Personal Information Privacy Policy

With respect to the protection of all personal information handled by our company, we are fully aware of our social mission and comply with laws and regulations regarding the protection of individual rights and personal information. In addition, we hereby declare that we have established a personal information protection management system to implement the following policy, and that we will make efforts throughout our company to continuously improve the system while being aware of the latest trends in IT technology, changes in social demands and the business environment.

1) Personal information will be collected, used and disclosed only to the extent necessary for the Company’s legitimate business operations in the areas of marketing research and consulting, digital marketing, restaurant, and rental space businesses, and for the employment and management of the employees. We will not use personal information beyond what is necessary to achieve the specified purposes of use (use for purposes other than those specified). We will also take measures to ensure that personal information is not used for purposes other than those stated.

2) We will comply with laws, regulations, national guidelines, and other norms regarding the protection of personal information.

3) To prevent the risk of leakage, loss or damage of personal information, we will continuously improve our personal information security system by providing management resources that match the actual conditions of our business to prevent such risks through reasonable security measures. In addition, we will promptly take corrective measures if any problems are found in the protection of personal information.

4) Complaints and consultations regarding the handling of personal information will be handled in prompt, sincere, and appropriate manner.

5) The management system for the protection of personal information will be reviewed in a timely and appropriate manner to reflect changes in the environment in which the Company operates, and will be continuously improved.

Issued June 3, 2020
Last revised June 3, 2020
10 Inc.
Representative Director Takanori SATO

Contact for Inquiries

For inquiries regarding our privacy policy, please contact the following.
10 Corporation Personal Information Inquiry Desk
Space M B111, 1-30-15 Higashi-Nakano, Nakano-ku, Tokyo, 164-0003, Japan
TEL: +81 (0)90-2258-1010
Hours: 10:00-18:00
(Excluding Saturdays, Sundays, national holidays, year-end and New Year holidays, Golden Week, and summer vacation)

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Personal Information Disclosure Statement

Handling of Personal Information

Purpose of Use of Personal Information Handled by the Company
1) The purpose of using personal information obtained directly from the individual in writing (including information obtained through websites, e-mail, etc.): The Company will clearly disclose in writing to the individual the purpose for which the information will be collected prior to use.
2) Purpose of use of personal information obtained through methods other than those described in the previous paragraph:

CATEGORY	PURPOSE
Individual Customer Information	To Manage Usage History To Respond to Inquiries
Personal Information About the Business Partner’s Contact Person	To Confirm Order Details (e.g., correspondence records)
Personal Information Obtained from Customers in Connection with Outsourced Operations	To Properly Execute the Delegated Operation

Dissemination of Matters Concerning Retained Personal Data

With respect to retained personal data held by the Company or records of provision to a third party, the Company will respond to requests from the individual or the individual’s representative for notification of the purpose of use, disclosure, correction, addition or deletion, suspension of use, deletion, or suspension of provision to a third party (hereinafter referred to as “Request for Disclosure”) as follows.

a) Name of business

10inc.

b) Chief Privacy Officer

Name of the administrator: Takanori SATO
Title: Representative Director
Contact number: +81 (0)90-2258-1010

c) Purposes of use of all retained personal data

CATEGORY	Purpose of Use
Individual customer information	To properly conduct the business of marketing research and consulting services To provide user support To manage usage history To provide information on our services To respond to inquiries
Information about the contact person of the business partner	To confirm the content of orders for our services (e.g., correspondence records, etc.)
Information about our employees	To manage the human resources, work, health and safety of employees
Information about applicants who are seeking employment with our company	To contact job applicants and to manage the Company’s recruitment activities
Specific personal information	For the purposes specified in the My Number Act

d) Contact for complaints regarding the handling of retained personal data

10 Inc. Personal Information Inquiry Desk
Space M B111, 1-30-15 Higashi-Nakano, Nakano-ku, Tokyo, 164-0003, Japan
TEL: +81 (0)90-2258-1010
MAIL: info@10inc.co.jp
Hours: 10:00-18:00
(Excluding Saturdays, Sundays, national holidays, year-end and New Year holidays, Golden Week, and summer vacation)

e) Authorized personal information protection organization

Currently, we are not a member of any authorized personal information protection organization.

f) Procedures for responding to requests for disclosure and such of retained personal data or records provided to third parties

1) Contact for requests for disclosure
Requests for disclosure and such should be addressed to the Personal Information Inquiry Desk above.
* If you wish to request disclosure and such through electromagnetic procedures, please let us know.
   In principle, we will respond in accordance with your request.

