Privacy Policy

Personal Information Protection Policy

Saison Information Systems Co., Ltd., HULFT China Co., Ltd., HULFT Pte. Ltd. and HULFT, Inc. (collectively, the "SIS Group") retain various types of data in the course of their businesses. Among such data, the SIS Group recognizes that personal information, specific personal information (which is defined under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures as personal information which contains individual numbers) and personally referable information (which is defined under the Act on the Protection of Personal Information as information relating to a living individual which does not fall under personal information, pseudonymously processed information or anonymously processed information) are extremely important matters which need to be handled with care.

Problems such as information leakage from the SIS Group would not only cause significant inconvenience to the individuals concerned, but would also impair such individuals’ rights as information subjects. Therefore, the SIS Group places the highest priority on the protection of personal information, specific personal information and personally referable information.

The SIS Group has established the following provisions for processing personal information, specific personal information and personally referable information, and strives to properly protect personal information through the implementation of these provisions.

Any reference to personal information in the following provisions for processing the same shall include reference to specific personal information.

[Acquisition, Use and Provision of Personal Information]

The SIS Group shall clarify the purposes of use of personal information and acquire the same through proper methods. Such personal information shall be processed within the scope of the purposes of use thereof, and shall not be provided to any third parties without the prior consent of the individuals concerned.

[Security Management of Personal Information]

The SIS Group shall appoint an administrator responsible for information security and shall implement security management measures to prevent unlawful access to, or unauthorized use, provision, loss, destruction, alteration, or leakage of, personal information. When consigning the processing of personal information to any third party, the SIS Group shall exercise the necessary and proper supervision over such consignee.

For details concerning the system for the acquisition of personal information by the SIS Group and measures taken in relation thereto, please make contact at the contact point set forth in "Contact Point for Inquiry on the  Personal Information Protection Policy" below.

[Compliance with Laws and Regulations and Other Standards]

The SIS Group shall comply with any provisions concerning the protection of personal information and any other applicable laws and regulations.

[Responses to Complaints and Consultations]

The SIS Group shall clarify in advance how to respond to, and the contact point for, complaints and consultations concerning the processing of personal information, and shall sincerely respond to the same.

[Continual Improvement]

In order to prevent its policies from becoming outdated due to changes in the environment and to respond to new threats, the SIS Group shall revise such policies on a regular basis.

Prepared: July 5, 1999
Revised: June 21, 2022
Makoto Hayama
President

Contact Point for Inquiry on the  Personal Information Protection Policy

Contact:

Minoru Kuchiki, Manager of Quality Management Department,
Data Protection Officer

Saison Information Systems Co., Ltd.
Quality Management Department
19F, Akasaka Intercity AIR, 1-8-1 Akasaka, Minato-ku, Tokyo 107-0052, Japan
Email Address : is_receipt@sis2.saison.co.jp
Telephone Number : +81 3 6370 2000

Efforts Toward Personal Information Protection

Publication matters based on the Personal Information Protection Act

Purposes of Use of Personal Information Acquired

The purposes of use of personal information acquired by Saison Information Systems Co.,Ltd. ,HULFT CHINA Co.,Ltd. ,HULFT Pte.Ltd. and HULFT,Inc.(Hereinafter referred to as "the SIS Group")  (the "Purposes of Use") shall be as follows:

Type of Personal Information Purpose of Use

1.Customers

  • To provide the SIS Group’s products and maintenance services based on a contract;
  • To make contact as necessary in the course of business based on a contract;
  • To provide various notices relating to exhibitions and seminars, etc. held by the SIS Group;
  • To provide various notices and conduct questionnaire surveys relating to the SIS Group’s products and services; and
  • To respond to inquiries and requests from customers.

*In the case of inquiries made by telephone, the call may be recorded in order to ensure an accurate response is provided. 

2.Shareholders

  • To make confirmation and send materials in accordance with the Companies Act.

3.Investors and analysts

  • To provide various notices, such as notices of financial results briefings.

4. Employment applicants

  • To make confirmation of applicants and to provide notices of an interview, notices of the results of employment examinations and notices relating to preparations for joining the company.

5.Dispatched workers

  • To accept workers in accordance with the Act for Securing the Proper Operation of Worker Dispatching Undertakings and Improved Working Conditions for Dispatched Workers.

6.Employees/Boards/Officers

  • To business communication, various procedures based on laws and regulations, payroll-related operations, social insurance-related procedures, provision of welfare benefits, and other labor management.
  • To responding to inquiries and requests after retirement.

