Handling of Personal Information

Works Human Intelligence Co., Ltd. (hereinafter “Company”) shall handle personal information as follows.

Works Human Intelligence Co., Ltd.
Momoko Tsuda, Personal Information Protection Manager
TEL: 03-5575-5279

Name, address and name of representative of the Company

Works Human Intelligence Co., Ltd.
21st Floor Ark Mori Building, 1-12-32 Akasaka, Minato-ku, Tokyo
Tomitaro Anzai, Representative Director and Chief Executive Officer

Purpose of use of personal information

The Company shall acquire personal information by fair and appropriate means and shall use personal information for the following purposes.
 

[1] Customer management operations in the Company’s business activities

• Replying to questions and inquiries concerning the Company and the Company’s products and services
• Providing the Company’s product information, support information, etc.
• Providing information on the Company’s events and seminars, etc.
• Delivering e-mails to customers desiring mail distribution service
• Asking for cooperation in questionnaires, etc.

[2] Provision of the Company’s products and services to customers

• Providing data transfer support and validation and confirmation, etc. due to introduction and maintenance support, etc. of the Company’s products
• Handling within necessary scope for the performance of contracts in consigned business
• Providing services including the Company’s products, support and group training
• Replying to questions and inquiries concerning the Company’s product information and support information, etc.
• Providing information on the Company’s product information, support information, seminars, regular briefings, section meetings, group training, etc.
• Asking for cooperation in questionnaires, etc. concerning the Company’s products and services

[3] Management operations concerning the Company’s shareholders

• Performing duties based on laws
• Replying to questions and inquiries concerning the Company
• Providing information on the Company’s financial briefings and general meeting of shareholders, etc.
• Asking for cooperation in questionnaires, etc. concerning the Company

[4] Management operations concerning employees of the Company’s associate companies, etc.

• Executing and confirming the performance of contracts with associate companies, etc.
• Instructing work, managing work and managing employment concerning employees of associate companies, etc.
• Confirming the skills of employees of associate companies, etc.
• Implementing security management
• Taking measures for the protection of confidential information, etc.

[5] Operations for recruiting the Company’s employees

• Recruitment screening
• Replying to questions and inquiries concerning the Company’s recruitment
• Providing information on the Company’s recruitment events and seminars, etc.
• Asking for cooperation in questionnaires, etc. concerning the Company’s recruitment operations

[6] Management operations concerning the Company’s employees

• Performing duties based on laws
• Executing personnel-related operations
• Providing benefit packages
• Smoothly executing business using groupware, etc. with the Company’s subsidiaries and contractors

[7] Management operations concerning group companies (including but not limited to the following matters)

• Implementing governance and internal control of group companies
• Risk management of group companies

Provision of personal information to third parties

The Company shall not provide personal information to another party without obtaining the consent of the relevant individual, except in the event based on laws and regulations and in the event that there is the possibility of endangering the life, health and property of the relevant individual and the public.

Entrusting personal information

There are cases in which the Company and group companies may consign a part of business to a contractor and it is necessary to entrust personal information to such contractor within necessary scope. In the event that personal information is to be entrusted, a contractor maintaining a certain level of personal information protection standards shall be selected and necessary measures such as executing contracts concerning the handling of personal information, etc. shall be taken. In addition, the contractor shall be appropriately supervised as necessary.

Joint use of personal information

There are cases in which the Company may jointly use personal information provided, with the Company’s group companies within reasonable and necessary scope. In the event that personal information is to be jointly used, a memorandum concerning the handling of personal information shall be executed with the said group company, and personal information shall be used in line with the following items.

• Items of personal information to be jointly used
  Name, information concerning affiliation (name of company, name of division, etc.), title, address, telephone number, facsimile number, e-mail address, etc.
• Scope of parties to jointly use personal information
  Works Human Intelligence Co., Ltd. and WHI Holdings group companies (not including Sekisui Business Associates; here for details)
• Purpose of use by party to jointly use personal information
  Same as the purpose of use set forth in the foregoing “Purpose of use of personal information.”
• Name, address and name of representative of the party responsible for managing personal information to be jointly used
  Works Human Intelligence Co., Ltd. Personal Information Protection Manager 21st Floor Ark Mori Building, 1-12-32 Akasaka, Minato-ku, Tokyo Tomitaro Anzai, Representative Director and Chief Executive Officer

Disclosure, correction, termination of use and deletion of personal information

The Company shall accept requests from the relevant individual, for the disclosure of retained personal data or record of third-party provision, notice of the purpose of use, corrections, etc. in the event that the details of retained personal data are contrary to the fact, the termination of use, etc. and termination of third-party provision (hereinafter “Disclosure, etc.”). Please refer to the following details with respect to procedures for requesting Disclosure, etc. Please contact the following point of contact with respect to the specific details.

