P r i v a c y p o l i c y
Privacy Policy
With respect to personal information entrusted to us by companies and individuals, and by our employees for the purpose of fulfilling our business activities and mission of social contribution, our company has clearly established the following privacy policy for the handling of personal information, including Personal Information Protection Policy, (hereinafter referred to as the “Privacy Policy”) and will strictly manage such personal information. For the purpose of the Privacy Policy, personal information shall mean personal information as defined in Article 2.1 of the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”). Unless otherwise specified in the Privacy Policy, the definitions of terms used in the Privacy Policy shall be in accordance with the provisions of the Personal Information Protection Act.
Personal Information Protection Policy
Established on August 1, 2017
Last revised on March 13, 2024
1. We will acquire, use, and provide personal information in a proper manner upon clarifying the purpose of use in order to conduct
our business objectives, etc. Unless otherwise permitted by the Personal Information Protection Act or other laws and regulations, we
will use any acquired personal information within the scope of the purpose of use and will take measures to prevent use of such
personal information for any other purpose or in a manner that may encourage or induce illegal or unjust acts.
2. For all personal information we handle, we will comply with applicable laws, regulations, national guidelines, and other norms
regarding the handling of personal information.
3. When entrusting all or part of the personal information we have collected to a third party, we will select and contract with a
company or individual that meets our management standards and will take measures to ensure the proper management of the personal
information.
4. We will take sufficient security control and measures to prevent leakage, loss, damage, or destruction of personal information and
will take necessary corrective measures for such incidents.
5. In accordance with the provisions of the Personal Information Protection Act, we will accommodate requests for disclosure, etc. of
personal information from the person who has provided us with his/her personal information.
6. We establish a contact desk to respond to complaints in good faith and in a timely manner.
7. We will continuously review our personal information management system, implement safety control measures throughout the
organization, and work to improve them from time to time.
This Policy shall be distributed and made known to all employees, and shall be posted on the Company’s website (hereinafter referred to as the “Company’s Website”), etc., to allow for access to the Policy at any time.
linkties Holdings Co., Ltd.
Representative Director Makoto Takano
[Contact Desk for inquiries about the contents of the Personal Information Protection Policy and for complaints and consultations regarding personal information]
Higashiazabu 1-chome Bldg. 2F, 1-9-15 Higashiazabu, Minato-ku, Tokyo 106-0044, Japan
Corporate Planning, Personal Information Protection Manager, linkties Holdings Co., Ltd.
TEL: 050-1745-9033 (Hours of operation: 10:00 – 19:00)
[Name of certified personal information protection organization and contact for complaint resolution]
Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032, Japan
Name of certified personal information protection organization: Japan Institute for Promotion of Digital Economy and Community
Contact for complaint resolution: Personal Information Protection Complaints Office
TEL: 03-5860-7565 / 0120-700-779
Handling of Personal Information
As part of our commitment to personal information protection, we provide the following information on our handling of personal
information, with details of what should be made accessible to the person, as well as matters that should be disclosed to the
public.
(In compliance with the latest Personal Information Protection Act)
The Company’s Website uses SSL (Secure Sockets Layer) data encryption system for all areas where personal information is input.
In addition, we have adopted measures to protect information on the Company’s Website, such as installing firewalls, etc. Please note,
however, that due to the nature of Internet communications, security cannot be completely guaranteed.
・Voluntary nature of personal information provision
The provision of personal information by customers is voluntary, however, if a customer does not provide us with the required
information, the relevant services, etc. may not be provided appropriately.
・Acquisition of personal information by means not easily identifiable to the person
We use cookies on the Company’s Website to make it more convenient for users visiting the website again, and they do not infringe on
the privacy of users nor have any harmful effects on the users’ computers. If you prefer to disable cookies, you may do so by changing
the settings on your web browser. However, disabling cookies may prevent you from using certain features of our services.
1. Name of Business
linkties Holdings Co., Ltd.
