Privacy Policy

V3D Asia Inc. (hereinafter referred to as "the Company") recognizes the importance of protecting personal information and complies with the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"). We strive to handle and protect personal information appropriately in accordance with the following privacy policy (hereinafter referred to as "this Privacy Policy"). Unless otherwise specified in this Privacy Policy, the definitions of terms in this Privacy Policy shall be in accordance with the provisions of the Personal Information Protection Act.

1. Definition of Personal Information

In this Privacy Policy, personal information shall mean personal information as defined in Article 2, Paragraph 1 of the Personal Information Protection Act.

2. Purpose of Use of Personal Information

The Company will use personal information for the following purposes:

• To provide the businesses/services operated by the Company (hereinafter collectively referred to as "the Company's Businesses").
• To provide information and respond to inquiries regarding the Company's Businesses.
• To provide information on the Company's products, services, etc.
• To respond to acts that violate the Company's terms, policies, etc. (hereinafter referred to as "Terms, etc.") regarding the Company's Businesses.
• To notify of changes to the Terms, etc. regarding the Company's Businesses.
• To analyze information on the usage of the Company's Businesses by users to help improve the Company's Businesses, develop new businesses, etc.
• For employment management and internal procedures (regarding personal information of officers and employees), and for selection and contact in recruitment activities (regarding personal information of applicants).
• For shareholder management and procedures under the Companies Act and other laws and regulations (regarding personal information of shareholders, holders of share acquisition rights, etc.).
• To create statistical data processed into a form that cannot identify individuals in connection with the Company's Businesses.
• For other purposes incidental to the above purposes of use.

3. Changes to the Purpose of Use of Personal Information

The Company may change the purpose of use of personal information to the extent that it is reasonably recognized to be related, and if it is changed, the Company will notify or publicly announce it to the individual who is the subject of the personal information (hereinafter referred to as "the individual").

4. Use of Personal Information

4.1 The Company will not handle personal information beyond the scope necessary to achieve the purpose of use without obtaining the consent of the individual, except as permitted by the Personal Information Protection Act and other laws and regulations. However, this does not apply in the following cases:

• When based on laws and regulations.
• When it is necessary to protect a person's life, body, or property and it is difficult to obtain the consent of the individual.
• When it is particularly necessary for the improvement of public health or the promotion of the sound upbringing of children and it is difficult to obtain the consent of the individual.
• When it is necessary to cooperate with a national agency, a local government, or a person entrusted by them in executing the affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to hinder the execution of the said affairs.
• When providing personal data to an academic research institution, etc., and the said academic research institution, etc. needs to handle the said personal data for academic research purposes (including cases where part of the purpose of handling the said personal data is for academic research purposes, and excluding cases where there is a risk of unfairly infringing on the rights and interests of individuals).

4.2 The Company will not use personal information in a manner that is likely to encourage or induce illegal or unjust acts.

5. Proper Acquisition of Personal Information

5.1 The Company will acquire personal information properly and will not acquire it by deception or other wrongful means.

5.2 The Company will not acquire sensitive personal information (meaning what is defined in Article 2, Paragraph 3 of the Personal Information Protection Act) without obtaining the prior consent of the individual, except in the following cases:

• In cases falling under any of items 1 to 4 of Section 4.1.
• When acquiring sensitive personal information from an academic research institution, etc., and it is necessary to acquire the said sensitive personal information for academic research purposes (including cases where part of the purpose of acquiring the said sensitive personal information is for academic research purposes, and excluding cases where there is a risk of unfairly infringing on the rights and interests of individuals) (limited to cases where the said personal information handling business operator and the said academic research institution, etc. jointly conduct academic research).
• When the said sensitive personal information is made public by the individual, a national agency, a local government, an academic research institution, etc., a person listed in each item of Article 57, Paragraph 1 of the Personal Information Protection Act, or other persons specified by the rules of the Personal Information Protection Commission.
• When acquiring sensitive personal information that is obvious from its appearance by visually inspecting or photographing the individual.
• When receiving the provision of sensitive personal information from a third party, and the said provision by the said third party falls under any of the items of Section 8.1.

5.3 When receiving the provision of personal information from a third party, the Company will confirm the following matters as prescribed by the rules of the Personal Information Protection Commission. However, this excludes cases where the provision of the said personal information by the said third party falls under any of the items of Section 4.1 or any of the items of Section 8.1.

• The name and address of the said third party, and in the case of a corporation, the name of its representative (or, in the case of an unincorporated association with a representative or administrator, the name of its representative or administrator).
• The circumstances under which the said personal information was acquired by the said third party.

