We recognize the importance of protecting personal information in our modern information and communication based society and strive to protect our clients’ personal information based on the following policy. Please carefully review and agree to the following terms before providing us with any of your personal information.
1. Definition of Personal Information, etc.
(1) In this Privacy Policy, “personal information” is as defined by Article 2, Paragraph 1 of the Personal Information Protection Law of the British Virgin Islands, that is, information about living individuals that falls under any of the following descriptions:
① Information that can identify a specific individual by the name, date of birth, or other description contained in the information (which can easily be collated with other information, making it possible for the specific individual to be identified.)
② Information that includes a personal identification code.
(2) In this Privacy Policy, “sensitive personal information” is as defined by Article 2, Paragraph 3 of the Personal Information Protection Law of the British Virgin Islands, that is, the person's race, beliefs, social status, medical history, criminal history, etc. It additionally means information that includes the description specified by the Enforcement Ordinance of the Personal Information Protection Law, which is the fact that the person was harmed by a crime, or other matters that might require special consideration in handling so as not to cause unfair discrimination, prejudice, or other disadvantages to the person.
2. How the Personal Information will be Used (Usage Goals)
(1) To have applications for the Company’s products and services accepted.
(2) To receive information regarding the Company’s products and services.
(3) For market research related to the Company’s products and services, as well as the research and development of financial products and services through data analysis and questionnaires.
(4) To provide maintenance and support for the Company’s services.
(5) To notify purchasers of changes to the Company’s service’s rules, guidelines, risk explanations, policies, precautions and other individual rules (hereinafter collectively referred to as "rules".)
(6) To reply to inquiries and provide consultation regarding the Company’s services.
(7) To respond to violations of the Company’s service’s rules, etc.
(8) To verify purchasers’ identities.
(9) To confirm financial institution account information and the status of transfers.
(10) For emergency contact.
(11) To backup data.
(12) To conduct audits within the Company.
(13) For other purposes incidental to the above usage goals.
3. Restrictions on the Use of Personal Information
The Company will not utilize personal information for any purpose beyond those necessary to achieve the usage goals listed above without obtaining the prior consent of the purchaser, except in the following situations:
(1) When required by law to do so.
(2) When it is necessary to protect the life, physical health and safety or property of a person, but it is difficult to obtain their consent.
(3) When it is strongly needed for the sake of public health or to promote the sound development of children, but it is difficult to obtain the consent of the individual involved.
(4) When it is necessary to cooperate with a national or local governmental entity, or a person acting on its behalf, in carrying out a procedure stipulated by law, but there is a risk that obtaining the consent of the person involved will hinder the performance of the procedure.
4. Appropriate Acquisition of Personal Information
The Company will acquire personal information only through proper means and will not obtain it by deception or other improper methods.
5. Notification of how Personal Information will be Used when Acquiring it
When acquiring your personal information, the Company will inform you in advance of how it will be used, except in the following situations:
(1) When there is a risk of harm to the life, bodily health or safety, property or other rights and interests of the person involved or a third party if the usage goals are notified or disclosed to them.
(2) When there is a risk of harm to privacy rights or other legitimate interests by notifying or disclosing the usage goals to the person.
(3) When it is necessary to cooperate with a national or local governmental entity, or a person acting on its behalf, in carrying out a procedure stipulated by law, but there is a risk that notifying or disclosing the usage goals to the person involved will hinder the performance of the procedure.
(4) When it is recognized that the usage goal is clear from the status of acquisition.
6. Supervision of Contractors
In the event that the Company outsources all or part of the work which might require the handling of personal information, we will ensure that any contracts we conclude with the contractor include confidentiality requirements. We will also provide necessary and appropriate supervision so that the contractor can manage the security of personal information.
7. Restrictions on Provision to Third Parties
The Company will not provide personal information to a third party without the prior consent of the individual involved, except in the following situations:
(1) When required by law to do so.
(2) When it is necessary to protect the life, physical health and safety or property of a person, but it is difficult to obtain their consent.
(3) When it is strongly needed for the sake of public health or to promote the sound development of children, but it is difficult to obtain the consent of the individual involved.
(4) When it is necessary to cooperate with a national or local governmental entity, or a person acting on its behalf, in carrying out a procedure stipulated by law, but there is a risk that obtaining the consent of the person involved will hinder the performance of the procedure.
(5) When the following matters are disclosed or officially announced:
1．Provision to provide to third parties included in usage goals.
2．Data items provided to third parties.
3．Means or method of provision to a third party.
4．Provision of personal information to third parties stopped at the request of the individual involved.
However, the following cases do not apply to the third parties specified above:
(6) When the Company outsources all or part of the handling of personal information to the extent necessary to achieve the usage goals.
(7) When personal information is provided due to business succession resulting from merger or other reasons.
(8) In the case of joint use of personal information with a specific person or entity, when the facts, items of personal information used jointly, the scope of joint use, usage goals, the name or name of the person responsible for the management of the personal information, are notified in advance to the individual involved or is in a state where he or she can easily know it.
8. Disclosure of Personal Information
When the Company receives a request for the disclosure of personal information from a purchaser, we will disclose it without delay after confirming that the request is from them. If, however, the requested disclosure falls under any of the following, we may decide to not disclose all or part of it. In this event, we will notify the purchaser to that effect at once.
Please note that a handling fee of 2,000 yen (excluding consumption tax) per case will be charged for the disclosure of personal information.
(1) When there is a risk of harm to the life, bodily health or safety, property or other rights and interests of the person or a third party.
(2) When there is a risk of significant hindrance to the proper implementation of the Company’s business.
(3) When it violates any laws or regulations.
9. Personal Information Correction, etc.
When the Company receives a request from a purchaser for correction, addition or deletion (hereinafter referred to as "correction etc.") of their personal information because it is incorrect, we first confirm that the request is in fact from the purchaser himself or herself. Unless special procedures are stipulated by the provisions of any relevant laws or regulations, we will conduct the necessary investigations without delay, within the scope necessary to achieve the target goals. Based on the results, corrections, etc. of the purchaser’s personal information will be made and he or she will be notified to that effect.
Please note that a handling fee of 2,000 yen (excluding consumption tax) per case will be charged for this procedure.
10. Personal Information Suspension of Use, etc.
If a purchaser would like the Company to suspend or stop the usage of some or all of their personal information (hereinafter referred to as "suspension of use, etc.") because it is being used in a way that is beyond the scope of the usage goals announced in advance, or because it was acquired by deception or other improper means, the request must come from the purchaser himself or herself. After confirming this, we will conduct the necessary investigation without delay and, based on the result, we will suspend the use of the personal information and notify the purchaser to that effect.
If, however, the cost required to suspend the use of personal information is high, or if the suspension procedure is difficult, and if necessary alternative measures can be taken which protect the rights and interests of the individual, this alternative will be used. Also, if the purchaser’s request does not meet the requirements of the Personal Information Protection Act, we may not be able to comply with it. Please note that a handling fee of 2,000 yen (excluding consumption tax) per case will be charged for this procedure.
11. About the Use of Cookies, etc.
In the course of the Company’s business, we may collect and use our client’s cookie information, etc. in order to provide them with better service. If they prefer, purchasers can disable cookies by changing their web browser settings. If cookies are disabled, however, some functions of our service may not be able to be used.
12. Contact and Inquiries
For inquiries regarding personal information, please contact:
Personal Information Inquiry Desk
email:customer@protop.company
Pro Top Company Services Limited.