coolied, Inc. President and CEO Yasuki Onozaki 905 Fuji view tower Iidabashi 1-6-1 Fujimi, Chiyoda-ku, Tokyo 102-0071 enactment on March 11, 2013
cooled, Inc. (hereinafter referred to as “our company”) has formulated a personal information protection policy to ensure that personal information is handled properly and safely, in compliance with the “Law about protection of personal information” when handling personal information.
Collection and Use of Personal InformationWhen acquiring personal information, the Company clearly defines the purpose of acquisition within the scope of a legitimate business as follows, and acquires and uses it in a fair and fair manner to the extent necessary to achieve the purpose.
(1) Definition of personal information about client
- ICT Business
- Planning or making instruction manuals, technical data for services, sales promotion materials, etc.
- Communication, business negotiation, etc. necessary for duties
- For data investigation and setting in system development and maintenance work
- Education Planning and Management Business
- To respond to inquiries
- For inquiries to other schools before admission
- For school administration (providing services)
- Insurance procedure, airline ticket arrangement, etc.
- For public relations activities with the agreement of the person (such as posting photos on social networking service)
- For sending mementoes
- Management Department
- For business-related communication about accounting, finance and labor
(2) Definition of personal information about stockholderEnforcement of rights and obligations under the law, provision of various conveniences (various shareholder special treatment etc.), implementation of various stockholders measures (such as questionnaires), management of stockholders based on laws and regulations (such as creation of stockholder data)
(3) Definition of personal information about business partners, and executives and employees of other companiesCommunication, business negotiations, etc., business partner information management, payment and income processing
(4) Definition of personal information commissioned by business partnersFulfillment of contract for outsourcing business
(5) Definition of personal information about job applicant, employee, and leaver
- Providing and contacting employment information etc. to applicants for employment (including internships)
- Recruitment management at our company
- Employment management at our company
- Providing information and contact to leavers
About ConsignmentIf we entrust the work related to the data described in the personal information to the range necessary to achieve the purpose of use above, we will perform under the strict control of our company, promote the transparency of commission processing according to the scale and the actual situation, and strive to protect the information from leakage.
About Provision of Personal Data to Third PartiesOur company will not provide personal information provided by clients to third parties without obtaining prior consent from clients, except in the following cases.
- Where it is determined that the disclosure is required by law.
- Where the disclosure is needed to safeguard the life, body, or property of a certain individual in a situation where it is difficult to obtain your consent (Except in cases where protection of the rights and interests is sufficiently possible by other methods.).
- Where the disclosure is specifically required with a view to enhancing public health or promoting sound development of children in a situation where it is difficult to obtain your consent (Except in cases where enhancement of public health or sound development of children is sufficiently possible by other methods.)
- In cases where it is necessary for government agencies to obtain the cooperation of private companies etc. in carrying out their duties as defined by the law, and with regard to the cooperation of private enterprises, etc. to provide to government agencies and institutions in the corresponding country where obtaining consent of the person may hinder the execution of applicable duties.
- When performing opt-out. However, in this case, the details of opt-out will be posted on our website and displayed on the reception counter of the office. Currently, we are not performing opt-out.
- When outsourcing personal data to an external company based on a outsourcing contract. However, in this case, we will select a person who meets the criteria established by our company as a consignee and conclude the contract regarding handling of personal data, and appropriately supervise the safety management of personal data at the consignee.
- When business succession is carried out due to a merger, company split, business transfer or other reasons. However, in this case, in the negotiation stage prior to entering into a business succession agreement, our company receives the partner company’s investigation, and in the stage of providing personal data to the partner company, we will sign a necessary contract to ensure that the partner company complies with the safety management measures. When business succession is performed by it, personal data will be used within the scope of the purpose of use before it is transferred.
- When performing joint use. However, in this case, the details of joint use will be posted on our website and displayed on the reception counter of the office. Currently, we are not performing joint use.
About Request Procedure Such as DisclosureThe procedure for requesting disclosure of personal data held by our company (notification of the purpose of use, disclosure, correction, suspension of use, etc.) is as follows. We will not use personal information received in the procedures for disclosure etc. except for the response to such disclosure and storage of records.
(1) Those who can request disclosure and other proceduresThe person himself/herself, If the person is a minor or an adult guardian, the legal representative of the person, An agent authorized by the client in the process of requesting disclosure
(2) Necessary documents when requesting disclosure
- When the person himself/herself go through the formalities
- Application form specified by our company
- Identity verification documents (any of the following documents “passport, driver’s license, alien registration certificate, special permanent resident certificate, student ID card, health insurance card, national health insurance card, seafarer insurance card, company’s identification card or certificate of eligibility issued by a public organization with photos “)
- When the agent go through the formalities
- Application form specified by our company
- Identity verification documents (For both the person himself/herself and the agent)
- Our designated letter of attorney
(3) Acceptance request for disclosure etc.coolied, Inc. personal information complaints and consultation tel:03-6407-1721 fax:03-6407-1723 e-mail address:email@example.com
(4) Disclosure feeIf you request notification of the disclosure and purpose of personal information, you will be charged 1,000 JPY (tax included) for each request. Please enclose the stamp or postal note.
(5)Method and timing of responses to disclosure etc.Once we have confirmed that the information is the personal information of the person concerned, we will respond to the request within a reasonable period of time by sending a letter by postal mail to the person concerned. If you wish to receive a response in electronic form, we will, in principle, respond to your request by the method you specify. However, if it is difficult to respond by the specified method, we will respond in writing by mail. If we are unable to respond to you except in the following cases, we will notify you to that effect, clearly indicating the reason.
- When the purpose of using held personal data which identifies individual person is clear.
- When there is a risk of harming the life, body, property or other right or interest of the person or third party
- When there is a risk that the rights or interests of the business operator handling personal information may be violated
- When carrying out the office work prescribed by laws and regulations, there is a risk of affecting the execution of the office work concerned