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ASSC Workers Voice (AWV) Privacy Policy

The Global Alliance for Sustainable Supply Chain (hereinafter referred to as “ASSC”, or “we”, “us”) hereby establishes the following policy (hereinafter referred to as this “Policy”) on the handling of personal information (which may be defined as “personal data” under applicable laws) of the corporation or other entity (hereinafter referred to as the “Corporation, etc.”) with which ASSC has entered into an agreement (hereinafter referred to as the “Agreement”) for the implementation by the Corporation, etc., of the service provided by ASSC, the ASSC Workers Voice (hereinafter referred to as the “AWV”), and of the users to whom the Corporation etc., has decided to make the AWV available for use (hereinafter referred to as the “User” or “you”).This Privacy Policy shall be written in Japanese as the official text and translated into other languages for reference purposes only.

This Privacy Policy shall be written in Japanese as the official text and translated into other languages for reference purposes only.

1. Compliance with Related Laws, Regulations, Guidelines, etc

ASSC will handle all personal information in a lawful and appropriate manner, in compliance with the Personal Information Protection Law and other related laws and regulations, the guidelines and other rules set forth by the Personal Information Protection Commission of Japan, the EU General Data Protection Regulation (GDPR), the personal information protection laws and other related applicable laws and regulations of each country, as well as this Policy.

2. Acquisition of Personal Information

When the User uses the AWV, for the consent provided by the User or performance of the Agreement with the Corporation, etc. as the legal basis, ASSC may be provided with the User’s personal information listed below. ASSC will acquire, record, store, or analyze the personal information provided by the User to ASSC to the extent necessary for its operations and within the scope of the purpose of use set forth in this Policy, by lawful and appropriate means. Please note that, if you do not provide us with your personal information, we may not be able to use the services provided by AWV.

  1. Information directly acquired from the User
    • Age and date of birth
    • Name
    • Email address
    • SNS account information
    • Telephone number
    • Information determined by ASSC to be acquired through the consultation form on its website, which may include special categories of personal data as provided by Article 9.1 of GDPR, personal data relating to criminal convictions and offences as provided by Article 10 of GDPR, and sensitive personal information as defined under the laws of various countries
    • Other information on the User as specified by ASSC
  2. Device information
    • Terminal identifier, mobile device identifier, and IP address of a terminal or a mobile device on which the User uses the AWV
    • Any other information that is linked to the device by the User, such as the name, type of the device used, telephone number, country, and username, or which the User has chosen to provide, including email address
  3. Information on location
    • Information on the current location of the User, if the User uses the AWV on a terminal or a mobile device, and has consented to provide its location information therein
  4. Information on User actions
    • Information provided directly from the User to ASSC while using the AWV
    • Information provided through a third party providing the AWV (hereinafter referred to as the “Service Provider”)
    • Information on the User’s usage status of the AWV and interactions with other users
  5. Information pertaining to communications
    • If the User uses the AWV in its communication with other users and takes part in certain activities involving sharing of information (including texts, user profiles, messages, photographs, images, audio, video, applications and other information content) with other users, the archives of information pertaining to such communications
  6. Information acquired through cookies
    • The following specific technical information provided while accessing the AWV
    • Information stored in logfiles and tracking technology “cookies” used by ASSC (or the Service Provider acting on behalf of ASSC), IP address, type of the device used, mobile device identifier, browser type and language used, referring and exit page, type of platform used, number of clicks, domain name, landing page, number of browsed pages and browsing order, URL of accessed pages, browsing time for specific pages or website status on specific pages, date and time of activity on the website, and other usage information (ASSC uses the aforementioned information for internal purposes, and may associate such information with the User. Additionally, ASSC may use a web beacon to learn whether a specific page has been browsed or whether an email has been opened, as well as other technologies, including tracking pixels, that enable ASSC to provide advertisements for the User on other websites, making advertisements more effective.)
  7. Information acquired through linkage with external services
    • Information that is authorized by the User to be disclosed to the linked service through the privacy settings of the external service

3. Purpose of Use of Personal Information

ASSC will use the personal information provided by the User in connection with the provision of the AWV service, or within the scope of the following purposes of use or other purposes of use that are apparent from the circumstances under which such information has been acquired, for the consent provided by the User or performance of the Agreement with the Corporation, etc. as the legal basis. ASSC will not use any such information beyond the said purpose of use except with the consent of the User or as otherwise provided in the Terms of Use, etc., or permitted by laws and regulations.

