Privacy Policy

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Privacy Policy

Digital Hearts Co., Ltd. (the "Company") recognizes the importance of safely handling information in an advanced telecommunications society and deems the protection of personal information a top priority among its corporate duties. In order to ensure that this is put into practice, the Company has adopted the following Privacy Policy which shall be adhered to by all personnel when handling and managing personal information.

1. Proper Acquisition, Usage, and Provision of Personal Information

The Company pledges to specify the purpose of use to the extent necessary to perform its duties and acquire, use, and provide personal information as required. Any personal information acquired will only be used for the purpose of use, and measures will be taken to prevent usage outside of that scope.

2. Compliance with Relevant Laws, Regulations, Guidelines, Etc.

The Company shall comply with all laws and regulations concerning the handling of personal information, as well as guidelines and other standards established by the government pertaining to the management of personal information.

3. Security Control Measures

The Company implements reasonable safety protocols and corrective measures to deal with any potential risks that could result in the leaking, losing, or damaging of personal data.

4. Inquiries and Complaints

The Company will respond without delay to requests for disclosure, correction, deletion, suspension of use, and complaints and inquiries of personal data in its possession.

5. Continuous Improvement of Personal Information Management System

The Company strives to continuously review and improve its management system for protecting personal information.

6. Revisions to Privacy Policy

The Company may revise the contents of this Policy as necessary to protect personal information and comply with any amendments to laws and regulations. Such revisions will be effective from the date of publication.

Enactment Date: July 1, 2006
Last Revised: April 1, 2021
Digital Hearts Co., Ltd.
President and CEO, Yasumasa Ninomiya

Handling of Personal Information

Revision Date: December 29, 2021

1. Purpose of Use of Personal Information

The personal information acquired by the Company will be used for the following purposes.
In cases where the purpose of use of personal information is specified to the individual at the time of acquisition, such personal information will be used for the purpose stated at the time of acquisition.

A. Personal Information Subject to Disclosure

i. Personal data obtained in writing directly from the individual (including electronic methods).

Freelancer information will be used for:
• The provision of services and related information.
• Communication, meetings, negotiations, etc. necessary for conducting business, as well any as other related procedures.
• Concluding and executing contracts.
• Managing clientele and transaction details.
• Responding to inquiries and consultations.
• Provisions to third parties.
Information on individuals applying to job postings will be used for:
• Providing employment details and contacting applicants.
• Recruitment and managing employment data.
Information concerning executives will be used for:
• Business communications and management of facilities and equipment.
• Managing human resources.
• Labor management.
• Finalizing wages, bonuses, and other compensation, processing payments and taxes, as well as filing social insurance-related paperwork.
• Providing benefits.
• Health and safety, healthcare, and disease prevention.
• Complying with labor-related laws and regulations concerning retirees, as well as other necessary communications, etc.
• Provisions to third parties (e.g., a client in a temporary staffing situation).
Information attained from inquiries will be used for:
• Confirming, archiving, and responding to inquiries.
• Statistical data in a format that does not enable identification of individuals.
Information acquired through disclosure requests, etc. will be used for:
• Verifying disclosure requests, etc. as required, authenticating the identity of the requester and answering the contents of their request.
Information on participants in seminars held by the Company will be used for:
• The running of seminars as required.
• To the extent necessary when introducing the Company's services, submitting proposals, and sending out details on seminars, etc. being held.
Information on participants in education programs administered by the Company will be used for:
• The operation of programs as required.
• To the extent necessary when introducing the Company's services, submitting proposals, and sending out details on programs, etc. being held.

ii. Personal Information Acquired through Means beyond the Scope of (i)

Information on client (patrons, partners, etc.) signatories and representatives will be used for:
• The provision of services and related information.
• Communication, meetings, negotiations, etc. necessary for conducting business, as well any as other related procedures.
• Concluding and executing contracts.
• Managing clientele and transaction details.
• Responding to inquiries and consultations.
• Provisions to third parties.

2. Purpose of Use of Stored Personal Data

The personal data (personal information subject to disclosure)* the Company holds will be used for the same purposes listed under Section 1, Purpose of Use of Personal Information.

*Stored personal data (personal information subject to disclosure) is personal data for which a business operator handling personal information has the authority to disclose, amend, add, or delete content, stop usage of, erase, and stop provision of said data to third parties. This data can also be described as data not specified by Cabinet Order as being something whose existence or nonexistence would be detrimental to the public interest or other interests if it were made known.

3. Consignment of Personal Data Management

The Company may consign all or part of the management of personal data only to an extent within the scope of the purpose of use. In the event of consignment, the Company shall appropriately supervise the consignee by, for example, entering into a contract with the party concerning the handling of personal data.

4. Provision of Personal Data to Third Parties

The Company will not provide personal data to third parties without obtaining the prior consent of the individual, except as required by law.

5. Joint Use of Personal Data

The Company will respond without delay to requests for disclosure, correction, deletion, suspension of use, and complaints and inquiries of personal data in its possession.

A. Joint Use of the Company's Employee Information

In order for the Company to cooperate with its group companies and provide a comprehensive service, the Company's employee information shall be collectively used as follows within the scope of the purpose of use at the time of acquisition.

Personal data to be used collectively: The names, genders, skills, work history, etc. of the Company's employees.
However, identification numbers and sensitive personal information will be excluded.
Scope of joint users:
• Digital Hearts Holdings Co., Ltd.
• Digital Hearts Co., Ltd.
• Logigear Japan Corporation
• ANET Corporation
• Aetas, Inc.
• Flame Hearts Co., Ltd.
• AGEST, Inc.
• Digital Hearts Plus Co., Ltd.

