Privacy Policy

April 13, 2022
i Cubed Systems, Inc.
Tsutomu Sasaki, President and CEO

In consideration of the fact that we engage in development and provision of services based on information technology as a software platform vendor, upon recognition that personal information is important property of individuals, we will establish a personal information protection management system and strive for continuous improvement thereof, to properly acquire, use and provide personal information, comply with laws and regulations regarding personal information and prevent and rectify leaks, etc. of personal information.

• Proper acquisition, use and provision of personal information
  We will properly acquire, use and provide personal information. We will specify the purpose of use to the extent possible during acquisition, and take measures to prohibit the handling of personal information beyond the range necessary to achieve the specified purpose of use to prevent this, and in principle, we will not provide personal data to third parties without the consent of the individual. Furthermore, when providing personal data to a third party, and when outsourcing business processing, we will conclude contracts so that the personal data will not be leaked or re-provided, and have those parties implement appropriate management.
  * For details on the purpose of using personal information, please refer to our “Handling of Personal Information” below.
• Prevention and correction of leaks, etc. of personal data
  We will prevent leaks, loss or damage of personal data by operating a reasonable security management system according to the importance of the personal data, and should any leak, etc. occur, we will strive to rectify it in consideration of internal and external opinions and suggestions.
• Compliance with laws and regulations and other norms regarding personal information
  We will comply with the laws and regulations related to personal information including the Act on the Protection of Personal Information, as well as the guidelines and other norms set by the government, while paying attention to their enactment and revision as well.
• Continuous improvement of personal information protection management system
  We appoint a personal information protection manager, give responsibility and authority for the implementation and operation of the personal information protection management system thereto, and continuously review and improve the contents of the personal information protection management system.
• Contact information
  We will strive to respond appropriately to inquiries and complaints regarding personal information. For inquiries regarding our handling of personal information and the personal information protection management system, please contact us at the following contact point. In addition, for requests for disclosure, correction, suspension of use, etc. of retained personal data, and disclosure of records of provision to third parties, etc., please see Matters for Notification Regarding Retained Personal Data" below.

• Name of the company, address and name of representative
  i Cubed Systems, Inc.
  4th Floor, Dai'ichi Myojo Building, Tenjin 4-1-37, Chuo-ku, Fukuoka 810-0001
  Tsutomu Sasaki, President and CEO
• Purpose of use of personal data retained by us
  For details on the purpose of using personal information, please refer to our “Handling of Personal Information” below.
• About measures taken for the security management of our retained personal data
  (Formulation of basic policy)
  For the proper handling of personal information, we have formulated a Privacy Policy regarding “compliance with relevant laws and regulations, and guidelines, etc.” and “contact point for handling questions and complaints,” etc.
  (Development of discipline regarding the handling of personal data)
  We have put in place basic handling methods for acquiring, using and storing personal data, etc.
  (Organizational security management measures)
  In addition to conducting regular self-checks regarding the handling status of personal data, we also have other departments and external parties carry out audits.
  (Personnel security management measures)
  We provide regular training to employees regarding points to note on the handling of personal data.
  (Physical security management measures)
  We take measures to prevent theft or loss, etc. of devices, electronic media and documents, etc. that deal with personal data.
  (Technical security management measures)
  We have introduced mechanisms to protect information systems that deal with personal data from unauthorized access or software from the outside.
• Where to file complaints regarding the handling of retained personal data
  

