Handling of personal information

Privacy Policy

Disclosure matters based on the Personal Information Protection Act

Purpose of use of acquired personal information

The purposes for which personal information collected by Saison Technology Co., Ltd., Ltd., Saison Technology China Co., Ltd., Ltd., Saison Technology Singapore Pte. Ltd. and Saison Technology International, Inc. (hereinafter referred to as "our group") will be used are as follows:

• Items 1 to 7 are personal data held by our group.

Regarding provision to third parties

Our group will not provide personal information without the prior consent of the individual, except in the following cases or when permitted by other laws and regulations:

• When required by law
• When it is necessary to protect a person's life, body, or property, and it is difficult to obtain the consent of the individual.
• When it is particularly necessary for the improvement of public health or the promotion of healthy child development, and it is difficult to obtain the consent of the individual.
• When it is necessary to cooperate with a national government agency, local government, or a party commissioned by them in carrying out duties prescribed by law, and obtaining the individual's consent may impede the performance of said duties.

Regarding the outsourcing of personal information handling

Our Group may outsource the handling of acquired personal information within the scope of achieving the purpose of use. We will select outsourcees that meet our Group's criteria for selecting outsourcees and will provide necessary and appropriate supervision.

Retention period for personal information

If you have entered into a contract with the Group regarding the Group's products or maintenance support, etc., the Group will retain your personal information for five years after the end of that contract, or in other cases, for five years after your last contact with the Group, unless a longer retention period is required or permitted by law, contract, etc.

Safety Management Measures

1. Establishment of basic policies
   • To ensure the proper handling of personal information, we have established basic policies regarding "compliance with relevant laws, regulations, guidelines, etc." and "contact points for handling questions and complaints."
2. Establishment of rules regarding the handling of personal information
   • We have established procedures for handling personal information, including the handling method, responsible persons and their duties, for each stage of the process, such as acquisition, use, storage, provision, deletion, and disposal.
3. Organizational security control measures
   • We have appointed a person responsible for handling personal information, clarified the employees who handle personal information and the scope of personal information handled by those employees, and have established a system for reporting to the person responsible in the event that we become aware of any facts or signs of violations of laws or handling regulations.
   • We regularly conduct self-inspections regarding the handling of personal information, and also have audits conducted by other departments and external parties.
4. Personnel safety management measures
   • We provide regular training to our employees on important points to note regarding the handling of personal information.
   • Matters concerning confidentiality of personal information are stated in the work regulations.
5. Physical safety control measures
   • In areas where personal information is handled, we manage employee entry and exit and restrict the devices that can be brought in, and we also take measures to prevent unauthorized persons from viewing personal information.
   • We take measures to prevent theft or loss of devices, electronic media, documents, etc. that handle personal information, and we also take measures to prevent personal information from being easily identified when carrying such devices, electronic media, etc., including when moving within the office.
6. Technical safety control measures
   • We implement access control to limit the scope of personnel and the personal information databases they handle.
   • We have introduced mechanisms to protect information systems that handle personal information from unauthorized external access or malicious software.
7. Understanding the external environment
   • In accordance with the Personal Information Protection Act, the Group may provide personal information handled by the Group to third parties in foreign countries that have established systems that comply with the standards. The Group will understand the systems for protecting personal information in the foreign countries where the personal information is stored, and will require the third parties to implement necessary and appropriate safety management measures.
     In addition, we will provide appropriate information regarding the name of the foreign country, an outline of the system for protecting personal information in that foreign country, and an outline of the personal information protection measures taken by the third party in response to inquiries from the individual.

Procedures for responding to requests for disclosure, etc.

Our group will respond in good faith to requests for notification of the purpose of use, disclosure, correction, or suspension of use of personal data held by the individual. The procedures are as follows:

1. Please fill out the "Request for Notification of Purpose of Use of Personal Information, Disclosure, etc." form prescribed by our group, attach your identification documents (details are provided in the "Request for Notification of Purpose of Use of Personal Information, Disclosure, etc." form), and mail it to the address below.
   • Akasaka Intercity AIR 19F, 1-8-1 Akasaka, Minato-ku, Tokyo
     Saison Technology Co., Ltd. Business Management Headquarters
     Personal Information Protection Manager: Taku Katagiri
   Please note that the requester will be responsible for any costs incurred by the requester, such as postage, but our group does not charge any fees.
2. After confirming the details of your request, we will respond in writing or by email.

