Privacy Policy (GDPR)

Preamble

Linkers Corporation (“the Company”) recognizes that the personal data (“Personal Data”) it obtains from customers and users of its website and / or services (“Users”) is important information for the Company. Hence, the Company recognizes that protecting Personal Data is an important responsibility. The Company shall therefore handle Personal Data obtained through its business activities in accordance with the following policy.

1.Acquisition and Use of Personal Data

The Company obtains and uses the following Personal Data through legal and fair means:

• Personal identification information: address, telephone number, e-mail address, affiliation information
• Terminal information
• IP address and Users’ browsing habits on our website by using cookies (see our Cookie Policy below under 9).

Users directly provide the Company with most of the data the Company collects. The Company collects data and process data when Users:

• Register online to the Company’s or services.
• Voluntarily complete a survey or provide feedback on any of the Company’s message boards or via email.
• Use or view the Company’s website via your browser’s cookies.

The Company shall use such Personal Data for the following purpose:

Type of Personal Data	Purpose of Use
Information from persons who have requested information materials or inquired about the Company’s website.	To provide information (including sending e-mails, flyers, and other direct mailings) regarding various services (including services provided by our business partners) that the Company deems beneficial to our Users
Users and business partner information (including of seminar participants hosted or co-hosted by the Company and from exchange of business cards)	To provide our services based on the contents of your application To perform or claim performance of a contract entered into with a customer To communicate with Users, and to manage Users To provide information about our services (including sending e-mails, flyers, and other direct mailings) To provide information (including sending e-mails, flyers, and other direct mailings) regarding various services (including services provided by our business partners) that we deem beneficial to our Users To notify important changes to our services or terms and conditions To request cooperation for questionnaires, interviews regarding our services, and to post information on our website To report survey results To investigate and analyze our website visit history by linking IP addresses, cookie information with customer information held by us, and to use the results for improving the convenience of our services, proposing and providing services, planning, development, marketing activities, and advertising distribution operations.
Outsourced (including applicants) information	For selection, communication, and management of outside contractors by the Company To conclude contracts, perform tasks and billing To request cooperation for questionnaires and interviews regarding our services, and to post information on our website To report survey results
Data entrusted by business partners	For maintenance and operation work To manage exhibitions and seminars

The Company shall use Personal Data only to the extent necessary to achieve the purpose of use.

The Company shall process Users’ Personal Information as per the Company’s contractual relationship with the Users, in the meaning of art. 6.1 b GDPR .

Except where permitted by law, the Company shall obtain the prior consent of the individual when providing Personal Data to a third party. In the following cases, the person to whom Personal Data is provided shall not be considered a third party:

• When outsourcing part or all of the handling of Personal Data within the scope necessary to achieve the purpose of use. The Company remains responsible for the handling of Personal Data by such outsourced company.
• When Personal Data is provided as a result of the succession of the Company’s business due to a merger or other reasons.

The Company shall not use acquired Personal Data for any other purposes. In the event that it becomes necessary to use the information for purposes other than those stated, the Company shall notify Users in advance by clearly stating this on the Company’s website or system, in other written documents, or by contacting Users at their registered e-mail address or telephone number, and obtain their renewed consent for such new purpose of use.

2.Storage of Personal Data

The Company securely stores Users’ Personal Data on cloud services. Cloud services include Amazon Web Services, Google Workspace and Microsoft OneDrive.

The Company shall keep Users’ Personal Data for as long as the Users are using the Company’s services. Once the Users have terminated using the Company’s services, the Company shall delete Users’ Personal Data on the Company’s terminals, servers, and database.].

3.Marketing

The Company would like to send Users information about products and services of the Company that we think Users might like.

If you have agreed to receive marketing, you may always opt out at a later date. Users have the right at any time to stop the Company from contacting you for marketing.

4.Abidance by the laws and regulations

The Company shall endeavor to keep abreast of laws and regulations related handling of Personal Data, and shall ensure that all employees engaged in the Company’s business (“employees”) are aware of and comply with such laws and regulations.

5.Security control of Personal Data

In order to prevent leakage, loss, falsification of Personal Data, the following necessary measures shall be taken for appropriate management.

5.1 Basic Policy

A Personal Data protection policy is formulated and publicized on our website.

5.2 Establishment of Rules (Regulations) for Handling Personal Data

For each stage of acquiring, using, providing, and disposing of Personal Data, the Company has established internal regulations regarding handling methods, persons in charge, and their duties, which are reviewed on a regular basis.

5.3 Organizational Safety Control Measures

The Company has appointed a person responsible for the handling of Personal Data (Personal Data Protection Manager) and has established a system for reporting to and communicating with the Personal Data Protection Manager in the event that a violation or potential violation of laws, regulations, or internal rules is detected. In addition, periodic self-inspections, internal audits, and external audits are conducted.

5.4 Personnel Safety Management Measures

The Company has established internal regulations regarding the confidentiality of Personal Data, and provides regular training for employees regarding the handling of Personal Data.

5.5 Physical security control measures

We have in place thorough access control in areas where Personal Data is handled, restrictions on equipment brought into the office, and control of access privileges.

5.6 Technical Safety Control Measures

The Company has implemented access restrictions and other measures to limit the scope of employee handling, and has introduced mechanisms to prevent unauthorized access from outside.

