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Privacy
Policy

Enacted on July 1, 2015

Revised on June 1, 2020

JRCS Co.Ltd. Privacy Policy

JRCS Co.Ltd. (“JRCS”) hereby sets forth this Privacy Policy (this “Policy”) with respect to the handling of your Personal Information (as defined below).

Article 1. Personal Information to be Collected and Collection Method Thereof

“Personal Information” under this Policy means all information related to you which can identify you such as your personal information, the browsing history of our website (the “Site”) and other information created or accumulated in your devices (e.g., smart phone, personal computer). Depending on the collection method thereof, Personal Information may include the following:

1. Information to be provided from you to our sales department, including:
(1) Name;
(2) Name of your company;
(3) Address of your company;
(4) Postal code;
(5) Department;
(6) Positions;
(7) Phone number;
(8) Facsimile number;
(9) Email address.

2. Information to be provided through inquiry form
(1) Name;
(2) Name of your company;
(3) Address of your company;
(4) Postal code;
(5) Department;
(6) Position;
(7) Phone number;
(8) Facsimile number;
(9) Email address;
(10) Contents of inquiry.

3. Information contained in any documents provided to us
(1) Name;
(2) Name of your company;
(3) Address of your company;
(4) Department;
(5) Position;
(6) Phone number;
(7) Facsimile number;
(8) Email address;
(9) Any information contained in the documents.

4. Information to be provided through our training program
(1) Name;
(2) Name of your company;
(3) Your picture;
(4) Result of the training.

5. Information to be provided in your using our troubleshooting database
(1) Name, e-mail address, company, position, and photos;
(2) Browsing history and log information of website;
(3) Browsing history and log information of native application;
(4) Edit and create history of contents;
(5) Inquiries;
(6) IP address and Terminal ID code.

6. Other Personal Information Collected by JRCS
JRCS may collect following information other than specified in Article 1.1, 1.2, 1.3, 1.4 and 1.5 above:
(1) Log information;
(2) Cookie(s);
(3) Browsing history of the Site.

Article 2 Purpose of Use

1. Personal Information may be used not only for business contact with you as set forth in the following paragraph, but also for other purposes as set forth in Articles 2.3 and 2.4.

2. The specific purposes of use of Personal Information relating to Article 1.1, 1.2 and 1.3 shall be as follows:
(1) To send greetings, provide information about exhibition, take general contact;
(2) To provide guidance, respond to inquiries, etc. related to our services;
(3) To achieve other purposes of use incidental to the foregoing;
(4) In addition, to achieve legitimate business profits, such as through market analysis, development and improvement of products and management of the services.

3. The purposes of use of Personal Information relating to Article 1.4 shall be as follows:
(1) To issue a certificate of the training;
(2) To reissue a certificate of the training.

4. The purposes of use of Personal Information relating to Article 1.5 shall be as follows:
(1) To create user account
(2) To create and use statistical data for marketing purposes

5. The purposes of use of Personal Information relating to Article 1.6 shall be as follows:
(1) Purpose of Use: To create statistical data related to JRCS’s services and processed in a form that cannot identify an individual Corresponding Personal Information Items: Log information and cookies
(2) Purpose of Use: To distribute or display advertisements of JRCS or third parties
Corresponding Personal Information Items: Log information and cookies

6. When handling Personal Information for any purpose other than the above purposes, you shall be informed of the additional purpose of use and related information (i.e., retention period, data subject’s rights and other information as stipulated in the applicable personal information protection laws and regulations (the “Applicable Laws”)).

Article 3. Consent, Rights to Withdraw Consent and Necessity to Provide Personal Information

1. By indicating your intention to provide consent to this Policy, you shall be deemed to have provided your consent to JRCS’s handling of Personal Information and JRCS shall handle the Personal Information based on the consent provided from you; provided, however, you may withdraw such consent at any time (the foregoing shall not affect the handling of Personal Information before the consent is withdrawn). JRCS may use your Personal Information in order to perform a contract with you, achieve legitimate business profits as specified in Article 2.2(4), or comply with applicable laws and regulations.

