Privacy Policy
プライバシーポリシー 日本語版This Privacy Policy sets forth the terms and conditions, such as the purposes and methods of use, of personal information collected by primeNumber Inc. (“we,” “us,” or “our”) and describes how we protect personal information, and so forth.
1. How we collect personal information
We collect personal information by lawful and fair means after publishing or giving notice of the purposes of use of personal information.
2. What personal information we collect and purposes of use of personal informatione
We use the types of personal information below for the following purposes of use. We may use cookies (“Cookies”) and the like to collect and analyze information, such as website browsing history and browsing frequency, for the purposes of use listed below. For details about information collection using Cookies and the like, please see our Cookie Policy.
| Situations in which we collect personal information | Personal information we collect | Purposes of use |
|---|---|---|
| When receiving your applications to participate in events and seminars held by us | Name, e-mail address, phone number, occupation, job title, company name | To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. To announce products, services, events, etc. to our users. |
| When receiving your applications to participate in events and seminars jointly held by us with a third party | Name, e-mail address, phone number, occupation, job title, company name | To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. To announce products, services, events, etc. to our users |
| When product materials are downloaded from our website, etc. | Name, e-mail address, phone number, occupation, job title, company name | To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. To announce products, services, events, etc. to our users. |
| When white papers are downloaded from our website, etc. | Name, e-mail address, phone number, occupation, job title, company name | To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. To announce products, services, events, etc. to our users. |
| When the contact form on our website, etc. is used | Name, e-mail address, phone number, occupation, job title, company name, content of inquiry | To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. To implement marketing measures, such as announcements of products, services, events, etc. to our users. To respond to inquiries and complaints regarding our products and services, and to help improve our products and services for the purpose of implementing marketing measures, such as announcement of products, services, events, etc. to our users. |
| When we conduct interviews | Name, e-mail address, phone number, occupation, job title, company name | To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. |
| When our website is browsed | Cookies and web beacon information, IP addresses | To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. To announce products, services, events, etc. to our users. |
| When business cards or communications are exchanged with our representative | Name, e-mail address, company name, department, phone number, social media account username | To make business contacts and perform paperwork necessary to provide our services. To announce products, services, events, etc. to our users |
| When receiving your applications for and concluding contracts for our products and services | Name, e-mail address, company name, department, phone number | To provide our services. To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. |
| When a user makes inquiries within our services | Name, phone number, e-mail address, company name | To optimize conversion, attract new customers, and improve the quality of our products and services after analyzing information, such as the number of prospective customer companies and trends, through third-party services that we use. To implement marketing measures, such as announcements of products, services, events, etc. to our users. To respond to inquiries and complaints regarding our products and services, and to help improve our products and services. |
| When registering users of our services | E-mail address | To be used by users as their user IDs to access our services. |
| When a candidate applies for a position (including internships and casual interviews) | Name, phone number, e-mail address, work experience, etc. | To conduct screening for hiring. To contact applicants. To conduct onboarding procedures. To manage our hiring operations. To improve the hiring process. To consider and implement measures about employee aptitude for works (such as placement) and ensuring health maintenance after hiring. To support acquisition of entry visas and work permits necessary for onboarding procedures and the like. To be used for purposes incidental to recruitment activities, such as statistical use for future recruitment plans |
3. Legal basis
If the data protection laws applicable to the relationship between you and us require a legal basis for processing your personal information, we will process your personal information based on one or more of the legal bases listed below.
(a) Contract. This is where we need to process your personal information to perform contracts we enter into with you.
(b) Legitimate interests. This is where the processing of your personal information is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests. If personal information is processed based on legitimate interests, our legitimate interests include building or expansion of business relationships with our customers, business partners, and other persons; development of our products and services; prevention of fraudulent acts, unauthorized access to our websites and services, and other illegal acts; and compliance with applicable legal requirements.
(c) Consent. This is where you have given consent for us to process your personal information. The withdrawal of your consent will not affect the lawfulness of processing performed based on your consent before withdrawal.
(d) Legal obligation.This is where the processing of your personal information is required by the law of the country in which you reside.
4. Security measures for personal data
We implement the measures listed below to prevent leakage and loss of, and damage to, personal data we collect, and to manage personal information appropriately.
Organizational security measures
We have established personal information processing rules and appointed a person responsible for the processing of personal data to clarify the responsibilities.
