PRIVACY POLICY

date of establishment 1st Nov. 2019
date of revision 19 May. 2023
date of revision 19 Aug. 2024

WHERE, Inc.
Representative Director: Mitsuhisa Iwai

Contact regarding personal information protection
Contact details
3-5-27, SumitomoFudousan Mita SouthTower 3F,
Mita, Minato-ku, Tokyo, Japan
CPO: Takeshi Mori
Phone: +81-3-6261-5722

WHERE, Inc. (hereinafter referred to as “the Company”), whose main business is the providing applications and data analytics on EXBeacon Platform, recognizes that protecting personal information as it is important as a company handling personal information in its business is our important social mission. The Personal Information is protected in accordance with this Privacy Policy set forth below.

  • The Company strongly recognizes the importance of the protection of personal information, and in the handling of personal information held or deposited in-house, we will comply with laws and regulations on the protection of personal information, guidelines established by the country and company, other norms.
  • The Company will obtain the consent of the person by lawful and fair means when acquiring personal information. We will identify the purpose of use and notify or announce it, and handle personal information according to the purpose of use agreed to by the person, and will not use or provide it for any other purpose.
  • If the Company receives personal information in doing the business, we conclude and follow a contract with the client on keeping the secrecy of personal information, matters concerning re-consignment, sharing responsibility in case of an accident, return/disposal of personal information at the end of the contract.
  • When the Company consigns personal information to a third party in order to consign the business, we will select a company that meets a sufficient level of protection of personal information and will take appropriate measures in accordance with contracts, etc.
  • The Company will take reasonable safety measures and preventative/corrective measures against the danger of personal information leakage, loss or damage.
  • If there is a complaint or consultation regarding the handling of personal information, the Company will respond promptly and appropriately at the complaint and consultation window regarding personal information.
  • The Company set forth management rules and system regarding protection of personal information, and all the employees comply with these and continuously improve these measures by conducting periodical review of these measures.

Treatment of Personal Information We Handle

We are committed to protecting personal information appropriately based on our “Privacy Policy.” We handle the personal information that we acquire or hold for business purposes as follows.

1. Acquisition of personal information

When obtaining personal information, the purpose of use shall be clearly. The provisions under the preceding paragraphs shall not apply to those cases set forth in the following.

  • cases based on laws and regulations.
  • cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain a principal’s consent.
  • cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain a principal’s consent.
  • cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining a principal’s consent would interfere with the performance of the said affairs.
  • cases in which there is a risk of harming the Company’s rights or legitimate interests.

2. Purpose of using personal information

The purpose of use when acquiring directly from the person, third parties etc., and the purpose of using personal information held by the Company are as follows.

  • Personal information obtained through providing the Company’s applications will be used only for the same service applications. The Company may, however, use this information, in order to provide value-added service and improve the system, in the form of statistical data, after transforming the original so as not to be identifiable the individual. When the Company offers the application service, it is prerequisite that the Customer obtain the consent of its employees, etc, regarding the use of their personal information, under the Customer’s own regulation, clarifying beforehand the purpose of the use of personal information.
  • Inquire about our business and corporate information, request for various materials, subscribe to blogs, register when providing content from websites, apply for seminars and exhibitions, call, email, direct mail, visit, Personal information obtained through sales activities such as business card exchange will be used to provide information on our business, sales activities, survey requests, and supplier management.
  • When we share personal information with our specified partner companies, we will use it to provide information about our business and to provide services only if we obtain agreement on the purpose of use.
  • We use personal information about our shareholders for the exercise of the rights of shareholders under the Corporation Law and for the management of shareholders based on various laws and regulations.
  • We use personal information to use for recruitment work.
  • Personal information acquired in hiring activities is used only for the purpose of hiring selection and hiring appointments, or for personnel management after joining a company, and will not be used for any other purpose.
  • We use personal information when conducting employment management and various personnel measures such as employees.
  • We use cookies on our website to record and maintain data about the web pages you browsed. We use this data to deliver useful information to our customers. If you do not agree with this matter, please delete the cookie from your browser.

3. Measures to protect personal information

The Company shall take necessary and appropriate measures to prevent leakage, loss or damage of personal information and to manage the safety of other personal information.
In order to appropriately handle customer’s personal information, we will endeavor to continuously improve the internal system, including the review of this policy, through the maintenance of employee education and internal regulations.

4. Provision of personal information to third parties

Under the provisions of the law, the Company does not provide personal information to third parties without the consent of the customer, except in the case where there is a request to disclose information from an authority authorized by the police, court or other law or regulations.

5. Entrust of personal information processing

When outsourcing all or part of personal information held by the Company we will sign a non-disclosure agreement (NDA) with the subcontractor and perform appropriate management and supervision. In addition, if the contractor is also making a contract, the agreement shall be established in consultation with both parties.

6. Procedures for disclosure, etc. of personal information

We will promptly respond, under the Personal Information Protection Act, to requests concerning disclosure, etc. of retained personal data (notification of purpose of use, disclosure, correction, addition or deletion of content, suspension of use, suspension of record of provision to a third party, and disclosure of record of provision to a third party),　after confirming that you are the person in question. In addition, if the information about the individual is inaccurate as a result of the necessary investigation of the retained personal data, we will change it to be accurate based on the results. We will respond to your request regarding the disclosure method in the manner you prefer.

7. Inquiries to WHERE, Inc.

Please contact the following inquiries window. Please acknowledge beforehand that we will respond after confirming that the inquirer is the person in question.

8. Safety control measures

In order to handle personal information appropriately, we implement the following safety control measures to ensure the security of information systems that process personal information.

  • We have appointed a person responsible for handling personal information.
  • We have clarified the scope of personal information handled by employees who handle personal information and have established a reporting and contact system to the person responsible.
  • We provide regular education to employees on the handling of personal information.
  • In areas where personal information is handled, we manage employee entry and exit and restrict the devices they may bring in, as well as implement physical safety control measures.
  • We implement access control to limit the scope of personal information.

9. The name and address, and if a corporation, the name of its representative of the handler of personal information

Name of corporation: WHERE, Inc.
Name of representative: Mitsuhisa Iwai
Address: 3-5-27, SumitomoFudousan Mita SouthTower 3F, Mita, Minato-ku, Tokyo, 180-6303, Japan

10. The name, title, and contacts of the administrator of personal Information

The administrator of personal information: Takeshi Mori
　　e-mail: t_mori@where123.jp
　　Tel: +81-3-6261-5722

【Contact Details】
　3-5-27, SumitomoFudousan Mita SouthTower 3F, Mita, Minato-ku, Tokyo, Japan

　e-mail:　info@where123.jp
　TEL: +81-3-6261-5722
　FAX：+81-3-6261-5725
　(Reception hours: Monday through Friday 9:30 am to 18:00, except holidays)