PRIVACY POLICY

Personal Information Protection Policy

We, ClipLine, Inc., believe that the appropriate handling of personal information is one of our corporate social responsibilities. In developing and operating the digital solution business “ClipLine”, we have numerous occasions to handle our customers’ personal information.
We hereby stipulate the following provisions with respect to the protection of personal information that enables to identify individuals, and declare that we will implement and comply such provisions.

  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: April 18, 2023
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

Handling of Personal Information

1. Our Company Name, Address and Name of Representative

ClipLine, Inc.

5th floor, GranFirst Kandakonyacho,

15 Kandakonyacho, Chiyoda-ku, Tokyo 101-0035

Hayato Takahashi, CEO

 

 

2. Name or Title of Our Personal Information Protection Manager (or His/Her Agent), Affiliation and Contact Information

Takashi Fujimura, Personal Information Protection Manager

Mail to: privacy@clipline.jp

 


3. Purpose of Use of Personal Information

Type of Personal Information Purpose of Use

Applicability for
Retained Personal Data

Images used in Sales Support and gallery images To promote ClipLine, Inc. Yes
ClipLine account information (e.g. user names and passwords and information about your account usage) To perform contracted services (account management)

Yes

Personal information of business partners (e.g. name, contact details and information about orders for goods and services, including payment information) To communicate with, to deliver goods to, and to provide service with or without compensation to   business partners Yes

Personal information of individuals who have made inquiries to us (e.g. name, contact details and information relating to the relevant inquiry)

To answer inquiries, to use phone call records to improve the quality of telephone operation and to acquire an accurate understanding of inquiries Yes
Personal information of job applicants (e.g. name, contact details and information contained in the applicant’s CV and job application)
  1. To dispatch materials regarding recruitment
  2. For recruitment selection process and  communications regarding outcomes of said recruitment
  3. Process for employment
Yes

Personal information of our employees (e.g. information about their terms of employment, employee entitlements, and work performance or conduct)

  1. To carry out procedures for  personnel affairs, salary, health administration and  welfare for all employees
  2. To carry out performance review and skill assessment for employees
  3. For various communication with business partners
  4. For various procedures regarding resignees
Yes

Personal information received from ClipLine customers (outsourcer) (e.g. information required for ClipLine to provide services to customers)

To perform contracted services No

4.Provision to a Third Party

We will not provide acquired personal information to any third party except in the event as 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 within the scope to achieve the purpose of use.

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

 

5.Security Control Measures for Retained Personal Data

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

(1)   Establishment of Rules Regarding Handling of Personal Information

-To estabilish handling rules stating the handling, person in charge/management and their mission for personal data for each stages of obtainment, usage, storage, provision 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 softwares.

 

 

6. Disclosure of Personal Information and Complaints/Consultation

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

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Grand First Kandakonyacho 5F,
15 Kandakonyacho, Chiyoda-ku,
Tokyo, 101-0035

Japan 

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