Personal Information Protection Policy

1. In obtaining personal information, we shall specify, to the extent possible, the purpose of use for such information, and shall obtain only the necessary personal information to achieve such purpose. 
2. When obtaining personal information, we shall do so only to the extent necessary, and we shall provide the name of our company, the name of our personal information protection manager, and his/her contact information, the purpose of use, etc.
3. Personal information will be used within the scope of the purpose of use. We will also establish and implement appropriate procedures to take necessary measures in order to prevent unintended use.
4. Personal information will be managed in an appropriate manner and will not be disclosed or provided to any third party except in accordance with the applicable laws and regulations, etc.
5. We shall endeavor to manage personal information in accordance with the purpose of use, only to the extent necessary, in an accurate and up-to-date manner, take reasonable security measures against leakage, loss, or damage of personal information, and strive to prevent and correct such incidents.
6. When outsourcing the processing of personal information, we shall implement appropriate management by contractual obligations to prevent any leakage or disclosure of personal information to a third party.
7. We will respond promptly to disclosure requests from the individual who has made such request of his/her personal information, when such request has been made by contacting our inquiry desk.
8. We will respond to any individual who refuses the use of her personal information or the provision of such to a third party, when such request has been made by contacting our inquiry desk.
9. We will respond to any complaints and consultations regarding personal information, when it has been made by contacting our inquiry desk.
10. We will comply with all applicable laws and regulations, guidelines established by the government, and other rules regarding personal information.
11. We will establish a personal information protection management system, which will be periodically reviewed and continuously improved.
     

Established: October 1, 2014
Last amended: July 8, 2024
ClipLine, Inc.
Hayato Takahashi, CEO

Contact Information Regarding Personal Information Protection Policy
Takashi Fujimura, Personal Information Protection Manager
5th floor, GranFirst Kandakonyacho, 
15 Kandakonyacho, Chiyoda-ku, Tokyo 101-0035
Mail to: privacy@clipline.jp

ClipLine, Inc.

5th floor, GranFirst Kandakonyacho,

15 Kandakonyacho, Chiyoda-ku, Tokyo 101-0035

Hayato Takahashi, CEO

Takashi Fujimura, Personal Information Protection Manager

Mail to: privacy@clipline.jp

We will not provide acquired personal information to any third party except in any of the events specified below.

(1)   When it is consented by the person himself.

(2)   When it is based on laws and regulations.

(3)   When it is necessary in order to protect life, body, or property of another person, and is difficult to obtain consent from the person himself.

(4)   When it is especially necessary in order to improve public health or to promote healthy development of children, and is difficult to obtain consent from the person himself.

(5)   When it is necessary in order to cooperate with clerical work prescribed by laws and regulations performed by government organization or a local public organization or a person delegated by such entities, and obtaining consent from the person himself may interefere with the prosecution of said clerical work.

(6)   When handling of personal information is delegated to such third party to achieve the purpose of use.

(7)   When business succession is conducted for merger, company split, business transfer or on any other cause.

We have conducted security control measures for the Retained Personal Data as specified below.

(1)   Establishment of Rules Regarding Handling of Personal Data

-To establish rules regarding the handling of personal data, the person in charge, and their duties in respect of personal data for each stage of collection, usage, storage, disclosure and deletion/disposal.

(2)   Organizational Security Control Measures

-To appoint a person in charge for the handling of personal data, and to clarify the scope of employees handling personal data and the personal data to be handled by them, and to set up a reporting system to the manager in cases where there is, or may be, a violation of law or rules for handling personal data.

(3)   Human Security Control Measures

-To provide periodical training for employees regarding points of concern in handling personal data.

(4)   Physical Security Control Measures

-To manage entrance and exit of the employees in the areas where personal information is handled  and to limit the devices that are allowed to be brought in such areas, and also to restrict browsing of personal data by unauthorized personnels.

(5)   Technological Security Control Measures

-To limit the personnel in charge and the scope of personal information database to be treated by such personnel.

-To implement a framework to protect information systems that handle personal information from illegal access or illegal software.

We shall respond in writing or by any other electronic means to request for disclosure, etc. (notification of purpose of use, disclosure, correction, addition or deletion of contents, suspension of use, elimination, and suspension of provision to third parties) of the personal information held by us, or any complaints or consultations about the handling of personal information.

