SHIFT GROUP

Privacy Policy

Revised on March 24th, 2021

SHIFT Inc. (hereinafter “we”, “our” or “us”) recognizes that it is our social responsibility to ensure proper use and management of personal information, understanding the purposes of the Act on the Protection of Personal Information. We hereby establish this Privacy Policy, and all of our employees will endeavor to ensure the protection of personal information, understanding the importance thereof.

Our Basic Policy on Personal Information Protection

We will handle personal information in good faith in compliance with laws, guidelines and other regulations set out by the government with respect to personal information(hereinafter referred to as the “Related Laws”) and our Privacy Policy. In addition, we will strive to keep informed of the Related Laws and will keep our employees (hereinafter referred to as “our Employees”) and our business partners informed of the Related Laws and will have them comply with the Related Laws.

When collecting personal information, we will make clear the purposes of its use in advance and will use the collected personal information only within the purposes. If there is a need for use of your personal information for any purpose other than the above purposes, we will notify you of such purpose and use your personal information upon your consent. Please check the detailed purpose of use before you give consent to provide your personal information.

We will not provide your personal information collected by us to any third party without your prior consent, provided, however, that we may provide your personal information to a third party, (i) if we are required to do so in accordance with the Related Laws, (ii)if the provision of your personal information is necessary for protecting a person’s life, body, or property, and if it is difficult to obtain your consent, (iii)if the provision of your personal information is particularly necessary for improving public health or facilitating sound education for children, and if it is difficult to obtain your consent, (iv)if it is necessary for us to cooperate with national or local government or its agency in carrying out their duties pursuant to the Related Laws, and if it is detrimental to carrying out such duties to obtain your consent, (v)if we outsource your personal information to a third party within the scope of the intended purposes, (vi)if your personal information is provided by way of merger or any other events of business succession, transfer or assignment and if your personal information is handled within the scope of the same purposes as before the merger, business succession, transfer or assignment, (vii)if we share your personal information with the third party, and/or (viii)if there is any other reason that we are required or allowed to provide the personal information to the third party.

We take reasonable technical and organizational security measures and preventive measures against risks of leakage, loss, damage, or other similar events as to your personal information. In addition, we will carry out regular check-ups and if any violations, incidents, or accidents are found, we will correct such violations or causes of such incidents or accidents and take preventive measures against weaknesses without delay. We will provide thorough security education to our employees and business partners.

We will appropriately and promptly handle complaints and inquiries regarding our Privacy Policy after we receive them. We will also establish and maintain our system and procedures for such handling in a proper and timely manner. We respect an individual’s rights regarding personal information, and disclose, correct, or delete your personal information if and only if requested by yourself.

In order to use personal information properly and ensure its protection, we will monitor and review the compliance with our rules and regulations, endeavor to find violations, incidents, accidents and weaknesses, and carry out the management review. By reflecting the foregoing in our management of personal information and our rules and regulations, we will continuously review and improve this Privacy Policy, in compliance with the Related Laws and JISQ15001.

Managing personal information

(1) Notice of Purpose of Use

If a request for notification of the purpose of use is made to us, we will handle the request after verifying your identity or your representative’s identity. However, we may not be able to notify you according to your request, (i) if such notice is difficult in accordance with the Related Laws, (ii)if such notice may make it difficult to protect a person’s life, body, or property, (iii)if such notice may obstruct our necessary cooperation with statutory duties of a national or local government or its agency, or (iv)if such notice could harm or infringe our right or legitimate interests.

(2) Disclosure to You

If a request for disclosure is made to us, we will handle the request after verifying your identity or your representative’s identity. However, we may not be able to make such disclosure according to your request, (i) if such disclosure is difficult in accordance with the law or other applicable legislation, (ii)if such disclosure may make it difficult to protect a person’s life, body, or property, (iii)if such disclosure may obstruct our necessary cooperation with statutory duties of a national or local government or its agency, or (iv)if such disclosure could harm or infringe our right or legitimate interests.

(3) Addition, Correction, or Partial Deletion of Personal Data

If a request for addition, correction, or partial deletion is made to us, we will handle the request after verifying your identity or your representative’s identity. However, we may not be able to handle such request as you wish, if the Related Laws stipulate procedures for addition, correction, or partially deletion of personal data or if such request is in breach of what you have agreed in advance.

(4) Suspension of Use or Deletion

If a request for suspension or deletion is made to us, we will handle the request after verifying your identity or your representative’s identity. However, we may not be able to handle such request as you wish, if the Related Laws stipulate procedures for suspension of use or deletion of personal data, if such requested suspension or deletion makes it difficult to perform agreements or other necessary actions, or if such request is in breach of what you have agreed in advance.
Please note that the requested suspension of use or deletion may make it difficult for us to timely communicate with you or to provide information to you.

Our Handling of Personal Information

1. Name of the Company

SHIFT Inc.

2. Personal Information Manager

Motoya Kobayashi, Director

3. Purpose of Use

We may handle personal information collected by us for all or any of the purposes set out in the below (1) through (7) and other purposes that we notify or announce when collecting personal information.

