Privacy Policy on Personal Data Subject to GDPR

 

This Privacy Policy (hereinafter referred to as "this Policy") sets forth the handling of personal data (as defined below) by VALUENEX Japan Inc. (hereinafter referred to as "we" or "our company") when dealing with the personal data of natural persons residing in the European Economic Area (including EU member states, Iceland, Liechtenstein, and Norway, collectively referred to as the "EU") where the handling of such personal data is subject to the General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter referred to as "GDPR").

 

ARTICLE 1

Types of Personal Data Handled, Purposes of Processing, Legal Basis, and Retention Period

The types of personal data (as defined in Article 4(1) of the GDPR) that we obtain, the purposes of processing (as defined in Article 4(2) of the GDPR), the legal basis for processing, and the retention period (where required by applicable laws) are as follows. Additionally, we have a legitimate interest in maintaining and developing our products and services and managing appropriate HR information within our company and its group companies under the legal basis of Article 6(1)(f) of the GDPR.

1. Personal Data Related to Business Partners or Potential Business Partners ("Business Partner Data")

  • Types of Personal Data: Name, company name, job title, company address, company phone number, company fax number, email address, mobile phone number, gender, cookies, etc.

  • Purpose of Processing: Sales and marketing of our products and services, procurement of materials and services for our products, and other related purposes.

  • Legal Basis: Consent, preparation for contract execution, legal obligations, legitimate interests.

  • Retention Period: Until the business or potential business relationship with the business partner ends.

2. Personal Data Related to Our Company or Group Company Officers and Employees, or Potential Officers and Employees ("HR Data")

  • Types of Personal Data: Name, job title, job description, email address, mobile phone number, gender, birthdate, home address, home phone number, salary, work history, educational background, family information, language proficiency, network ID, cookies, etc.

  • Purpose of Processing: Recruitment, employment contract maintenance and management, workplace environment maintenance and construction, tax processing, regulatory reporting, and other related purposes.

  • Legal Basis: Consent, preparation for contract execution, legal obligations, legitimate interests.

  • Retention Period: Until the data subject (as defined in Article 4(1) of the GDPR) resigns or is confirmed as not being hired.

 

ARTICLE 2　

Provision of Personal Data to Third Parties

Where permitted by applicable law, we may provide personal data to third parties as follows:

1. Business Partner Data

  • Group companies

  • Cloud infrastructure providers

  • Data analytics and marketing providers

  • Payment processing providers

  • Development and operational support providers

  • Legal request recipients

2. HR Data

  • Group companies

  • Payroll and benefits providers

  • Recruitment providers

  • HR management, evaluation, and training providers

  • IT and security providers

  • Travel and expense management providers

  • Health and labor management providers

  • Legal and compliance providers

  • Legal request recipients (labor, tax, immigration, etc.)

 

ARTICLE 3　

Indirect Acquisition of Personal Data

We may obtain personal data indirectly from the following sources, which are not publicly available:

1. Business Partner Data

  • Group companies

  • Outsourcing partners

  • Other business partners involved in transactions

2. HR Data

  • Group companies

 

ARTICLE 4　

Transfer of Personal Data outside the EU

We may transfer personal data obtained to third countries outside the EU. If the European Commission has not recognized an adequate level of protection under Article 45(3) of the GDPR, we will take appropriate measures as required by the GDPR, such as entering into contracts that include standard data protection clauses.

 

ARTICLE 5　

Rights of Data Subjects

  1. Data subjects whose personal data we obtain have the following rights:

    • Right to request access to personal data (Article 15 of the GDPR)

    • Right to request rectification or erasure of personal data or restriction of processing (Articles 16-18 of the GDPR)

    • Right to object to the processing of personal data (Article 21 of the GDPR)

    • Right to request data portability (Article 20 of the GDPR)

    • Right to lodge a complaint with a supervisory authority (Article 77 of the GDPR)

    To exercise these rights, please contact us at the inquiry contact provided in Article 8.

ARTICLE 6

Consent and Withdrawal

If the legal basis for obtaining personal data is the consent of the data subject, the data subject has the right to withdraw consent at any time. However, such withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

 

ARTICLE 7

Necessity of Providing Personal Data

  1. Personal data of business representatives and employees of business partners is required to conclude contracts with us. Providing such information is not a legal obligation; however, refusal may result in our inability to transact with the business partner.

  2. HR data is required to conclude delegation or employment contracts with us. Providing such information is not a legal obligation; however, refusal may result in our inability to delegate or employ the data subject.

  3. If applicable law requires us to obtain personal data, Articles 1 and 2 above do not apply, and we may not be able to conduct transactions or employ the individual concerned if the required data is not provided.

 

ARTICLE 8

Compliance with Supplemental Rules

The Company shall comply with the Personal Information Protection Act in handling personal data transferred from the EU and the UK based on adequacy decisions, and shall also comply with the "Supplementary Rules on the Handling of Personal Data Transferred from the EU and the UK Based on Adequacy Decisions under the Personal Information Protection Act," as established by the Personal Information Protection Commission.

 

ARTICLE 9

Contact Information

For inquiries and other communications regarding this Policy, please contact us at the following:

Address: Twin Hills Myogadani 3F & 4F, 4-5-16 Kohinata, Bunkyo-ku, Tokyo 112-0006, Japan

Phone Number: +81-3-6902-9833

Email Address: customer@valuenex.com

 

ARTICLE 10

Changes to the Privacy Policy

We may amend this Policy as necessary. Please check this webpage periodically to stay informed about any changes to our Privacy Policy.

 

Last updated: April 1, 2025