Date of revision: 19 JUNE 2020
FunkyCorp Ltd.
Director: Terumasa Mori

1. Purposes

This Privacy Policy (hereinafter the “ Policy”) intends to stipulate the following items in relation to personal information (as defined in the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003) (hereinafter the “ Act”) which may be collected by FunkyCorp Ltd. (hereinafter the “ Company”).
(1) The methods of collecting, using, disclosing, holding and storing personal information by the Company; and
(2) The methods of contacting the Company if you wish to access or make corrections to the personal information the Company holds about you, or if you wish to state your opinion on how we have handled your personal information.

2. Compliance with the applicable law

The Company handles personal information in compliance with the Act, its related government ordinances, regulations, guidelines established by the Personal Information Protection Commission of Japan and any other applicable laws and regulations (hereinafter collectively, the “Applicable Laws and Regulations”) and this Policy.

3. Collection

The Company collects the following personal information:
(1) Information which the Company obtains for recruitment and for contacting and management of prospective employees. Provided that the information in relation to the current and former employees of the Company shall be handled in accordance with the Rules on the management of personal information of employees, and thus shall be excluded from the scope of this Policy.
(2) Information obtained during the course of the Company’s business activities, including those with clients, suppliers, and contractors under service agreements.

4. Sensitive personal information

Under the Policy, sensitive personal information shall mean information regarding race, religion, thoughts and beliefs including political opinions, social status, union activities, sex life, sexual orientation, medical history, criminal records and other personal information which has potential of provoking unjustifiable discrimination or prejudice. The personal information requiring special care defined in the Act shall always be included in Sensitive personal information hereunder.
Notwithstanding any of the provisions hereof, the Company does not collect or provide to a third party any sensitive personal information through this website or in any other manner unless we receive your consent or collection or sharing of the sensitive personal information with a third party is permissible under the Applicable Laws and Regulations.
If you voluntarily submit to the Company your sensitive personal information which we do not require (e.g., by submitting your resume or a job application online), it is deemed that you expressly consent to your sensitive personal information being used in accordance with this Policy.

5. Purposes of use

The Company will use personal information we collect for the purposes set out below or other purposes which is obvious under the circumstances we collected your personal information or otherwise in accordance with the Applicable Laws and Regulations. (hereinafter the “Purposes”).
(1) Personal information of our clients (including potential clients) and their officers, employees, contractors under service agreements, agents and other individuals involved in the deals with the clients (hereinafter collectively, “Clients”): the Company uses Clients’ personal information for communication necessary for transactions, invoicing our fees and expenses, introducing the Company services, delivering our newsletters, inviting Clients to our seminars and for direct marketing or promotional activities.
You may at any time ‘opt out’ from receiving marketing materials from us by following the unsubscribe instructions included in each communication you may receive from us, by indicating so when the Company contacts you, or by contacting the Company directly.
(2) Personal information of suppliers, individual contractors or officers, employees, agents of companies, etc. under service agreements, or individuals or officers, employees, agent of contractors of such contractors, (hereinafter collectively, the “Suppliers”) : the Company uses the personal information of its Suppliers, etc. for the purpose of procurement, making orders or other requests and payments and for communications necessary for transactions.
(3) Personal information of job applicants to the Company: the Company uses job applicants’ personal information for recruitment-related purposes, and for contacting and management of prospective employees. The personal information may include personal information which is written in your resume or job applications you submit online, through recruitment agencies or through third-party sites such as LinkedIn or others.
(4) Personal information provided on our websites, etc.: the Company may ask our websites visitors to complete surveys for its research purposes, in order to expand our business such as improving the quality of our services or improving the ease of use of our websites, which you may choose not to respond to. Also, the Company may receive comments from visitors of websites which the Company manages.
The Company uses these personal information provided on our websites for direct marketing or promotional activities in accordance with the Laws and Regulations. Direct marketing or promotional activities may include providing you with specific information that you have requested or providing more general information about other services of the Company.
You may at any time ‘opt out’ from receiving each marketing material from us by following the unsubscribe instructions included in each communication you may receive from us, by indicating so when the Company contacts you, or by contacting the Company directly.
(5) Personal Information of individuals who request Disclosure, etc. (defined in Section 10 below): the Company uses the personal information to handle your requests.