  • (1) Personal information in relation to our clients;
    1. (a) for carrying out the services or work outsourced to us;
    2. (b) for providing our services;
    3. (c) for planning and/or development of new services;
    4. (d) for advertising and/or promoting our services (including analysis of information and/or marketing, and/or providing information on any products, services, and/or events such as exhibitions by email, direct mail or other means).
    5. (e) for performing any agreement with any of our clients or business partners and/or support services for them.
    6. (f) for handling inquires; and/or,
    7. (g) for keeping record as to our visitors.
    　　　　
  • (2) Personal information in relation to our business partners;
    1. (a) for performing any agreement with any of our business partners, order management, and/or support services
    2. (b) for referral to our clients or acting as an agency or intermediary with regard thereto
    3. (c) for planning and/or development of new services;
    4. (d) for advertising and/or promoting our services (including analysis of information and/or marketing, and/or providing information on any products, services, and/or events such as exhibitions by email, direct mail or other means).
    5. (e) for taking measures in connection with office safety and hygiene or prevention of disease;
    6. (f) for handling inquires; and/or,
    7. (g) for keeping record as to our visitors.
    　　　　
  • (3)Personal information of persons participating in or attending seminars or events that we hold or join
    1. (a) for any actions necessary for holding and operating seminars or events, including without limitation, reception of applications, various actions on the days of the seminars or events, handling inquiries, support services after the seminars or events
    2. (b) for any actions necessary for providing information as to seminars and/or events held by us or any of our subsidiaries and affiliated companies (hereinafter collectively called “our Group Companies”)
    3. (c) for advertising and/or promoting our services and/or our Group Companies’ services (including analysis of information and/or marketing)
    　　　　
  • (4) Personal information of persons offering to be employed by us or any of our Group Companies
    1. (a) for providing information to such persons or communicating with them
    2. (b) for selecting employees
    　　　　
  • (5) Personal information of employees and former employees of us and our Group Companies
    1. (a) for business contact and communication, management of facilities and equipment, and/or other matters
    2. (b) for employee evaluations, personnel changes (including secondments and dispatching), awards and disciplines, and/or other personnel management
    3. (c) for employees’ labor management
    4. (d) for determination and payment of salaries and/or bonuses, tax related matters, and /or procedures relating to social security
    5. (e) for providing welfare services
    6. (f) for safety and hygiene, health care, or prevention of disease
    7. (g) for advertising us or our services
    　　　　
  • (6) Personal information of shareholders of us or any of our Group Companies
    1. (a) shareholders relations activities pursuant to laws and regulations such as various procedures, sending documents, and/or managing shareholders data
    2. (b) taking measures for enhancing relations between the shareholders and us or our Group Companies
    　　　　
  • (7) Personal information of our inquirers
    1. (a) for handling inquires
    　　　　

4. Providing Personal Information to Third Parties

We will not provide your personal information collected by us to any third party without your consent, except where such disclosure:

  • (1) is required by the applicable laws and regulations;
  • (2) is necessary to protect a person’s life, body, or property, and it is difficult to obtain your consent;
  • (3) is necessary in particular to improve public hygiene or promote healthy upbringing of children and it is difficult to obtain your consent;
  • (4) is necessary to cooperate with national or local government or its agency in carrying out their statutory duties, which may be obstructed by obtaining your consent; or
  • (5) is made after your personal information is processed so that an individual cannot be identified.

5. Outsourcing

Within the scope of the purposes set forth in this Privacy Policy, we may outsource collected personal information to an outside contractor. As to such outsourcing, we will select a company or business entity that manages personal information appropriately in accordance with our standards, conclude an agreement regarding appropriate handling of personal information, and oversee the company or business entity.

6. Information Not Identifying an Individual Person

We may process collected personal information so that information that cannot identify an individual person is produced, and we may provide such non-identifying information to any third party, including without limitation, our clients.

