Privacy Policy

Privacy Policy
Inbound Platform Corp.
CEO Shin O

We recognize that the protection of the personal information of customers, business partners, employees, and related parties is our important duty. Therefore, based on the personal information protection principles and the code of conduct established by us, we fully recognize our social mission and comply with laws and regulations concerning the protection of the rights of individuals and personal information. In addition, we hereby declare that we will establish a personal information protection management system to realize the following policies and that we will make company-wide efforts for the continuous improvement of such system while always being aware of the latest technology trends, changes in social demands, changes in the business environment.

(a)
Personal information will be obtained, used, and provided only to the extent necessary for the Company's legitimate business operations in the Wi-Fi, campervan, and media businesses, as well as for the employment and personnel management of employees, and personal information will not be handled beyond the extent necessary to achieve the specified purposes of use. We will not use personal information beyond the scope necessary to achieve the specified purposes of use (use for purposes other than those specified). We will not use personal information in a manner that may encourage or induce illegal or unlawful activities. Furthermore, we will take measures to prevent such use.
(b)
We will comply with laws, regulations, national guidelines, and other norms regarding the protection of personal information.
(c)
To prevent the risk of leakage, loss, or damage of personal information, we will continuously improve our information security system by injecting management resources that match the actual conditions of our business to prevent such risks through reasonable security measures. In addition, we will promptly take corrective measures if any problem is found in the protection of personal information.
(d)
Complaints and consultations regarding the handling of personal information will be handled promptly, sincerely, and appropriately.
(e)
In order to maintain appropriate protection of personal information, we will regularly review and endeavor to continuously improve our personal information protection management system.
(f)
Handling of Anonymous Processed Information
We will not handle anonymously processed information through our business. If handling occurs in the future, we will disclose the necessary information required by laws, regulations, and related guidelines, implement safety control measures, and appropriately handle the information."

This policy shall be made known to all employees, and measures shall be taken to make it available to anyone at any time by posting it on the Company's website and other means.

【Information Desk for Disclosure and Opt Out】

For requests regarding disclosure of personal data held by the Company and inquiries regarding other personal information, please contact the following information desk.
Where to submit inquiries regarding personal information:

Inbound Platform Corp., Personal Information Inquiries
Address: 4th floor, SW Shimbashi Building, 6-14-5 Shimbashi, Minato-ku, Tokyo 105-0004
Tel: 03-3437-3129 [Reception: weekdays from 10: 00-19: 00]

Handling of Personal Information

a)Disclosure of Personal Data in Our Possession

Inbound Platform Corp.

b)Name or title, affiliation, and contact information of the personal information protection manager

Personal Information Protection Manager:Director and CFO
Contact: SW Shinbashi Building 4F, 6-14-5 Shinbashi, Minato-ku, Tokyo
Tel.03-3437-3129 Fax.03-3437-3132

c)purpose of use of personal information handled by the Company

(1) Purpose of use of personal information obtained directly from the person in writing (including information obtained through the website, e-mail, etc.)

In advance of its acquisition, the purpose of use shall be specified in writing to the individual concerned.

(2) Purposes of use of personal information obtained by methods other than those described in the preceding paragraph
ClassificationPurpose of use
Individual customer informationTo provide the services you have applied for
For user support
To manage your usage history
To provide information about our services
To respond to inquiries
To negotiate, contact, consult, place and receive orders, settle payments, or other processing related to transactions.
To transfer goods or services related to a transaction.
To ensure the appropriate and smooth performance of our other business activities.
Information for the person in charge of our suppliersTo confirm order details
(e.g., correspondence records)
Information about the Company's Officers, Employees, Former Employees, and their Family MembersTo handle rights and obligations related to labor-related laws and regulations, tax-related laws and regulations, and social welfare-related laws and regulations, including business communication, information exchange, personnel policies (including career development such as transfer, evaluation, and education), salary payment, attendance management, and welfare programs.
To handle various procedures stipulated in internal regulations.
To submit reports to government and municipal offices, their affiliated organizations, or organizations with which we are affiliated.
To provide welfare services and related procedures.
To communicate in case of emergency.
To facilitate other labor management and our business.
Information on applicants for employment with our companyTo contact applicants for employment and to manage the Company's recruitment process.
Specified personal information For the purposes of use stipulated in the Numbering Act
Shareholder informationTo exercise rights and fulfill obligations as a shareholder under the Companies Act and other laws and regulations.
To implement various measures for the status as a shareholder.
To manage shareholders' data under the prescribed standards based on various laws and regulations.
To manage shareholders, such as preparing shareholder data in accordance with prescribed standards under various laws and regulations.
To properly and smoothly execute other Company businesses.