5.7 Knowledge about foreign rules and regulations

In cases where Personal Data is handled in foreign countries, efforts are made to understand the systems for the protection of Personal Data in those countries.

6.Users’ data protection rights

Users are entitled to the following data protection rights:

1. The right to access – Users have the right to request the Company for copies of Users personal data.
2. The right to rectification – Users have the right to request that the Company correct any information Users believe is inaccurate. Users also have the right to request the Company to complete the information Users believe is incomplete.
3. The right to erasure – Users have the right to request that the Company erase Users personal data, under certain conditions.
4. The right to restrict processing – Users have the right to request that the Company restrict the processing of Users personal data, under certain conditions.
5. The right to object to processing – Users have the right to object to the Company’s processing of Users personal data, under certain conditions.
6. The right to data portability – Users have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If Users make a request based on the above the Company have one month to respond. Users who would like to exercise any of these rights, can contact the Company at:

Address: Linkers Corporation Personal Data Inquiry Desk
Sumitomo Fudosan Iidabashi Building 6F, 2-3-21 Koraku, Bunkyo-ku, Tokyo 112-0004, Japan
E-mail: feedback@linkers.net

Contact Us

7.Procedure to exercise Users’ data protection rights

The procedures to be followed when the Company responds to a request made by Users or his/her representative for the exercise of Users’ data protection rights as mentioned under Article 6 above, are as follows. Any Personal Data obtained following a request by Users shall be used only to the extent necessary to respond to such request.

7.1 Documents to be submitted when requesting disclosure

The Company may request documents and / or a telephone inquiry to confirm from Users person making such request, for identification purpose. In cases where telephone verification is not possible, the Company may ask the requesting Users to submit a copy of his/her driver’s license, resident certificate , health insurance card, or any other identity document

7.2 Request by proxy

Users who wish to authorize a representative to make a request on their behalf, shall enclose the following documents:

• A copy of a document to verify the identity of the proxy
• A power of attorney

7.3 Fees for request to access

The Company shall charge a fee of JPY 500 by request to access.

7.4 Method of Response to Users request and refusal

The Company shall respond to the requesting Users by the method (written or electromagnetic) indicated by such requesting Users.

However, in the following cases, the Company shall not disclose or respond to the request. In such case, the Company shall notify the requesting Users with a note to that effect. Please not that, even in the case of non-disclosure or non-response, the prescribed fee shall be charged.

• When the identity of the applicant cannot be confirmed.
• When the power of attorney cannot be verified when an application is filed by a proxy.
• When the information provided by the applicant is incomplete.
• When the request does not fall under the category of Personal Data handled by the Company.
• If there is a risk of harm to the life, body, property, or other rights or interests of the Users or a third party.
• If there is a risk of significant hindrance to the proper conduct of our business.
• In other cases, as provided for in laws and regulations, and in cases where such use would violate laws and regulations.

8.Transfer of Personal Data outside of the European Union

As the Company is based in Japan, the Company securely process Users’ personal data in Japan. On January 23, 2019 the European Commission has adopted an adequacy decision on Japan, allowing personal data to flow freely between the two economies on the basis of strong protection guarantees.

9.Cookie Policy

The Company uses cookies in a range of ways to improve Users’ experience on our website, including:

• Keeping you signed in
• Understanding how Users use our website

9.1 Types of cookies

The Company’s website uses cookiesfor the following purposes:

• To display our website, to improve our services, and to provide basic functions for the use of our website.
• To obtain IP addresses and cookies when a customer accesses the Company’s website, and to obtain content browsing history and browsing conditions in association with customer information held by the Company, for use in the Company’s marketing activities (identifiable information )
• For statistical research and analysis of website access (Google Analytics)

9.2 About Google Analytics

The Company uses Google Analytics, an access analysis tool provided by Google, Inc. The Company uses cookies for the purpose of collecting data with Google Analytics, but the data is collected anonymously and is not personally identifiable. The information collected, recorded, and analyzed by Google Analytics does not contain any information that identifies website’s visitors as a specific individual. Please refer to the following URL for Google Analytics Terms of Use and Google’s Privacy Policy.

Google Analytics
Tool provider: Google Inc.
Google Analytic Terms of Use
Google Privacy Policy
Information collected: use of the website

9.3 How to manage and delete cookies

Although many of browsers enable the use of certain cookies by default, Users can limit or disable the use of cookies by changing the settings in the browser.
However, please note that if cookies are disabled, some website features may not be available or some pages may not be properly displayed.
Cookie information will remain on your device for a certain period of time, but can be deleted by the Users.

10.Ongoing improvement and change to this Privacy Policy

Our Personal Data protection management system monitors and audits the status of compliance with internal rules and regulations for the protection of Personal Data to detect violations, incidents, accidents, and vulnerabilities, which are reviewed by management. This shall be reflected in management measures and internal regulations, and efforts shall be made to continuously improve the Personal Data protection management system.

11.How to contact the Company

For inquiries regarding the content of the Privacy Policy, please contact

Address: Linkers Corporation Personal Data Inquiry Desk
Sumitomo Fudosan Iidabashi Building 6F, 2-3-21 Koraku, Bunkyo-ku, Tokyo 112-0004, Japan
E-mail: feedback@linkers.net

Contact Us

12.Right to contact the appropriate authority

Users have the right to contact the competent Supervisory Authority to report a complaint or if they feel that the Company has not addressed their concern in a satisfactory manner.