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Synspective Group Privacy Policy

Recognizing the importance of personal information, Synspective Inc. and Synspective Japan, Inc. (collectively “Synspective Group”; for further details please refer to the company profile (https://dev.synspective.com/stargazer)) complies with the Personal Information Protection Law (hereinafter defined) and related laws and regulations, and hereby establish the following Privacy Policy (hereinafter referred to as the (“Policy”) regarding the handling of personal information.

Article 1. Article 1. Definition of “Personal Information”, “you” and “User”

“Personal Information” shall mean “personal information” as defined in the Act on the Protection of Personal Information(Act No.57 of 2003) (“Personal Information Protection Act”), as it relates to any information concerning a living individual that:

  1. in combination with other Personal Information, can be used to identify a specific individual by combining such information concerning, for example, the name, face image, date of birth, address, telephone number, contact information and other descriptions contained in such information; and
  2. can, by itself, be used to identify a specific individual, for example, through information such as physical appearance, fingerprints, physical feature data on voiceprint, and My Number (Social security number), driver’s license, insured’s number on a health insurance card (personal identification information).

The terms “you” or “User” shall refer to any natural person who discloses Personal Information when accessing the website managed and operated by Synspective Group (such website, hereinafter, the “Website”) such as through the use of the various services provided by Synspective Group (such services, hereinafter, the “Services”) or otherwise. The term “you” or “User” shall also include natural persons who disclose Personal Information in the course of entering into contracts with Synspective Group for the purpose of activities such as sales activities, and recruitment activities as well as when entering into contracts for the use of the Services.

Article 2. Purposes of Collection and Use of Personal Information

  1. Synspective Group may request Personal Information such as the User’s name, address, telephone number, email address and company name, when the User registers for use of the Services.
  2. The purposes (hereinafter “Purposes of Use”) for collecting and using such Personal Information by Synspective Group are as follows:
    1. Concerning Personal Information in connection with the person using the Services:
      1. To provide and operate the Services;
      2. To respond to inquiries from the User (including to verify the identity of the User);
      3. To send emails regarding new functions, renewal information, campaigns and other information of the Services being used by the User and information regarding the other services as may be provided by Synspective Group;
      4. To plan and hold events including, but not limited to, online forums and social networks, etc.;
      5. To provide promotional or event information regarding Synspective Group and related companies;
      6. To send the latest information and newsletters regarding Synspective Group and its Services;
      7. To communicate regarding maintenance and important notices, as necessary;
      8. To identify Users who have violated any terms of use and Users who are trying to use the Services for unlawful or unfair purposes, and to restrict the use thereof;
      9. To investigate any technology issues and improve the quality of the Services;
      10. Any other activities incidental to the purposes listed in this Article 2.2(1).
    2. Concerning Personal Information related to Synspective Group’s business partners:
      1. To enter into contracts with Synspective Group;
      2. To process payments and prepare payment records (such as for compensation and fees, real estate rental fees, consideration for acquisition of real estate, and commission for brokerage of real estate sales or leasing);
      3. Any other activities incidental to the purposes listed in this Article 2.2(2).

Article 3. Amendment to Purpose of Use

  1. Synspective Group shall amend the Purposes of Use of the Personal Information only where such amendments can be reasonably recognized to have relevance to those Purposes of Use prior to such amendment.
  2. If the Purposes of Use are amended, the User will be notified regarding the amended Purposes of Use via the method designated by Synspective Group or via announcement of such amended purposes on the Website.

Article 4. Safety Control Measures

All Personal Information retained by Synspective Group shall be protected from unlawful cracking, loss, breaking, falsification and leaking through the implementation of security measures which limit access to personal information files and record and log all access to such Personal Information, as well as security measures to protect against external unlawful access and organizational, physical, human and technical safety measures. Where any incident concerning the leakage of the User’s Personal Information or other such information should occur, based on the Personal Information Protection Act and related guidelines, and in accordance with “the control authority” instructions as provided in the Personal Information Protection Act, in addition to immediately informing the Personal Information Protection Committee and any affected User of such incident, Synspective Group shall take the necessary actions and implement the necessary measures to prevent reoccurrence of similar incidents. For further details on safety control measures for Personal Information, please refer to the documents in the links below:
https://www.ppc.go.jp/personalinfo/legal/guidelines_tsusoku/#a1

Please review below the committee to personal information protection’s page with respect to overview of Singaporean system,
https://www.ppc.go.jp/files/pdf/singapore_report.pdf

