date and time of your visit, and the pages you visited. However, we do not collect information that can identify you as an individual, such as your name or your IP address, in ways you are not readily aware of. We handle information acquired by using cookies or web beacons, etc.in accordance with the Cookie Policy displayed on our website.
• Measures for Managing Security
  We provide our employees with the necessary and appropriate supervision to ensure the security of personal information against risks such as loss, destruction, falsification, and leaks. Moreover, when we outsource the handling of personal information fully or in part, we provide the contractor with the necessary and appropriate supervision to ensure the security of personal information. Details of specific security measures for the personal data we hold are as follows.

  Formulation of basic policy	Formulate this Privacy Policy as the basic policy on compliance with relevant laws, regulations, and guidelines and the contact point for questions and complaints processing, etc. in order to ensure the proper handling of personal data
  Establishment of rules for handling personal data	Establish handling rules for personal data for each stage of collection, use, storage, provision, deletion, and disposal, etc. with regards to the handling methods, the responsible persons, the handling staff, and their duties, etc.
  Institutional measures for managing security	1) Appoint a person who is responsible for the handling of personal data, clearly specify which employees handle personal data and the scope of personal data that they handle and establish a system for reporting to the person who is responsible if actual or suspected violations of laws or the handling rules are discovered 2) Implement regular self-checks on the state of personal data handling as well as audits by other departments or external parties
  Personnel measures for managing security	1) Provide regular training for employees on important considerations in the handling of personal data 2) Include a section on maintaining the confidentiality of personal data in the Rules of Employment
  Physical measures for managing security	1) Implement access controls and restrictions on devices, etc. for employees in areas where personal data is handled and take measures to prevent unauthorized people from viewing personal data 2) Take measures to prevent the theft or loss of devices, etc. electronic media, and documents, etc. containing personal data and measures to prevent personal data from being easily identified when moving such devices and electronic media, ,etc. including when they are being carried within the workplace
  Technological measures for managing security	1) Implement access controls to limit the scope of staff who handle personal data and the personal information databases, etc they handle 2) Introduce mechanisms to protect information systems that contain personal data from external unauthorized access and unauthorized software
  Understanding of external environments	Identify the locations where personal data is stored and take measures for managing security based on an understanding of the systems to protect personal information in the relevant country
  Supervision on contractors	When we entrust a third party with the handling of personal information, we select a contractor satisfying our standard for selection of contractors, execute an entrustment contract with the contractor and monitor the status of the handling of personal information through methods such as receipt of periodical reports from the contractor.

Joint Use of Personal Data

We may jointly use personal data of customers who register for seminars and other events that we organize or co-host and those who take part in questionnaires and other surveys at expo venues where we exhibit with co-hosts and sponsoring companies as follows.

• Personal Data to be Jointly Used
  • Your name;
  • Information about your workplace (company name, postcode, address, telephone number, fax number, email address, etc.)
• Scope of Joint Users
  Companies that co-hosted seminars or jointly exhibited with us at seminar or exhibitions etc. you registered for or where you filled in a questionnaire or other survey at the venue, as well as sponsoring companies of events organized by us (As co-hosts and sponsoring companies are different for each seminar, etc., we inform you when we collect your personal information.)
  
• Purpose of Use of Users
  The same as in “Purpose of Use of Personal Information” above.
• Person with Responsibility for Managing Personal Data
  Core Concept Technologies Inc.
  11th Floor DaiyaGate Ikebukuro, 1-16-15 Minami-Ikebukuro, Toshima-ku, Tokyo
  Representative: Takeshi Kaneko, Representative Director
  Person with responsibility: General Manager of the Business Administration Division

Notification of Matters Related to Personal Information Subject to Disclosure

• Name of Business
  Core Concept Technologies Inc.
• Person with Responsibility for Managing Personal Information
  Core Concept Technologies Inc.
  11th Floor DaiyaGate Ikebukuro, 1-16-15 Minami-Ikebukuro, Toshima-ku, Tokyo
  Representative: Takeshi Kaneko, Representative Director
  Person with responsibility: General Manager of the Business Administration Division
• Purpose of Use of all Personal Information Subject to Disclosure
  As above
• Contact Details for Complaints/Requesting Corrections and Deletions Related to the Handling of Personal Information Subject to Disclosure
  Core Concept Technologies Inc.
  11th Floor, DaiyaGate Ikebukuro, 1-16-15 Minami-Ikebukuro, Toshima-ku, Tokyo
  Representative: Takeshi Kaneko, Representative Director
  Contact e-mail address: p-mark ★ cct-inc.co.jp
  (Please replace ★ with @ before sending.)

  On Saturdays, Sundays, public holidays, and during the New Year and Golden Week holidays, we will reply on the next business day or later.