7.Personal information received upon consignment of processing

  • To implement information processing services based on a consignment agreement with a consignor.

*Items 1 through 6 are retained personal data of the SIS Group.

Provision to Third Parties

The SIS Group shall not provide personal information to any third party without the prior consent of the individuals concerned, unless any of the following applies or such provision is otherwise permitted by applicable laws or regulations:

  • Such provision is conducted in accordance with applicable laws or regulations;
  • Such provision is necessary for the protection of the life, body or property of any individual, and it is difficult to obtain the consent of such individual;
  • Such provision is specifically necessary for improving public health or promoting the sound growth of children, and it is difficult to obtain the consent of the relevant individual; or
  • Such provision is necessary for cooperating with a state organ or local government, or its third-party service provider in executing any affairs prescribed by applicable laws or regulations, and obtaining the consent of the relevant individual threatens to impede the execution of such affairs. 

Consignment of Personal Information Processing

The SIS Group may consign the processing of personal information acquired thereby to any third-party service provider within the scope necessary for achieving the Purposes of Use. The SIS Group shall consign such processing to third-party service providers who meet the SIS Group’s standards for selecting consignees, and shall exercise the necessary and proper supervision over such consignees.

Personal Information Retention Period

Where you have entered into a contract with the SIS Group concerning the SIS Group’s products or maintenance services, etc., the SIS Group shall retain your personal information for five (5) years after the termination of such contract, or otherwise for five (5) years after the last communication between you and the SIS Group; provided, however, that the same shall not apply if a longer retention period is obligated or permitted by any applicable laws or contracts, etc.

Procedures in Response to Requests for Disclosure, etc.

The SIS Group shall sincerely respond to any request you make for the following, in accordance with applicable laws and regulations: (i) notification of the Purposes of Use; (ii) disclosure, revision or suspension of use of the retained personal data that can identify you; or (iii) disclosure of records provided by third parties. The procedures are as follows:

  1. Make contact at the contact point for inquiries and complaints.
  2. We will send you the prescribed documents as necessary. Please fill them in and send them back to us.
  3. After confirming your request, we will respond either in writing or by email. 

Processing of Personal Information of EEA Residents

Personal information (meaning information relating to an identified or identifiable natural person (who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person) of residents in the European Economic Area (the "EEA") shall be processed in accordance with the General Data Protection Regulation (the "GDPR"), and the following provisions shall also apply thereto.

1.Legal Basis for Processing Personal Information

The SIS Group shall process your personal information within the scope necessary for achieving the Purposes of Use based on your consent to this Personal Information Protection Policy. The SIS Group shall also process your personal information within the scope necessary for achieving the Purposes of Use in the case where the SIS Group’s processing of your personal information meets any of the following requirements:
(1) Such processing is necessary for the performance of a contract to which you are a party or in order to respond to your request prior to entering into a contract; or
(2) Such processing is necessary for the purposes of the legitimate interests pursued by the SIS Group or any third party (including, without limitation, interests such as those pertaining to the provision of services by the SIS Group, consideration of whether to employ employment applicants, and labor management).

Where provision of your personal information is mandatory and you choose not to provide the same, then the SIS Group will not be able to provide you with the relevant services.

You may withdraw your consent via the contact point for inquiries and complaints provided below; provided, however, that the consent which you have provided for the SIS Group’s collection, use and provision of your personal information will remain valid until such time as this consent is withdrawn by you.

2.Disclosure of Personal Information

Companies in the SIS Group may disclose your personal information to other companies within the SIS Group, in order to achieve the Purposes of Use. Companies in the SIS Group which the SIS Group discloses your personal information to may be located outside the EEA (including, without limitation, Japan and the U.S.; the same shall apply hereinafter). In this case, you shall be deemed to have agreed to the following matters by providing consent to this Personal Information Protection Policy:
(1) In the case where the recipient of your personal information is located in a country outside the EEA, such country does not have any data protection laws which are equivalent to those in the EEA, i.e., many of the rights granted to data subjects in the EEA are not granted in such country; 
(2) Your personal information shall be acquired and processed by the recipients for achieving the Purposes of Use; and
(3) Your personal information shall be disclosed to the recipients located outside the EEA.

The SIS Group complies with its legal obligations and takes proper measures for the protection of your personal data. With regard to the transfer of your personal data to countries outside the EEA, the SIS Group protects your personal data by using the Standard Contractual Clauses. For copies of the Standard Contractual Clauses, please make contact with the SIS Group via the contact point for inquiries and complaints.