6. Disclosure of personal information

6.1 Outsourcing (to third-party contractors under service agreements)
The Company may retain third-party contractors to process your personal information if it is necessary for our efficient operation of business and to handle our services. Whenever we retain such data processor, the Company shall conduct monitoring which is necessary and appropriate to ensure the secure management of the personal information entrusted at the third-party contractors.
6.2 Provision of information to a third party (such as governmental authorities, for business reorganisations)
The Company will not provide personal information to any third parties (except for data processors set forth in Section 6.1) unless one of the following applies. If the Company provides personal information to any third parties, the Company shall prepare records of such provision.
(1) You have consented;
(2) It is necessary for the protection of a person’s life, body or property and it is impractical to obtain your prior consent;
(3) It is necessary to cooperate with the Japanese government authorities, local enforcement authorities and obtaining your prior consent may impede the execution of the operations concerned;
(4) In circumstances where your personal information is provided to a third party as a result of the succession of the Company’s business due to a merger, etc.; or
(5) It is otherwise required or authorized by law.
6.3 Provision of information to a third party in a foreign country
The Company may entrust data processing of your personal information to a third party in a foreign country. In such a case, the Company shall follow the Applicable Laws and Regulations.
6.4 The Company will not use personal information for any purpose other than those specific in 5. Purposes of Use. We will also take measures to prevent unauthorized use.

7. Data quality

The Company will make reasonable efforts to ensure that the personal information we collect is accurate, up to date and complete.

8. Protection of personal information

The Company uses appropriate security measures in order to protect the personal data we collect, use or transfer from loss, misuse, alteration or destruction. However, you should be aware that, due to the open and unsecured character of the Internet, the Company cannot be responsible for the security of transmissions of the personal data over the Internet. In addition, we have put in place a management system for personal information which supports these policies and which takes into consideration IT technology trends, changes in social requirements and the business environment on an ongoing basis to constantly improve our management system.

9. Retention of personal information

The Company retains your personal information only for as long as is necessary to comply with its legal and contractual obligations or otherwise in accordance with the retention period prescribed by the Applicable Laws and Regulations. When such retention period is over, the Company will take reasonable steps to destroy or delete the information.

10. Disclosing, correcting, adding, deleting, ceasing to use or erasing your personal information

Subject to the provisions of the Applicable Laws and Regulations, you can request the Company to disclose, correct, add, delete, cease to use or erase your personal information (collectively, “Disclosure”) that the Company holds about you by contacting us. You can do this by contacting us directly (details of which are below). The Company may charge a reasonable fee for the processing of your requests.
When the Company receives a request for disclosure, it will promptly disclose your personal information pursuant to the Applicable Laws and Regulations. When the Company receives a request to correct, add, or delete your personal information, it will make necessary investigation without delay to the extent necessary for achieving the Purposes and treat your request appropriately in light of the results of the investigation. When we receive a request to cease to use or erase your personal data, we will treat your request appropriately if we find that your request has good reason, in accordance with the Applicable Laws and Regulations.
Where permitted by the Applicable Laws and Regulations, the Company may decline your requests of Disclosure. In such situation, the Company will notify you of such decline with reasons therefor.

11. Contacting the Company for questions, complaints or Disclosure

If you have any questions or complaints about any personal information that the Company holds about you, or if you wish to request Disclosure, then you can contact our Data Protection Officer by sending an email to privacy@funkycorp.com.

12. EU residents’ data

If the Company handles personal data of residents within the EU region as a Data Processor under the EU General Data Protection Regulation, the Company will handle such data in accordance with the instructions made by the Data Controller of such data.

13. Cookies

Our website automatically collects internet domain names, IP addresses, and browsing information, etc. of our websites. Among these, cookies (information sent from servers to browsers of the users and accumulated in computers of the users in order to identify users from the servers side) are used for limited purposes of the smooth operation of the services provided by our website and do not include any personal information. Such collected information is used for reference purposes for the smooth operation of the services provided by our website.

14. Notification of changes to this Policy

This Policy was established on 13 December 2019. We may periodically update this Policy to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. If amendment is made, it will be posted on our website. The amendment will be in effect when the amendment is posted on our website.

15. Language

There is a Japanese version of this Policy. If there are any discrepancies between this English version and the Japanese version, the Japanese version shall prevail.
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