Personnel security measures
We have our employees comply with the personal information processing rules we established and
provide them with guidance and education on the proper processing of personal data to ensure compliance.
Physical security measures
We store and manage personal data using third-party cloud services that we deem appropriate.
Technical security measures
We implement appropriate access controls to limit the personnel processing personal data.
Understanding the external environment
When we use a service provided by a business operator in a foreign country, we confirm the personal
information systems, the situation of personal information processing, and other conditions in the
foreign country and take measures necessary for the security control of personal information, as necessary.
5. Use of cloud services
We use the cloud services listed below to process personal information.
Personal information may be stored in a foreign country when we use these cloud services. For the
storage locations in such cases and the policies established by the cloud service operators, please see
“Storage location” and “Policy link” in the table below.
| Service | Business operator | Storage location | Policy link |
|---|---|---|---|
| Amazon Web Service | Amazon Web Services, Inc | Japan | https://aws.amazon.com/jp/privacy/ |
| Salesforce | Salesforce Japan Co., Ltd. | Japan | https://www.salesforce.com/jp/company/privacy/ |
| Google Cloud Platform | Google LLC | Japan, USA | https://policies.google.com/privacy?hl=ja |
| Adobe Marketo Engage | Adobe Inc. | USA | https://www.adobe.com/jp/privacy/policy.html |
| Slack | Slack Technologies, LLC | USA | https://slack.com/intl/ja-jp/trust/privacy/privacy-policy |
6. Storage period of personal information
We will retain the personal information we collect for the period necessary for processing it, which is not to exceed three (3) years after termination of our business relationship, except where we are required by law to retain personal information for a longer period, in which case, we will retain it for the period required by law.
7. Disclosure, correction, and cessation of use of personal information
You have a number of legal rights in relation to your personal information held by us. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but will typically include the following:
(a) the right to obtain information regarding the processing of your personal information and to access the personal information that we hold about you;
(b) the right to request that we rectify your personal information if it is inaccurate or incomplete;
(c) the right to request that we erase your personal information in certain circumstances;
(d) the right to request that we restrict our processing of your personal information in certain circumstances;
(e) the right to object to our processing of your personal information;
(f) the right to receive personal information in a structured, commonly used, and machine- readable format and/or to the right to transmit the personal information directly to a recipient to an extent technically feasible (the so-called right to data portability); and
(g) the right to withdraw your consent to our processing of your personal information at any time.
You can exercise your rights by contacting us using the contact information indicated in Section 8 below. You can also file a complaint with the competent data protection authority if you believe that any of your rights have been infringed by us.
When we disclose your personal information and otherwise. responding to your requests, we may require that you submit materials to verify your identity, and for disclosure requests under Japanese law, we will charge a fee of 1,000 yen (excluding tax) for each request.
8. Contact information for this Privacy Policy and disclosure and other requests
For inquiries about this Privacy Policy, please contact us using the contact information below.
Address: JR Tokyu Meguro Building 5F, 3-1-1 Kamiosaki, Shinagawa-ku, Tokyo
Company name: primeNumber Inc.
Department in charge: Corporate Operations division
E-mail:secretary@primenumber.co.jp
9. Amendment and revision to this Privacy Policy
We may revise this Privacy Policy without giving notice to users. The revised Privacy Policy will take effect when it is posted on our website. If we are required to perform procedures stipulated by law to revise this Privacy Policy, we will make revisions in accordance with those procedures.
---- Addendum follows ----
For customers in the EEA and the UK
This section applies to customers in the EEA and the UK.
Transfers of your personal data outside the EEA or the UK
Your personal data may be transferred to, and stored by, third parties outside the EEA or the UK. Notwithstanding Section 7 of this Privacy Policy, if we transfer your personal data to a third party outside the EEA or the UK, we will ensure that:
(a) the recipient destination has been subject to a finding from the European Commission or has been designated by the government of the UK as ensuring an adequate level of protection for the rights and freedoms that you possess in respect of your personal data; or
(b) the recipient enters into with us standard contractual clauses that have been approved by the European Commission (in respect of personal data from the UK, referring to those that have been corrected in accordance with an addendum formulated by the Information Commissioner’s Office of the UK) or other contracts for the transfer of personal data as required by data protection laws.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA or the UK by contacting us using the contact information indicated in Section 8 Privacy Policy.