d)provision of personal data to third parties

However, we may provide personal information we have obtained to third parties within the scope necessary to achieve the purpose of use. We will ensure that these third parties have adequate security measures in place for handling of personal information, and we will carry out necessary and appropriate supervision.

<Purpose of providing information to third parties>
For real estate rental brokerage, sale services, and other services provided by our company.

<Items of personal information to be provided>
Address, name, date of birth, telephone number, FAX number, email address, name of employer

<Means or method of provision>
In writing, by telephone, fax, or email

<Type of organization and attributes of the person or persons to whom the information is provided.>
Real estate brokers, various service providers

・provision of personal data to third parties in foreign countries

When we disclose or provide personal data to third parties in foreign countries, we will comply with the regulations of laws and regulations related to the protection of personal information, and in principle, we will obtain your consent after providing you with the information required to be provided by the laws and regulations related to the protection of personal information in advance.

e)Outsourcing the Handling of Personal Information

In the course of business operations, we may outsource all or part of the personal information to other companies within the scope of the usage purposes mentioned above. In such cases, we select contractors with high level of personal information protection, conclude contracts regarding appropriate management and confidentiality of personal information, and ensure appropriate management is carried out.

f)Request for Disclosure of Personal Information

You may contact us at the address below to request disclosure of your personal information (notification of purpose of use; disclosure; correction/addition/deletion of contents; suspension of use or deletion; suspension of provision to third parties). We will respond to such requests within a reasonable period of time upon confirming your identity.

【Contact for Inquiries】
Inbound Platform Corp. Personal Information Inquiry Contact
SW Shinbashi Building 4F, 6-14-5 Shinbashi, Minato-ku, Tokyo, 105-0004
Tel.03-3437-3129 Fax.03-3437-3132

g)Voluntary nature of Providing Personal Information

Whether or not you provide us with your personal information is voluntary. However, if necesary items are not provided, we may not be able to respond appropriately.

■ Cookie Policy

What is a cookie?
Cookies are a widely used mechanism that stores the usage history, input contents, and other information sent and received between the browser and the server as a file on the computer of the website user (hereinafter referred to as "user") when the website is used.
When a user accesses the same website again, the website operator can use the information from the user's cookie to allow the page operator to change the display of the website for each user.
If you allow cookies to be sent and received in your browser settings, the website can retrieve cookies from your browser. Please note that the user's browser will only transmit cookies sent and received by that website server to protect privacy.

About cookie settings
Users can choose to Allow all cookies," Reject all cookies," or ""Notify user when cookies are received"" for settings related to sending and receiving cookies. The setting method varies depending on the browser. Please refer to your browser's ""Help"" menu for cookie-related settings.
Please note that if you select a setting that rejects all cookies, you may be restricted from using various services on the Internet, such as not being able to receive services that require authentication

What we do with cookies
We use cookies for the following purposes

・When you log in to our authentication service, we refer to your stored registration information so that we can provide you with services customized to your needs. ・To research the number of users and traffic to our site ・To improve our services ・To maintain security, prompt users to re-enter their passwords (re-authentication) after a certain period of time has elapsed since their last use of the site. ・Where our advertisements are placed on various sites on the Internet by third-party distribution providers such as Google, Yahoo! JAPAN, and Facebook, these providers distribute advertisements based on past access information to our website. However, such identification information and access information do not contain personally identifiable information, and will not be used for any purpose other than the delivery of advertisements. In addition, users of our website can disable the use of cookies by accessing the opt-out page for those vendors' advertisements. To disable behavioral targeting advertising services, please visit the following page and follow the instructions.