6. Security Management of Personal Information

The Company will provide necessary and appropriate supervision to its employees to ensure the security management of personal information against risks such as loss, destruction, falsification, and leakage of personal information. In addition, when the Company entrusts all or part of the handling of personal information, it will provide necessary and appropriate supervision to the entrusted party to ensure the security management of personal information. The specific details of the security management measures for the personal data held by the Company are as follows:

• Establishment of a basic policy
  To ensure the proper handling of personal data, this Privacy Policy is established as a basic policy regarding "compliance with relevant laws, regulations, guidelines, etc.," "contact point for questions and complaints," etc.
• Development of rules for handling personal data
  Establishment of rules for handling personal data at each stage of acquisition, use, storage, provision, deletion/disposal, etc., regarding the handling method, responsible person/person in charge, and their duties.
• Organizational security management measures
  • Establishment of a person responsible for the handling of personal data, clarification of the employees who handle personal data and the scope of personal data handled by such employees, and establishment of a system for reporting to the person in charge in the event of a fact or sign of violation of laws or handling rules.
  • Regular self-inspections of the handling status of personal data, as well as audits by other departments and external parties.
• Human security management measures
  • Regular training for employees on matters to be aware of regarding the handling of personal data.
  • Inclusion of matters concerning confidentiality of personal data in the rules of employment.
• Physical security management measures
  • In areas where personal data is handled, management of employee entry and exit and restrictions on equipment brought in, as well as measures to prevent unauthorized persons from viewing personal data.
  • Measures to prevent theft or loss of equipment, electronic media, and documents handling personal data, and measures to ensure that personal data is not easily identified when such equipment, electronic media, etc. are carried, including movement within the office.
• Technical security management measures
  • Implementation of access control to limit the scope of persons in charge and personal information databases, etc. handled.
  • Introduction of a mechanism to protect information systems handling personal data from unauthorized external access or fraudulent software.
• Understanding of the external environment
  Implementation of security management measures after understanding the system for the protection of personal information in country A where personal data is stored.

7. Reporting in Case of Leakage, etc.

In the event of a leakage, loss, or damage of personal information handled by the Company, if it is necessary to report to the Personal Information Protection Commission and notify the individual in accordance with the provisions of the Personal Information Protection Act, the Company will make such a report and notification.

8. Provision to Third Parties

8.1 The Company will not provide personal information to a third party without obtaining the prior consent of the individual, except in cases falling under any of the items of Section 4.1. However, the following cases do not fall under the provision to a third party as defined above:

• When providing personal information in connection with the entrustment of all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
• When personal information is provided in connection with the succession of business due to a merger or other reasons.
• When jointly used in accordance with the provisions of the Personal Information Protection Act.

8.2 Notwithstanding the provisions of Section 8.1, the Company will obtain the consent of the individual to the effect that it will provide personal information to a third party in a foreign country (excluding countries designated by the rules of the Personal Information Protection Commission based on Article 28 of the Personal Information Protection Act) (excluding persons who have established a system that complies with the standards specified by the rules of the Personal Information Protection Commission based on Article 28 of the Personal Information Protection Act) in advance, except in cases falling under any of the items of Section 4.1.

8.3 When obtaining the consent of the individual for the provision to a third party in a foreign country based on Section 8.2, the Company will provide the individual with information on the following matters. However, if the matter in item 1 cannot be specified, the Company will provide the fact that the matter in item 1 cannot be specified and the reason therefor, and if there is any information that should be helpful to the individual in place of the said matter, the said information will be provided in place of the matters in items 1 and 2.

• The name of the said foreign country.
• Information on the system for the protection of personal information in the said foreign country.
• Information on the measures taken by the said third party for the protection of personal information (if such information cannot be provided, the fact and the reason therefor).

8.4 When the Company provides personal information to a third party, it will create and store a record in accordance with Article 29 of the Personal Information Protection Act.

8.5 When the Company receives the provision of personal information from a third party, it will perform the necessary confirmation in accordance with Article 30 of the Personal Information Protection Act, and will create and store a record of the said confirmation.

8.6 If the Company is requested by a third party to whom it has provided personal information to submit a record certifying that it has obtained the consent of the individual regarding the provision of personal information to the third party and the use of the provided personal information, the Company may submit the said record to the said third party.