Article 5. Provision of Personal Information to Third Parties

  1. Notwithstanding instances as permitted under the Personal Information Protection Act and other laws or regulations, Synspective Group will not provide Personal Information to any third parties without obtaining the User’s prior consent, except in the below situations:
    1. Where all or a part of the handling of Personal Information is entrusted to Synspective Group to the extent necessary for Synspective Group to achieve the Purposes of Use, and where the provision of Personal Information to such third parties are for the following purposes:
      1. During the registration process of an event co-hosted by a business operator, where a User or prospective customer may input or provide Personal Information such as name, affiliation, official position, phone number etc.. In such cases, the purpose of the provision of such Personal Information will be:
        1. To plan and hold events, online forums, social networks and so on;
        2. To provide information with respect to Synspective Group and associated company promotions, events and so on;
      2. Where a business partner provides a product or service in cooperation with the Services, it may be necessary to share basic Personal Information such as name, affiliation, official position, phone number and other Personal Information that is necessary for sales activities such as User or prospective customer’s interest and concern. In such cases the purpose of the provision of such Personal Information will be:
        1. For managing and maintaining relationships;
        2. For the execution of related transactions and business matters;
        3. For the planning and hosting of events;
    2. Where Personal Information is provided as a result of the succession of business due to merger or otherwise;
    3. Where there are cases in which Personal Information, to be jointly used by Synspective Group and a specified person, is provided to such specified person (hereinafter, “Specified Person”), and when a User has in advance been informed or a state has been in place where a principal can easily know to that effect as well as of the purpose and scope of use of the Personal Information by the Specified Person, and the name or appellation of a user responsible for controlling the Personal Information provided to the Specified Person.
  2. Notwithstanding the preceding clause, a recipient of such Personal Information shall not be considered a third party in any of the below instances:
    1. Where there is a need to protect the life, body or property of a User and where it is difficult to obtain the advance consent of the User;
    2. Where there is a particular need to improve public health or promote the healthy development of children and where it is difficult to obtain the advance consent of the User;
    3. Where there is a need to cooperate with the execution of business set forth in the laws or regulations by a national agency or local government entity, or a User entrusted thereby, and where there is the likelihood that obtaining the User’s consent will interfere with such execution of business; and
    4. Where details on the below items are provided and where Synspective Group notifies the Personal Information Protection Commission:
      1. That the purpose of use includes the provision to third parties;
      2. The extent of the personal data being provided to third parties;
      3. The method of obtaining personal data provided to third parties;
      4. The means or method of the provision of the personal data to third parties;
      5. That the User may request the cessation of the provision of the Personal Information to third parties; and
      6. The method of receiving such a request from the User.
    5. Where handling of Personal Information is entrusted as under Article 5.1(1) Synspective Group shall cause the outsourcing company to implement all necessary and appropriate monitoring in accordance with the Personal Information Protection Act.

Article 6. Provision to a Third Party in a Foreign Country

  1. Synspective Group may provide User’s Personal Information to third parties in foreign countries in the following cases:
    1. Where it has obtained approval from the User in advance to provide such Personal Information to a third party in a foreign country (where Japan is deemed the home country);
    2. Where measures in accordance withing to the Personal Information Protection Act chapter 4 section 2 are implemented by appropriate and reasonable method, in relation to the handling of Personal Information.
  2. In accordance with the preceding clause, where Personal Information is being provided to any foreign country listed below:

    Singapore

Article 7. Shared Use of Personal information

Customer’s Personal Information is shared within Synspective Group in accordance with the following :

  1. Types of Personal Information shared:
    1. Name
    2. Address
    3. Phone number
    4. Mail address
    5. Company name
    6. Obtained other individual information
  2. The scope of the Specified Person
    1. Synspective Inc.
    2. Synspective Japan, Inc.
    3. Synspective SG Pte. Ltd.
  3. Purposes of use Refer to Article 2 of this Policy
  4. Person responsible for controlling the Personal Information shared within the Synspective Group In respect to address and representative name are below.