2. Name or Title, Affiliation and Contact Information of Responsible for Personal Information Management
Please refer to “Contact Desk for complaints and consultations regarding personal information” under “Personal Information Protection Policy”.
3. Purpose of Use of Personal Information
We will not handle personal information beyond the scope necessary for achieving the purpose of use specified below without the consent of the identifiable person, except as permitted by the Personal Information Protection Act or other applicable laws and regulations.
(1) Personal information acquired directly from the identifiable person
The following applies to information that we acquire directly from the identifiable person.
Such information may be disclosed
without delay when requested by the identifiable person, as per his or her right.
Purpose of use: | To provide products and services in our publishing business, digital media business, seminar and event business, community business, brand business and other businesses of the Company (hereinafter referred to as “Our Products, etc.”) |
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Information to be used: | Name, address, date of birth, occupation, type of business, job title, gender, company name, department, title, amount of financial assets held, telephone number, e-mail address, and other personal information concerning customers who have used Our Products, etc. |
Purpose of use: | To improve the quality of Our Products, etc., and to develop new products and services. |
Information to be used: | Name, address, date of birth, occupation, type of business, job title, gender, company name, department, title, amount of financial assets held, telephone number, e-mail address, and other personal information concerning customers who have used Our Products, etc. |
Purpose of use: | To provide information on Our Products, etc., and to respond to inquiries, etc. |
Information to be used: | Name, address, company name, department, title, telephone number, and e-mail address. |
Purpose of use: | To manage customers and fulfill contracts for online shopping. |
Information to be used: | Name, address, gender, company name, department, title, telephone number, e-mail address, and other personal information concerning online shopping customers. |
Purpose of use: | To notify of changes in our terms of use, policies, etc. (hereinafter referred to as “Terms of Use, etc.”) regarding Our Products, etc. or online shopping, or to respond to violations of the Terms of Use, etc. |
Information to be used: | Name, address, gender, company name, department, title, telephone number, e-mail address, and other personal information concerning online shopping customers. |
Purpose of use: | For business negotiations and various business communications, order receipt/placement, and billing and payment operations. |
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Information to be used: | Name, company name, department, title, telephone number, and e-mail address. |
Purpose of use: | For personnel and labor management, task management, health management, security management, and internal procedures. |
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Information to be used: | Name, company name, department, title, telephone number, e-mail address, address, individual number (My Number), and other personal information required for procedures in personnel and labor management, etc. |
Purpose of use: | For screening and communication in recruitment processes. |
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Information to be used: | Name, company name, department, title, telephone number, e-mail address, experience of volunteer activities, hobbies, external activities, acquired certifications/licenses, and other personal information about the job applicant submitted in relation to recruitment. |
Purpose of use: | To respond to inquiries. |
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Information to be used: | Name, company name, department, title, telephone number, and e-mail address. |
(2) Purpose of use of personal information acquired not directly from the identifiable person
This mainly refers to personal information that we have received from our business partners and customers as necessary to carry out part or all of certain tasks entrusted to us.
Purpose of use: | For commissioned work such as production of booklets and digital media. |
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Information to be used: | Name, gender, company name, department, title, telephone number, and e-mail address. |
Purpose of use: | In case of acquiring information on the personnel of a partner company. |
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Information to be used: | Name, gender, company name, department, title, telephone number, and e-mail address. |
Purpose of use: | For job applicants through Hello Work, employment placement websites, or staffing agencies, for recruitment processes. |
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Information to be used: | Name, gender, company name, department, title, telephone number, and e-mail address. |
(3) Purpose of use of personal information acquired directly or not directly from the identifiable person
Purpose of use: | To manage shareholders and to comply with procedures required by the Companies Act and other applicable laws and regulations. |
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Information to be used: | Name, company name, department, title, telephone number, e-mail address, and other personal information of shareholders and stock acquisition right holders. |
Purpose of use: | For purposes incidental to the purposes of use described in (1) through (3) above. |
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Information to be used: | All Personal Information. |
4. Provision of Personal Information to Third Parties
We may provide personal information to third parties in cases permitted by the Personal Information Protection Act or other laws and regulations, and we may also provide personal information to third parties to the extent necessary to achieve business objectives as follows:
(1) Purpose of provision to third parties: | To inform about new products and services. |
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(2) Categories of personal information to be provided | Name, address, telephone number, membership number, e-mail address. |
(3) Means or method of provision: | Sent as an email attachment protected by a password. |
(4) Type and attributes of recipient organizations: | Partner companies in the fields of publishing, digital media, and seminars and events. |
(5) Agreement on Handling of Personal Information: | The recipient companies are bound by a non-disclosure agreement with us to properly protect the personal information. |
5. Outsourcing of Personal Information Handling
In the course of our business operations, we outsource some of our business operations to provide better services to our customers. Please refer to Item 3 of the Personal Information Protection Policy for information on measures to be taken upon entrusting all or part of the personal information collected.
