Policy for Handling Personal Information

Policy for handling personal information
When handling personal information, we appropriately handle it in compliance with the laws regarding personal information protection, including the Act on the Protection of Personal Information (Act No. 57 in 2003, hereinafter referred to as the “Act”) and guidelines provided by competent authorities as well as in accordance with our policies for personal information protection.
Definition of personal information
“Personal information” hereunder is defined as under paragraph 1 of article 2 of the Act.
Purposes of use of personal information
The purposes of our use of personal information are as follows:

  1. To provide our products and services that are ordered, registered or subscribed.
  2. For the invitation of events, seminars and so on.
  3. To provide respondents to questionnaires or event attendees with reports or information relevant to questionnaires or events.
  4. To provide services via direct mails, emails or facsimile.
  5. To respond to applications for a position.
  6. For the other services relevant or ancillary to the business operations above.
Third party provision of personal information
We do not provide personal information to a third party in any case except for those that we obtain consent of the relevant subject or that is allowed under applicable laws and ordinances. When obtaining such consent, we specify the third party and personal information provided to such third party prior to obtaining such consent.
Scope of third parties
In the cases set forth in the following, a person who receives personal information does not fall under a third party in regard to applying provisions hereunder.

  1. Cases in which we entrust a whole or part of the handling of personal information within the necessary scope to achieve utilization purposes (in these cases, we take all responsibility for the handling of personal information within a contractor).
  2. Cases in which personal information is provided accompanied with business succession caused by a merger or other reason.
  3. Cases in which personal information is to be jointly used with a specified person.
Entrusting of personal information handling
When entrusting a whole or part of the handling of personal information within the scope necessary to achieve utilization purposes, we appoint an appropriate contractor and supervise them appropriately so that the personal information entrusted is handled in a safe manner by the contractor.
Joint use of personal information
We may, to the extent necessary, jointly use personal information as follows:

  1. Categories of personal information: name, contact details and other personal information
  2. Scope of jointly using person: Seicho Holdings, Inc.
  3. Utilization purposes: To provide services which are related to our business operations in a beneficial and safe manner.
  4. Name of person responsible for controlling the personal information: GRID INC.
Separate handling of personal information
If we expressly provide you with a privacy policy or usage guidelines, etc. in relation to the matters regarding personal information(hereinafter collectively referred to as the “Guidelines, etc.”) at the time of acquisition of the relevant personal information, we handle such personal information in accordance with the Guidelines, etc. We are not liable for any problem, issue or incident which falls under a disclaimer provided under the Guidelines, etc.
Accuracy of personal information provided
We make reasonable efforts to process the data of provided personal information with accuracy; provided, however that, the data subject is responsible for ensuring that the personal information is correct and the latest at the time of provision.
Controlling of personal information
We make reasonable efforts to accurately maintain and update the personal information we hold within the scope necessary to achieve the utilization purposes, and delete the personal information without delay when such utilization becomes unnecessary. We take necessary and appropriate security control actions for preventing unauthorized access, altering and leakage based on the existing level of technology.
Utilization of statistical data
We will produce statistical data by processing personal information provided from you so as not to be able to identify a specific individual. We may use statistical data by which a specific individual cannot be identified without any restrictions.
External websites
Our website will include links to external websites. We assume no responsibility or liability for acquisition, controlling and other handling of personal information and the contents on such external websites. If you have any inquiries about the above, please make an inquiry to the linked external websites.
Disclosure, correction and cease of utilization, etc.
When disclosure, correction, addition, deletion, cease of utilization or erasure (hereinafter collectively referred to as “Disclosures etc.”) is requested, we deal with it promptly after verifying that the person requesting is the subject of the relevant personal information, unless there is any special reason. Please make a request for Disclosures, etc. addressed to the Representative Office for Personal Information Protection set forth in “Contact details about personal information control” below. For Disclosure, etc., we will charge service fees depending on its content.
Contact details about personal information
For Disclosures etc. or other inquiries to us, please contact the following office via mail.

GRID INC.
“Representative Office for Personal Information Protection”
[Headquarters] Ao Bldg. 6F, 3-11-7 Kitaaoyama, Minato-ku, Tokyo 107-0061, Japan

Date of enactment:27th May 2019
GRID INC.
CEO Masaru Sogabe

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