Effective Date:February 5, 2007
Last Revision Date:March 7, 2022
Leverages Co., Ltd.
Representative Director Tomohide Iwatsuki
Leverages Co., Ltd., its affiliated companies and its subsidiary companies (“Leverages Group”) are engaged in the business in relation to development of software, system maintenance service, mobile contents service, resident development service, and recruitment service (collectively, “our Services”), under our business ethics of “Success and achievement for our clients and employees will lead us a great success of Leverages Group.”
In operation of any business, it is our social duty and obligation to manage personal information in a safe and proper manner; and to fulfill our duty or obligation, Leverages Group will comply with the policies as below.
Collection of Personal Information
We will obtain personal information within the scope required, in proper and adequate manner, and with the purpose of use clarified. For any person who contact us via CONTACT, we would ask you to acknowledge that we may reach you for the purpose of confirming details of your inquiry.
Management and Provision of Personal Information
1）Purpose of use
We will use personal information to the extent as follows and take measures to prevent an utilization for unintended purpose:
1. responding to your inquiry and any business operation to carry out our Services promptly;
2. anything specified at the time we obtain personal information;
3. responding to notification or guidance required by the laws or the competent authorities; or
4. where you inquired us via CONTACT, if needed, provision our affiliates (“Third Party”)with personal information, by communicating on phone, document, electronic means etc. to properly respond. We may cease the provision Third Party if you request.
In other case, we will not use any personal information obtained in accordance with the Article 1 for any purpose other than the purpose of use clarified above a consent from the person such information belongs to.
2）Disclosure to the Third Party
Except for the case stipulated in the item 3 and 4 of immediately preceding paragraph, we will never disclose any personal information obtained in accordance with the Article 1 to a third party without a consent from the person such information belongs to. Provided, however, that we may disclose personal information to our Partner Companies to the extent required to carry out the purpose of use. With respect to such disclosure, we are aware that we are in obligation to require our Partner Companies to manage personal information in a safe and proper manner and take reasonable measures to manage personal information properly.
3）Managing Personal Information Properly
We represent and warrant that we will take reasonable measures of safety to prevent unauthorized access, loss, damage, or falsification of personal information. We will also make our best efforts to educate any employee dealing with personal information, including but not limited to regulatory training for management of personal information conducted by administrators.
Compliance with Applicable Laws and Regulations
With respect to the management of personal information, we represent and warrant that we will comply with applicable laws, regulations, guidelines, and any other regulatory established in Japan.
Handling with Contacts, Inquiries or Claims
We will handle or deal with any contact, inquiry or claim promptly. In the case where we have any request for any disclosure, correction, addition, deletion, cease of use etc, we sincerely deal with such request in compliance with the applicable laws and regulations.
If you have any request, please contact us via Contact Information below.
Operational systems on management of personal information
With respect to operational systems on management and protection of personal information (the “Operational Systems”), we will manage it properly and make any revise required to manage personal information in a safe and proper manner. We will also review and improve on the Operational Systems regularly and continuously, in consideration of changes of social circumstances or tendencies surrounding personal information.
Safe Management Measures
We take the following measures as safe management measures for retained personal data.
【Organizational safe management measures】
・ In order to take safe management measures for personal data, we have set up information managers in each department as managers.
・ In the case that leakage of personal data occurs or is likely to occur, we will take necessary measures should be taken according to the case, such as prompt investigation of the facts and cause, in accordance with the reporting communication system we established.
・ Upon handling personal data, we have installed and implemented in-house manuals, and have regularly checked the system usage status using access logs etc.
【Personal safe management measures】
・ We implement regular training and dissemination to employees regarding rules and precautions of handling of personal data, and accident cases that occurred at other companies, etc.
・We have the work regulations and other internal regulations in which stipulated the confidential obligation of personal data during and after employee enrollment.
【Physical safe management measures】
・ We implement security measures such as requiring an IC card to enter and leave our office.
・ We limit the equipment that can be brought into our office, and we manage the personal data at the place which is able to be locked or store them in a server that requires authentication.
・ When destroying personal data, we implement processes such as dissolution and shredder so that it cannot be restored.
・ When moving or carrying electronic devices, we make such devices locked with passwords to prevent leakage of personal data.
・ We prevent personal data from being lost or stolen by storing personal data on encrypted devices, file servers or clouds with advanced security measures etc.
【Technical safe management measures】
・ Upon using personal data, we take the access control by restriction of access with an IP address, requirement of ID and password to access the database, setting two-step verification, and limitation of employees who can view the information according to the type of information.
・ We thoroughly install security software on the equipment used by employees.
【Understanding the external environment】
Please contact each inquiry counter for the status of understanding the external environment. We will individually respond according to our service you use.