Privacy policy

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Company Information

Our company (LreiC Co.,Ltd.) has established the following policy with regard to protecting our customers' sensitive personal information. Each and every one of our employees receives training on how to ensure privacy protection, and as a company, we strive to maintain the highest standards of security.
This is an English summary of the original Japanese Privacy Policy. In legal matters, the Japanese policy takes precedent and supersedes anything written in the English version.

Clause 1 General Provisions

Amendment 1: (Aims)

The purpose of this policy is to protect the rights and interests of the customers, businesses, vendors, and other parties with which our company interacts; we do this by protecting any and all personal information that is shared with us through the most secure means.

Amendment 2: (Definitions)

For the intents of the privacy policy, we define the following words in the following ways.

  • Personal Information
    Any and all information which pertains to persons living, such as name, DOB, etc. that could be used to identify an individual. Includes any numbers, symbols, or codes that may be used to identify a specific individual in our internal systems.
  • Personal Information Database
    Gathered personal information will be organized into a database using either electronic means (computers) or, if necessary, paper filing systems, for ease of retrieval and use. This organized information is called the Personal Information Database.
  • Personal Data
    Personal information stored in the personal information database.
  • Retained Personal Data
    The Company reserves the right to legally disclose, revise, supplement, delete, suspend use of, and erase, as well as cease furnishment to third parties of all retained personal information unless it is clear that doing so will put the individual or third parties in legal or mortal peril.
  • The Individual(s)
    The person(s) who can be identified by the personal information.
  • Employees
    Those parties under the direct orders or instruction of the The Company who conduct the affairs of the Company.
  • Anonymization
    The process of removing all descriptors and identifiers from the personal information of individuals such as name, DOB, and/or address.

Amendment 3: (Obligations of The Company)

The Company observes all laws and ordinances as pertains to the handling of sensitive personal information, and makes every possible effort to ensure total compliance and security. It also maintains personal information with precision and in its most up-to-date form. To protect all personal information from illegal access, loss, damage, falsification, and disclosure, the Company maintans a secure data system and also provides the proper education of its employees to ensure total security. The Company utilizes the strictest measures possible to maintain its personal information database.

Clause 2 Specifics of Using Personal Information

Amendment 4: (Specifics of Using Personal Information)

  • The Company specifies that personal information must be used only in the following ways.
  • If the Company uses any personal information outside of these ways, they will only do so within a reasonable and related manner.
  • If the Company does use any personal information in ways not proscribed in this policy, they will contact any concerned parties, or make a public announcement.
  • The Company outlines the use of personal information in the following ways.
  • The Company will use personal information to send communication or business information or inquiries via e-mail.

Amendment 5: (Specifics of Usage for Each Business)

The Company will elucidate its practices in regards to what types of personal information it gathers, when and how that information is used, and how it may be offered, in the document "Instructions for Secure Handling of Personal Information" .

Amerndment 6: (Limits for Use of Personal Information Outside Those Proscribed in Amendment 4)

  • The Company will not deviate from the specified usage purposes outlined in previous paragraphs without the consent of the concerned individual(s).
  • If the Company is bought out or is absorbed by another corporate entity and that entity becomes the owner of previously collected personal information, the Company cannot hand it over without the consent of the Individual(s) concerned.
  • Although outlined in the previous paragraphs, if the following conditions are present, the Company may use collected personal information without the consent of the Individuals concerned.
    • Reasons of Law
    • For reasons to protect people from harm both physical and legal, and there is an impediment to obtaining proper consent.
    • For reasons of public decency or to protect minors, and there is an impediment to obtaining proper consent.
    • For reasons of cooperation with a governermental or legal authority, and there is an impediment to obtaining proper consent.
  • For any reasons outside the previously outlined paragraphs, the Company will only handle personal information if absolutely necessary.

Clause 3 Limits of Acquisition of Personal Information

Amendment 7: (Limits of Acquisition)

  • When the Company acquires any personal information, they shall specifically state the purpose of acquisition and shall acquire it in a lawful and approriate way.
  • The Company will absolutely not acquire any information based on the Individual`s thoughts, beliefts, or religion, nor will it collect any information that could be used as a basis of prejudice or discrimination.
  • As a general rule, the Company acquires personal information from the individuals themselves. However, this may not be the case in the following situations.
    • When the individual has given consent for otherwise.
    • When there is a legal stipulation.
    • When the individual is in mortal or physical peril, and to ensure the individual`s safety.
    • When the individual cannot be found, or is of impaired judgement, and cannot give consent.
    • When the individual has granted permission for a specific purpose to the Company to advise, assist, coach, represent, or act on their behalf.
  • In the event that the Company has acquired information from a third party and not the individual(s), and the individual will be notified of its intended use.