2）Procedures for Requests for Disclosure
① After receiving your request, we will send you by mail the prescribed request form “Request Form for Disclosure of Retained Personal Data”.
② Please send the completed request form, or documents verifying the identity of the representative if such a request is made, and a postal money order for the fee (only for requests for notification of purpose of use or disclosure) to the Personal Information Inquiry Desk above.
③ After receiving the above request form, we will inquire about two pieces of personal information registered on file (e.g., telephone number and date of birth, etc.) to confirm your identity.
④ As a general rule, we will respond to you in writing (by sealed envelope).

3) Materials verifying the identity of the representative, if the request is made by a representative
If the person requesting disclosure and such is a representative, please enclose materials certifying that the person is a representative and materials verifying the representative’s identity. The permanent address and other such information contained in each document should be limited to the prefecture, and any personal information beyond that should be blacked out or otherwise edited. Please send us the documents that do not contain your individual number or black out all numbers.

① Documents verifying that the person is a representative
<In the case of a representative authorized to make a request for disclosure and such>
・Letter of attorney from the individual (original)
<If the representative is a legal representative of a minor> Copy of one of the following:
・Certificate of the family register
・Certificate of residence (showing the relationship between the minor and the representative)
・Other official documents that can verify the authority of legal representation
<If the legal representative of an adult ward> Copy of any of the following:
・Certificate of registered matters related to the guardianship registration and such
・Other official documents that can verify the authority of legal representation

② Documents proving the identity of the representative
・Driver’s license
・Passport
・Health insurance card (Please black out all symbols, numbers, etc. of the insured individual before submitting)
・Certificate of residence

4) Fee for requests for notification or disclosure of purpose of use
1,000 JPY per request
(If the request is made in writing, please enclose a postal money order with the request form to be sent. If the request is made by other means, we will consult with you at the time of your request)

g) Details of the system for handling retained personal data and the measures being taken

1) Formulating the Basic Policy
To ensure the proper handling of personal data in our possession, we have established a “Personal Information Protection Policy” regarding “compliance with relevant laws, regulations, guidelines, etc.,” and a “contact for questions and complaints.“

2) Establishment of Discipline in the Handling of Retained Personal Information
For each stage of acquisition, use, storage, provision, deletion or disposal, etc., we have established personal information protection regulations regarding the handling methods, responsible persons/persons in charge and their duties.

3) Organizational Security Control Measures
① In addition to appointing a person responsible for the handling of retained personal data, the Company will clarify the employee who will handle the retained personal data and the scope of the retained personal data that will be handled by such employee, and has established a system for reporting to and communicating with the person responsible in the event that a violation of the law or the handling of such information occurs or is suspected.
② In addition, the Company will conduct periodic self-inspections of the handling of retained personal data, and audits will be conducted by other departments and outside parties.

4) Personnel Security Control Measures
① Regular training shall be provided to employees on matters to be considered when handling retained personal data.
② All employees will be required to sign a confidentiality pledge, including personal data held by the Company.

5) Physical Security Control Measures
① In the area where retained personal data is handled, measures are taken to control the entry and exit of employees and restrict the equipment, etc. that they bring in, and to prevent unauthorized
persons from viewing retained personal data.
② Measures are taken to prevent theft or loss of equipment, electronic media, and documents, etc. that handle retained personal data, and measures are also taken to ensure that the retained personal data is not readily identifiable when such equipment, electronic media, etc. is carried, including during movement within the business premises.

6) Technical safety control measures
① Access control is implemented to limit the scope of persons in charge and the handling of personal information database and such.
② A mechanism is established to protect the information system that handles retained personal data from unauthorized external access or unauthorized software.