  1. Purpose of use of personal information of the User working in the factories, stores, offices, and other similar facilities
    • Conducting surveys, studies, and analyses of the working environment in the workplace
    • Collecting information on the working environment in the workplace
    • Ensuring safety at the workplace
    • Providing results of the information analyses
    • Providing advice on employees' behavior
    • Enabling appropriate and smooth communication with the User
    • Contributing to magazines, websites, and other advertising media
  2. Purpose of use of personal information relating to the organization to which the User belongs, its business partners (hereinafter collectively referred to as the "Business Partner") and other companies in the same industry as the Business Partner
    • Conducting surveys, studies, and analyses of the working environment in the workplace of the User
    • Collecting information on the working environment in the workplace of the User
    • Ensuring safety at the workplace of the User
    • Providing results of the information analyses
    • Providing advice on the Business Partner’s behavior
    • Notifications and reporting to government agencies and affiliated organizations
    • Enabling appropriate and smooth communication
    • Contributing to magazines, websites, and other advertising media
  3. Purpose of use of registered information and personal information (hereinafter referred to as the "Registered Information, etc.")
    • Operating the AWV (including providing any information from ASSC to the Corporation, etc., and the User)
    • Providing information on ASSC’s services, including the AWV, or on the products, services, etc., of advertisers or partner companies, which ASSC determines to be beneficial to the Corporation, etc., or the User
    • Conducting questionnaire surveys and analyses of the results from such surveys to ensure quality control of the AWV
    • Sending notices to the User regarding matters that significantly affect the operation of the AWV (including, but not limited to, material changes to the content of the AWV and temporary suspension of the AWV service)
    • Contacting the User to request its consent for the handling of the Registered Information, etc.

4. Outsourcing

ASSC may outsource the handling of personal information, in whole or in part, to its subcontractor(s) for the consent provided by the User or performance of the Agreement with the Corporation, etc. as the legal basis. In such cases, however, the personal information outsourced will be limited to the minimum extent necessary for such subcontractor(s) to carry out the outsourced work. In addition, there may be cases where personal information will be outsourced or provided to overseas subcontractor(s).

5. Provision of Personal information to Third Parties

ASSC will not provide personal information to third parties (excluding subcontractor(s)), except with the prior consent of the User, or as permitted by applicable laws and regulations, or where the consent of the User is not required under applicable laws and regulations; provided, however, the Corporation, etc., and the User hereby agree that ASSC discloses the Registered Information, etc., to third parties in the following cases.

  1. When it is necessary to aggregate, analyze, etc., the Registered Information, etc., for the purpose of improving the AWV or other related services or developing related business
  2. When disclosing or providing to third parties the information obtained through the aggregation, analysis, etc., referred to in the preceding item in a personally unidentifiable manner
  3. When consent of the User to whom the Registered Information, etc., pertains has been obtained for the disclosure or use thereof
  4. When it is determined that the disclosure or use of the Registered Information, etc., is necessary to provide the services desired by the Corporation, etc., or the User
  5. When the Registered Information, etc., is required by a partner company or other relevant third party for the purpose of providing the services desired by the Corporation, etc., or the User (provided that such partner company or other relevant third party may not use the Registered Information, etc., provided by ASSC beyond the scope necessary for the provision of such services)
  6. When required by laws and regulations
  7. When it is necessary to protect the life, body or property of ASSC, the Corporation, etc., the User or any other third party, or to protect any and all services provided by ASSC
  8. When it is particularly necessary for the improvement of public health or the promotion of the sound growth of children
  9. When required to cooperate with a national institution, a local public body, or an individual or entity entrusted by either a national institution or local public body to carry out the affairs prescribed by laws and regulations, and disclosure is duly requested by either of them

6. Data Transfer

If personal information has been acquired in a country other than Japan, ASSC may transfer such data from such country to its offices in Japan, after obtaining required approvals and taking other necessary measures in accordance with laws and regulations, the legal basis of which is the consent provided by the User or the performance of the Agreement with the Corporation, etc.