Personal information with authority to respond to requests for Disclosure, etc.

It is as follows concerning retained personal data or records of third-party provision over which the Company has the authority to respond to requests for Disclosure, etc.

Purpose of use of retained personal data

• Customer management operations in the Company’s business activities
  • Replying to questions and inquiries concerning the Company and the Company’s products and services
  • Providing the Company’s product information, support information, etc.
  • Providing information on the Company’s events and seminars, etc.
  • Delivering e-mails to customers desiring mail distribution service
  • Asking for cooperation in questionnaires, etc.
• Provision of the Company’s products and services to customers
  • Providing data transfer support and validation and confirmation due to introduction and maintenance support, etc. of the Company’s products
  • Handling within necessary scope for the performance of contracts in consigned business
  • Providing services including the Company’s products, support and group training
  • Replying to questions and inquiries concerning the Company’s product information and support information, etc.
  • Providing information on the Company’s product information, support information, seminars, regular briefings, section meetings, group training, etc.
  • Asking for cooperation in questionnaires, etc. concerning the Company’s products and services
• Management operations concerning the Company’s shareholders
  • Performing duties based on laws
  • Replying to questions and inquiries concerning the Company
  • Providing information on the Company’s financial briefings and general meeting of shareholders, etc.
  • Asking for cooperation in questionnaires, etc. concerning the Company
• Management operations concerning employees of the Company’s associate companies, etc.
  • Executing and confirming the performance of contracts with associate companies, etc.
  • Instructing work, managing work and managing employment concerning employees of associate companies, etc.
  • Confirming the skills of employees of associate companies, etc.
  • Implementing security management
  • Taking measures for the protection of confidential information, etc.
• Operations for recruiting the Company’s employees
  • Recruitment screening
  • Replying to questions and inquiries concerning the Company’s recruitment
  • Providing information on the Company’s recruitment events and seminars, etc.
  • Asking for cooperation in questionnaires, etc. concerning the Company’s recruitment operations
• Management operations concerning the Company’s employees
  • Performing duties based on laws
  • Executing personnel-related operations
  • Providing benefit packages
  • Smoothly executing business using groupware, etc. with the Company’s subsidiaries and contractors
• Management operations concerning group companies (including but not limited to the following matters)
  • Implementing governance and internal control of group companies
  • Conducting risk management of group companies

 

note) The above purpose of use is an analogous indication of the purpose of use of corresponding personal information. *Retained personal data refers to “Personal data over which the Company has the authority to disclose, to correct, add or delete the content, to discontinue its utilization, to erase, and to discontinue its provision to a third party, excluding the data which is specified by a Cabinet Order as harming public or other interests if its presence or absence is known.”

Procedures for request, etc. for Disclosure, etc.

• When requesting Disclosure, etc., please contact the following point of contact first.
• The Company’s prescribed “Request for notice of purpose of use/disclosure of personal information,” “Request for correction, etc. of personal information,” “Request for termination of use of personal information,” “Letter of proxy” (if a representative is designated) will be delivered by postal mail or e-mail to the relevant individual or the representative.
• Please return the request in the second paragraph above to the Company upon the relevant individual or the representative filling in the details. Please also enclose or attach identification documents, etc.
• In accordance with the request for Disclosure, etc., there will be notice from the Company in the “Notice of disclosure of personal information” by provision, in principle, of electromagnetic record.
• Please note that there may be cases in which Disclosure, etc. is not possible in reply to a request for Disclosure, etc. based on the provisions of laws and regulations.

Identification

• Documents for identification
  • Driver’s license
  • Passport
  • Family register
  • Health insurance ID card
  • Pension handbook
  • Other official documents by which the relevant individual can be identified
• In the event of the relevant individual
  • In the event of documents with face photos such as driver’s license or passport, please submit either one. (In other events, it is, in principle, necessary to submit at least two or more types of documents)
• In the event of a representative
  • In the event of a legal representative for the relevant individual, a minor or an adult ward, please submit the following documents in addition to the above documents.
  • Documents for confirming the identification of the legal representative (two or more types of among driver’s license, passport, family register, health insurance ID card, pension handbook or other official document by which the relevant individual can be identified, or in the event of documents with face photos such as driver’s license or passport, please submit either one)
  • Document for confirming legal authority of representation (any one of family register, health insurance ID card or certificate of registered matters)

note) In the event that information on the permanent legal address is indicated in the documents to be submitted for identification, please black out such part.