2. if you fail to provide your Personal Information which is necessary for providing our service, you may not use such services.

Article 4. Provision to Third Parties

Unless required to be disclosed pursuant to applicable laws and regulations, JRCS shall not provide Personal Information to any third party without obtaining your prior consent, except in cases where:
(1) JRCS entrusts third parties such as cloud service vendors and service management companies with the handling of Personal Information in whole or in part, to the extent necessary to achieve the purposes of use. In this case, JRCS shall supervise such third parties (i.e., entrustees) to ensure that they take proper and appropriate protection measures in accordance with the provisions of the Applicable Laws;
(2) JRCS may provide Personal Information to its group companies if such Personal Information is needed for providing our service to you
(3) Personal Information is provided in association with a business succession resulting from a merger or other reasons;
(4) JRCS is required to cooperate with a state organ or local government, or an individual or business operator entrusted by either of the former two in executing the affairs prescribed by applicable laws and regulations and in which obtaining your consent is likely to impede the execution of the affairs concerned; or
(5) In addition to the foregoing, in cases where JRCS is entitled to provide Personal Information pursuant to applicable laws and regulations.

Article 5. Overseas Transfer of Personal Information

JRCS may transfer Personal Information to countries outside the country in which you are located (the “Client’s Country”). You agree that countries outside the Client’s Country may not have personal data protection laws as comprehensive as those that exist in the Client’s Country, and further agrees that the same level of protection as the protection measures set forth in the Client’s Country may not necessarily be guaranteed. In this case, JRCS shall implement necessary safety management measures pursuant to the provisions of the Applicable Laws.

Article 6. Safety Management of Personal Information

1. JRCS takes safety management measures to appropriately handle Personal Information and endeavors to prevent the divulgence, destruction, damage, loss, alteration or unauthorized access thereof.

2. JRCS shall cause its employees to recognize the importance of Personal Information and the danger in any breach of the rules for handling Personal Information and shall supervise its employees to ensure that Personal Information is managed in an appropriate manner.

Article 7. Your Rights

1. You shall have the following rights in relation to the Personal Information only when you satisfy the requirements under the Applicable Laws. Any request for each of these rights in relation to the Personal Information should be submitted to the “Inquiry Desk” specified in Article 9.
(1) Right to request access (i.e., disclosure of purpose, type, destination, retention period, source of acquisition, etc.);
(2) Right to request correction;
(3) Right to request erasure;
(4) Right to request restriction on handling;
(5) Right to request transfer or copy (i.e., portability) to enable the Personal Information to be used in services other than those of JRCS; and
(6) Right to withdraw consent at any time.

2. In addition to the rights specified in the preceding paragraph, if you satisfy the requirements under the Applicable Laws, you shall have the right to make an objection to the handling of your Personal Information. Any inquiry on the exercise of this right shall be submitted to the “Inquiry Desk” specified in Article 9.

3. You have the right to file a complaint regarding the handling of Personal Information at JRCS with the supervisory authority governing the region where you are located.

Article 8. Retention Period

JRCS shall retain your Personal Information to the extent necessary for its purpose of use specified in Article 2; provided, however, that, after your withdrawal, JRCS shall promptly erase such Personal Information upon request from you.

Article 9. Inquiry Desk

Any suggestions, questions, complaints and other inquiries regarding the handling of Personal Information should be submitted as follows:

Address: 1-2-14 Higashiyamato-machi, Shimonoseki, Yamaguchi, 750-8515 Japan
JRCS Co.Ltd.
Email: privacy@jrcs.co.jp

Article 10. Procedures to Modify This Policy

JRCS shall, from time to time, review and endeavor to continuously improve the operational status of the handling of Personal Information and may modify this Policy as necessary. Any modification to this Policy shall be posted on the Site; provided, however, that, for any modification requiring consent from you pursuant to applicable laws and regulations, your consent shall be obtained pursuant to the procedures designated by JRCS.

Article 11. Privacy Policy for Individual Service

In the event of the provisions resulting in a conflict between any other privacy policy for individual service and this Policy, the former will prevail.