  4th Floor, Dai'ichi Myojo Building, Tenjin 4-1-37, Chuo-ku, Fukuoka 810-0001
  
  i Cubed Systems, Inc.
  Personal Information Inquiry Desk

  Email:privacy@i3-systems.com

• Name of the authorized personal information protection organization with which we are affiliated and the contact point for requests for resolution of complaints
  We do not belong to an authorized personal information protection organization.
• Procedures for disclosure, etc. of retained personal data (*The same shall apply to disclosure procedures for “records related to provision to a third party” and “records when receiving provision from a third party” created by the us)
  (i) Where to make a request for disclosure, etc.
  Please mail us the documents prescribed by us as described in the subsequent item.
  (ii) Document formats to be submitted when requesting disclosure, etc. and other methods for requesting disclosure, etc.
  ・- Application form for requesting, etc. retained personal data prescribed by us (as the disclosure method, please select either sending as an e-mail attachment, or written reply. If no selection is made, we will reply in writing.)
  - One copy of an official document with a photo that can be used for identification
  (iii) How to confirm that the person making the request for disclosure, etc. is an agent If the person requesting disclosure, etc. is a legal agent of a minor or an adult ward, or an agent delegated by the principal to make request for disclosure, etc., in addition to the documents as referred to in the preceding paragraph, please enclose the certification materials or power of attorney prescribed by us.
  (iv) No fee will be charged for requests for disclosure, etc.

• Purpose of use of personal information
  We use personal information for the following purposes.
  

  (1)Personal information acquired on CLOMO business

  Items of personal information to be acquired	Purpose of use
  - Personal information about devices (owner's name, owner's email address, phone number, latitude, longitude, location information acquisition date and time, outgoing phone number, incoming phone number, incoming and outgoing call date and time, etc.) - Personal information about users (name, employee code, UPN, portrait photo, company address, company phone number, company extension number, company fax number, sub-email address, organization code, job title, etc.)	(i) Initial settings related to CLOMO, account management and other operation proxy service (ii) Troubleshooting and operating instructions for CLOMO
  Personal information about 24/365 services (reporter's name, contact information, etc.)	Provision of remote control proxy operating services such as remote wiping

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  *The user data that the user inputs and saves on a cloud server such as Microsoft Azure through the programs provided by us in the CLOMO service is information directly input and saved by the user in the operating company of said cloud service such as Microsoft Corporation, and we have no management responsibility for this.
  * In programs provided by us in the CLOMO service, if users desire to control apps provided by third parties such as Google LLC or Apple Inc., the operation log, location information, etc. of the said app may be automatically transferred to the app provider. However, we will not incorporate such automatic transfer programs into the CLOMO service unless so instructed by the user.

  (2)Personal information acquired when responding to inquiries and conducting sales activities

  Items of personal information to be acquired

  Purpose of use

  - Name, company name, company address, affiliated department, e-mail address, etc.

  (i) Responding to inquiries such as requesting materials and applying for use of evaluation software (ii) Solicitation activities via telephone or e-mail regarding the use of various services provided by us or a third party affiliated with us (iii) Delivery of news emails about us and our services (iv) Various communications such as on contract renewal (to coordinators at the client company) (v) Sales support (for coordinators at our partner companies)

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  (3)Personal information acquired upon hiring

  Items of personal information to be acquired	Purpose of use
  Name, email address, phone number, address, gender, date of birth, educational background/work history, discipline or awards, qualifications, number of spouse and dependents	For consideration in hiring

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  (4)Personal information acquired when outsourcing

  Items of personal information to be acquired	Purpose of use
  Name, email address, phone number, Individual Number (number verification, identity verification material), savings account no., etc.	(i) For ordering operations processing (ii) For proper tax processing such as preparation of payment records

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  (5)Personal information of employees

  Items of personal information to be acquired	Purpose of use
  Name, email address, phone number	For business communications
  Name, address, date of birth, Individual Number, dependent information, etc.	For employment personnel management, assignment, preparation of employee name list, provision of welfare and benefits, withholding procedures, social insurance related procedures, legally required procedures, and other employment management
  Savings account no.	Payment of salary, etc.
  Physical and health information	Physical and health information (for health management, ensuring an appropriate working environment, leave of absence, assignment determinations, working hour management, and other employment management)

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• Outsourcing of personal data
  We may outsource the handling of personal data to a third party if necessary to achieve the purpose of use specified in advance. In this case, we will properly manage and supervise the outsourcee.
• Matters for notification regarding retained personal data
  For the purpose of use and disclosure procedures regarding personal data retained by us (including disclosure of our records of provision to third parties), see Matters for Notification Regarding Retained Personal Data.