7. Expected Recipients in relation to Articles 4, 5 and 6

To achieve the desired objectives under Articles 4, 5 and 6 above, it may be necessary to disclose your personal information to the following recipients in certain cases. This includes:

  1. the transmission of personal information to the internet platforms engaged by us when you use our online system
  2. disclose and transfer customer and consumer personal information to third parties, including to our contractors or service providers who provide services which are integrated into our Products or perform functions on our behalf; and

personal information may be disclosed by being transferred, disseminated, or provided by other means to:

Recipient
Location
Basis for transfer to third party county
1
ASSC
Japan
Adequacy decision
2
Lawyers, law firms, and partners affiliated with One Asia Lawyers Group
The location of each entity of One Asia Lawyers Group described in the following website: https://oneasia.legal/en/
Consent

8. Management of Personal information

  1. Ensuring the accuracy of data content

    ASSC will, for the consent provided by the User or performance of the Agreement with the Corporation, etc. as the legal basis, keep personal information accurate and up-to-date to the extent necessary to achieve the purposes of use, and to delete the relevant personal information when the purpose of the consent provided by the User or the Agreement with the Corporation, etc. has been fully performed and the usage is no longer necessary.

  2. Security management measures

    ASSC will take necessary and appropriate measures to prevent leakage, loss, or damage of personal information and for other security management purposes, as follows. For details on the safety management measures taken by ASSC, please contact the "Contact Point for Inquiries, etc., and Complaints" specified in Article 13.

    1. Although the Internet environment can never be 100% secure, ASSC will endeavor to ensure the security of personal information sent to it by the User. In order to ensure the security of personal information provided to ASSC by the User, ASSC applies the following measures: (i) prevention of unnecessary access to personal information by clarifying the equipment used to handle personal information as well as the employees handling such equipment; (ii) identification and authentication of employees with access to information systems used to handle personal information databases, etc., using the standard user control features (User Account Control) of the equipment; (iii) keeping the operating system of the equipment, etc., used to handle personal information up-to-date; (iv) installing security software or other security measures on the equipment, etc., used to handle personal information, and keeping them up-to-date using automatic updates or other means; and (v) password protection for files containing personal information, when sending such files via email or other similar means.
    2. In the event that ASSC's physical, technical or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of personal information, causing damage to the legitimate rights and interests of the User, ASSC will assume legal liability in accordance with applicable laws and regulations.
    3. In the event of leakage, loss or damage of personal information data (hereinafter referred to as the “Personal Information Security Incident”), ASSC will, in accordance with applicable laws and regulations, inform the User without delay to whom such personal information data pertains, of the general status of the Personal Information Security Incident and potential impacts thereof, response measures that have already been taken or will be taken in the future by ASSC, suggestions of preventive measures that can be voluntarily applied by the User to minimize risks, and remedial measures or other corrective actions for the User. ASSC will also notify without delay such User of any situations related to the Personal Information Security Incident via email, written notice, telephone, or other means of communication. When it is difficult to notify each User on an individual basis, ASSC may release announcements using reasonable and effective methods. In addition, ASSC will report the status of its response to the Personal Information Security Incident to the relevant authorities as required by applicable laws and regulations or government authorities.
  3. Supervision of employees

    When allowing its employees to handle personal information, ASSC will provide the employees with proper training, implement necessary and appropriate supervision of the employees, ensuring that they are thoroughly aware of the proper handling of personal information.

  4. Supervision of subcontractor(s)

    When ASSC outsources the handling of personal information, ASSC will select as its subcontractor(s) a partner company that has in place the appropriate security management measures, and will implement necessary and appropriate supervision of such subcontractor(s).

  5. As a general rule, ASSC will collect, store, and create backups of personal information of the User in Japan, even if the User is located outside of Japan.

9. Request for Disclosure, etc.

Regarding personal information retained by ASSC, ASSC will, as set forth below, respond to the request for notification of purpose of use, disclosure of the retained personal information or records of provision to third parties, correction, addition, or deletion of the content, suspension of use, and suspension of provision to third parties (hereinafter referred to as the “Request for Disclosure, etc.”).