■Disclosure of Personal Data in Our Possession

With respect to requests from the individual or his/her representative for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, elimination, or suspension of provision to a third party (hereinafter referred to as "Request for Disclosure, etc.") of retained personal data held by the Company, the Company will respond to such requests in accordance with the following procedures.

(a) Name of business

Inbound Platform Corp.

(b) Personal Information Protection Manager

Personal Information Protection Manager: Director and CFO
  Contact: SW Shinbashi Building 4F, 6-14-5 Shimbashi, Minato-ku, Tokyo
  Tel.03-3437-3129 Fax.03-3437-3132

(c) Purpose of use of all retained personal data

Classification Purpose of Use
Individual Customer Information To provide the services you have applied for
For user support
To manage your usage history
To provide information about our services
To respond to inquiries
To negotiate, contact, consult, place and receive orders, settle payments
or other processing related to transactions
To transfer goods or services related to a transaction
For the appropriate and smooth execution of our other business operations.
Information for the person in charge of our suppliers To confirm order details
(e.g., correspondence records)
Information about the Company's Officers, Employees, Former Employees, and their Family Members Business communication, exchange of information, personnel policies (including transfers, evaluations, training, and other career development), payroll payment, and attendance management.
(including career development such as transfer, evaluation, training, etc.), salary payment, attendance management, benefits, and other labor-related laws and regulations, tax-related laws and regulations, and labor-related laws and regulations, tax-related laws and regulations, and social welfare-related laws and regulations, such as and social-welfare-related laws and regulations.
To handle rights and obligations related to labor-related laws and regulations, tax-related laws and regulations, and social welfare-related laws and regulations
To comply with various procedures stipulated in internal regulations
To submit notifications and reports to government and municipal offices, their affiliated organizations
To submit notifications and reports to government agencies, their affiliated organizations, or our member organizations, etc.
To provide welfare services and related procedures
For emergency communication
To communicate in the event of an emergency
For other labor management and smooth execution of our business operations.
Information on applicants for employment with our company To contact applicants for employment and to manage the Company's recruitment process
Specified personal information For the purposes of use stipulated in the My Number Act
Shareholder information To exercise rights as a shareholder under the Companies Act and other laws and regulations
To exercise the rights and fulfill the obligations as a shareholder under the Companies Act and other laws and regulations
To implement various measures for the status of a shareholder
To manage shareholders' data in accordance with prescribed standards based on various laws and regulations
To manage shareholders, such as preparing shareholder data in accordance with prescribed standards under various laws and regulations
To properly and smoothly conduct other Company business

【Information Desk for Disclosure and Opt Out】

Where to submit inquiries regarding personal information:

Inbound Platform Corp., Personal Information Inquiries
Address: 4th floor, SW Shimbashi Building,
6-14-5 Shimbashi, Minato-ku, Tokyo 105-0004
Tel: 03-3437-3129 [Reception: weekdays from 10: 00-19: 00]

(e) Authorized personal information protection organization

Currently, we are not a member of any authorized personal information protection organization.

(f) Procedures for Requests for Disclosure, etc. of Retained Personal Data

(1) Contact for requests for disclosure, etc.

Requests for disclosure, etc., should be made to the Information Desk for Disclosure and Opt-Out. If you wish to request disclosure, etc. through electromagnetic procedures, please let us know. In principle, we will process your request according to your wishes.

(2) Procedures for Requests for Disclosure, etc.

① After receiving your request, we will mail you our "Request Form for Disclosure of Retained Personal Data, etc.".
② Please send the completed request form, documents verifying that the request is made by a representative, and a postal money order for the fee (only for requests for notification of purpose of use and disclosure) to the Personal Information Inquiry Section above.
③ After receiving the above request form, we will inquire about two items of personal information registered with us (e.g., telephone number and date of birth, etc.) to confirm the identity of the person making the request.
④ In principle, a response will be sent in writing (by sealed envelope) to the person in question.

