Liberteenz Group Global Privacy Policy
Our commitment to safeguarding your personal information
Liberteenz, Inc. (the “Company”) and the Company’s group companies(collectively, the “Group”, “we”, “us”, and “our”) endeavor to protect your privacy by conducting lawful, fair, and transparent processing, by ensuring accuracy, integrity, and recency of personal data, and by taking appropriate security measures among other means under this “Liberteenz Group Global Privacy Policy” (this “Privacy Policy”) and laws and ordinances regarding personal data protection.
This Privacy Policy applies to processing of your personal data that is conducted by companies within the Group that adopt this Privacy Policy. Reading this Privacy Policy will deepen your understanding with respect to the protection of your privacy within the Group.
1. Personal data obtained by the Group
2. Purpose of use of personal data
3. Provision of personal data by the Group
4. Lawful processing of personal data
5. Transfer of personal data abroad
6. Storage period for personal data
7. Your Choices
8. Logging in from social media accounts
9. Processing of children’s personal data
10. Cookies
11. Organizational and technical measures to protect your personal data
12. Customer rights
13. Administrator of this Privacy Policy
14. Revision of this Privacy Policy
In addition to, or separately from, this Privacy Policy, some companies, products, and services of the Group may set forth individual privacy policies that inform you about detailed information in relation to the processing of your personal data. In such cases, if any discrepancies arise between this Privacy Policy and any of those individual privacy policies, that individual privacy policy will prevail.
1. Personal data obtained by the GroupCategories of personal data obtained by the Group are as follows:
▪name, category of business, company name, department, official position, country of residence, and other information related to contact details, such as phone number, email address, and social media accounts;
▪information related to products and services you have purchased (including products and services you intend to purchase) (including, software version, details of product model, information regarding warranties, information regarding the status and use of products, location information, and service history);
▪details regarding your opinions, requests, inquiries, and the other information provided by you;
▪information related to an individual that is obtained or derived in connection with products and services (including work incidental to or in connection with those products and services) provided by the Group;
▪information related to an individual that is obtained or derived in connection with investigations and various events conducted by or in relation to the Group;
▪other information related to an individual that is obtained or derived in order to achieve “2. Purpose of use of personal data”; and
▪information on categories for which the Group provides separate notice.
Personal data obtained by the Group includes information directly provided by you to the Group, information provided through a third party, such as contractors, business partners, and social media providers (including Facebook and Google), and information provided through products and services provided by the Group. Such information might be used in a combined form within the scope of “2. Purpose of use of personal data.”
We will not obtain or use sensitive information that reveals your data concerning health, genetic data, data concerning sexual orientation, or the like, unless provided for in laws and ordinances or you consent to us doing so.
2. Purpose of use of personal dataYour personal data obtained by the Group will be used for the following purposes:
▪Provision of products and services handled by the Group (including work incidental to and in connection with those products and services);
▪Management of customer information and related records, and internal administration including sharing information with other companies in the Group;
▪Collection and analysis of information, which includes market surveys in order to improve the quality of, develop, and enhance products and services provided by the Group;
▪Handling of your inquiries, opinions, and requests;
▪Quality evaluations or other internal evaluations of products and services provided by the Group;
▪Marketing activities and analysis regarding products and services provided by the Group;
▪Introduction of information related to products and services provided by the Group;
▪Introduction, operation, and management of, and provision of various types of information for, various events and campaigns conducted by or related to the Group;
▪Compliance with laws, ordinances, prefectural ordinances, and other regulations;
▪Security measures, such as access control and log acquisition;
▪Early ascertainment and handling of information regarding defects related to products and services provided by the Group, and prompt response and settlement of defects related to products and services provided by the Group and other matters in dispute;
▪Purposes of use for which separate notice is provided upon obtainment of the personal data in question; and
▪Other purposes permitted by applicable laws and ordinances.
If after obtaining your personal data we change the purpose of use for which it is processed, we will process that personal data in accordance with applicable laws, ordinances, and the like.
Separately from the details stated in “4. Provision of personal data by the Group”, your personal data may be converted into a form whereby an individual is unable to be identified and then shared within the Group as statistical or aggregated data, regardless of the purpose of use.
3. Lawful processing of personal dataApplicable laws and regulations may require the Group to process personal data pursuant to a legal basis. In this section, we describe the common legal bases upon which the Group relies where this requirement applies.
1) Where the individual has consented to the processing of his or her personal data for one or more specified purposes.
＊Subject to limitations under applicable law, such consent may be withdrawn at any time in the manner specified by the Group at the time of obtaining consent. Withdrawal of consent will not affect the legality of processing based on consent prior to its withdrawal.
2) Where the processing is necessary to fulfill a contract or in order to take steps prior to entering a contract.
3) Where the processing is necessary to comply with legal obligations.
4) Where the processing is necessary to protect a person’s vital interests.
5) Where the processing is necessary for the performance of a task carried out in the public interest.
6) Where the processing is necessary for the purposes of the legitimate interests pursued by the Group or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual whose personal data is processed.
＊Examples of legitimate interests may include:
· Marketing to customers (direct marketing)
· Customer service
· Application for recruitment to the Group
· General HR management and performance assessment
4. Provision of personal data by the GroupWe do not disclose or provide your personal data to a third party, unless:
▪we inform you about such disclosure or provision;
▪you give consent yourself; or
▪that disclosure or provision is set forth in applicable laws and ordinances.