  1. If a request has been made by the User or its agent for notification of purpose of use of the retained personal information, or disclosure of the retained personal information or records of provision to third parties, ASSC will respond to such request without delay, except in cases where ASSC is not required to do so under applicable laws and regulations. Such cases may include, but are not limited to, the following (provided that even in any of the following cases, disclosure will be made if required by applicable laws and regulations):
    1. When disclosure is likely to harm the life, body, property, or other rights or interests of the User or a third party
    2. When disclosure is likely to harm the rights or legitimate interests of ASSC
    3. When disclosure is likely to seriously impede the proper execution of the business of ASSC
    4. When disclosure violates laws and regulations
    5. When it cannot be confirmed that the request for disclosure is from the User
  2. If a request has been made by the User or its agent for correction, addition, or deletion of the content of retained personal information, ASSC will undertake investigations without delay, and based on the results thereof, make the correction, addition, or deletion of the content of retained personal information to the extent permitted by the Personal Information Protection Law and other applicable laws and regulations.
  3. If a request has been made by the User or its agent for suspension of use, restriction of processing, or suspension of provision to third parties of the retained personal information, and ASSC finds grounds for such request, ASSC will respond to such request appropriately in accordance with the Personal Information Protection Law and other applicable laws and regulations.
  4. If the User or its agent requests the retained personal information to be transmitted to it in a structured, commonly used or machine-readable format, ASSC will respond to such request appropriately. Further, the User or its agent has the right to transfer such data to another administrator without hindrance from ASSC.
  5. To make a request regarding personal information retained by ASSC as described in each section of this Article, please contact the "Contact Point for Inquiries, etc., and Complaints" specified in Article 13. ASSC will internally share the content of the request and respond accordingly. The personal information provided to ASSC will be kept in a secure manner, and will be used for the purpose of responding to the request of the User. Please note that the request form and all attachments thereto, including copies of personal identification documents submitted, will not be returned.

10. Handling of Anonymously Processed Information

ASSC may, to the extent permitted by applicable laws and regulations, acquire anonymously processed information processed by an appropriate method under the relevant laws and regulations, etc., so as neither to be able to identify a specific individual nor to be able to restore the personal information of that individual. ASSC may utilize such information for analysis, interpretation, investigation, etc., and to the extent necessary for its business operations, continuously provide it to third parties with clear indication that the information is anonymously processed information. In addition, the items of personal information included in the anonymously processed information provided to third parties and the method of providing anonymously processed information are as follows.

  1. Anonymously processed information to be created
    • Information such as sex and age
    • Information on the content of the consultation
  2. Anonymously processed information to be provided to third parties
    1. Items of personal information
      • Information such as sex and age
      • Information on the content of the consultation
    2. Method of providing anonymously processed information
      • Upload to a server with appropriate access control, transmission via email, or provision via external storage media such as USB memory sticks

11. Retention Period of Personal information

ASSC will retain the personal information of the User until the purpose of the consent provided by the User or the Agreement with the Corporation, etc. is fully performed for the consent provided by the User or performance of the Agreement as the legal basis. Further, personal information that is no longer necessary will be deleted or erased without the prior or subsequent consent of the User. ASSC may, for ASSC’s legitimate interest as the legal basis, retain certain User’ personal information as necessary for security and fraud prevention purposes.

12. Rights of User

GDPR and other applicable data protection laws protect certain rights for the User, as data subjects. In particular:

  1. Right of Access

    Right to obtain confirmation of which of your personal information is processed and information about it, for instance, which are the purposes of the processing, what are the conservation periods, among others.

  2. Right to Erasure or "right to be forgotten"

    Right to erase your personal information, provided that there are no valid grounds for its retention, for example in cases where we have to keep the personal information to comply with legal obligation or because a court case is in progress.

  3. Right to Data Portability

    Right to receive the personal information you have provided us in a digital format of current use and automated reading or to request the direct transmission of your personal information to another entity that becomes the new responsible for your personal information, however only if technically possible.

  4. Right of Rectification

    Right to request modification of your personal information that is inaccurate or request incomplete personal information, such as the address, email, telephone contacts, or others.