Personal information

When providing products and services from our group, we may obtain cookie information etc. via websites etc.

Please refer to the link below for details.

Cookie Policy :: Saison Technology

Voluntary provision of personal information

Providing personal information from customers is at their discretion, but please note that if you do not provide the information, you may not be able to use some or all of the services.

Handling of personal information of individuals residing in the European Economic Area (EEA)

Legal basis for handling personal information of EEA residents (applies only to EEA residents)

If you reside in the European Economic Area (hereinafter "EEA"), our group will handle your personal information to the extent necessary to achieve the above-mentioned purposes of use, based on your consent to this Privacy Policy. In addition, if our group's handling of your personal information meets either of the following requirements (1) or (2), our group will also handle your personal information to the extent necessary to achieve the above-mentioned purposes of use.

(1) When the processing is necessary for the performance of a contract to which you are a party, or when the processing is necessary to respond to your request prior to entering into a contract

(2) When handling is necessary for the purposes of legitimate interests sought by our Group or a third party (including, but not limited to, the provision of services by our Group, consideration of the employment status of applicants, and labor management).

In cases where it is essential for you to provide personal information, if you choose not to provide it, our group will not be able to provide you with the relevant services.

You can withdraw your consent by contacting the inquiry and complaint desk below. However, your consent regarding the collection, use, and provision of your personal information by our group will remain valid until you withdraw your consent.

Sharing of personal information of EEA residents (only applies to EEA residents)

If you reside in the EEA, our group companies may share your personal information with other group companies to achieve the purposes of use mentioned above. The group companies to which our group discloses personal information may be located outside the EEA (including, but not limited to, Japan and the United States; the same applies hereinafter). In such cases, by agreeing to this Privacy Policy, you agree to the following:

1. If the recipient of personal information is located in a country outside the EEA, that country does not have the same data protection legislation as the EEA, and does not provide many of the rights that are available to data subjects within the EEA.
2. Your personal information will be collected and handled by the recipient in order to achieve the above-mentioned purposes of use.
3. Your personal information will be shared with recipients located outside the EEA.

Rights of EEA residents (only applies to EEA residents)

If you reside in the EEA, you have the right to request from the Group a copy of your personal information, to request correction, to request deletion or restriction of processing (suspension of use) of your personal information, and to request that personal information that you have provided to the Group for the purposes of a contract or on the basis of your consent be provided in a structured, machine-readable format.

You may also object to the processing of your personal information in certain circumstances (in particular where we process the information for direct marketing purposes).

However, these rights may be limited if, for example, fulfilling your request would reveal personal information of a third party, would infringe the rights of a third party (including our Group), or if we are legally required to hold it or have a legitimate interest in holding it. The relevant exceptions are contained in applicable privacy laws. We will make sure to inform you of any exceptions we rely on when fulfilling your request.

If you wish to exercise these rights, please contact our Group via the inquiry and complaints desk below. If your complaint is not resolved, you may also lodge a complaint with the EU data protection authority with jurisdiction over your place of residence, place of employment, or the area where you believe the infringement occurred.

Handling of personal information of residents of California, USA

This Supplementary Provision applies to the handling of personal information (meaning information that directly or indirectly identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked with, a particular consumer or household; the same applies hereinafter in this Supplementary Provision) of individuals who reside in the state of California, USA, in accordance with the provisions of the California Consumer Privacy Act and the California Privacy Rights Act (collectively, the "California Privacy Laws").

Information we collect

For the purposes set out in "Purposes of Use of Personal Information Collected" above, we have collected the categories of personal information from you in the past 12 months, and will continue to collect the categories of personal information set out in the table below.

Disclosure of Personal Information

We may disclose your personal information (including sensitive personal information; the same applies hereinafter in this Supplementary Provisions) to third parties for business or commercial purposes. When disclosing personal information to service providers or contractors for such purposes, we will enter into a contract with the service provider or contractor that describes the purpose and requires the service provider or contractor to maintain the confidentiality of the personal information and to refrain from using the personal information for any purpose other than performing the contract.

