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Privacy Policy

SkyDrive Inc. (“SkyDrive”) and its subsidiaries (together with SkyDrive, “SkyDrive Group,” “we” or “our”), in light of the importance of protecting personal information in an advanced information and communications society, will strive to appropriately manage and protect personal information, through setting out this privacy policy (this “Policy”) in accordance with the “Act on the Protection of Personal Information of Japan (Act No. 57 of 2003; “Personal Information Protection Act”)” and other applicable laws, regulations and guidelines related to the protection of personal information (collectively, “Privacy Laws”).

Article 1 (Personal Information)

“Personal Information” in this Policy means personal related information as covered by the Privacy Laws; and therefore, it means information which can identify a specific living individual by name, date of birth or other description contained in such information; or which includes a code that can identify a specific individual.

Article 2 (Purpose of Use of Personal Information)

We may acquire and use Personal Information of SkyDrive Group’s customers, suppliers, SkyDrive Group’s and their directors, officers, employees and other members (collectively, the “Business Partners”) to the extent necessary for the following purposes. If we seek to use such Personal Information beyond the following purposes, we will obtain the prior written consent of the Business Partners whose Personal Information is concerned.

(1) To respond to inquiries and consultations to SkyDrive Group;
(2) To plan, research, develop, manufacture, sell, supply, manage, lease, or perform other actions concerning SkyDrive Group’s products and services;
(3) To advertise, publicize, and promote SkyDrive Group’s products and services;
(4) To accept for applications and/or offers for SkyDrive Group’s products and services, and provide such products and services to the Business Partners;
(5) To evaluate, implement, and perform contracts between SkyDrive Group and the Business Partners;
(6) To internally communicate within SkyDrive Group to the extent necessary for the other purposes herein;
(7) To communicate with and provide necessary information to the Business Partners in case of emergency or urgent;
(8) To carry out procedures related to SkyDrive Group’s shares/stocks and shareholders/stockholders, creditors, and other interest holders;
(9) To carry out recruitment activities and talent acquisitions for SkyDrive Group; and/or
(10) To carry out other business activities related to or incidental to the above items.

Article 3 (Management and Protection of Personal Information)

We will appropriately manage Personal Information as below and will not disclose or provide such Personal Information to any third parties without the prior written consent of such Business Partners whose Personal Information is concerned, except in case of emergency or urgent situations or in case of providing to third parties as required by the applicable laws and regulations. We will take necessary and appropriate measures for security of Personal Information against the risks such as Personal Information leaking to outside parties, unauthorized use of Personal Information, or computer viruses.

(1) We will strive to handle Personal Information appropriately in the day-to-day business by means of forming the organization/framework for the appropriate control of Personal Information, keeping SkyDrive Group’s directors, officers, employees, and other members informed about this Policy; and
(2) We designate a Personal Information protection management officer who controls protection and management of Personal Information, and we clarify that officer’s role.

Article 4 (Entrustment of Personal Information Handling)

We may entrust third-party subcontractors to handle Personal Information in whole or in part, to the extent necessary for the purposes mentioned herein. In such case, we will carefully examine their eligibility, obligate such third-party subcontractors to maintain confidentiality obligations by contract, and will conduct the necessary and appropriate supervision over such third-party subcontractors.

Article 5 (Joint Use of Personal Information)

SkyDrive Group entities may jointly use Personal Information acquired by any of SkyDrive Group entities, for the purposes mentioned in Article 2 (Purpose of Use of Personal Information), provided each of SkyDrive Group entities shall remain responsible for the security of the same. Such Personal Information may include, without limitation, Business Partners’ name, phone number, email address, affiliation, department, and job title (in the case of recruitment activities and talent acquisitions, this includes personal information such as address, skills, experience, education, and background).

Article 6 (Requests for Disclosure, Correcting, Disuse and Erasure)

When the Business Partners request SkyDrive Group to disclose, correct, disuse or erase Personal Information retained by SkyDrive Group, or lodges complaints with SkyDrive Group, SkyDrive Group will appropriately respond to such requests and complaints in accordance with the applicable laws, regulations and internal procedures set out by SkyDrive Group. Also, a data subject can withdraw its consent to the using of Personal Information at any time.

Article 7 (Procedures for Amending Privacy Policy)

We will review the content of this Policy from time to time and endeavor to improve this Policy. The content of this Policy can be amended unless otherwise stipulated in the applicable laws and regulations, and this Policy. The amended Policy will be valid when notified to the Business Partners or publicly announced in accordance with our procedures.

Article 8 (Compliance with Privacy Laws, Regulations, and Rules)

We will comply with the Privacy Laws and other applicable rules. Security measures for specific Personal Information are set out in separate SkyDrive Group’s internal rules titled the “Specific Personal Information Handling Rules.”

Article 9 (Security Measures)

As to Personal Information provided by the Business Partners to SkyDrive Group, we strive to protect them from unauthorized access, loss, destruction, falsification, leakage and other issues through organizational, physical, personal and technical measures such as restricting access to Personal Information files, recording access logs, and taking security measures to prevent unauthorized access from outside.

Article 10 (Address, Name of Representative and Personal Data Protection Officer)

The principal registered address of SkyDrive as a responsible entity for this Policy, the representative of SkyDrive, and the Personal Information protection management officer are as follows:

Address: 1-3-13, Hirakawacho, Chiyoda-ku, Tokyo 102-0093, Japan
Representative: Tomohiro Fukuzawa, Representative Director, SkyDrive Inc.
Personal Information Protection Management Officer: Tomohiro Fukuzawa, CEO, SkyDrive Inc.

Article 11 (Contact)

For inquiries concerning the handling of Personal Information at SkyDrive Group, please contact:

Contact: Personal Information Inquiry Desk, SkyDrive Inc.
Via Mail: 1-3-13, Hirakawacho, Chiyoda-ku, Tokyo 102-0093, Japan
Via E-mail: dataprivacy@skydrive.co.jp

Established on June 20, 2024
Effective on June 20, 2024