Your Rights Under the GDPR

You have the right to request the SIS Group: (i) for a copy of your personal information; (ii) to revise, delete or restrict the processing (suspend the use) of your personal information; and (iii) to provide you with the personal information you have provided to the SIS Group for a contract or based on your consent, in a structured, machine-readable format.

In addition, you may object to the processing of your personal information in certain circumstances (in particular, where the SIS Group is processing the information for direct marketing purposes).

However, these rights may be limited, for example if fulfilling your request would reveal personal information of a third party or would infringe upon the rights of a third party (including the SIS Group’s rights), or if the SIS Group is required by law to retain or has legitimate interests in retaining your personal information. Relevant exemptions are included in applicable laws on privacy. The SIS Group will inform you of the relevant exemptions which the SIS Group relies upon when responding to any request you make.

If you wish to exercise any of these rights, please contact the SIS Group via the contact point for inquiries and complaints provided below. If you have any unresolved concerns, you may lodge a complaint with an EU data protection authority having jurisdiction over the area in which you live or work, or where you believe a breach may have occurred.

Processing of Personal Information of U.S California Residents

The following supplementary provisions apply to the processing of personal information (any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household; the same shall apply to these supplementary provisions hereinafter) of U.S. California residents in accordance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA; collectively, the “California Privacy Laws”).

 

Information Collected by the SIS Group

The SIS Group has collected in the last twelve (12) months and will continue to collect the following categories of personal information from you for the purposes stated in “Purposes of Use of Personal Information Acquired.”

Category Examples

Identifiers

Name, email address, telephone number, domain information, ID and password, internet protocol address, JSON Web Token, cookies

Commercial information

Payment information for usage fees (credit card information, etc.) and inquiries sent to the SIS Group

Internet or other electronic network activity information 

Request history

Professional or employment-related information 

Information regarding the department in or company by which you are employed (company name, address, telephone number) 

Sensitive personal information 

ID and password 

Disclosure of Personal Information

The SIS Group may disclose your personal information (including sensitive personal information; the same shall apply to these supplementary provisions hereinafter) to third parties for business or commercial purposes. When disclosing personal information to a service provider or contractor for such purpose, the SIS Group executes an agreement that indicates such purposes and requires that the service providers or contractors keep such personal information confidential and not use personal information for any purpose except performing such agreement.

The SIS Group has shared or disclosed personal information to the following categories of third parties for business or commercial purposes during the last twelve (12) months: 

  • SIS Group companies (https://home.saison.co.jp/company/group.html);
  • Third parties that provide services to the SIS Group (such as providers of cloud services in which data of the SIS Group services is processed and stored);
  • Competent authorities as set forth under applicable laws and regulations (including courts and other public authorities that have jurisdiction over the SIS Group); and
  • Any other third parties who may reasonably require access to your personal information in connection with the foregoing purposes.

Sale or Sharing of Personal Information

The SIS Group has not sold or shared any personal information in the preceding twelve (12) months.

In these supplementary provisions, the term “sale” means disclosing, etc. your personal information to a third party for monetary or other valuable consideration, and the term “sharing” means disclosing your personal information to a third party for cross-text behavioral advertisements, regardless of monetary or other valuable consideration.

Retention of Personal Information

The SIS Group will retain your personal information to the extent necessary for the purposes stated in “Purpose of Use of Personal Information to be Acquired.”

The criteria for determining the SIS Group retention period includes, but is not limited to: (i) the duration of the contractual relationship between you and the SIS Group; (ii) the legal obligations assumed by the SIS Group; and (iii) a need to perform an agreement to which you are a party.

Your Rights and Choices Under the California Privacy Laws

The California Privacy Laws grant rights regarding personal information to consumers who are residents of California. The following describes your rights and how to exercise those rights under the California Privacy Laws.

(1) Right to Access Specific Information

You have the right to request that the SIS Group disclose certain information to you in relation to the collection, sharing, disclosure, or use of your personal information by the SIS Group over the twelve (12)months preceding the date of your request. Upon receipt and confirmation of your verifiable consumer request, the SIS Group will disclose to you any or all of the following information:

  • The categories of your personal information that the SIS Group has collected;
  • The categories of sources of your personal information from which the SIS Group has collected;
  • The business or commercial purpose of the SIS Group for the collection, sale, or sharing of such personal information;
  • The categories of third parties the SIS Group discloses, sells, or shares such personal information;
  • The categories of your personal information that the SIS Group has disclosed, sold, or shared to each; and
  • The specific pieces of your personal information that the SIS Group has collected.