6. Security Control of Personal Information
The specific safety control measures for the personal data we hold are as follows:
Formulation of basic policy | The Privacy Policy has been established as a basic policy for “compliance with relevant laws, guidelines, etc.”, “contact desk for inquiries and complaints” and other related matters to ensure the proper handling of personal data. |
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Establishment of rules for handling of personal data | The handling rules for personal data have been established, stipulating the handling methods, the responsible persons and their duties, etc., for each stage of the process, including acquisition, use, storage, provision, deletion and disposal. |
Organizational Safety Control Measures |
(1) A responsible person for the handling of personal data has been appointed, and employees who handle personal data and the
scope of the personal data handled by those employees have been clarified, as well as a reporting and communication system to
the responsible person in the event of discovery of any facts or signs of violations of laws or handling rules has been
established. (2) The status of handling of personal data is regularly checked through self-inspection, and also through audits by other departments and external parties. |
Human Safety Control Measures |
(1) Regular training is provided to employees on the important matters regarding the handling of personal data. (2) Provisions regarding the confidentiality of personal data are included in the Rules of Employment. |
Physical Safety Control Measures |
(1) In areas where personal data is handled, employee access to the area is controlled, devices brought into the area are
restricted, and measures are taken to prevent access to personal data by unauthorized persons. (2) Measures are taken to prevent the theft or loss of equipment, electronic media, documents, etc. that handle personal data, and to ensure that personal data is not easily identified when transporting such equipment, electronic media, etc., including when moving within the office. |
Technological Safety Control Measures |
(1) By controlling access, the personnel who handle personal information databases, etc. and the scope of their access are
limited. (2) A system to protect our information system handling personal data from unauthorized access or malicious software has been introduced. |
Comprehension of external environment | When storing personal data, we may use servers located in multiple countries, and we are unable to accurately identify the country in which the relevant server is located. |
7. Joint Use
We jointly use personal information with our group companies.
Details for each item are as follows.
If a consent form is used, consent will be obtained using a consent form that specifically states the following contents.
