Privacy Policy

1. Name of Business

S-Pool, Inc.

2. Privacy Officer

Chief Human Resources Manager, S-Pool, Inc.

3. Personal Information

Personal information refers to information concerning individuals that can be used to identify specific individuals using the names, dates of birth, and other information contained therein (including information on the basis of which it would be easy to identify specific individuals by cross-referencing other information).

4. Purposes of Use of Personal Information

We will access and use the personal information, which we obtained and collected, for the following purposes. We will communicate and obtain consent in advance for use of the personal information for any purposes other than the below or for changes in the purposes of use.

• (1) Personal information concerning partner companies
  a. To conclude various contracts with partner companies
  b. To communicate with partner companies regarding business discussions and meetings
  c. To manage information concerning partner companies
  d. To implement operations contracted to us
  e. To implement operations associated with the above
• (2) Personal information concerning applicants for employment and internships
  a. To provide information to applicants (including applicants for internships) and implement operations related to hiring activities
  b. To manage provisional hiring decisions
  c. To verify and analyze hiring activities (including activities for internships) and for reference in future planning and administration
  d. To implement operations associated with the above
• (3) Personal information concerning executives and employees
  a. To implement operations related to human resources, labor management, health management, and safety management, including services on behalf of other parties
  b. To implement operations related to welfare and benefits
  c. To implement operations related to the Employee Stock Ownership Program
  d. To implement operations associated with the above
• (4) Personal information concerning shareholders and investors
  a. To exercise rights and fulfill obligations under the Companies Act
  b. To send shareholder reports and other materials and for related communications
  c. For shareholder management, including preparation of shareholder data, in accordance with standards specified by applicable laws and regulations
  d. For communications and implementing other activities in response to inquiries
  e. To implement operations associated with the above
• (5) Information on users of our services
  a. To perform various procedures related to user registration
  b. To provide various services that users seek
  * See the individual service webpages for the privacy policies that apply to services to be used.
  c. For activities such as communicating how to obtain information on our services (e.g., through events and seminars)
  d. To guide, provide, and enhance the products and services handled by our group companies
• (6) Personal information concerning parties who have made inquiries with us
  a. To respond to inquiries and for related communications
• (7) Personal information in images captured using security cameras installed in our facilities
  a. For crime prevention and other safety management

Even for purposes of use other than those above, personal information may be used or accessed without prior consent when permitted by applicable laws and regulations or when necessary to protect important interests such as life, health, or property.
Providing personal information is optional. However, failure to provide such information may significantly affect various processes that support the use of our services.

5. Sharing of Customers' Personal Data within the S-Pool Group

The S-Pool Group may share personal information among its group companies when it deems it appropriate for the group companies to respond to inquiries from customers,or for the purpose of providing information on and enhancing the products and services handled by the group companies. See “Sharing of Customers' Personal Data” below for information.

6. Disclosure and Provision of Personal Information to Third Parties

We will not disclose or provide personal information we collected to third parties except in the following cases:

• (1) When required by applicable laws and regulations
• (2) When necessary to protect important public interests such as life, health, or property in cases in which it would be difficult to obtain the consent of the individuals in question
• (3) When outsourcing operations to outside businesses that have concluded nondisclosure agreements within the scope of the purposes of use
• (4) When prior consent has been obtained

7. Management of Personal Information

We will handle personal information in reasonable ways that reflect full consideration for privacy and treat, retain, and manage personal information rigorously via technical and organizational measures to address risks related to such information (e.g., unauthorized access, loss, damage, unauthorized alteration, or leakage).

8. Entrustment of Personal Information

To ensure the strict management of personal information, we may entrust operations to partners or subcontractors that have concluded nondisclosure agreements.

9. Requests for Disclosure, Etc. Concerning Personal Data Held

We will accept requests for disclosure, etc. concerning the personal data we hold. See “Matters Concerning Personal Data Held” below for information on making such requests.

10. Obtaining Personal Information Through Methods Not Easily Recognizable to the Individuals Concerned

We do not seek to obtain personal information through methods not readily recognizable to the individuals concerned—for example, using web beacons.

11. Privacy Policy

See the Privacy Policy on our website.

12. Contact Point for Inquiries, Complaints, and Consultations Regarding Personal Information

Please direct any inquiries, complaints, or consultations regarding personal information to the following contact point.

Inquiries regarding personal information

S-Pool, Inc.

Tel.: +81-3-6859-5599 (weekdays 10:00 a.m. – 6:00 p.m.)

1. Businesses Handling Personal Information and Privacy Officer

Businesses Handling Personal Information
Sohei Urakami
Representative Director
S-Pool, Inc.
6F, Akihabara Daibiru, 1-18-13, Sotokanda, Chiyoda-ku, Tokyo 101-0021

Privacy Officer
Chief Human Resources Manager, S-Pool, Inc.
Tel.: +81-3-6859-5599 (weekdays 10:00 a.m. – 6:00 p.m.)

2. Purposes of Use of Personal Data Held

3. Contact Point for Complaints and Consultations Regarding the Handling of Personal Data Held

Please direct any inquiries, complaints, or consultations regarding personal information to the following contact point. Please note that we are unfortunately unable to accept requests or inquiries through visits in person.

Inquiries regarding personal information

S-Pool, Inc. contact point for privacy

Tel.: +81-3-6859-5599 (weekdays 10:00 a.m. – 6:00 p.m.)

4. Requests for Disclosure, Etc. Concerning Personal Information

After verifying that the party making the inquiry is the individual in question, we will respond swiftly to inquiries concerning notification of purposes of use; disclosure, disclosure of records provided to third parties; correction, addition, or partial deletion of details; suspension of use; complete deletion; or suspension of provision to third parties of the personal information we hold. We may request answers to questions we pose in response to such inquiries in order to verify the identity of the inquiring party.

5. Measures Taken for the Secure Management of Personal Data Held

The following key measures have been taken for the secure management of personal data and other sensitive information we hold.

• (1) Organizational security management measures
  We have appointed an officer in charge of the handling of personal data, and clarify which employees handle which personal data. We have also established a structure for reporting to the officer in charge in the event of potential or actual violation of laws, regulations, or handling rules.
• (2) Human security management measures
  We provide periodic employee training regarding precautions for the handling of personal data.
• (3) Physical security management measures
  We implement access management for physical zones in which personal data is handled and take measures to prevent unauthorized individuals from viewing personal data. We also take measures to prevent the theft or loss of devices, electronic media, and documents that contain personal data.
• (4) Technical security management measures
  We take measures that include access control for the information systems used to handle personal data, storing of identification information on individuals who accessed the systems, prevention of unauthorized access, prevention of information leaks through use of data encryption, passwords, and other protection measures, and information systems monitoring.

1. Personal Data to be Shared

Personal data held by S-Pool Group
Example of personal data : Name, address, telephone number, e-mail address, gender, date of birth, workplace information, business card information, contract details stated in application forms, etc., information necessary for the introduction, provision, and maintenance of various products and services, and information necessary for the operations stated in the purpose of use and other items necessary to achieve the purpose of joint use

2. Scope of joint use

S-Pool Inc. and subsidiaries of S-Pool Inc.

3. Purpose of joint use

4. Party responsible for joint use management

Privacy Officer
Chief Human Resources Manager, S-Pool, Inc.