9. Disclosure of Personal Information, etc.

9.1 When the Company is requested by an individual to disclose personal information in accordance with the provisions of the Personal Information Protection Act, the Company will disclose it to the individual without delay after confirming that the request is from the individual himself/herself (if the said personal information does not exist, it will notify to that effect). However, this does not apply if the Company is not obligated to disclose it under the Personal Information Protection Act or other laws and regulations.

9.2 The provisions of the preceding paragraph shall apply mutatis mutandis to the record of provision to a third party created based on Section 8.4 and the record of provision from a third party created based on Section 8.5, which relate to personal information by which the individual is identified.

10. Correction, etc. of Personal Information

If an individual requests the correction, addition, or deletion (hereinafter referred to as "correction, etc.") of the content of personal information on the grounds that the personal information is not true, in accordance with the provisions of the Personal Information Protection Act, the Company will conduct the necessary investigation without delay within the scope necessary to achieve the purpose of use after confirming that the request is from the individual himself/herself, and based on the results, will make the correction, etc. of the content of the personal information and notify the individual to that effect (if a decision is made not to make the correction, etc., it will notify the individual to that effect). However, this does not apply if the Company is not obligated to make the correction, etc. under the Personal Information Protection Act or other laws and regulations.

11. Suspension of Use, etc. of Personal Information

If an individual requests the suspension of use or deletion (hereinafter referred to as "suspension of use, etc.") of his/her personal information in accordance with the provisions of the Personal Information Protection Act on the grounds that (1) the individual's personal information is being handled beyond the scope of the purpose of use published in advance, or is being used in a manner that is likely to encourage or induce illegal or unjust acts, or that the individual's personal information was acquired by deception or other wrongful means, (2) the personal information is being provided to a third party without the consent of the individual, or (3) the Company no longer needs to use the individual's personal information, a situation prescribed in the main text of Article 26, Paragraph 1 of the Personal Information Protection Act concerning the individual's personal information has occurred, or there is a risk that the rights or legitimate interests of the individual will be harmed by the handling of the individual's personal information, and it is found that there is a reason for the request, the Company will suspend the use, etc. or suspend the provision of the personal information without delay after confirming that the request is from the individual himself/herself and will notify the individual to that effect. However, this does not apply if the Company is not obligated to suspend the use, etc. or suspend the provision under the Personal Information Protection Act or other laws and regulations.

12. Provision of Personally-Referable Information to Third Parties

12.1 When it is assumed that a third party will acquire personally-referable information (meaning what is defined in Article 2, Paragraph 7 of the Personal Information Protection Act, and limited to what constitutes a personally-referable information database, etc. as defined in Article 16, Paragraph 7 of the said Act; the same shall apply hereinafter) as personal data, the Company will not provide the said personally-referable information to the said third party without first confirming the following matters as prescribed by the rules of the Personal Information Protection Commission, except in cases listed in each item of Section 4.1:

• That the consent of the individual has been obtained to the effect that the said third party is permitted to acquire the personally-referable information from the Company and acquire it as personal data by which the individual is identified.
• In the case of provision to a third party in a foreign country, that when trying to obtain the consent of the individual in the preceding item, the individual has been provided in advance with information on the system for the protection of personal information in the said foreign country, the measures taken by the said third party for the protection of personal information, and other information that should be helpful to the individual, as prescribed by the rules of the Personal Information Protection Commission.

12.2 When the Company provides personally-referable information to a third party, it will create and store a record in accordance with Article 31 of the Personal Information Protection Act.

12.3 When the Company receives the provision of personally-referable information from a third party, it will perform the necessary confirmation in accordance with Article 31 of the Personal Information Protection Act, and will create and store a record of the said confirmation.

13. Handling of Pseudonymously Processed Information

13.1 When the Company creates pseudonymously processed information (meaning what is defined in Article 2, Paragraph 5 of the Personal Information Protection Act, and limited to what constitutes a pseudonymously processed information database, etc. as defined in Article 16, Paragraph 5 of the said Act; the same shall apply hereinafter), it will process personal information in accordance with the standards specified by the rules of the Personal Information Protection Commission.

13.2 When the Company creates pseudonymously processed information, or acquires pseudonymously processed information and the deletion information, etc. related to the said pseudonymously processed information (meaning what is defined in Article 41, Paragraph 2 of the Personal Information Protection Act; the same shall apply hereinafter), it will take measures for the security management of the deletion information, etc. in accordance with the standards specified by the rules of the Personal Information Protection Commission as necessary to prevent the leakage of the deletion information, etc.

