PRIVACY POLICY

Released, 22 October 2018
Revised, 1 July 2019
Revised, 13 December 2019 (Change main office address)

Hashilus Co., Ltd., (hereinafter “We”) shall hereby stipulate and release this privacy policy to promote the protection of personal data by motivating our officers, employees, and related personnel to recognize its importance and ensure the undertaking thereof.

Purpose of Privacy Policy

The privacy policy seeks to inform you of the types, details, procedures for collection, and the purposes of handling personal data to be collected by us when you use our website or other services.

Definitions of Terms Used

All technical terms used herein are based on the definitions specified under Article 4 of the General Data Protection Regulations 2016/679 (GDPR) stipulated by the European Parliament and Council.

Your Rights

You have the following rights pertaining to your personal data unless your exercise of such rights may be contrary to the public interest; detrimental to the life, health, property or interest of ours or of any third party; or not in compliance with laws and regulatory obligations applicable to us, in which case these may precede your rights.

Access Rights

You have the right to check if we are processing your personal data; if we are, you may access some information.

Right to Rectification

You have the right to make a request for rectification of any inaccurate personal data related to you. We will, upon request, rectify such data without any unreasonable delay.

Right to Erase

You have, to some extent, the right to make a request for erasure of personal data related to you, in which case we will, upon request, erase such data without any unreasonable delay.

Right to Restrict Processing

You have, to some extent, the right to restrict us from processing personal data; in other words, the restriction on processing means that such personal data will be marked for restriction from future use.

Right to Data Portability

You have, to some extent, the right to receive, in structured, generally used and mechanically readable forms, any personal data related to you and provided to us from you; in addition, the right to transfer such personal data to any third party other than us.

Right to Object

You have the right to object anytime to our processing of personal data on any of the following legal bases:

a. Process personal data on a legal basis in the public interest or for performance of job duties to exercise public rights granted to us b. Process personal data on a legal basis for pursuit of legitimate interests by us.

In addition, you have the right to object anytime to having your personal data processed for direct marketing such as direct mail transmission, in which case we will suspend the processing of your personal data for the purpose of direct marketing.

Your Identification

We may seek specified information from you for identification if you wish to exercise the preceding right to object to us.

Right to Store Personal Data

We will retain or store our collected personal data in electromagnetic form on any server of ours or of any third party under a contract with us. In addition, we will take the necessary precautions and implement security measures for strict control of personal information, including maintenance of security systems, improvement of maintenance systems, and assurance of employee education in order to maintain personal information in accurate and up-to-date conditions and prevent illegal access to, loss, damage, alteration or leakage of personal information.

We will retain your personal data as long as necessary to achieve the purposes of personal data collection or to fulfill legal obligations; in other words, we usually retain your personal data for two years after you cease to be a customer.

Data to Be Collected

We may, through our website, collect, use, store, or transfer the following personal data concerning you:

  • Status of access to our website; specifically, system information, including the computer OS and Web browser with which you have accessed the website, and access network IP address, access dates and times, access hours, browsed webpages, and viewed images
  • Contact information necessary for responses to inquiries and for business transactions; specifically, your name, email address, phone number, department name, job details, account information, and previously exchanged emails
  • Various types of information necessary for the application for personnel recruitment; specifically, your name, email address, phone number, birthdate, gender, address, academic background, professional experience, and portrait photo necessary for your resume.

Procedures to Collect Personal Data

We will collect personal data concerning you through the following procedures:

  • Collect data from the Web browser when you access our website
  • Collect data entered to send your inquiry form on our website
  • Collect data entered to send any application for participation in any event using external services
  • Collect data entered to apply for personnel recruitment using external services
  • Collect data for business discussions and transactions through communication means including email and telephone

Cross-border Processing of Personal Data

We will comply with the GDPR and Japanese laws, ordinances, and related standards for the protection of personal information in handling information that we have transferred or directly collected from the EEA (European Economic Area).

We may transfer data overseas when processing your personal data, in which case we will follow the procedures stipulated in the laws and ordinances to protect the data.

Details, Purposes, and Legal Bases for Processing Personal Data

We will handle your provided personal data under any of the following conditions, including processing details, purposes, and legal bases.

Using Google Analytics to Collect/Analyze Our Website Access Data

We will use Google Analytics to collect data on your access to our website in order to continue improving the website and provide useful information for you. Google Analytics uses Web beacons and cookies to collect information from Web browsers used by users. Refer to the following webpages for details of information collected by Google Analytics.

Processing such personal data shall be on a legal basis for pursing our legitimate interests. Such processing forms our marketing strategy, which will be necessary for our business development while defining the types of customers for our products and services and maintaining our website in up-to-date and appropriate condition. We will study the expected effects on you and your rights when handling your personal data based on legitimate interests and continue to ensure that they will not precede our legitimate interests. We will not use your personal data for such business activities if those effects on your rights and interests exceed our legitimate interests. In addition, you may install the Google Analytics Opt-out Add-on in your Web browser to prevent Google Analytics from collecting information.

