Personal Information Protection Policy
Asian Bridge Partners Inc. (“ABP”) operates the Internet and mobile-based information platforms and provides a range of accompanying services. In operating its business, ABP handles a large amount of personal information regarding customers and employees. Therefore, ABP has established this Policy and a personal information management system based on its Code of Ethics, through which ABP, as a company, is committed to realizing the responsible handling of personal information.
ABP will, to the extent possible, specify the purposes of using the personal information and will properly handle the personal data within the scope necessary to achieve such goals. ABP will take measures to ensure the prevention of any use of personal information other than for the intended purposes of use.
ABP will obtain personal information only through legitimate and appropriate means.
ABP will not provide any third party with the personal information of any individual without the consent of such individual.
In managing personal information, ABP will make efforts to take all necessary and appropriate measures to prevent and correct any leakage, loss, or damage of the personal information, as well as the otherwise secure management of the personal data.
In handling personal information, ABP will make efforts to ensure that the individual who has provided the information may properly be involved in the handling process and make efforts to keep the personal information accurate and updated to the extent possible.
ABP will comply with laws and regulations about the protection of personal information and establish, continuously review and comply with its internal rules about the protection of personal information.
ABP will have a section for responding to complaints and consultations concerning the protection of personal information and make efforts to respond to such complaints and consultations properly.
Asian Bridge Partners Inc. Takeshi Hanyu, CEO
Enacted and enforced on October 30, 2020
- Handling of Personal Information
- Personal Information
Personal information is the information of a User as an individual, which can identify the User based on the name, address, telephone number, e-mail address, company name, or other descriptions constituting such information. In addition, any information that cannot identify the User solely by itself but can easily be cross-referenced with additional information and, as a result, can identify the User, is also included in the scope of personal information.
- Acquisition of Personal Information
The personal information that ABP collects through or in connection with the Services shall be determined based on the collection methods as follows.
i) Information provided by the User for or through the use of the Services shall include the following:
- Information relating to date of birth, sex, and professional profile;
- Email address, telephone number, address, and contact information;
- Credit card, bank account, and electronic money information relating to payment methods;
- Static image information including portrait of the User; or
- Information input or sent by the Users in entry forms and by other methods specified by ABP.
ii) Information that ABP collects for the Users’ use of the Services
ABP may collect information relating to the access status and usage of the Services. The information includes the following:
- IP addresses;
- Information relating to server access logs; or
- Cookie, ADID, IDFA, and other identifiers.
iii) Information that ABP collects for the Users’ use of the Services based on individual Users’ consent
- ABP collects the following information from the terminals during their use of the Services.
- Purposes of Use of Personal Information
ABP shall use personal information only for the following purposes:
i) Personal authentication or the provision of the Services to a User;
ii) Communication or distribution of direct mail or notices regarding usage of the Services
iii) Provision of personal information to a User Company based on Users' consent/application;
iv) Distribution or display of advertisements and contents based on attribute information, terminal information, location information or action history records, or provision of the Services;
v) Improvement of the Services, service development, survey and analysis on usage of the Services, or marketing activities;
vi) Implementation of champaigns, questionnaire surveys, or interviews;
vii) Distribution of URL information regarding inquiries;
viii) Comments regarding the Services, confirmation of or response to inquires; or ix) Investigation on any breach of the terms of service or agreements thereof, such as an application for commercial use or for purposes other than initially intended, duplicated applications, transfer of rights, registration of false information, or confirmation of such application details based on the results of the investigation.
- Voluntary Nature of Provision of Personal Information
Users who do not provide the information required to use the Services may not be able to use the Services.
- Provision of Personal Information to Third Parties
ABP, as a general rule, shall not provide personal information to a third party without the User’s consent, except for the cases described below. ABP shall only provide, upon identifying the recipient and the content of the information provided, the information to a third party with the User’s consent, unless any of the following cases apply:
i) Provision for the services operated by Level Bridge Inc., a wholly-owned subsidiary; or
ii) Provision for the User Companies for offering services, including a request for information materials, application, reservation, and purchasing.
In such cases, the content of the information provided and the methods for providing the information shall be as described below.
a) Items of personal information provided
Personal information for being provided shall mean any information out of the information (containing service use history and any action history records, including information relating to browsing, retrieval, and bookmarks) obtained from the Users to the extent necessary to achieve the intended use.
b) Methods or means of providing personal information
Personal information shall be sent in writing or transmitted by electronic method. Upon agreement to this Policy, the User is considered to have agreed to provide their personal information to third parties under 6 i)-ii) above.