  5. Right to object and Automated Decision-Making (ADM)

    When the processing of personal information, including the processing for the definition of profiles, is exclusively automated (without human intervention) and may have effects in your legal sphere or significantly affect it, you shall have the right not to remain subject to any decision based on such automated processing, except as otherwise provided by law and shall have the right that we take appropriate measures to safeguard its rights and freedoms and legitimate interests, including the right to have human intervention in decision making by us, the right to express its point of view or contest the decision taken on the basis of automated individual information processing.

  6. Right to Withdraw Consent or Right of Opposition

    Right to object or withdraw consent at any time to processing, for example in the case of processing for marketing purposes, provided that no legitimate Interests exist prevailing over your interests, rights and freedoms, such as defending a right in a judicial process.

  7. Right of Limitation

    Right to request the limitation of the processing of your personal information, in the form of: (i) suspension of processing or (ii) limitation of the scope of processing to certain categories of personal information or purposes of processing.

  8. Right to complain

    Right to complain to the supervisory authority, in addition to us.

The period for handling a request is 30 days unless it is a particularly complex request.
Once the retention period expires, personal information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

13. Processing data related to children

ASSC may collect personal information of individuals defined or treated as children under applicable law (for example, under the age of 16 under the GDPR) and is committed to protecting the privacy of children who use our services. ASSC does not knowingly collect personal data from children under this age without obtaining verifiable parental consent or the children, in case obtaining verifiable parental consent is difficult.

If we become aware that we have inadvertently collected personal data from a child under the age of 16 without parental consent or himself/herself in case obtaining verifiable parental consent is difficult, we will take immediate steps to delete that information. If you believe that we might have any information from or about a child under 16 invalidly, please contact us at Contact Point provided below.

Parents or guardians of the children may withdraw consent at any time by contacting us at Contact Point　provided below. Upon withdrawal of consent, we will cease to process the child’s personal information unless we have a legitimate legal basis to continue processing it.

14. Processing criminal history information

ASSC is committed to protecting the privacy of individuals whose criminal history information we process.

 

We may collect the following types of criminal history information:

  1. details of criminal convictions
  2. details of criminal offenses
  3. information related to criminal investigations
  4. information related to legal proceedings

 

The criminal history information collected is used for the purposes provided in the provision 3 of this Policy and the following:

  1. to protect the safety and security of organizations of our clients and stakeholders
  2. to conduct risk assessments and due diligence

 

We process criminal history information based on the following legal grounds:

  • Consent: We obtain explicit consent from individuals before processing their criminal history information.
  • Legal Obligation: We process criminal history information to comply with legal and regulatory requirements.
  • Legitimate Interests: We process criminal history information to protect legitimate interests of our clients, such as ensuring the safety and security of organizations of our clients.

 

We implement appropriate technical and organizational measures, including access controls, etc., to protect criminal history information from unauthorized access, disclosure, alteration, or destruction.

 

We retain criminal history information only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Once the information is no longer needed, we will securely delete or anonymize it.

15. Contact Point for Inquiries, etc., and Complaints

The Global Alliance for Sustainable Supply Chain ASSC WORKERS VOICE (AWV) Secretariat

Estage Osaki Building 6F, 3-5-2 Osaki, Shinagawa-ku, Tokyo 141-0032, Japan
Tel: 050-6875-4342 (main)
Phone hours: 9:00 to 17:00
(excluding Saturdays, Sundays, national holidays and company holidays)
E-mail: AWV_Office@g-assc.org

We will normally respond within 30 days of receiving an inquiry or complaint. If we are unable to respond within 30 days, we will advise you of the expected timeframe for the response.

16. Revision of Privacy Policy

ASSC will review this Policy from time to time, and may make changes as necessary. Any changes made will be posted on ASSC’s website. In such case, the revised version of this Policy will take effect on the date on which it is posted, or on the effective date to be separately specified on its website. For material changes, ASSC will additionally provide a more prominent notice. Material changes referred to herein include, but are not limited to, the following:

  1. Material change in the purpose or method of use of personal information
  2. Material change in the ownership structure of personal information, organizational structure or other aspects, such as change of ownership of personal information due to business adjustment, bankruptcy or merger and acquisition, etc.
  3. Change in the party with or to whom the personal information are shared, transferred or disclosed
  4. Material change in the right to process the User’s personal information or in the way of exercising such right

17. Governing Law

In the event that the definition or interpretation of terms used in this Privacy Policy differs depending on the applicable laws and regulations, the definition and interpretation under the laws and regulations applicable to the relevant personal information shall prevail.