For specific procedures regarding complaints/consultation, disclosure, etc. (applicant, application form, identity verification, etc.), please contact <Contact Information Regarding Personal Information> below.

Please note that we will charge a fee (JPY 1,000) for responding to each requests for notification of our purpose of use and requests for disclosure.

Please contact <Contact Information Regading Personal Information> below in relation to any complaints and consultations regarding personal information.
 

Contact Information Regarding Personal Information

ClipLine, Inc.

Takashi Fujimura, Personal Information Protection Manager

5th floor, GranFirst Kandakonyacho,

15 Kandakonyacho, Chiyoda-ku, Tokyo 101-0035

Mail to: privacy@clipline.jp
 

(1)  Usage of Website Encryption, Information Relating to Individuals (Cookies and Web Beacons)
1 Communication Encryption
When acquiring personal information from a website, we protect such personal information of the customer by using encryption technology for communications such as SSL (Secure Sockets Layer)/TLS (Transport Layer Security) on such website. In the event that the browser that does not support SSL/TLS, it may not be able to access such webpage.

2 Usage of Information Relating to Individuals (Cookies and Web Beacons)
We may use Information Relating to Individuals (information relating to any living individual, but which does not fall under any of the followings: Personal Information, Information Edited to Ficitious Names and Information Edited to Anonymity.  For example, information regarding to browsing history, positional information and cookies, etc., but which cannot be used to identify an individual.) to provide better services on our website.

(2)    About Cookies
Cookies may be used to customize a website to meet the needs of each individual of the customer in order for the effective operation of the internet and to improve the contents of the website and services provided (including advertisement) in order to make the customer more content.
Depending on the browser setting, the customer may refuse to accept cookies or be alerted when receiving a cookie; provided, however, that, when refusing to accept cookies, there may be restrictions, such as not being able to use a certain function.

(3)    About Web Beacons
Web beacons (Clear GIF) are a technology that uses GIF files and scripts to apprehend the access status from the customer’s computer and to collect statistics on the usage rate of specific web pages.
Also, web beacons, when used in conjunction with the cookies described above, can obtain detailed statistical information.
Our website may use web beacons and other technology in order to obtain statistical information necessary to improve the website and other purposes.
Even when the customer refuses to accept cookies, web beacons can apprehend the status of access, but we will not collect any personal information through web beacons. 
 

 This section applies specifically to the collection and management of personal information in relation to ClipLine’s business in Australia.  It applies in addition to the terms set out above.

We generally collect personal information directly from you, such as where you register for an account with us or order goods or services from us.  However, in some cases we may collect personal information from a third party, such as where one of our customers provides us with your information for the purposes of engaging us to provide a service.  If we do not collect information about you, we may not be able to accomplish our purposes provided in Section 1 above.

We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers.  Sometimes we also keep hard copy records of this personal information in physical storage facilities.  We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats.

We may disclose or provide your information: (i) to third parties such as our officers, employees and advisers, our business partners, agents and service providers, prospective purchasers of all or part of our business or shares in our company, professional advisers, government authorities, as reasonably necessary for our business, (ii) to other third parties with your consent, or (iii) to comply with applicable laws.

In some cases, we may store your information outside Australia or may disclose your information to a person outside Australia where they are subject to different privacy regimes.  The countries in which these people are likely to be located include Japan.
If you want to access any of the personal information that we hold about you or to correct some aspect of it (e.g., because you think it is incomplete or incorrect), please contact us using the contact details and following the procedure specified in Section 2 above.

If you want to make a complaint about a possible breach of the Australian Privacy Principles, or any other relevant privacy obligations that apply in Australia, please contact us using the contact details and following the procedure specified in Section 2 above.  Complaints must be lodged in writing.  We will deal with the matter within a reasonable time and will keep you informed of the progress of our investigation.  If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns.  You are also entitled to make a complaint to the Office of the Australian Information Commissioner (“OAIC”).  Contact details can be found at the OAIC’s website: www.oaic.gov.au

We may make changes to this policy from time to time, to take into account changes to our practices and procedures or where necessary to comply with new laws and regulations.  The latest version of this policy will always be available on our website.

(1)   General

This section applies specifically to the collection, use, and disclosure of personal information in relation to ClipLine, Inc.’s business in Singapore.  It applies in addition to the terms set out above.