(2) Right to Request Deletion

You have the right to request that the SIS Group delete any of your personal information that the SIS Group has collected from you and retained, subject to certain exceptions. Upon receiving your verifiable consumer request, the SIS Group will delete your personal information from our records and will notify any service providers and contractors, as well as third parties to which the SIS Group has sold or with which the SIS Group has shared personal information, that they must delete such personal information from their records, unless an exception applies.

The SIS Group may deny your request to delete your personal information if it is necessary for the SIS Group or the SIS Group’s service providers or contractors to retain your personal information in order to: 

  • Complete the transaction for which the SIS Group collected the personal information, fulfill requirements for a product recall conducted in accordance with a written warranty or federal law, provide a good or service that you requested, enable you to take measures reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform an agreement between the SIS Group and you;
  • Provide support to ensure the security and integrity of your personal information to the extent reasonably and proportionally necessary for the purpose of use;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of other persons to exercise their free speech rights, or exercise other rights provided by law;
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres or adapts to all other applicable ethics and privacy laws, where the SIS Group’s deletion of such information may render impossible or seriously impair the ability to compete such research, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the SIS Group and compatible with the context in which you provided the information; or
  • Comply with legal obligations.

(3)Right to Request Correction of Inaccurate Personal Information

You have the right to request that the SIS Group correct any inaccuracies in your personal information that the SIS Group collected from you. Upon receipt and confirmation of your verifiable consumer request, the SIS Group will correct your inaccurate personal information from our records and will notify any service providers and contractors, as well as third parties to which the SIS Group has sold or with which the SIS Group has shared such personal information, that they must correct such personal information from their records. We may deny your correction request if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

(4)Right to Opt-Out of Share or Sharing

The SIS Group has not and will not sell or share any personal information collected from you.

(5)Right to Request to Limit the Use of Sensitive Personal Information

The SIS Group will not use or disclose sensitive personal information collected from you for purposes other than the following:

  • To provide products and services that are reasonably expected by average consumers;
  • To provide support for ensuring security and integrity;
  • For short-term temporary use (except for any use involving profiling or modification to future consumer experiences);
  • To provide services on behalf of the SIS Group; and
  • To maintain or improve the quality and safety of the SIS Group’s services and devices.

(6)Right of Non-Discrimination

The SIS Group shall not discriminate against California residents for exercising any of their rights under the California Privacy Laws. Moreover, unless permitted by the California Privacy Laws, the SIS Group will not engage in any of the following acts:

  • Deny goods or services to you;
  • Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide you with a different level or quality of goods or services;
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services; or
  • Retaliate against you if you are our employee, applicant for employment, or independent contractor.

(7)Exercising Your Rights to Access, Delete, and Correct

To exercise your rights to access, delete, and correct described above, please submit a verifiable consumer request to the SIS Group by contacting us via the information in “Contact Point for Inquiries and Complaints.”

Only you, a natural person authorized by you, a person registered with the California Secretary of State, a person entrusted by you, or your conservator may submit a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

A “verifiable consumer request” must:

  • Provide sufficient information that allows the SIS Group to reasonably verify that you are the person whose personal information the SIS Group has collected or an authorized representative thereof; and
  • Describe your request with sufficient detail that allows the SIS Group to properly understand, evaluate, and respond thereto.

Contact Point for Inquiries and Complaints

Please make contact at the following for inquiries or complaints about the processing of your personal information:

Contact:

Minoru Kuchiki, Manager of Quality Management Department,
Data Protection Officer

Saison Information Systems Co., Ltd.
Quality Management Department
19F, Akasaka Intercity AIR, 1-8-1 Akasaka, Minato-ku, Tokyo 107-0052, Japan
Email Address : is_receipt@sis2.saison.co.jp
Telephone Number : +81 3 6370 2000

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Registration No. 1182059(12)
Acquired: December 3, 1999
Designated Organization: Japan Information Technology Service Industry Association
Applicable Standard: JISQ15001:2017

The contact information for our representatives in the EEA Region is as follows.
PLANIT // LEGAL Rechtsanwaltsgesellschaft mbH
Jungfernstieg 1, 20095 Hamburg, Germany
Email address : mail@planit.legal

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