Item regarding the fact of “Joint Use” | Specify on the Company’s Website and in the consent form. |
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Categories of “Personal Information Jointly Used” | Name, address, contact telephone number, e-mail address, hobbies, and other information on the person necessary to achieve the purposes of use of the “Joint Users” described below. |
Extent of “Joint Users” | linkties Co., Ltd., LIGHTHOUSE MEDIA Inc., and linkties Digital Co., Ltd. (all of which are our group companies, and hereinafter, including the Company, collectively referred to as the “linkties Group”). |
Purpose of use by “Joint Users” |
(1) To provide publications, subscription services, article writing, merchandise sales services, community services, CMS tool
services, and other products and services that we or joint users handle. (2) For sending direct mailings, providing information on products and services, and conducting surveys, etc., by us or joint users. (3) For sales analysis and other research and studies, and for development of new products and services, etc., by us or joint users. (4) To communicate and hand over to the relevant company inquiries, applications for use, and other requests from customers regarding products and services provided by us or joint users. (5) In addition to the above items (1) through (4), to ensure the appropriate and smooth performance of transactions with customers by us or joint users. (6) For business management and internal control of the linkties Group. |
Name and address of the person responsible for and representative name of the person responsible for “Managing the Personal Information Jointly Used,” and name of representative of the Company |
Higashiazabu 1-chome Bldg. 2F, 1-9-15 Higashiazabu, Minato-ku, Tokyo 106-0044, Japan Makoto Takano, Representative Director, linkties Holdings Co., Ltd. |
Item regarding “Acquisition Method of Personal Information Jointly Used” | Acquired through application postcards, etc., participation in seminars, etc. held by us, e-mail and various social networking services, and exchange of business cards. |
8. Provision of Information Related to Personal Information to Third Parties
(1) Except in cases permitted by the Personal Information Protection Act, if it is assumed that a third party acquires information related to personal information (meaning those set forth in Article 2, Paragraph 7 of the Personal Information Protection Act, and limited to those compiled in a database or the equivalent of information related to personal information set forth in Article 16, Paragraph 7 of the same act; hereinafter the same applies) as personal data, we shall not provide the information related to personal information to the third party without confirming the matters set forth below pursuant to Order of the Personal Information Protection Commission:
(i) the identifiable person’s consent to the effect that the person approves of the third party acquiring information related to
personal information as personal data that can identify the person from us has been obtained;
(ii) for provision to a third party in a foreign country, before the businesses obtain the identifiable person’s consent referred to
in the preceding item, information on the personal information protection system of the foreign country, information on the measures
the third party takes for the protection of personal information, and other information that serves as a reference to the person,
has been provided in advance to the person pursuant to Order of the Personal Information Protection Commission.
(2) When having provided information related to personal information to a third party, we shall prepare and keep a record pursuant
to Article 31 of the Personal Information Protection Act.
(3) When receiving information related to personal information from a third party, we shall confirm necessary matters pursuant to
the Personal Information Protection Act and prepare and keep a record of such confirmation.
9. Handling of Pseudonymized Personal Information
(1) When preparing pseudonymized personal information (meaning those set forth in Article 2, Paragraph 5 of the Personal Information
Protection Act, limited to those compiled in a pseudonymized personal information database or the equivalent set forth in Article
16, Paragraph 5 of the same act; hereinafter the same applies), we shall process personal information in accordance with standards
prescribed by Order of the Personal Information Protection Commission.
(2) When having prepared pseudonymized personal information or having acquired pseudonymized personal information and deleted or
other related information (meaning those set forth in Article 41, Paragraph 2 of the Personal Information Protection Act;
hereinafter the same applies) related to the pseudonymized information, we shall take measures for the management of the security of
deleted or other related information in accordance with standards prescribed by Order of the Personal Information Protection
Commission as those necessary to prevent the leaking of deleted or other related information.
(3) With respect to pseudonymized information (limited to personal information; hereinafter the same applies in this paragraph (3)),
we shall comply with the following provisions:
(i) Notwithstanding the provision of the “Personal Information Protection Policy” and this “Handling of Personal Information,” and
except in cases based on laws and regulations, we shall not handle pseudonymized personal information beyond the necessary scope to
achieve the purpose of use;
(ii) Notwithstanding the provisions of Paragraph 4, and except in cases based on laws and regulations, we shall not provide a third
party with personal data that constitutes pseudonymized personal information;
(iii) In handling pseudonymized personal information, we shall not collate the pseudonymized personal information with other
information in order to identify a person identifiable by personal information that was used to prepare the pseudonymized personal
information.
(iv) In handling pseudonymized personal information, we shall not use contact addresses and other information contained in the
pseudonymized personal information for telephoning, for sending by mail or by correspondence delivery, for delivering a telegram,
for transmitting information using a facsimile machine or electronic or magnetic means, or for visiting a residence.