We may share your personal data within the Group to the extent necessary to achieve the purpose of use that you were notified of in advance.
We provide your personal data to the following third parties. If it is necessary to provide your personal data to a third party other than those provided below, we will individually inform you to that effect.
1) Contractors
In providing products and services to you, we may engage contractors to perform all or part of our duties and may provide personal data to the extent necessary to achieve the purpose of use. If we engage any such third parties to process your personal data, we will take necessary and appropriate measures in accordance with applicable laws and ordinances.
2) Business partners and counterparties
In providing products and services to you, we may, to the extent necessary to achieve the purpose of use, provide your personal data to the following entities after giving you prior notice: our business partners, such as product development and sales services providers, IT and software development service providers, various manufactures, and co-researchers; and counterparties, such as agencies.Also, in dealing with your inquiries, requests, or the like, under certain circumstances where it is difficult for us to obtain your prior consent, we may share your personal data with business partners and counterparties to the extent necessary to achieve that purpose.
3) Legal or regulatory authorities, and professional advisors
We may also share or disclose your personal data with government authorities, regulatory agencies, law enforcement officials, and our professional advisors, if required for the purposes we have told you about, if mandated by law, or if required for the legal protection of our legitimate interests in complying with applicable laws.
5. Transfer of personal data abroad
We are engaged in business activities on a global scale, and in some cases we will transfer your personal data to a country or a region that does not have laws, ordinances, and the like equivalent to those related to protection of personal data in the country or the region where you reside / locate. Upon transferring your personal data abroad, we will take appropriate measures in accordance with provisions set forth in applicable laws and ordinances.
6. Storage period for personal data
We store your personal data for the period necessary to achieve the purpose of use or to perform our obligations under applicable laws, ordinances, and the like.
7. Your Choices
In principle, the provision of your personal data to the Group is made based on your will, and you are not obligated to provide us with your personal data.
However, if you do not provide us with your information, you may experience disadvantages, such as inability to use various services provided by the Group or partial system malfunctions.
8. Logging in from social media accounts
Some services provided by the Group adopt functions that enable users to log in by using their social media (including Facebook and Google) accounts. When you use those functions, we may request your permission to use your social media account information, which includes name and email address, and you will be able to utilize our services using those functions if you grant that permission. You may at any time remove your account from the applicable services of the Group and withdraw your approval from your social media accounts.
Please note that if you use a social media account to log in to our services, it is possible that the social media provider will process information related to you, such as use of applications provided by the Group, and the Group will not be liable for that processing of your information. For details on information related to you that is processed by each social media provider, please refer to each social media provider’s privacy policy.
9. Processing of children’s personal data
With respect to a child’s personal data, we will obtain consent from statutory agents, such as a person with parental authority over that child, and take other necessary steps in accordance with applicable laws, ordinances, and the like.
10. CookiesThe Group’s websites and applications (the “Applications”) may generate cookies, web beacons, and other similar technologies. These enable us to provide you with an enhanced experience when you use the Applications and allow us to improve the Applications. For more details, please refer to the cookie policy.
11. Organizational and technical measures to protect your personal data
We have established a management system pertaining to personal data protection and appropriately take organizational, physical, and technical safety management measures in order to prevent unauthorized access to personal data, prevent personal data loss, destruction, tampering, leakage, and the like, and otherwise to safely manage personal data. Also, we are aware of the importance of personal data protection and appropriately take personal safety management measures, which includes making efforts to provide educational and awareness campaigns regarding personal data protection for officers, employees, and the like who process personal data.
In the unlikely scenario that leakage of personal data or any other accident occurs, we will appropriately deal with the situation through investigation of the facts and causes and implementation of preventive measures for secondary damage and reoccurrence, etc.
12. Customer rights
If you exercise rights (right of access, right to erasure, and the like) as permitted within the relevant jurisdiction, we will faithfully and appropriately deal with that exercise of rights in accordance with provisions set forth in applicable laws, ordinances, and the like after confirming that the person exercising those rights is you or a person delegated by you to act on your behalf.
If you have any demands, inquiries, or requests regarding the processing of personal data, please contact the following address in writing.
Contact address:Administration Division, Liberteenz, Inc.1-2-14 Yu-den hamamatsucho Bld.4F, Hamamatsucho , Minato Ku, Tokyo To, 105-0013, Japan
When you contact us, please inform us of your contact details, including your name, address, phone number, and email address, so that we can accurately respond to your requests. We may contact you if any details sent by you are unclear. We may not be able to respond to you if we are not able to confirm such details.
13. Administrator of this Privacy Policy
Liberteenz, Inc.
1-2-14 Yu-den hamamatsucho Bld.4F, Hamamatsucho , Minato Ku, Tokyo To, 105-0013, Japan
E-ｍail：privacy@liberteenz.jp
Please be aware that inquiries to this email address are limited to inquiries related to this Privacy Policy. If we receive an unrelated inquiry, we may not be able to reply.The replies that we send to customers are intended to send to individual customers for the purpose of answering their inquiries. Please refrain from forwarding part or all of the replies for any other purposes.
14. Revision of this Privacy PolicyWe may amend, revise, add to, or delete the contents of this Privacy Policy from time to time to deal with changes required by amendments to laws and ordinances, business-related requirements, and the like. If there are any substantial or material amendments to this Privacy Policy, we will inform you to that effect on this page and, if necessary, inform you to that effect by a method that enables you to become aware of those changes.
Enactment date or Last updated : October 1st, 2022
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