Enacted July 3rd, 2020
Revised May 15th, 2024
Revised March 27th, 2025

ASSC Workers Voice(AWV) Terms of Use


These Terms of Use (hereinafter referred to as these “Terms”) set forth the terms and conditions for the use of the service provided by the Global Alliance for Sustainable Supply Chain (hereinafter referred to as "ASSC"), the ASSC Workers Voice (hereinafter referred to as the “AWV”), between ASSC and the corporation or other entity (hereinafter referred to as the “Corporation, etc.”) with which ASSC has entered into an agreement (hereinafter referred to as the “Agreement”) for the implementation by the Corporation, etc., of the AWV, and between ASSC and the users to whom the Corporation, etc., has decided to make the AWV available for use (hereinafter referred to as the “User”).


Article 1 (Consent to these Terms)

１．The Corporation, etc., and the User shall use the AWV in accordance with these Terms and other terms and conditions separately set forth by ASSC, including the ASSC Workers Voice (AWV)

Privacy Policy.

２．If the User is a minor, the consent of a person with parental authority or other statutory agent (including their consent to these Terms) is required prior to using the AWV. If the User who was

a minor at the time of consenting to these Terms uses the AWV after reaching the age of majority, the User is deemed to have ratified its use of the AWV during the period the User was a minor.

３．In regard to the AWV for which individual terms of use are stipulated, such individual terms of use shall apply to the use of the AWV in addition to these Terms.

４．If the use of the AWV is subject to the laws and regulations of a country other than Japan, the Corporation, etc., and the User shall comply with any such applicable laws and regulations.


Article 2 (Modifications to these Terms)

１．ASSC may modify these Terms at any time if it determines that such modifications are not contrary to the purpose for which it has concluded the Agreement and are reasonable in light of

the necessity of the modifications, appropriateness of the content after the modifications, existence or details of the modified provisions, and other circumstances pertaining to the modifications.

２．The modified version of these Terms shall take effect at the time it is posted on appropriate section of the AWV or the website operated by ASSC, or on the effective date to be separately

specified in such posting. By continuing to use the AWV following any modifications to these Terms, the User is deemed to have validly and irrevocably agreed to the modifications to these Terms, even if such modifications do not conform to the general interest of the User. When using the AWV, the User shall refer to the most current version of these Terms, as needed.

３．If the Corporation, etc., enters into an agreement with ASSC separate from these Terms, such agreement shall take precedence over these Terms in relation to the Corporation, etc., and the

Users. In such case, the Corporation, etc., shall ensure that the User is aware of the content of such agreement.


Article 3 (AWV Overview)

In addition to the services provided by ASSC under the name of AWV as specified in these Terms, ASSC provides the following services through the AWV, as separately agreed between ASSC and the Corporation, etc., or the User: consultation for inquiries from the User; suggestions for improvement of the User’s workplace, sharing of issues related to the User’s workplace, and on-site investigation in the User’s workplace; providing reports and proposing response measures to the Corporation, etc.; construction and analysis of database; whistleblowing; requesting an attorney or other qualified person deemed necessary by ASSC; assistance and aid for the Corporation, etc., or the User; and other services separately designated by ASSC. The Corporation, etc., or a third party deemed necessary by ASSC may cooperate with ASSC in performing the aforementioned services. The Corporation, etc., and the User may use the AWV in accordance with these Terms and other terms and conditions separately agreed upon with ASSC. In addition, all communication costs necessary for receiving emails, browsing websites, etc., on information communication devices (including, but not limited to, mobile phones), incurred in connection with the use of the AWV shall be borne by the Corporation, etc., or the User. ASSC may outsource the operation of the AWV to its subcontractor(s).


Article 4 (Provision of the AWV)

  1. ASSC may provide all or part of the AWV only to eligible Users who have satisfied certain conditions deemed necessary by ASSC, including whether the Corporation, etc., or the User has provided all the necessary information (hereinafter referred to as the “Registered Information”).

  2. Prior to using the AWV, the Corporation, etc., and the User shall confirm the conditions set forth by ASSC, including, but not limited to, those pertaining to the name and content of the AWV, age and usage environment, and shall use the AWV in accordance with such conditions and within the scope specified by ASSC.