(3) In the case of a request by a representative, documents confirming the representative's identity. If the person requesting disclosure, etc. is a representative, please enclose documents proving the representative's identity and documents proving the representative's identity. The information on the place of legal domicile included in each document should be limited to the prefecture of origin, and any information after that should be blacked out or otherwise processed.

① Documents certifying that the applicant is a proxy
< In the case of a representative authorized by the principal to make a request for disclosure, etc.>

A letter of attorney from the principal (original)

< In the case of a legal representative of a minor> A copy of either

A copy of the family register
Certificate of residence (with the relationship between the applicant and the proxy indicated)
Other official documents that can confirm the authority of legal representation."

< If the proxy is a legal representative of an adult ward> A copy of either

Certificate of registered matters relating to guardianship registration, etc.
Other official documents that can confirm the authority of legal representation.

② Documents proving the agent's identity

Driver's License
Passport
Health insurance card (Please submit all digits of the symbol and number of the insured, etc., in black ink)
Certificate of residence
Basic Resident Registration Card

(4) Fee for requests for notification or disclosure of the purpose of use

500 yen per request (as registered mailing fee, etc.)
If the request is made in writing, please enclose a postal money order with the request form, etc. to be sent. (If you wish to make your request by other means, we will discuss this with you at the time of your request.)"

(g) Details of the system for handling personal information and measures taken

(1) Formulation of Basic Policy

To ensure the proper handling of personal data, the Company has formulated a "Personal Information Protection Policy" regarding "compliance with relevant laws, regulations, guidelines, etc." and "point of contact for questions and complaint handling.

(2) Establishment of Rules for Handling Personal Data

For each stage of acquisition, use, storage, provision, deletion/disposal, etc., the Company has established personal information protection rules that outline handling methods, responsible persons/persons in charge, and their duties, etc.

(3) Organizational Safety Control Measures

① In addition to appointing a person responsible for the handling of personal data, the Company clarifies the employees who handle personal data and the scope of personal data handled by such employees and has established a system for reporting to the person responsible in the event that a fact or indication of a violation of the law or handling regulations is detected.

② Periodic self-inspections are conducted on the status of personal data handling, and audits are conducted by other departments and outside parties.

(4) Human security management measures

① Regular training is provided to employees on points to keep in mind regarding the handling of personal data.
② All employees are required to submit a written pledge regarding confidentiality of personal data.

(5) Physical security management measures

① In the area where personal data is handled, measures are taken to prevent unauthorized persons from accessing personal data, as well as to control the access of employees and restrict the equipment, etc. that they bring into the area.
② Measures are taken to prevent theft or loss of equipment, electronic media, documents, etc. that handle personal data, and measures are taken to prevent personal data from being easily discovered when such equipment, electronic media, etc. are carried, including during transportation within the business site.

(6) Technical safety management measures

① Access control is implemented to limit the scope of persons in charge and the personal information database, etc. handled.
② A mechanism is in place to protect the information system handling personal data from unauthorized external access or unauthorized software.

(7) Grasping the External Environment

In the event that the handling of information, including a portion of personal data, is outsourced to a foreign entity, we will implement safety management measures based on information provided by the Personal Information Protection Commission to understand the system for the protection of personal information in that foreign country.

Year and Month of Establishment: October 1, 2018
Latest Correction Date: March 31, 2022

Privacy Policy for Persons Who are in the EEA

At Inbound Platform Corp., we are committed to providing a secure online environment while protecting your privacy. This Privacy Policy (the "Privacy Policy for Persons Who are in the EEA") aims to confirm to handle of personal data located in EEA legally and appropriately.

1. What kind of personal information is collected about you?

The categories of personal data we may collect and process include:

- Contact information that assists us in communicating with you, including your name, mailing address, nationality, telephone number, email address, and occupation, all things you provide on our website

- As needed, credit card information, etc., to provide the service requested by our customers

2. Why Inbound Platform Corp. uses your personal information?

We use your information collected on the Site to:

- To provide the services you have applied for

- For user support

- To manage your usage history

- To provide information about our services

- To respond to inquiries

- To negotiate, contact, consult, place and receive orders, settle payments, or other processing related to transactions.