Where this section applies, each of the following terms in the Personal Information Protection Policy (including this Section 9) shall have their respective meanings ascribed hereto:

“PDPA” shall mean the Personal Data Protection Act 2012 of Singapore;

“personal information” is defined as data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access; and

“personal information protection manager” shall be taken to refer to ClipLine’s data protection officer, designated pursuant to Section 11(3) of the PDPA.

(2)   Handling of Personal Information; Consent

We generally collect personal information directly from you, such as where you register for an account with us or order goods or services from us.  However, in some cases we may collect personal information from a third party, such as where one of our customers provides us with your information for the purposes of engaging us to provide a service.  If we do not collect information about you, we may not be able to accomplish our purposes provided in Section 3 above.

We will generally seek your consent before collecting, using, and/or disclosing any personal information, for any purpose or reason, that is not described at Sections 3 and 4 above, unless otherwise required or authorized under applicable laws.  You acknowledge and agree that in registering for an account with us, ordering goods or services from us, or using any of our services, you shall be deemed to have consented to each of the purposes of use and reasons for disclosure of personal information set out in Sections 3 and 4 above.

We may also disclose or provide your information: (i) to third parties such as our officers, employees and advisers, our business partners, agents and service providers, prospective purchasers of all or part of our business or shares in our company, professional advisers, government authorities, as reasonably necessary for our business, (ii) to other third parties with your consent, or (iii) to comply with applicable laws.

We may have to store or transfer your information outside Singapore, or may disclose your information to a person outside Singapore where they are subject to different privacy regimes. The destination countries to which your personal information may be transferred and in which such persons are likely to be located include Japan.  You acknowledge and agree that this is necessary for the conclusion or performance of the services envisaged in this policy and that by registering for an account with us, ordering goods or services from us, or using any of our services, you shall be deemed to have consented to such overseas transfer.  

In each overseas transfer of your personal information, we will also endeavor to ensure that your personal information will be protected in such destination countries, such as by ensuring that: (a) there are legally enforceable obligations imposed on the recipient (whether under law, a contract, binding corporate rules, or any other legally binding instrument) that provide for a standard of protection to your personal information that is comparable to that under the PDPA; or (b) the recipient holds valid Asia Pacific Economic Cooperation Cross Border Privacy Rules certification (where it is receiving your personal information as an organization) or Asia Pacific Economic Cooperation Privacy Recognition for Processors (where it is receiving your personal information as a data intermediary), and on this basis you also further give your express consent for us to transfer your personal information overseas as may be required by us from time to time.

(3)   Information Storage

We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers.  Sometimes we also keep hard copy records of this personal information in physical storage facilities.  We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats.

We retain your personal information for as long as is necessary to fulfil the purpose(s) for which it was collected, or as required or permitted by applicable laws. When we determine how long to keep your personal information after our relationship with you has ended, we take into account our legal rights and obligations. In particular we may retain records to investigate, commence or defend potential legal claims. We will cease to retain your personal information or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business reasons.

(4)   Your Rights

You have certain rights regarding the personal information we hold about you, subject to Singapore law. These may include the rights to access, correct, restrict or object to our use of, or receive a portable copy in a usable electronic format of, your personal information. If you want to make an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, you may submit your request in writing or via email to us using the contact details and following the procedure specified in Section 6 above. Please note that a reasonable fee (that may differ from the fee of JPY 1,000 specified at Section 6 above) may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

We also encourage you to contact us using the contact details specified in Section 6 above to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our products to you and we shall, in such circumstances, notify you before completing the processing of your request. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Please note that we may require additional information from you in order to honour your requests.

If you would like to discuss or exercise any rights you may have under law, please contact us using the contact details specified in Section 6 above.

If you want to make a complaint about a possible breach of the PDPA, or any other relevant privacy obligations that apply in Singapore, please contact us using the contact details and following the procedure specified in Section 6 above.  Complaints must be lodged in writing.  We will deal with the matter within a reasonable time and will keep you informed of the progress of our investigation.  If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns. 

(5)   Changes to this Policy

We may make changes to this policy from time to time, to take into account changes to our practices and procedures or where necessary to comply with new laws and regulations.  The latest version of this policy will always be available on our website.