Safety control measures

The Company takes the following measures with respect to personal information (personal information acquired or about to be acquired by the Company, including those expected to be handled as personal data), in order for the prevention of leakage, loss or damage and for other appropriate management of personal data.

[Formulation of basic policy]

• There is a policy on the protection of personal information established as the basic policy with respect to “compliance with relevant laws, regulations and guidelines, etc.” and “point of contact for inquiries concerning the handling of personal information,” etc. in order to secure the appropriate handling of personal information.

[Maintenance of rules concerning the handling of personal information]

• There are internal regulations setting forth the procedures for handling personal information established for each of the stages, acquisition, use, preservation, provision, deletion, disposal, etc. of personal information.
• There are operational procedures separately setting forth the details so that all employees handling personal information will be able to execute business more appropriately.

[Organizational safety control measures]

• There is a chief administrator appointed concerning the handling of personal information, the employees to handle personal information and the scope of personal information to be handled by such employees are clarified and there is a system for reporting and notifying the chief administrator in the event of the discovery of a fact or signs of violation (including occurrence of leakage or loss, etc.) of the Act on the Protection of Personal Information or internal regulations.
• In order to secure operation in accordance with the rules concerning the handling of personal information, there is a supervisor appointed who manages authorization concerning database, etc. that include personal information, and the situation of use is also recorded and managed by system logs. Internal audits concerning the situation of the handling of personal information are conducted periodically by the auditing division.

[Human safety control measures]

• Education and training of employees are periodically conducted with respect to points to note concerning the handling of personal information and information security and their understanding of such education and training are confirmed, aimed at ensuring the employees’ handling of personal information in accordance with the internal regulations and further improving awareness.
• Provisions concerning the confidentiality of personal information are set forth in the rules of employment and written oaths are collected from the employees at the time they join the Company.

[Physical safety control measures]

• The employees’ entry into and exit from office areas are managed and measures are taken to prevent access to personal information by those without authority.
• Measures are taken in order to prevent the theft or loss, etc. of devices, electronic media and documents, etc. handling personal information, and measures are taken in order to minimize the effects in the event of the occurrence of theft or loss, etc., such as encrypting or locking, etc. devices and electronic media, etc. when moving within the office so that personal information cannot be easily identified.
• When disposing of documents on which personal information is indicated and devices and electronic media, etc. on which personal information is recorded, irrecoverable procedures are taken.

[Technical safety control measures]

• In order to limit the scope of persons in charge and personal information database, etc. to be handled, access rights granted to user IDs are managed and the accessing persons are authenticated.
• A system is adopted for protecting the information system that handles personal information from external unauthorized access or illegal software, and access logs, etc. are monitored.
• In order to prevent the leakage, etc. of personal information in the use of the information system, vulnerability assessments are conducted by external institutions, the most recent security information is constantly obtained and the safety of the system is periodically reviewed.

[Understanding of external environment]

• In the handling of personal information in a foreign country, the Company takes necessary and appropriate measures for safety control upon periodically collecting and understanding information concerning the system for protecting personal information in the said country. Please contact the “Point of contact for inquiries concerning personal information” below, with respect to details such as whether or not personal information is handled in a foreign country.

[Supervision over contractors]

• In the event that the handling of personal information is to be entrusted to a third party, a contractor satisfying the standards for selecting contractors set forth by the Company is selected, and upon executing consignment contracts or memorandums concerning the protection of personal information, the Company has understanding of the contractor’s handling of personal information by method such as receiving periodical reports in writing.

Handling of personal information

The handling of personal information by the Company, the Company’s group companies and business contractors shall be conducted based on the laws of each applicable country, in accordance with the “Policy on the Protection of Personal Information” posted on the Company’s website and this “Handling of Personal Information” and the internal regulations, etc. of each company. In using the Company’s website, the customer shall be deemed to have agreed to the customer’s personal information being recorded or preserved in countries and areas in which the Company, the Company’s group companies and business contractors are located and being used, etc. by the Company, the Company’s group companies and business contractors.

Revisions concerning handling of personal information

The details of this “Handling of Personal Information” may be subject to change without notice to the customer, except for matters otherwise set forth in laws and regulations, and this “Handling of Personal Information.” Unless otherwise set forth by the Company, the revised “Handling of Personal Information” shall be effective from the time it is posted on this website.

Certified personal information protection organizations

The Company is registered as a covered business operator of the “Japan Institute for Promotion of Digital Economy and Community” which has been certified by the Minister of Economy, Trade and Industry and the Minister for Internal Affairs and Communications as a certified personal information protection organization based on the provision of the Act on the Protection of Personal Information. This institute accepts complaints and consultations concerning the handling of personal information by covered business operators.

