2. What is personal information? How will personal information be handled?
2.1. What personal information do we collect?
The Company will acquire personal information in an appropriate manner and will not acquire personal information through deception or other wrongful means.
The types of personal information the Company collects will depend on how the Client interacts with us. Typically, we collect the following personal information:
(b) title of position;
(c) business address;
(d) e-mail address;
(e) phone number;
(f) fax number;
(g) information you provide to us through surveys or feedback forms, or when you register for the Company’s events and seminars.
We normally do not collect sensitive information about our Clients such as information relating to the Client’s health, religion, political beliefs or race. However, when such information is obtained, it will be handled appropriately in accordance with the law.
If you apply for employment with the Company, the Company may also collect personal information including details contained in letters of application and CV/résumé, previous employment background, education history, work-related licenses, certifications, or other professional credentials, and language(s) and other relevant skills. You may also voluntarily choose to provide other relevant information as part of your application. If you intend to provide us with personal information of a reference or any other third party as part of your application for employment, it is your responsibility to obtain consent from that third party prior to providing the personal information to us.
2.2. How does the Company collect personal information?
Situations in which the Company obtains personal information typically include the following:
(a) when the organization you belong to purchases our solutions and/or services;
(b) when we respond to your inquiries and requests;
(c) during conversations or email exchanges between you and the Company;
(d) when we obtain feedback from you about our solutions and services;
(e) when obtaining personal information is necessary for us to carry out our administrative and business functions;
(f) when you register for our events, workshops and seminars or subscribe to our mailing lists and newsletters;
(g) when we market our solutions and services to you;
(h) through your access and use of our website;
(i) if you apply for employment with us.
We may at times obtain personal information through third parties. Where we do so, we will ask such third parties to confirm in writing that they have legally obtained your personal information and that we have the right to acquire it from them and to use it.
2.3. For what purpose does the Company use personal information?
We use personal information for the following purposes:
(a) to communicate with Clients as necessary for the performance of our business;
(b) to establish, manage, and maintain our business relationships;
(c) to respond to inquiries and requests;
(d) to develop, promote sales of, and to deliver and improve our services and solutions;
(e) to inform you about our services and solutions;
(f) to obtain feedback from you on our services and solutions;
(g) to provide you with a more personalized service experience;
(h) to conduct administrative and business functions;
(i) to update our records and keep them up to date;
(j) to enable you to register for and receive our newsletters and mailing lists, and to enable you to register for the Company’s events, workshops, and seminars that you have requested, as well as to enable us to conduct such events, workshops, and seminars;
(k) to process your application for employment with us, evaluate whether your qualifications may be suitable for other employment positions with the Company, and for employment-related purposes if you are hired;
(l) to assess the performance of our websites and to improve their operation;
(m) to process and respond to privacy complaints;
(n) to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, in cooperation with any governmental authority of any country, or as we otherwise believe to be necessary or appropriate under applicable law.
2.4. To whom do we disclose personal information?
2.4.1 Joint utilization of personal information
For the purposes set forth in Section 2.3 above, the Company may jointly utilize personal information with the following affiliated companies of NTT Communications Corporation (NTT Communications Corporation and its group companies (click here) and affiliated subsidiaries of NTT Limited (click here)).The items of personal information to be jointly utilized are limited to those listed in Section 2.1 above. In the case of joint utilization of personal information by our affiliated companies, we will be responsible for managing such personal information.
2.4.2 Providing Personal Information to Third Parties
The Company will not disclose or provide your personal information to third parties except in the following cases:
(a) when we have your consent;
(b) when required by law;
(c) when it is necessary for the protection of a person’s life, body, or property and it is difficult to obtain your consent;
(d) when it is particularly necessary for the purpose of improving public health or promoting the sound growth of children and it is difficult to obtain your consent;
(e) in cases where it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and where obtaining your consent is likely to impede the execution of such affairs;
(f) when personal information pertaining to our business is provided in connection with the succession of our business due to a merger, corporate separation, transfer of business, etc.;
(g) when such personal information is provided in connection with the entrusting of all or part of the operations related to the handling of personal information within the necessary scope for achieving the purpose of use.
Our website may allow you to post questions or comments that will be viewable by third parties visiting the website. Please note that any such information may be available to the general public. We urge you to exercise caution when deciding to post any personal information online.
2.5. Does the Company disclose personal information to recipients outside of Japan?
We may disclose personal information to our overseas affiliates (affiliated subsidiaries of NTT Limited) and other third parties located overseas only in cases where any of the items in Section 2.4.2 above applies or where it is permitted by law.
We will take the necessary steps to contractually ensure that recipients of personal information located overseas will have a level of protection for personal information equivalent to that required by the Personal Information Protection Act.
2.6. How do we store and secure personal information?
We will endeavor to take reasonable precautions to protect personal information from leakage, unauthorized access, or alteration by, for example, implementing a combination of the following security measures:
(a) We will establish a basic policy to ensure the proper handling of personal data.
(b) In addition to appointing a person responsible for the handling of personal data, we will have a system in place to ensure that each employee reports to the person responsible when he or she becomes aware of any indication of a violation of law or regulation regarding the handling of personal data.
(c) Regular self-inspections and audits by other departments and others will be conducted on the status of personal data handling.
(d) Regular training for executives and employees regarding the handling of personal data shall be conducted.
(e) We will limit the scope of employees who handle personal data by implementing access control in areas where personal data is handled and by restricting access to personal data.
(f) We will implement mechanisms to protect information systems that handle personal data from unauthorized access and unauthorized software.
3. Direct Marketing
We may send you direct marketing communications and information about our services and solutions that we consider may be of interest to you. We may send communications in various forms, including mail, SMS, fax and email, in accordance with the Act on Regulation of Transmission of Specified Electronic Mail.
We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related communications from us, we may still send you important administrative messages.
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4. How can you access, correct, or stop the use of personal information?
We will take all reasonable steps to ensure that the personal information we hold about you is accurate, up to date and complete.
Except for cases falling under exceptions permitted under the Personal Information Protection Act and other related laws and regulations, you may at any time request that we notify you of the purpose of use of your personal information in our possession, or disclose, correct, or discontinue use of your personal information or records of provision to third parties.
If you wish to request notification of the purpose of use, disclosure, correction, or suspension of use of your personal information, please send an e-mail from the “Inquiries about Personal Information Protection Policy” page or submit a written request to our contact listed below. The department in charge will contact you within 30 days after the submission of the e-mail or request form. We may charge a small fee to cover the cost of responding to your request.
If we deny your request, we will provide you with written reasons for refusing your request and the mechanisms available to you to complain about our refusal.
If you have concerns about how your personal information is being handled by the Company or wish to make a complaint about a breach of the Personal Information Protection Act by the Company, please send your concerns or complaints by e-mail from the “Inquiries about Personal Information Protection Policy” page, or in writing to our contact listed below.
The department in charge will respond to you in writing within 30 days of receiving your complaint, setting out what action the Company will take as a result of your complaint or alternatively providing an explanation to you if there has been no breach of the law.
5. Contacting us
If you have any questions or concerns about how your personal information is being handled by the Company, please contact us as follows:
Attention: ISMS Committee
President & CEO: Junichi Nojima
NTT Com DD Corporation
34th Floor, Granpark Tower, 3-4-1 Shibaura,
Minato-ku, Tokyo 108-0023