  3. ASSC may, without prior notice or demand to the User and for any reason, set or change the name, scope of use, etc., of the AWV. Further, ASSC may implement any other necessary measures, including setting, adding to, deleting, changing the content of, suspending, or discontinuing all or part of the AWV’s functions.

  4. In order to contribute to the prevention of human rights violations and promote respect for human rights, including early detection and improvement of labor rights issues across the supply chain, ASSC may publish on the website it operates any information available on the AWV, such as the content of consultations provided via the AWV and other case-related information (including,

    but not limited to, those pertaining to the Corporation, etc., or the User), and use all such information freely to the extent it deems necessary, while considering the anonymity of the User. The Corporation, etc., may, in the same manner as ASSC, publish such case-related information on the website it operates, considering the anonymity of the User. In addition, by using the AWV, the Corporation, etc., and the User are deemed to have agreed to the terms of this section.

  5. The User shall agree that ASSC may retain information on the content of consultations from the User for a reasonable period, for backup, archival or audit purposes, and that ASSC retains archival copies of the User’s records as required by law, or for legitimate business purposes.


Article 5 (Registered Information and Personal Information)

ASSC shall handle the Registered Information and personal information in accordance with these Terms and the Privacy Policy separately established by ASSC.


Article 6 (Suspension of Use, etc.)

  1. If the User falls under, or if ASSC determines that the User is likely to fall under, any of the following items, ASSC may, at its own discretion and without prior notice or demand to the Corporation, etc., or the User, and without consent from the Corporation, etc., or the User, suspend the use of all or part of the AWV, or take other measures as ASSC determines appropriate against the Corporation, etc., or the User (hereinafter referred to as the "Temporary Suspension, etc."). In the event of the Temporary Suspension, etc., ASSC shall promptly notify the User subjected to the Temporary Suspension, etc.; provided, however, if ASSC determines that the registered email address of the User is not active, such notice shall be deemed to have been given to the User by taking measures such as suspension of use:

    1. The User has violated these Terms;

    2. The User has violated the laws and regulations of Japan, or the laws and regulations of another country or region where the User is located at the time of use of the AWV;

    3. The Registered Information is found to be false or erroneous;

    4. ASSC determines that the registered email address is not active;

    5. The User has resigned from or left a company that the Corporation, etc., outsources its services;

    6. The death of the User; or

    7. ASSC determines that the User is not appropriate as a user of the AWV.

  2. In the event ASSC suffers any damage due to any of the cases referred to in the preceding section, the Corporation, etc., shall, on behalf of the User, compensate ASSC for such damage arising out of the acts of the User, and the User shall directly compensate ASSC for such damage arising out of its own acts.

  3. ASSC shall have no obligation to disclose to the User the reason for taking the measures described in section 1 of this Article.


Article 7 (Intellectual Property Rights, etc.)

  1. All copyrights (including the rights stipulated in Articles 27 and 28 of the Copyright Act), and other intellectual property rights, rights of likeness, publicity rights and other personal rights, and property rights and other proprietary rights in and to the text, images, videos, programs, and other information comprising the AWV, shall belong to ASSC.

  2. ASSC may, and the Corporation, etc., and the User agree that ASSC may, store and accumulate all information (including, but not limited to, text and images) posted, uploaded, or stored through the AWV by the User, and use such information in any manner, including translation, for the purpose of smooth operation and improvement of the AWV, or advertising and publicizing ASSC and the AWV (including, but not limited to, using such information in introductory articles or content for publication in third-party media).

  3. Either the Corporation, etc., or the User agrees not to exercise its moral rights of author against ASSC or any party that has succeeded to or been granted the rights of ASSC.

  4. In the event of any infringement of third-party rights or other similar issues arising in connection with any work created by the Corporation, etc., or the User, either the Corporation, etc., or the User shall undertake to resolve such issues at its own cost and responsibility, and not to cause any trouble or damage to ASSC.