13.3 The Company will comply with the following provisions regarding pseudonymously processed information (limited to what is personal information; the same shall apply in this Section 13.3):

• Notwithstanding the provisions of Section 4.1, the Company will not handle pseudonymously processed information beyond the scope necessary to achieve the purpose of use, except in cases based on laws and regulations.
• Regarding the application of Section 3 to pseudonymously processed information, the phrase "change within a scope reasonably recognized to be related" in the said section shall be read as "change," and the phrase "notify or publicly announce" shall be read as "publicly announce."
• Notwithstanding the provisions of Sections 8.1 to 8.3, the Company will not provide personal data that is pseudonymously processed information to a third party, except in cases based on laws and regulations. However, cases listed in each item of Section 8.1 do not fall under the provision to a third party as defined above.
• When handling pseudonymously processed information, the Company will not collate the said pseudonymously processed information with other information to identify the individual related to the personal information used to create the said pseudonymously processed information.
• When handling pseudonymously processed information, the Company will not use the contact information and other information contained in the said pseudonymously processed information to make phone calls, send mail or letters, send telegrams, transmit by fax or electromagnetic means, or visit residences.
• The provisions of Sections 7 and 9 to 11 shall not apply to pseudonymously processed information.

13.4 The Company will comply with the following provisions regarding pseudonymously processed information (excluding what is personal information; the same shall apply in this Section 13.4):

• The Company will not provide pseudonymously processed information to a third party, except in cases based on laws and regulations. However, cases listed in each item of Section 8.1 do not fall under the provision to a third party as defined above.
• The Company will provide necessary and appropriate supervision to its employees to ensure the security management of pseudonymously processed information against risks such as leakage of pseudonymously processed information. In addition, when the Company entrusts all or part of the handling of pseudonymously processed information, it will provide necessary and appropriate supervision to the entrusted party to ensure the security management of pseudonymously processed information.
• When handling pseudonymously processed information, the Company will not acquire deletion information, etc. or collate the said pseudonymously processed information with other information to identify the individual related to the personal information used to create the said pseudonymously processed information.
• When handling pseudonymously processed information, the Company will not use the contact information and other information contained in the said pseudonymously processed information to make phone calls, send mail or letters, send telegrams, transmit by fax or electromagnetic means, or visit residences.

14. Handling of Anonymously Processed Information

14.1 When the Company creates anonymously processed information (meaning what is defined in Article 2, Paragraph 6 of the Personal Information Protection Act, and limited to what constitutes an anonymously processed information database, etc. as defined in Article 16, Paragraph 6 of the said Act; the same shall apply hereinafter), it will process personal information in accordance with the standards specified by the rules of the Personal Information Protection Commission.

14.2 When the Company creates anonymously processed information, it will take measures for security management in accordance with the standards specified by the rules of the Personal Information Protection Commission.

14.3 When the Company creates anonymously processed information, it will publicly announce the items of information concerning individuals contained in the said anonymously processed information as prescribed by the rules of the Personal Information Protection Commission.

14.4 When the Company provides anonymously processed information (including what it has created and what it has received from a third party; the same shall apply hereinafter unless otherwise specified) to a third party, it will publicly announce in advance the items of information concerning individuals contained in the anonymously processed information to be provided to the third party and the method of its provision, and will clearly indicate to the said third party that the information to be provided is anonymously processed information, as prescribed by the rules of the Personal Information Protection Commission.

14.5 When handling anonymously processed information, the Company will not (1) collate the anonymously processed information with other information, and (2) acquire descriptions, etc. or personal identification codes deleted from the said personal information, or information on the processing method performed in accordance with the provisions of Article 43, Paragraph 1 of the Personal Information Protection Act (item (2) only applies to the said anonymously processed information received from a third party) in order to identify the individual related to the personal information used to create the anonymously processed information.

14.6 The Company will take necessary and appropriate measures for the security management of anonymously processed information, handle complaints concerning the creation and other handling of anonymously processed information, and take other necessary measures to ensure the proper handling of anonymously processed information, and will endeavor to publicly announce the content of such measures.

15. Use of Cookies and Other Technologies

The Company's Businesses may use cookies and similar technologies. These technologies are useful for grasping the usage status of the Company's Businesses by the Company and contribute to the improvement of services. Users who wish to disable cookies can do so by changing their web browser settings. However, if cookies are disabled, some functions of the Company's Businesses may not be available.

16. Inquiries

For requests for disclosure, etc., opinions, questions, complaints, and other inquiries regarding the handling of personal information, please contact the following contact point:

17. Continuous Improvement

The Company will review the operational status of the handling of personal information as appropriate and strive for continuous improvement, and may change this Privacy Policy as necessary.