- To transfer goods or services related to a transaction.

- To confirm order details(e.g., correspondence records)

- To ensure the appropriate and smooth performance of our other business activities.

3. Legal Grounds

We may collect and process your personal information based on the following legal grounds:

- Your consent

- Performing a contract with you

- Addressing legal obligations

- Protecting public interests, performing the public authority for the general interests

- Protecting our customers' essential interests

- Or based on the legitimate interests of Inbound Platform Corp., which are our usual business activities.

4. With whom may your personal information be shared?

- Inbound Platform Corp. sometimes uses third parties, such as service providers, to perform tasks on its behalf and may need to share your personal information with them for the purpose described in paragraph 2 above. Any processing of that personal data will be on our instructions and compatible with the original goals.

- As required by law, Inbound Platform Corp. may disclose your personal information to Public Institutions to comply with regulations, court orders, or sometimes by government or law enforcement agency requests. Including to meet national security or law enforcement requirements and including to agencies and courts in the countries where we operate.

5. The kind of security measures that are in place to protect your personal data

- We apply technical, physical, and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and against other unlawful forms of processing.

- Access to personal data is restricted to authorized recipients on a need-to-know basis. We also maintain a data security practice that is proportionate to the risks associated with processing your personal data. The approach is continuously adapted to protect personal data.

- Inbound Platform Corp. is not responsible for the safety of your personal data transmitted to the websites of any other companies that may be attached to this Site. Visitors to any such websites should refer to such websites' privacy policies and practices.

6. Your rights regarding your personal data

You have the right to:

- Right of access by the data subject (GDPR Article 15);

- Right to rectification (GDPR Article 16);

- Right to erasure ('right to be forgotten') (GDPR Article 17);

- Right to restriction of processing (GDPR Article 18);

- Right to data portability (GDPR Article 20);

- Right to object (GDPR Article 21);

- Right not to be subject to a decision based solely on Automated individual decision-making, including profiling (Article 22);

- Right to lodge a complaint with a supervisory authority;

7. Access

By accessing and using the Site, you understand and agree to the collection, processing, international transfer, and use of your personal data as outlined in this Privacy Policy.

Where required by law, we will ask for your explicit consent. You may always object to the use of your personal data for direct marketing purposes or withdraw any consent previously granted for a specific purpose by clicking on relevant links on our websites, following the directions contained in an email, or by contacting us at the email address described in the below paragraph 11.

8. Retention

We may collect, use, and disclose your personal information as required or permitted by applicable law. We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. 

9. Cookies

As with many websites, our Site may use cookies and other automated information collection means, subject to your consent where required. Cookies are information about you from our website that is stored on your browser or hard drive. Cookies save you time because you do not need to manually re-enter the information stored on your hard drive. Cookies also help us upgrade our website by showing when and how users use our website. You can set your browser to notify you when a cookie is sent or refuse cookies altogether, but certain features of our website might not work without cookies.

10. Changes to this Policy

As this Privacy Policy can be modified at any moment without prior notice, we will update the updated date at the bottom of this Policy when we change this Policy, so please refer to it on a regular basis.

11. Contact

If you request the right to be performed described in the above paragraph 6 or if you have any inquiries about this privacy policy and the protection/processing of personal data, don't hesitate to get in touch with the below.

Regarding the personal data provided for the inquiries, we will use them only to respond to the inquiries, etc.

[contact]
If you are in the European Union, you may address privacy-related inquiries to our EU representative pursuant to Article 27 GDPR: 
EU: EU-REP.Global GmbH, Attn: Inbound Platform Corp., Hopfenstr. 1d, 24114 Kiel, Germany
inbound-platform@eu-rep.global

If you are in the United Kingdom, you may address privacy-related inquiries to our UK representative pursuant to Article 27 GDPR:
UK: DP Data Protection Services UK Ltd., Attn: Inbound Platform Corp., 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom
inbound-platform@eu-rep.global
www.eu-rep.global

Updated: [2022.12.1]
Inbound Platform Corp.
President, Representative Director, and Executive Officer: Shin O