In the past 12 months, we have shared or disclosed personal information with the following categories of third parties for a business or commercial purpose:

• Our group companies (group companies)
• Third parties that provide services to us (such as cloud service providers that process and store data on their services)
• Competent authorities prescribed by applicable laws and regulations (including courts and other public institutions with jurisdiction over our company or our group companies).
• Other third parties who reasonably require access to your personal information in connection with the above purposes

Sale and Sharing of Personal Information

We have not sold or shared any personal information in the past 12 months.

For the purposes of this Supplementary Provision, "sale" means the disclosure of your personal information to a third party for monetary or other valuable consideration, and "sharing" means the disclosure of your personal information to a third party for cross-context behavioral advertising, regardless of whether monetary or other valuable consideration is received.

Retention of Personal Information

We will retain your personal information to the extent necessary for the purposes set out in the "Purposes of Use of Personal Information Obtained" above.

The criteria used to determine our retention periods include, but are not limited to, (i) the duration of our contractual relationship with you, (ii) whether we have a legal obligation to do so, and (iii) whether it is necessary for the performance of a contract to which you are a party.

Your Rights and Choices Under California Privacy Law

If you are a California resident, California privacy law provides you with specific rights regarding your personal information. Below we describe your rights under California privacy law and explain how to exercise them.

(1) Right of access to specific information

You have the right to request that we disclose to you certain information about our collection, sharing, disclosure, or use of your personal information in the 12 months prior to your request. Once we receive and confirm your verifiable request, we will disclose to you some or all of the following information:

• The categories of personal information we have collected about you
• The categories of sources of the personal information we collect about you
• Our business or commercial purpose for collecting, selling, or sharing such personal information
• The categories of third parties to whom we disclose, sell, or share such personal information
• The categories of personal information disclosed, sold, or shared with each third party
• The specific personal information we collect about you

(2) Right to request deletion

You have the right to request that we delete any part of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and notify any service providers or contractors and third parties with whom we have sold or shared your personal information) your personal information from our records, subject to certain exceptions.

We may deny your request to delete information if retaining it is necessary for us or our service providers or contractors to:

• To complete the transaction for which we collected your personal information, to fulfill the terms of a warranty or a product recall made pursuant to federal law, to provide a product or service you have requested, to take steps reasonably anticipated by you within the context of our ongoing business relationship, or otherwise to perform a contract between you and us.
• To help ensure the security and integrity of your personal information, to the extent our use of it is reasonably necessary for and proportionate to the purposes for which it is used.
• To debug our products to identify and fix errors that prevent existing intended functionality.
• To exercise free speech, ensure your right to exercise free speech, or exercise other rights provided for by law.
• To comply with the California Electronic Communications Privacy Act (Calif. Penal Code § 1546 et seq.).
• To engage in public or peer-reviewed scientific, historical, or statistical research that complies with or conforms to all other applicable ethical and privacy laws, where the deletion of such information would likely render impossible or seriously impair your ability to complete the research, and you have provided your prior informed consent.
• To enable only internal uses that are reasonably consistent with your expectations based on your relationship with us and consistent with the context in which you provided the information.
• To comply with a legal obligation.

(3) Right to request correction

You have the right to request that we correct inaccurate personal information about you that we have collected from you and retain. Once we receive and confirm your verifiable request, we will correct (and notify our service providers or contractors, and any third parties with whom we sold or shared your personal information, to delete) the inaccurate personal information from our records. However, we may deny your request for correction if we determine that the personal information in question is more likely than not accurate given the totality of the circumstances.

(4) Right to Opt Out of Sales or Sharing

We do not and will not sell or share any personal information we collect from you.

(5) Right to request restriction on use of sensitive personal information

We will not use or disclose sensitive personal information collected from you for any purposes other than those listed below.

• To provide goods and services that the average consumer reasonably expects.
• To help ensure security and integrity.
• For short-term, temporary use (excluding profiling or changes to future consumer experience).
• To provide services on our behalf.
• To maintain or improve the quality and safety of our services and devices.

(6) Right to be free from discrimination

We will not discriminate against any California resident for exercising their rights under California Privacy Law. In addition, except as permitted by California Privacy Law, we will not:

• Denying you products or services.
• Charge you different prices or rates for products or services, including by offering discounts or other benefits or imposing penalties.
• Providing you with a different level or quality of products or services.
• Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
• Retaliation against you if you are an employee, job applicant or independent contractor of ours.

(7) Exercising the right to access, delete and correct

To exercise the above rights of access, deletion, and correction, please contact our office listed in the "Contact Point for Inquiries and Complaints" section of this Policy and make a verifiable request to us.