Amendment 8: (How Notification of Intended Use May be Conducted)

  • If the Company has acquired personal information, and outside of cases where the purpose has been publicly announced beforehand, the Company will with all due haste notify the individual of how their personal information will be used (or make a public announcement).
  • In spite of the provisions laid out in the previous paragraph, when there is a contract or similar document between the Company and the individual(s), the Company will explicitly make clear the purpose of the personal information gathered for said document(s). However, if this is done at a point where the individual is in mortal or physical peril and/or in an emergency situation, this may not be immediately possible.
  • The previous two paragraphs apply to the following cases.
    • When it is possible that the individual(s) or a third party`s life, physical wellbeing, assets, or other rights/interests are compromised.
    • When the Company must comply with a national, local, or representative entity of a governing body`s request for personal information, the purpose of usage will be made clear to the individual(s) or publicly announced, unless there is an impediment exerted to properly doing so.

Clause 4 Proper Management of Personal Data

Amendment 9: (Proper Management of Personal Data)

  • The Company will, within reason as stipulated by the purposes of usage, maintain personal data in its most recent and updated form.
  • The Company will take every possible precaution to ensure that personal data is not leaked, lost, damaged, or compromised.
  • The Company will make sure that its employees are properly managed to ensure their compliance with personal data security measures.
  • When keeping personal data is no longer necessary, the Company will immediately and securely delete or discard it.
  • When the Company must share complete or partial personal data with a third party for the purpose of business, as a a general rule, the Company will stipulate usage rules to the entrusted third party and will follow through with supervising the third party during the data`s use.

Clause 5 Furnishing Personal Data to a Third Party

Amendment 10: (Furnishing Personal Data to a Third Party)

  • The Company promises to never furnish personal data to a third party without the individual(s) permission outside of the following reasons.
    • Reasons of Law
    • For reasons to protect people from harm both physical and legal, and there is an impediment to obtaining proper consent.
    • For reasons of public decency or to protect minors, and there is an impediment to obtaining proper consent.
    • For reasons of cooperation with a governmental or legal authority, and there is an impediment to obtaining proper consent.
    • For reasons of conducting business on behalf of the individual(s) who are customers who have requested services that necessitate the sharing of personal data.
  • If data is furnished to a third party, that party is vetted by the Company.
    • The Company will only give personal data to trusted third parties.
    • If personal data is shared due to a merger of the Company with another entity
    • If personal data is furnished to a particular entity due to a merger or other business reason, the individual(s) will be notified of the name or corporate name of the entity or the individual will be told in specific terms what is happening with their data.
  • If the entity changes its name, that information will be promptly provided to the individual(s).

Clause 6 Disclosure, Revision, Addition, Deletion, and Suspension of Usage of Retained Personal Data

Amendment 11: (Legal Disclosure of Retained Personal Data)

  • When the Company receives a request, whether in writing or verbally, for personal data about the individual(s) from the indvidual(s) themselves, the Company will confirm their identity either through a photo ID or verbally. If identity cannot be confirmed, the request will be denied. It also may be denied in the following instances.
    • For reasons to protect people from harm both physical and legal, and there is an impediment to obtaining proper consent.
    • If it will be a hindrance to the reasonable carriage of the Company`s business.
    • If the disclosure will be considered a crime in the face of the law.
  • Data disclosure will be in writing, unless the Company has the express permission to do so in another form.
  • The individual(s) will be promptly notified of data disclosure (or non-disclosure.)

Amendment 12: ( Revision, Addition, Deletion, and Suspension of Usage of Retained Personal Data)

  • If the Company receives a written or verbal request from an individual who has provided retained personal data to revise, add to, delete, or suspend use of the data, the Company will conduct a brief examination of the request and provide a response in writing.
  • If the Company receives another request after the individual has been notified of the examination results, the Company will repeat the same process outlined in the previous paragraph.

Clause 7 Organization and Structure

Amendment 13: (Manager of Personal Information Protection)

  • The Company shall desginate a manager for the protection of personal information, and shall compel the manager to use best practices when working with it.
  • The manager shall be appointed at the beginning of each fiscal year.
  • The manager shall act under the directive of company directors and according to company rules, and shall enforce appropriate measures and counter-measures for protection, as well as provide the proper education for employees to understand the Company`s privacy policy.
  • The manager shall periodically evaluate the necessary measures to ensure personal information security and conduct the necessary improvements and reconsiderations.
  • The manager shall appropriately delegate to and supervise employees who are handling the proper measures to ensure personal information security.

Amendment 14: (Support for Complaints9

  • The Company shall make appropriate allowances for complaints about the handling of personal information and shall make efforts to respond appropriately to any complaints that may arise.
  • A complaints manager shall be appointed at the beginning of each fiscal year.
  • The complaints manager shall trust the fielding of complaints to the employees who will then make the situation clear to the manager.

Amendment 15: (Employee Obligations)

  • Employees shall never disclose personal information to anyone outside the company, nor shall they ever use the information in an inappropriate way.
  • If an employee deviates from this privacy policy, or there is a possibility that they have infracted on it, the Personal Information Manager must be notified immediately.
  • The Personal Information Manager will examine the contents of the (potential) infraction and notify the Board of Directors of the result of the examination, as well as indicate a course of action to the concerned departments.

Clause 8 Miscellaneous

Amendment 16: Others

Any other necessary rules or regulations to ensure personal information privacy shall be made elsewhere.

By-laws

This policy is effective as of April 1st, 2015.


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