However, personal information may be disclosed without the User’s consent within the scope not conflicting with applicable laws and regulations when:
a) The User is considered detrimental to the third party;
b) The provision of personal information is essential for improving public hygiene or promoting the sound growth of children, and it isn't easy to obtain the User’s consent;
c) The provision of personal information is necessary for cooperating with a state institution, a local public body, or an individual or entity entrusted by such an institution or body to execute operations prescribed by law, and obtaining the User’s consent might impede the execution of such operations. A court, prosecutor’s office, police department, or any other institution with corresponding authority requests disclosure of the User’s personal information;
d) The User him/herself explicitly requests the provision or disclosure to the third party; or
e) The provision of personal information occurs due to business succession in a merger or otherwise and is utilized within the purpose range set before the succession.
- Disclaimer for Third-Party Provision
ABP assumes no responsibility for the acquisition of any personal information by third parties if any of the following cases apply:
i) A User indicates his/her personal information to a User Company using any function of the Services or other means (Please inquire with your company regarding the handling of personal information by your company.);
ii) A User is unexpectedly identified with the information entered by the User under the Services;
iii) A User provides personal information to an external site linked to the Services and the information is used by the User; or
iv) Anyone other than a User obtains the User's information (ID, password, etc.) which can identify the User as an individual.
- Outsourcing of Personal Information Processing
ABP may outsource personal information handling in part or in whole. ABP is responsible for the handling of personal information by the party to which such work is outsourced.
- Use of Statistical Data
ABP may, based on the personal information provided, create statistical data which shall be processed in a manner that cannot identify any individual. ABP may, without restriction, use such statistical data that cannot identify individuals.
- Modifications, etc. to Personal Information
As a general rule, only the User him/herself can make a request regarding the "Purposes of Use of Personal Information," the disclosure or correction of, addition to, deletion or suspension of his/her registered personal information, or the provision thereof to third parties (the “Modifications to Personal Information, etc.”). For specific instructions, please contact the personal information management contact below.
However, ABP may not agree to respond to the Modifications to Personal Information, etc. if any of the following applies:
i) If there is a risk of harm to the life, body, property, or other rights or interests of the User or a third party;
ii) If there is a risk of significant hindrance to the proper operation of the Services; or
iii) If it results in a violation of other laws and regulations.
Furthermore, if a request for the suspension or deletion of the personal information in question requires a significant amount of money or is difficult to accommodate and ABP takes alternative measures necessary to protect the rights and interests of the Users, ABP may not be able to agree to comply with such request.
- Accuracy of Personal Information
ABP shall make efforts to accurately process the personal information provided. However, the Users are responsible for ensuring that the personal information they provide is accurate and up to date.
- Limitation on Acquisition of Sensitive Personal Information
ABP, as a general rule, shall not obtain any User’s personal information which contain any of the following information, unless the personal information has been provided by the User him/herself:
i) Information relating to personal philosophy, belief, or religion;
ii) Race, ethnic background, social status or origin, domicile (except for information on the prefecture of residence), physical or mental disability, criminal record, or other matters that may cause social discrimination;
iii) Information relating to the right to organize or any acts of collective bargaining or collective actions as a worker;
iv) Information relating to participation in acts of mass demonstration, the exercise of petition rights or other political rights; or
v) Information relating to health and medical conditions or sex life.
ABP shall verify the individual’s identify based on information that can identify such individual (i.e., name, address, phone number, e-mail address, User ID, password, etc.) in the following cases. However, ABP shall not be responsible for any use of personally identifiable information obtained by anyone other than a User.
i) When a User signs up for web services or when a User uses the Services; or
ii) When ABP accommodates a User’s request for the disclosure, correction, deletion, or suspension of use of such User’s personal information.
- Acquisition and Use of Attribute Information, Terminal Information, Location Information, Activity History Record, etc.
Cookies, etc. of attribute information, terminal information, location information, and action history records (the “Action History Records, etc.”)
- Access Logs, etc., among Action History Records, etc., in the following case:
When a User logs in to and uses the Services, ABP may, upon identifying the identity of such User, distribute, display advertisements, contents, etc., and provide the Services using the Action History Records, etc., before such log-in by the User. To unsubscribe these advertisements, etc., please contact the personal information management contact below.
Personal Information Protection Manager
Takeshi Hanyu, Director in charge of the Services
Asian Bridge Partners Inc.
For inquiries regarding personal information, please contact us at:
Enacted and enforced on October 30, 2020