7. Joint Use

  • (1) Shared users:
  • (2）The Party responsible for the management of jointly-used personal information:
    • SHIFT Inc.
  • (3) Items of personal information to be shared:
    • Types of personal information to be shared Items of personal information to be shared
      Personal information in relation to any of our clients;
      • Information on contact persons of our clients including without limitation such persons’ related organization names, titles, names, and/or contact details (such as email addresses and telephone numbers)
      Personal information in relation to any of our business partners;
      • Information on contact persons of our business partners including without limitation such persons’ related organization names, titles, names, contact details (such as email addresses and telephone numbers), and/or information on their qualifications, licenses, skills, and career.
      Personal information of any person participating in or attending seminars or events that we hold or join
      • Information on persons participating in or attending seminars or events that we hold or join including without limitation such persons’ related organization names, titles, names, contact details (such as email addresses and telephone numbers), and/or names of seminars or events that such persons participate in or attend
      Personal information of any person offering to be employed by us or any of our Group Companies
      • Basic information on such offering persons including without limitation their names, contact details (such as email addresses and telephone numbers), addresses, headshots
      • Information on wages including without limitation salaries and/or bonuses
      • Information on personnel matters including without limitation qualifications, licenses, skills, and/or academic or job histories
      • Information on family matters including without limitation family members to provide for
      • Information on employment examinations such as CAT test, results of job interviews, and/or other related matters
      • Other information stated in resumes or curriculum vitaes
      Personal information of employees and former employees of us and our Group Companies
      • Basic information on employees themselves including without limitation their department names, company names, titles, names, contact details (such as email addresses and telephone numbers), addresses, employee numbers, headshots
      • Information on attendance records, operation records of supplied PCs and/or mobile phones, records of internal network usage, office access records
      • Information on personnel matters including without limitation qualifications, licenses, skills, academic or job histories, in-house transfer histories, employee evaluations, and/or awards and disciplines
      • Information on salaries, bonuses, severance payments, corporate pensions, and/or other related matters
      • Information on the usage of welfare services and/or other related matters
      • Information on health check results and/or other related matters
      • Information on names, addresses, contact details (such as email addresses and telephone numbers), dependency relations, health conditions, and other matters with respect to family members of the employees or the former employees
      • Any other information we collect and retain in relation to personnel affairs or corporate operations
      Personal information of any of our inquirers
      • Information provided to us when you fill out our inquiry form, including without limitation, names and contact details (such as email addresses and telephone numbers)
  • (4) Purpose of Use
    • Type of information Purpose of use
      Personal information in relation to any of our clients;
      • The same purposes as those described in the above 3.(1) “Personal information in relation to our clients”.
      Personal information in relation to any of our business partners;
      • The same purposes as those described in the above 3.(2) “Personal information in relation to our business partners”.
      Personal information of any person participating in or attending seminars or events that we hold or join
      • The same purposes as those described in the above 3.(3) “Personal information of persons participating in or attending seminars or events that we hold or join”.
      Personal information of any person offering to be employed by us or any of our Group Companies
      • The same purposes as those described in the above 3.(4) “Personal information of persons offering to be employed by us or any of our Group Companies”.
      Personal information of an employee or former employee of us or any of our Group Companies
      • The same purposes as those described in the above 3.(5) “Personal information of employees and former employees of us and our Group Companies”.
      Personal information of any of our inquirers
      • The same purposes as those described in the above 3.(7) “Personal information of our inquirers”.
  • (5) How we collect
    • Type of information How we collect
      Personal information in relation to any of our clients;
      • We may collect such personal information, which is stated in a written or electronic document given by such client, is communicated orally by the client, and/or is obtained from a third party based on the consent of the person identifiable by such personal information.
      Personal information in relation to any of our business partners;
      • We may collect such personal information, which is stated in a written or electronic document given by such business partner, is communicated orally by the business partner, and/or is obtained from a third party based on the consent of the person identifiable by such personal information.
      Personal information of any person participating in or attending seminars or events that we hold or join
      • We may collect such personal information, which is stated in a written or electronic document given by such participant or attendee, is communicated orally by the participant or attendee, and/or is obtained from a third party based on the consent of the participant or attendee.
      Personal information of any person offering to be employed by us or any of our Group Companies
      • We may collect such personal information, which is stated in a written or electronic document given by such person, is communicated orally by the person, and/or is obtained from a third party based on the consent of the person.
      Personal information of an employee or former employee of us or any of our Group Companies
      • We may collect such personal information, which is stated in a written or electronic document given by such employee or former employee, is communicated orally by the employee or former employee, and/or is obtained from a third party based on the consent of the employee or former employee.
      Personal information of any of our inquirers
      • We may collect such personal information stated in a written or electronic document given by the inquirer.

8. Your Choice to Provide Personal Information

You may choose not to provide personal information to us, However, if you do not provide personal information when requested, we may be hindered from providing our services or handling your inquiries or accepting an offer to do business with us.

9. Changes to this Privacy Policy

We will review the management of personal information from time to time, and make continuous efforts for improvement thereof, and may revise this Privacy Policy if necessary. After this Privacy Policy is revised, it will be notified on our website or by other means.

10. Personal Information Enquiries Desk

The below “Personal Information Enquiries and Complaints Desk” will handle your request relating to your personal information in our possession, such as a request for notification of the purpose of use, disclosure, correction/addition/deletion, suspension of use, erasure, and suspension of provision to third parties.

Personal Information Enquiries and Complaints Desk
Please contact here:

Our Website

Use of Cookie, Web Beacon, or Other Technologies

On our website, we may use cookies, web beacons, or other technologies to obtain usage status information and attribute information in order to enhance usability, deliver advertisements, and obtain statistical data. The obtained information will not contain any personal information. Please note that some of our services may not be available if you disable cookies, web beacons, or other technologies.

Use of Google Analytics

We use Google Analytics to know how users use our website. The privacy policy set out by Google Inc. will apply to our handling of personal information when using Google Analytics, in addition to this Privacy Policy. In such case, we will bear no liability for any damages or losses as to the usage of Google Analytics.

Links to other websites

Though this Privacy Policy applies to the personal information collected by means of our website, in no events we will be responsible for other websites linked from our website. Our SNS accounts will be subject to the related SNS’s privacy policy.

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