• Accredited Personal Information Protection Organization
  At present, we do not belong to any Accredited Personal Information Protection Organizations.
• Procedure for Responding to Requests for disclosure, etc. of Personal Information Subject to Disclosure
  As far as is required by the Act on the Protection of Personal Information and other laws and regulations, we disclose, correct, terminate use of, and delete personal information, as well as disclose records of the provision of personal information to third parties and records of the provision of personal information from third parties ("disclosure, etc.") in accordance with the following procedure.
  • Contact details for requesting disclosure, etc.
    Requests for disclosure, etc. should be made to the personal information inquiry office above.
  • Procedure for requesting disclosure, etc.
    • After receiving your request, we will mail you the prescribed request form to be used.
    • Please fill in the request form and mail it to the personal information inquiry office above together with a document verifying that you are the representative if you are making the request on behalf of another person and a postal money order for the handling fee (only when requesting notification and disclosure of purpose of use).
    • After receiving the request form above, we will ask you for about two pieces of personal information registered with us that can be used to verify your identity (e.g. your telephone number and date of birth, etc.).
    • As a rule, we will reply in writing (by mail).
  • For requests by a representative
    If you are requesting disclosure, etc., as a representative, please enclose documents verifying that you are the representative and documents verifying your own identity. For the registered domicile information in each document, please only show the prefecture portion and black out or otherwise redact more specific information.
    • Documents verifying you are the representative
      <If the individual concerned has appointed you as their representative to request disclosure, etc.>
      A power of attorney from the individual concerned (original)
      <If the representative is the legal representative of a minor>
      A copy of either:
      Family register
      Certificate of Residence(showing the family relationship)
      Other public document that verifies the right of legal representation
      <If the representative is the legal representative of an adult ward>
      A copy of either:
      Certificate of Registered Information regarding Legal Guardianship, etc.
      Other public document that verifies the right of legal representation
    • Documents certifying the representative’s own identity
      Driver’s license
      Passport
      Health insurance card
      Certificate of Residence
      Basic Resident Registration Card
      Handling fee for request for notification or disclosure of purpose of use
      1,000 yen per request (Please enclose a postal money order with the request form you send us.)
  • Handling fee for request for notification or disclosure of purpose of use
    1,000 yen per request (Please enclose a postal money order with the request form you send us.)

Reporting Information Leaks, etc.

In the event of leak, loss, damage, etc. of personal information handled by us, we report it to the Personal Information Protection Commission in accordance with the provisions of the Act on the Protection of Personal Information, and, if we are required to notify the individual(s) concerned, we provide a report and notification.

Pseudonymized Personal Information

• When we prepare pseudonymized personal information (means information stipulated in Article 2, Paragraph 5 of the Act on the Protection of Personal Information, limited to that compiled in a pseudonymized personal information data base or the equivalent as stipulated in Article 16, Paragraph 5 of the same Act; the same applies hereinafter), we prepare the information in accordance with standards as provided for by Order of the Personal Information Protection Commission and process personal information and handle pseudonymized information in accordance with the provisions of laws and regulations.
• When having prepared pseudonymized personal information or having collected pseudonymized personal information and deleted or other related information (means information stipulated in Article 41, Paragraph 2 of the Act on Protection of Personal Information; the same applies hereinafter), we take measures for the management of the security of deleted or other related information in accordance with standards as provided for by Order of the Personal Information Protection Commission as those necessary to prevent the leaking of deleted or other related information.
• We do not provide personal data which is pseudonymized personal information to third parties, except in accordance with laws and regulations.
• We do not handle pseudonymized personal information (limited to personal information; the same applies hereinafter in “Pseudonymized Personal Information”) beyond the scope required to achieve the purpose of use, except in accordance with laws and regulations.
• When we change the purpose of use of pseudonymized information, we will publish the change.

Information Related to Personal Information

• When a third party is expected to collect information related to personal information (means information stipulated in Article 2, Paragraph 7 of the Act on the Protection of Personal Information, limited to that compiled in a database or the equivalent of information related to personal information as stipulated in Article 16, Paragraph 7 of the same Act; the same applies hereinafter) as personal data, we do not provide any personal information to a third party without first verifying the following in accordance with the stipulations prescribed by Order of the Personal Information Protection Commission, except in cases set forth in Article 27, Paragraph 1 of the Act on the Protection of Personal Information.
  • Your consent has been obtained allowing the third party to obtain information related to personal information from our company and collect it as personal data that can identify you.
  • In the case of providing the information to a third party in a foreign country, when your consent is obtained under the preceding paragraph, you will be provided with information in advance on the system for protecting personal information in the foreign country, the measures for protecting personal information taken by the third party, and other information that may be useful to you, as provided for by Order of the Personal Information Protection Commission.
• Having provided information related to personal information to a third party, we prepare and keep records in accordance with Article 31 of the Act on Protection of Personal Information.
• When receiving information related to personal information from a third party, we carry out the necessary confirmation and prepare and keep records relating to such confirmation in accordance with Article 31 of the Act on the Protection of Personal Information.