Using HubSpot to Collect/Analyze Our Website Access Data and Collect Contact Information

We will use HubSpot to collect information for profiling your access to our website and for responding to your inquiries in order to continue improving the website and providing useful information for you, as well as to suggest or recommend products and services that may interest you.

HubSpot of the HubSpot Company uses Web beacons and cookies to collect information from terminals used by the users. Information to be collected will include the following:

  • (a) Viewing websites: IP addresses, browser types, domain names, ISP (Internet service providers), files displayed on our website (HTML pages, images, etc.), operating systems, data on screen transitions, access hours, and reference source website addresses
  • (b) Downloading white papers and product data in PDF: Names, email addresses, and company names

Your explicit consent shall be the legal basis for collecting any of the data above. For the processing under (a) above, we will obtain your explicit consent through a privacy agreement notice to be displayed upon your initial access to the website. No disadvantageous result will be brought to you even if you disagree. For the processing under (b) above, we will obtain your explicit consent upon your downloading. If you disagree, we may not provide you with our product information or data update information, etc. In addition, you may click the following button to stop HubSpot tracking if you wish to withdraw consent on the processing under (a) above. Contact us for withdrawing consent on the processing under (b) above.

For more information on the HubSpot Privacy Policy, refer to the following webpages:

[HubSpot Privacy Policy] (https://legal.hubspot.com/privacy-policy)

Registration with Personal Data Customer Database

We may register your personal data with the user database for the following purposes:

(a) Respond to inquiries from you (b) Execute transactions and contracts with you (c) Provide information and invitation/reception services for our sponsored events (d) Suggest or recommend products and services that may interest you

Our execution of the contract with you shall be the legal basis for any of the purposes (a)–(c) above.

Your explicit consent shall be the legal basis for purpose (d) above. We will obtain your consent through checkboxes for sending inquiry forms or other means of communication, including email. Contact us if you wish to withdraw consent.

Using Personal Data for Communication by Phone or Email

We will use your personal data for communication by phone or email for the following purposes:

  • (a) Respond to inquiries from you
  • (b) Execute transactions and contracts with you
  • (c) Provide information and invitation and reception services for our sponsored events
  • (d) Inform you of any urgent matter that may affect you
  • (e) Suggest or recommend products and services that may interest you

Our execution of the contract with you shall be the legal basis for any of the purposes (a)–(d) above.

Your explicit consent shall be the legal basis for purpose (e) above. We will obtain your consent through checkboxes for sending inquiry forms or other means of communication, including email. Contact us if you wish to withdraw consent.

What Not to Do with Your Personal Data

We will not use your personal data to process the following:

  • Automated decision making by profiling based on personal data.

Nondisclosure or Release of Personal Data to Third Parties

We will properly manage entrusted personal data and will not disclose such information to any third party except under any of the following conditions:

  1. With the consent of the user
  2. At the request of any public agency, including court or police according to laws and ordinances
  3. When detrimental to you or any third party with regard to life, health, property, or honor and when the consent is unavailable
  4. When necessary to protect or defend our rights, properties, or services from any activity violating the laws and ordinances or our terms of service or instructions and when the consent unavailable
  5. When allowed or necessary to disclose the information according to other standards or laws and ordinances

However, in order to provide our services for you and conduct business, we may outsource the processing of personal data to business operators (recipients) in the following categories:

  • Businesses who provide website Analytics functions (e.g., Google or HubSpot)
  • Businesses who provide in-house communication tools (e.g., Google or Slack)
  • Email delivery services (e.g., MailChimp or PR TIMES)
  • Event management platforms (e.g., Connpass)

Compliance with and Review of Laws, Ordinances, and Standards

We will review the details of this policy as appropriate for improvement and then comply with the Personal Information Protection Act, including Japanese laws, ordinances, and other related standards applicable to personal information.

This policy may be revised after a review, which will become effective as soon as it is released.

Release and Revision Dates

Release dates will be indicated in the Western calendar; the same applies to revision dates.

Contact for Inquiries and Complaints

Use the following linked form to contact us for inquiries and complaints on our handling of personal information; you may also access us from the following address:

Name (Trade name): Hashilus Co., Ltd.
Main Office Address: postal code: 114-0012, Tabata Shinmachi 1-20-5, Kita-ku, Tokyo

[Inquiry Form] (https://hashilus.com/contact/)

You have the right to lodge a complaint with a supervisory authority anytime concerning data protection problems; however, we would appreciate if you would inform us of your concern before doing so with the authority. If you so wish, you may use the inquiry form above to contact us or send a letter to the address.