Article 8 (Prohibited Acts)

  1. The User shall not engage in any of the following acts:

    1. An act of making false statements;

    2. An act of interfering with the operation of the AWV;

    3. An act of slandering, defaming or infringing the rights of other users, ASSC or any third party; or

    4. Any other acts that ASSC deems inappropriate.

  2. In the event the User engages in any of the prohibited acts listed in the preceding section, ASSC is entitled to seek compensation from the User for any damage (including reasonable attorney's fees) it incurs as a result thereof.


Article 9 (Suspension, Discontinuation, or Termination of the AWV)

  1. In case of any of the following events, ASSC may suspend the provision of the AWV service in whole or in part:

    1. When ASSC is required to perform regular or urgent maintenance or inspection of the computer system used to provide the AWV;

    2. When the AWV has been rendered inoperable due to fire, power failure, act of God, war, civil commotion, riot, disturbance, labor dispute, infectious disease, epidemic or other contingencies beyond the reasonable control of ASSC;

    3. When ASSC is unable to provide the AWV due to system failure, unauthorized access by a third party, virus infection, etc., on the computer used to provide the AWV;

    4. When ASSC is unable to provide the AWV due to measures adopted under the relevant laws, regulations, or other legal requirements;

    5. When ASSC has notified the User, to a reasonable extent, of the suspension in advance by email or other means; or

    6. When, for any other reason, ASSC deems such a suspension as being unavoidable.

  2. In the event that ASSC suspends the operation of the AWV pursuant to the preceding section, it shall notify the Corporation, etc., and the User, to a reasonable extent, of the suspension in advance by email or other means, except in emergency situations.


Article 10 (Disclaimer)

  1. ASSC disclaims all warranties of legality, accuracy, adequacy, reasonableness, morality, and licensure with respect to any information contained in the AWV.

  2. ASSC shall not be liable for any problems that may occur in connection with the AWV between the User and other user(s), or between the User and any third party(ies) including the Corporation, etc., (such problems may include, but are not limited to, those resulting from proposing any acts that are against the law or public order or morality, and defamation, insults, invasion of privacy, threats, slander, and harassment), except where such problems are caused by willful misconduct or gross negligence on the part of ASSC.

  3. ASSC shall not be liable for any damage (including, but not limited to, damage resulting from loss of information) that may be caused to the User due to changes to the AWV resulting from the suspension, discontinuation, or termination of the AWV as set forth in the preceding Article, except where such damage is caused by willful misconduct or gross negligence on the part of ASSC.

  4. ASSC shall not be liable for any damage resulting from the environment, etc., of any personal computer, smartphone, mobile device, network, software, etc., used by the User, nor for any damage resulting from virus infection, etc., on any personal computer used by the User. In addition, ASSC may notify the User of the appropriate environment and other conditions for using the AWV, including appropriate forms of use, through a method separately specified by ASSC.

  5. In addition to as provided for in each of the preceding sections, ASSC shall not be liable for any other damage that may be caused to the Corporation, etc., or the User as a result of the use of the

    AWV, except where such damage is caused by willful misconduct or gross negligence on the part of ASSC.

  6. ASSC’s liability for damages arising out of these Terms or the AWV, shall not exceed the amount of the AWV usage fee paid by the Corporation, etc., or the User in the month in which the relevant damage has occurred.

  7. The disclaimer in this Article does not apply if the agreement between ASSC and the User concerning the use of the AWV under these Terms is a consumer contract prescribed in the Consumer Contract Act. In such case, ASSC’s liability for the damages arising out of these Terms or the AWV shall be within the scope of damages that could ordinarily arise, and if the User is using the services for a fee, up to the amount of fees for the services (in the case of ongoing services, the amount of fees for the services the User has paid to ASSC during the past one month); provided, however, this limitation shall not apply if the relevant damage has been caused by willful misconduct or gross negligence on the part of ASSC.


Article 11 (Consultation and Jurisdiction)

  1. If any doubt or problem arises between the Corporation, etc., the User, ASSC, and/or third party(ies) with respect to the AWV, the relevant parties shall in each case consult in good faith to resolve the same.

  2. The Tokyo Summary Court or the Tokyo District Court shall have exclusive jurisdiction as the court of first instance over all actions or disputes arising from these Terms.


Article 12 (Governing Law)

These Terms shall be governed by and construed in accordance with the laws of Japan.


Enacted July 3, 2020

Revised May 15, 2024

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