Only you, a natural person authorized by you to act on your behalf or registered with the California Secretary of State, your designated agent, or your guardian may make a verifiable request regarding your personal information. You may also make a verifiable request on behalf of your minor children.

A "verifiable claim" is

• You must provide sufficient information that allows us to reasonably verify that you are the subject of the personal information we have collected or an authorized representative of that subject.
• It must describe your claim in sufficient detail to allow us to properly understand, evaluate, and respond to your claim.

Handling of personal information of individual customers residing in China

With regard to the handling of personal information of individual customers residing in China (hereinafter referred to as "Customers"), this Supplementary Provisions shall apply in accordance with the provisions of the Personal Information Protection Law and other relevant laws and regulations of the People's Republic of China (hereinafter referred to as "Relevant Chinese Laws and Regulations").

1. Types of personal information

In this Supplementary Provision, personal information refers to any information relating to an identified or identifiable natural person that is recorded electronically or by other means.

The personal information we collect from you is as follows:

(i) Name, address, telephone number, email address, company name, department name, job title, etc. provided when registering an account or user registration for our products or services
(ii) Name, address, telephone number, email address, company name, department name, job title, inquiry details, product serial number, etc. provided through the inquiry form on our website
(iii) Name, address, telephone number, email address, company name, department name, job title, survey response details, etc. provided through the event participation application form or survey response form on our designated website

2. Purpose of handling personal information

We process your personal information for the following purposes:

(i) Account registration or user registration, technical support for products and services, send of email newsletters, etc.
(ii) Responding to inquiries via web forms, etc.
(iii) Responses to applications or responses made via web forms
(iv) Analysis of your usage history and inquiry history for the purposes of the above three points

3. Provision of personal information (domestic and cross-border transfer)

We will not provide your personal information to any entity inside or outside China without your consent.

4. Safety management measures and outsourcing of personal information handling

We will handle your personal information appropriately by taking safety control measures in accordance with relevant Chinese laws and regulations.Personal information acquired by us will be stored only to the extent and for the period necessary in light of "2. Purpose of handling personal information" above.

Furthermore, we may outsource all or part of the handling of your personal information to a third party, within the scope necessary to achieve the purposes set out in 2. "Purpose of handling personal information" above, after taking necessary protective measures.

5. Exercise of Rights

In accordance with relevant Chinese laws and regulations, you may exercise the following rights regarding the handling of your personal information:

① Request to confirm the handling status of personal information
② Request to view and copy personal information
③Request for correction and supplementation of personal information
④Request for deletion of personal information
⑤ Request for withdrawal of consent (this does not affect the lawfulness of the handling of personal information carried out before consent was withdrawn).
⑥Other rights of personal information subjects stipulated in relevant Chinese laws and regulations

6. Contact Us

If you wish to carry out various procedures with us based on the rights set out in 5. "Exercise of Rights" above, or if you wish to make inquiries or consultations regarding the handling of your personal information, you may contact our office as set out in the "Inquiries and Complaints Office" section of this Privacy Policy.

7. Changes to Content

If there are any changes to the contents of this Privacy Policy, we will notify you of the changes in advance, and if it is necessary to obtain your consent again, we will obtain your consent before handling your personal information in accordance with the revised Privacy Policy.

Inquiries and complaints desk

For inquiries or complaints regarding the handling of personal information, please contact us at the address below.

Inquiry

Akasaka Intercity AIR 19F, 1-8-1 Akasaka, Minato-ku, Tokyo
Saison Technology Co., Ltd. Business Management Headquarters
Personal Information Protection Manager: Taku Katagiri

株式会社セゾンテクノロジーのEUにおける代理人のご連絡先は、次のとおりです。
PLANIT // LEGAL Rechtsanwaltsgesellschaft mbH
住所: Jungfernstieg 1, 20095 Hamburg, Germany
Emailアドレス: mail@planit.legal

About SSL

Our group's website uses the SSL (Secure Socket Layer) encrypted communication method on pages where users enter personal information. By using SSL, we prevent important information about users from being stolen or intentionally altered.

What is SSL (Secure Socket Layer)?

SSL (Secure Socket Layer) is a communication protocol for encrypting communication content, and is a technology used to prevent personal information, etc. from being stolen or altered during transmission when entering such information over the Internet.