Compliance with Related Laws and Guidelines

Collecting Personal Information

1. User Provided Information

   • Age or Date of Birth
   • Name
   • Email Address
   • Other Information such as passwords to verify the identity of the person accessing the account
   • Information established by ASSC to be collected by the application or the website
   • Any other information about the user specified by ASSC

2. Terminal Information

   ASSC may obtain the terminal identifier, mobile device identifier and IP address when the user utilises AWV on the terminal or mobile device. Also, ASSC may obtain any other information you choose to provide, such as the name the user associated with the device, device type, phone number, country and username, or an email address.

3. Location Information

   ASSC may obtain information about the location of the user, if AWV is utilised on a terminal or a mobile device and the user authorises it to do so.

4. Information on User Actions

   ASSC may, when utilising ASSC services, collect and store information that the user directly provided to ASSC or information furnished via a third party service provider of AWV. ASSC may also collect information about a user’s AWV usage status and interactions with other users.

5. Communication Function

   ASSC may record and store information of archived communication, if users utilised AWV in their communication with other users and maintained a certain level of activity in information sharing (including text, user profile, messages, photos, images, audio, video, applications and any other information content).

6. Collecting Information Using Cookies

   ASSC collects the following specific technical information when the user accesses AWV. ASSC and service providers standing in proxy for ASSC use log files and tracking technology to collect and analyse cookies, IP addresses, device types, mobile device identifiers, browser types, browser languages, reference and exit pages, platform type, number of clicks, domain name, landing page, number of browsed pages and page browsing order, URL of each page, browsing time of specific page, application or website statuses, date and time of activity on ASSC application or website, and any other information. The information will be intended for internal use and ASSC may also associate this information with your user ID number. Additionally, ASSC may also use (i) a web beacon to check whether a specific page has been viewed or whether an email has been opened, (ii) other technologies, including tracking pixels, that excludes existing users from a specific promotional message, identify a new installation source or providing advertisements for users on other websites allowing advertisements to be more effective.

7. Information Collected with External Services

   ASSC may collect information the user gave the external service the permission to disclose through the user ID used in the external service and the privacy setting entered by the user.

Purpose of Personal Information Usage

1. Purpose of use of Personal Information for those employed in factories, stores, offices etc.:
   • Survey/research/analysis of the work environment at the employment location
   • Collection of information on the work environment at the employment location
   • Securing safety at the place of employment
   • Providing the result on the information analysis
   • Providing advice on employee behaviours
   • Proper and smooth communication with users
2. Purpose of use of Personal Information related to organisations the user belongs to (hereinafter, “affiliated organisation”), its trading partners (hereinafter, “business partner”) and other companies in the same industry (hereinafter, “industry peers”),
   • Survey/research/analysis of the work environment at the employment location of the user
   • Collection of information on the work environment at the employment location of the user
   • Securing safety at the employment location of the user
   • Providing the result on the information analysis
   • Providing advice on business partners’ behaviours
   • Notifications/reports to government agencies/member organisations
   • Proper and smooth communication
   • Contributions to magazines/websites

Subcontracted Work

Third-party Provision

Shared Use

Data Transfer

1. when such third party is in a country prescribed by the rules as a foreign country establishing a Personal Information protection system recognised to have equivalent standards to that in Japan in regard to the protection of an individual’s rights and interests
2. when the Business Operator Handling Personal Information and the third party who received the provision of Personal Data have implemented coordinated measures, in respect to the processing of Personal Data by such third party, by an appropriate and reasonable method (contract, other form of binding agreements or binding arrangements within a corporate group), providing an equivalent level of protection measures as that of the Personal Information Protection Law
3. in cases falling under each item of Article 23, paragraph (1) of the Personal Information Protection Law

Management of Personal Data

1. Ensuring Accuracy

   ASSC strives to keep Personal Data accurate and up-to-date within the scope necessary to achieve the purpose of use, and to erase such Personal Data when it is no longer necessary.

2. Security Management Measures

   ASSC shall take necessary and appropriate measures to prevent leakage, loss or damage of Personal Data and for other safety management purposes.

3. Employee Supervision

   In order for the employees to be able to handle Personal Data, ASSC shall implement appropriate training and conduct necessary and appropriate supervision together with the familiarisation with the proper processing of Personal Information.

4. Subcontractor Supervision

   When entrusting the processing of Personal Data, ASSC will select a partner company that deploys appropriate safety management measures for their subcontractors and will conduct necessary and appropriate supervision of their subcontractors.

Basis for the Processing

1. When the user gives consent to the processing of his or her Personal Data.
2. When processing is required to provide the AWV service and achieve the purpose of use.
3. When processing is required for ASSC to comply with its legal obligations.
4. When processing is required for legitimate interests sought by ASSC or a third party. The “legitimate interest” may be the use of Personal Data to execute the purposes of use in Article 3 and to collect information to contribute to the improvement of the purposes of use. However, this excludes cases where basic rights and freedoms that require protection of Personal Data, especially if the data subject were a child, take precedence over such right.
5. When processing is required to execute tasks for the public interest or to exercise the public authority given to ASSC.

Reception of Retained Personal Data

1. A notification will be made without delay, when a request is made from the user or agent to be notified on the purpose of use of Retained Personal Data, except in the following cases:
   1. When the purpose of use of the Retained Personal Data that identifies the user is clear
   2. When there is a risk of harming the life, body, property or other rights and interests of the user or a third party
   3. When there is a risk to ASSC’s rights or legitimate interest
   4. When required by laws or regulations for ASSC to cooperate with national agencies or local public institutions to execute administrative work and there is a risk of hindrance to the execution of such administrative work
2. A notification will be made without delay, when a request is made from the user or agent for the disclosure of Retained Personal Data, except in the following cases:
   1. When there is a risk of harming the life, body, property or other rights and interests of the user or a third party
   2. When there is a risk of hindrance for ASSC to appropriately execute its operations
   3. When it violates laws and regulations
3. The user will be contacted without any delay after an investigation and appropriate action based on the result will be taken, if a person or agent requests correction, addition, or deletion of Retained Personal Data.
4. Appropriate action will be taken when the request is found to have a reason, if the user or agent requests the suspension or deletion of the Retained Personal Data.
5. Appropriate action will be taken, if there is a request from the user or agent to restrict the processing of Retained Personal Data.
6. Appropriate action will be taken, if the user or agent requests that the Retained Personal Data be structured, intended for general use, or received in a machine-readable format. Additionally, the user or agent has the right to transfer such data to other administrators without hindrance by ASSC.
7. Appropriate action will be taken, if the user or agent disputes the processing of the Personal Data based on the need for processing for the purpose of legitimate interests pursued by ASSC or a third party.
8. The user has the right not to submit to any decision based solely on automated processes, such as profiling, that will have a legal effect or a similar significant effect on such user.
9. Please direct the request to the ASSC liaison office listed in 13, if such a request described in prior item 8 exists. The Personal Information provided will be used for the purpose of responding to the request from the user and the user data will be stored with the utmost care. Please note that any invoices or attached documents will not be returned.

Anonymously Processed Information

1. Anonymously Processed Information to be created Information pertaining to sex and age, etc. Information pertaining to the description of consultation
2. Anonymously Processed Information to be provided to a third party
   1. Information items related to an individual included in Anonymously Processed Information provided to a third party Information pertaining to sex and age, etc. Information pertaining to the description of consultation
   2. Method of providing the Anonymously Processed Information Provided by a server with proper access control, individual email, or post/courier service

Retention Period of Personal Data

For Inquiries and Complaints

Privacy Policy Revisions