    Synspective Inc.
    Address: 3-10-3 Miyoshi, Koto-ku, Tokyo
    Representative: Motoyuki Arai, CEO

    Synspective Japan, Inc.
    Address: 3-10-3 Miyoshi, Koto-ku, Tokyo
    Representative: Motoyuki Arai, CEO

    Synspective SG Pte.Ltd.
    Address: 10 ANSON ROAD #14 – 06 INTERNATIONAL PLAZA SINGAPORE 079903
    Representative: Motoyuki Arai, CEO

Article 8. Disclosure of Personal Information

  1. When the disclosure of the Personal Information is requested by the User, Synspective Group will disclose such information to the User without delay; provided, however, that if any of the below applies due to the disclosure, all or a part thereof may not be disclosed. Where a decision is made not to disclose, the effect thereof will be notified without delay. Furthermore, a fee of JPY1,000 per case will be charged to the User upon the disclosure of the Personal Information:
    1. Where there is the likelihood of harming the life, body, property or other rights or interests of the User or a third party;
    2. Where there is the likelihood of causing significant harm to the proper execution of Synspective Group’s business;
    3. Where it will otherwise violate laws or regulations.
  2. Notwithstanding the provisions of the preceding clause, any information other than Personal Information, such as historical information and characteristic information will, in principle, not be disclosed.

Article 9. Correction and Deletion of Personal Information

  1. In the event the User’s Personal Information that is in Synspective Group’s possession is incorrect, the User may make a request Synspective Group for the correction, addition to, or deletion of the Personal Information (the “Corrections”) in accordance with the procedures set forth by Synspective Group.
  2. Where Synspective Group receives a request as indicated in the preceding clause from the User and where Synspective Group determines that there is a need to respond to such request, Synspective Group shall make the necessary Corrections to such Personal Information without delay.
  3. Whether Synspective Group decides to the Corrections in accordance with the provisions of the preceding clauses or decides to not make the Corrections, Synspective Group will notify the User of its decision without delay.

Article 10. Suspension of Use of Personal Information

  1. If Synspective Group is requested by the User to suspend its use of or to delete the Personal Information due to the reason that the Personal Information is being handled in a manner beyond the scope of the Purposes of Use or due to the reason that the Personal Information was acquired by fraudulent means (such suspension, hereinafter, “Suspension of Use”), Synspective Group will conduct necessary inspections without delay.
  2. If Synspective Group determines that there is a need to respond to such request based on the inspection results of the preceding clause, Synspective Group will proceed with the Suspension of Use of such Personal Information.
  3. Irrespective of whether Synspective Group proceeds with the Suspension of Use measures or determines, further to its inspections, not to proceed with the Suspension of Use measures, Synspective Group will notify the User thereof without delay.
  4. Notwithstanding the preceding two clauses, where significant expenses will be incurred in proceeding with the Suspension of Use, or where proceeding with the Suspension of Use is otherwise determined to be difficult, and where an alternative available that is deemed sufficient in protecting the rights and interests of the User and can that be taken in place of the Suspension of Use, Synspective Group shall take such alternative measure.

Article 11. External Transmission of User information and Information Collection Module

The User acknowledges and accepts that there are cases where Synspective Group provides User information to a person who provides information collection modules including those outside of Japan as follows:

appellation Provider Disclosure of information by provider
Google Analytics Google LLC https://policies.google.com/technologies/partner-sites
SalesForce Salesforce, Inc https://www.salesforce.com/jp/company/personalinfo/
Pardot Salesforce, Inc https://www.salesforce.com/jp/company/personalinfo/

These collection modules collect User information without information that can identify individual and collected information is managed based on privacy policy set forth by each information collection module provider.

Article 12. Use of Cookies

  1. Technology to identify the customer’s browser called “cookies” may be used on the Website for the purposes set forth below:
    1. For the User to use the Website more conveniently when the User re-visits the Website;
    2. To measure and analyze the usage status of the Website;
  2. If the User accesses contents that issue cookies, cookies will be recorded in the User’s computer; however, the recorded information will not contain information that can identify the User.
  3. The acceptance of cookies can be rejected by the User by changing the settings of the browser; provided, however, that a part of the Website may no longer be used if the acceptance of cookies is rejected.
  4. For more information about the use of cookies, see our Cookie Policy.

Article 13. Amendment to the Policy

  1. Except for matters that are set forth in the laws or regulations or are otherwise set forth in this Policy, the contents of this Policy may be amended without notifying the User.
  2. Unless otherwise set forth by Synspective Group, the amended Policy shall become effective from when it is published on the Website.

Article 14. Contact for Inquiries

Please contact the following for inquiries regarding this Policy:
Address: Review company overview (https://dev.synspective.com/stargazer/)
Company Name: Synspective Inc.
Representative: Motoyuki Arai, CEO
Department: PR Team
Email Address: hello@synspective.com