[Name of certified personal information protection organization and point of contact concerning requests for settlement of complaints]

This is not the point of contact for inquiries concerning the Company’s products and services. Name of certified personal information protection organization
Japan Institute for Promotion of Digital Economy and Community
Point of contact concerning requests for settlement of complaints
Personal Information Protection Consultation Service Office
Roppongi First Building, 1-9-9 Roppongi, Minato-ku, Tokyo, 106-0032
Tel: 03-5860-7565 / 0120-700-779

Point of contact for inquiries concerning personal information

Please contact the following with respect to requests for the disclosure (including disclosure of third-party provision), correction, deletion or termination of use of personal information or other inquiries concerning personal information.

Works Human Intelligence Co., Ltd.
Personal Information Inquiries Office
21st Floor Ark Mori Building, 1-12-32 Akasaka, Minato-ku, Tokyo, 107-6021
Tel: 03-5575-5279
E-mail: privacy@works-hi.co.jp
Reception hours: 9:30 a.m. – 6:30 p.m. weekdays
(excluding Saturdays, Sundays, public holidays and the Company’s holidays)

 

 

Website’s security measures and cookie policy

 

Technology for safe site display

The Company’s website uses encrypted communication using SSL/TLS as security for protecting personal information. SSL/TLS is a common technology used as a communication safety measure on websites and prevents interception by encrypting data that has been input before transmission on the internet.

Cookie policy

Cookie is a small data file which the website writes on the user’s hard disk when the user accesses the website and is used for recognizing pages accessed by the user. Cookie information is exchanged between the website and the user’s internet browser, but it is not possible to read from the website side, cookies and other data on the hard disk written by other websites.
The Company, using cookies and other tracking technologies (for example, Web beacon), collects information, including identifiers such as IP address, etc. concerning the customer’s records of access and situation of use of this website (hereinafter “Cookie Information”).

 1.The Company shall use Cookie Information and the results of analysis of such information for the following purposes.

• Appropriately and safely managing and operating this website
• Statistically analyzing the customer’s records of use of this website and upon linking it to the user’s personal data, utilizing it for improving the convenience of this website and in sales activities, etc. concerning the Company’s products and services, etc.
• Transmitting advertisements, etc. concerning the Company, the Company’s group companies or the Company’s products and services, etc. on websites managed by partner business operators, corresponding to preference by analyzing information such as browsing histories and inquiries, etc. obtained on this website.

Unless the customer’s prior approval is obtained, this website shall not obtain for statistical information, any information (name, address, telephone number, e-mail address, etc.) from Cookie Information from which the relevant individual can be identified.

 2.In the measurement and analysis of the situation of use of this website, the Company shall use mainly the following tools and may, at times, provide information to the tool provider. In such event, information provided shall be used for the purpose set forth in the terms of use or privacy policies of each of the tool providers, in addition to the purposes set forth in Paragraph 1. Please confirm the tool provider’s website with respect to the handling of information acquired by each tool and procedures for terminating transmission of information to the tools.

Tools used for the Company’s acquisition and analysis, etc. of information (tool provider)	Privacy policy of tool providing company	Procedures for terminating transmission of information to tools
Google Analytics (Google LLC)	Google Privacy Policy GOOGLE’s use of information collected from sites and apps that use GOOGLE’s services	Google Analytics opt-out add-on
Marketing Cloud Account Engagement(former Pardot) (salesforce.com, inc.)	Salesforce: Statement concerning privacy Salesforce Basic Policy on Protection of Personal Information	Please change the browser’s setting and invalidate the domain “pardot.com” cookie

 

 3.The Company may, at times, provide statistical information concerning this website to advertisement delivery companies that have been consigned the delivery of advertisements, in order to display advertisements of the Company, etc. on other companies’ websites. The delivery of advertisements by advertisement delivery companies may be terminated by taking opt-out procedures on the opt-out pages, etc. of the advertisement delivery companies.

Advertisement delivery server (advertisement delivery company)	Privacy policy of advertisement delivery company	Procedures for opt-out
Google Ads Google AD manager (Google LLC)	Google Privacy Policy	Block specific advertisements
Yahoo Advertising (Yahoo, Inc.)	Privacy Policy	Use of personal data in advertisements, etc. transmitted by Yahoo! JAPAN
Facebook Ads (Meta Platforms, Inc.)	Privacy Policy	Management of advertisements shown
X Ads (X, Inc.)	X Privacy Policy	Setting for displaying customized advertisements

[Formulated August 1, 2019]
[Revised October 17, 2024]