(v) The provisions of paragraph 4 of the “Personal Information Protection Policy”, paragraph 4 of the “Handling of Personal
Information”, and the “Requests for Disclosure, etc. of Personal Data We Hold” and the “Information on Procedures for Requests for
Disclosure, etc. of Personal Data We Hold and Records of Provision of Personal Data to Third Parties” shall not apply to
pseudonymized personal information.
(4) With respect to pseudonymized information (excluding personal information; hereinafter the same applies in this Paragraph (4)), we shall comply with the following provisions:
(i) Except in cases based on laws and regulations, we shall not provide pseudonymized information to a third party;
(ii) We shall exercise necessary and appropriate supervision over our employees to ensure that the pseudonymized information is
securely managed against risks such as leakage of the pseudonymized information. In addition, when outsourcing all or part of the
handling of pseudonymized information, we shall provide necessary and appropriate supervision to ensure that the outsourced company
securely manages the pseudonymized information;
(iii) In handling pseudonymized information, we shall not acquire deleted or other related information, or collate the pseudonymized
information with other information in order to identify a person identifiable by personal information that was used to prepare the
pseudonymized personal information.
(iv) In handling pseudonymized information, we shall not use contact addresses and other information contained in the pseudonymized
information for telephoning, for sending by mail or by correspondence delivery, for delivering a telegram, for transmitting
information using a facsimile machine or electronic or magnetic means, or for visiting a residence.
10. Handling of Anonymized Personal Information
(1) When preparing anonymized personal information (meaning those set forth in Article 2, Paragraph 6 of the Personal Information
Protection Act, limited to those compiled in a anonymized personal information database or the equivalent set forth in Article 16,
Paragraph 6 of the same act; hereinafter the same applies), we shall process personal information in accordance with standards
prescribed by Order of the Personal Information Protection Commission.
(2) When having prepared anonymized personal information, we shall take measures for security management in accordance with the
standards prescribed by the Order of the Personal Information Protection Commission.
(3) When having prepared anonymized personal information, we shall disclose the categories of information on an individual that is
contained in the anonymized personal information, pursuant to Order of the Personal Information Protection Commission.
(4) We, before providing anonymized personal information (including those which we have prepared ourselves and those which we have
been provided by a third party; hereinafter the same applies unless otherwise specified) to a third party, shall disclose the
categories of information on an individual that is contained in the anonymized personal information to be provided to the third
party, and the means of provision of such information, and state to the third party explicitly that the information we will provide
is anonymized personal information, pursuant to Order of the Personal Information Protection Commission.
(5) When handling anonymized personal information, we will not (i) collate the anonymized personal information with other
information, or (ii) acquire information relating to identifiers or their equivalent or individual identification codes deleted from
the personal information or information relating to methods of processing carried out pursuant to the provisions of Article 43,
Paragraph 1 of the Personal Information Protection Act in order to identify a person identifiable by personal information that was
used to prepare that anonymized personal information ((ii) shall apply only to the anonymized personal information having been
provided by a third party).
(6) We shall endeavor to take the necessary and appropriate measures for managing the security of anonymized personal information
and the necessary measures to ensure the proper handling of anonymized personal information such as processing complaints about the
preparation and handling of anonymized personal information, and shall endeavor to disclose the content of those measures.
Requests for Disclosure, etc. of Personal Data We Hold and Records of Provision of Personal Data to Third Parties
Customers may make a request for disclosure, etc. (notification of purpose of use; disclosure; correction, addition, or deletion of information; ceasing to use or deleting; ceasing to provide to third parties; and disclosure of records of provision to third parties) of their own personal information and other information to our “Contact Desk for complaints and consultations regarding personal information”. Upon such request, we will confirm the identity of the customer and respond accordingly within a reasonable period of time. For details on requests for disclosure, etc., please contact the “Contact Desk for complaints and consultations regarding personal information” of the “Personal Information Protection Policy”.
Information on Procedures for Requests for Disclosure, etc. of Personal Data We Hold and Records of Provision of Personal Data to Third Parties.