Purpose of use of joint users:
• Human resource management across group companies (including employees on loan, transfers, etc.).
• Submitting proposals to clients, advising, and conducting transactions with clients (including contacting and coordinating with representatives).
• Party responsible for managing personal data for joint use: Digital Hearts Co., Ltd.
• Acquisition Method: In writing or electronically.

B. Joint Use of Client Enterprises' Personnel Information

In order for the Company to utilize the expertise of its group companies to provide a comprehensive service, the personnel information of its clients' enterprises shall be collectively used as follows within the scope of the purpose of use at the time of acquisition.

Personal data to be used collectively:
• Names of client executives and freelancers; affiliated organization and department; location; job title; email address; phone and fax number; transaction history; etc. Scope of joint users:
• Digital Hearts Holdings Co., Ltd.
• Digital Hearts Co., Ltd.
• Logigear Japan Corporation
• ANET Corporation
• Aetas, Inc.
• Flame Hearts Co., Ltd.
• AGEST, Inc.
• Digital Hearts Plus Co., Ltd.

Purpose of use of joint users:
• Submitting proposals to clients, advising, and conducting transactions with clients (including contacting and coordinating with representatives).
• Party responsible for managing personal data for joint use: Digital Hearts Co., Ltd.
• Acquisition Method: In writing or electronically.

6. Cookies

The Company uses cookies on its website.
A cookie is a piece of information sent to your browser from a website and stored on your device. By using cookies, it is possible to obtain information such as the browsing data on your device. Cookies themselves do not contain any personally identifiable information, such as your name, address, telephone number, or email address. Furthermore, they will not have any adverse effects on your device.

You can also disable cookies by changing your browser settings. For information on how to configure cookies, please refer to your browser's help menu.
Please note that if you choose to disable all cookies, you may not be able to use services that require authentication, or you may experience other restrictions when using online services.

Purpose of Use of Cookies:
To provide improvements to services.

7. Voluntary Provision of Personal Information

The Company requests personal information from all individuals as needed for the purposes of use listed here. The provision of this information is voluntary, except when required by law (verification of identity and status of residence, provision of My Number, etc.). However, please understand that the Company may not be able to provide its services or fulfill other requests if you are unable to comply or if the information you provide is incomplete.

8. Procedures for Responding to Requests for Disclosure of Stored Personal Data

Individuals may request disclosure* of stored personal data. The Company accepts requests for disclosure of stored personal data through the following method.
*Requests for disclosures include notifications of the purpose of use pertaining to personal data; disclosures, or deletion of stored personal data; amendments, additions, or deletion to stored personal data; stoppage of use; erasing of data; and suspension of provision of data to third parties.

A. How to Apply and Where to Submit Requests

Please fill out the required application form, attach the necessary documents, and mail it to the "Personal Information Inquiry Desk" (through simplified registered mail or other means by which a record of delivery can be confirmed).
*Postal charges incurred when making requests shall be borne by the applicant.
*Please write "Application for Disclosure of Personal Information Enclosed" in red ink on the envelope.
*Please note that requests cannot be made in person.

B. Documents to Be Submitted

1. Application for Disclosure of Personal Information
2. Documents verifying the identity of the applicant or their representative
3. Postal stamps equivalent to the fee (in the event that a request requires a fee)

C. Documents Verifying the Identity of the Applicant or Their Representative Requesting the Disclosure

i. If the request for disclosure is made by the applicant:

A copy of their personal identification document(s) must be submitted. Choose between one of the methods listed below.
1. One copy of any photo identification document issued by a government or municipal office:
A driver's license, passport, residence card, Individual Number Card (the side with the individual number is not required), etc.
2. One copy of two personal identification documents without a photo issued by a government or municipal office:
A health insurance card, pension book, etc.

ii. If the request for disclosure is made by a representative:

If you are requesting disclosures as a voluntary agent designated and authorized by the applicant or a legal representative for a minor or adult ward, please submit the following documents.
1. Documents to confirm authorization of proxy
i. In the case of a legal representative
• In the case of a minor: A copy of the applicant's family register or an insurance card with the applicant's name listed under the dependents section
• In the case of an adult ward: A Certificate of Registered Matters as stipulated in Article 10 of the Act on Guardianship Registration
ii. In the case of a voluntary agent:
• A letter of attorney and certificate of seal registration from the applicant
2. Documents verifying the identity of the agent
• A copy of the identification document(s) listed in (i) above must be submitted for the agent.

4. Fees Pertaining to Requests for Disclosure

Requests that require fees are as follows.
• Requests to be notified of the purpose of use for stored personal data
• Requests for disclosure of stored personal data
The fee is 1,000 yen per request (tax and cost of return postage is included).
*Please enclose postage stamps equivalent to the fee in the same envelope with the documents being submitted.
*If the fee submitted is insufficient or not enclosed with the documents, you will be contacted on this matter. However, please be aware that if the fees are not paid within a given period of time, the request will not be processed.
*In the event that a request for disclosure cannot be fulfilled, any fees paid will not be refunded.

Personal Information Manager:

Administration Department Head, Toshiyuki Takahashi

Personal Information Inquiry Desk:

Digital Hearts Co., Ltd.
Administration Department, Privacy Mark Office
Tokyo Opera City Bldg. 41F
3-20-2 Nishi-Shinjuku, Shinjuku-ku, Tokyo 163-1441
Email: pmark@digitalhearts.com

Name of authorized personal information protection organization affiliated with company and contact for complaints:

JIPDEC
Privacy Mark Promotion Center
Personal Information Protection Complaint Office
Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
Phone: 0120-700-779