With respect to personal data we hold, we will accept requests for notification of purpose of use, disclosure, correction, addition, or deletion of information, ceasing to use, deleting, suspension of provision to third parties, and disclosure of records of provision to third parties (hereinafter collectively referred to as “Disclosure, etc.”) made by the identifiable person of the personal data or his/her representative in the request form prescribed by us. In accordance with the provisions of the Personal Information Protection Act and other laws and regulations, Disclosure, etc. may not be made, in which case we will inform you with the reason thereof in our response.
1. Request for Disclosure, etc. of Personal Data We Hold
Disclosure, etc. of personal data we hold refers to the disclosure of personal data we hold, notification of the purpose of use,
correction, addition, or deletion of personal data we hold, and ceasing to use, deletion, or suspension of provision to third parties
of personal data we hold, as stipulated in the Personal Information Protection Act.
The personal information subject to your request is limited to personal information for which we are legally authorized for
Disclosure, etc.
(1) Contact for requests for Disclosure, etc.
Requests for Disclosure, etc. of personal data we hold should be made directly to our “Contact Desk for complaints and consultations
regarding personal information” set forth in the “Personal Information Protection Policy” (hereinafter referred to as our “Personal
Information Contact Desk”).
The procedures for filing a request for Disclosure, etc. with our Personal Information Contact Desk are described in (2) through (5)
below.
(2) Documents required to be submitted for requests for Disclosure, etc.
Please fill out the “Personal Information Disclosure Request Form” and send it to our Personal Information Contact Desk by mail to request for disclosure, notification of purpose of use, correction, addition, deletion, cessation of use, and deletion of personal data we hold, and suspension of provision to a third party. Please ask us directly for a Personal Information Disclosure Request Form.
(3) Fees for requests for disclosure and notification of purpose of use of personal data we hold
A fee of 1,000 yen (including consumption tax) will be charged for each request for disclosure and notification of purpose of use of
personal data we hold. Please be sure to send the disclosure request form or the purpose-of-use notification request form together
with postage stamps or postal money order equivalent to 1,000 yen enclosed by mail.
☆”Postal money orders” are issued at post offices. Customers are responsible for any fees associated with the issuance of a money
order.
(4) Persons eligible to request for Disclosure, etc.
The following persons are eligible to request for Disclosure, etc.:
(i) The person himself/herself (the individual identifiable by the personal information subject to Disclosure, etc.)
(ii) The representative (person authorized by the identifiable person, or legal representative such as a person with parental
authority)
(5) Documents to verify the identity of the person and his/her representative
When making a request for Disclosure, etc., you must submit documents to verify that the person making the request is the identifiable person or his/her representative. (Power of attorney, etc.)
(i) If the person making the request for Disclosure, etc. is the identifiable person, please attach one of the following items:
・A copy of one of the following items: driver’s license, health insurance card, or resident certificate (within 3 months from the
date of registration)
・A copy of student ID card or student handbook
・A copy of residence card
・Certificate of national qualification
(ii) If the person making the request for Disclosure, etc. is the representative
One of the above items and a power of attorney from the identifiable person.
(A seal of the identifiable person must be affixed and a certificate of seal registration for such seal must be submitted. If the
representative is a legal representative such as a person with parental authority, a document indicating the relationship between the
representative and the identifiable person must be submitted. If the representative is a lawyer or other licensed professional, please
include the occupation and registration number.)
2. Other
We may change our Personal Information Protection Policy, procedures for Disclosure, etc. without prior notice for the purpose of
further enhancing our efforts to protect personal information or in response to changes in laws, regulations, or other norms.
Information
can be disclosed by data, paper, or other means. Please indicate the method you prefer on the request form.
3. Contact information for complaints and inquiries regarding personal information protection
If you have any questions, concerns, complaints, or other inquiries regarding our commitment to the personal information protection, please contact our Personal Information Contact Desk.
For inquiries, please contact the following:
linkties Holdings Co., Ltd.
Higashiazabu 1-chome Bldg. 2F, 1-9-15 Higashiazabu, Minato-ku, Tokyo 106-0044
TEL: 050-1745-9033