1. Protection of Personal Information
Morpho Inc. (hereinafter, referred to as “COMPANY”) understands social importance of protecting Personal Information (as defined below) and presumes appropriate protection and management of the information to be important responsibility. COMPANY shall handle Personal Information as follows.
- a) COMPANY shall acquire Personal Information by a legitimate and fair means in compliance with applicable personal information protection laws and in accordance with generally accepted personal information handling practices.
- b) COMPANY shall specify the purposes of process in case of acquisition of Personal Information and process the information only within a scope of the purposes.
- c) If Personal Information handling is entrusted to a third party, COMPANY shall implement impartial investigation on the third party and carry out necessary and appropriate measures for confidentiality.
- d) If a Data Subject (as defined below) himself/herself requests to disclose, correct or delete his/her Personal Information held by COMPANY or disconnect the service, COMPANY shall accept the request in a prescribed manner and treat the request properly.
- e) COMPANY shall articulate rules regarding to Personal Information handling and inform employees of the rules, while restructuring an internal organizational system properly.
- f) COMPANY shall take necessary measures for preventing leakage, loss and falsification of Personal Information and manage the information appropriately.
2. Personal Information
Personal Information means any information relating to identified or identifiable natural person (“Data Subject”), including name, address, date of birth, telephone number, email address or identification number of the individual, or the Data Subject’s image or voice, and information by which an individual can be identified or specified in combination with other information.
The provision of Personal Information is not a statutory or contractual requirement unless COMPANY designates specifically. However, it may be necessary to enter into a contract, in such case, failure to provide such information may cause to miss some business opportunities.
3. Purpose of the Processing
If a Data Subject provides or COMPANY collects his/her Personal Information which is required for COMPANY’s business operation, COMPANY will not process the information out of a scope of proper purposes without his/her consent, unless it is required in a state of emergency regarding laws, life crisis and public hygiene or it is permitted by laws and regulations. COMPANY will process the Personal Information only within a scope of the following purposes of processing:
- a) planning, development, sales, provision, support and maintenance of COMPANY’s products and services;
- b) notification, publicity, campaign, event and questionnaire survey regarding to COMPANY’s products and services etc.;
- c) data collection for planning and examining improvement of COMPANY’s products and services etc.;
- d) execution of contract and exercise and preservation of COMPANY’s rights;
- e) reply to inquiries etc.;
- f) implementation of business operations accompanying the above operations.
4. Legal Basis for the Processing
COMPANY may process Personal Information only if and to the extent that at least one of the following applies:
- a) the Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which COMPANY is subject;
- d) processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; or
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in COMPANY.
The Data Subject has the right to withdraw consent set forth above at any time, without affecting the lawfulness of processing based on consent before its withdrawal, and the right to lodge a complaint with a supervisory authority.
COMPANY may transfer Personal Information to third countries where an adequacy decision by the European Commission is absent; provided, however, that COMPANY provides appropriate safeguards by standard data protection clauses adopted by the European Commission.
6. Disclosure and Provision to Third Party
COMPANY may occasionally entrust an external body with a part of its business operations in order to smoothly implement the operations. If a necessary range of Personal Information is provided to the external body, COMPANY shall carry out necessary and appropriate measures for protecting the Personal Information, e.g. making an agreement concerning Personal Information handling with the external body. COMPANY shall not disclose or provide the Personal Information to a third party unless the information is provided to the above external body or it is applicable to the following cases:
- a) With consent of the Data Subject;
- b) When the information is disclosed or provided as a part of statistical data so that the Data Subject is not identified;
- c) When disclosure or provision is required by laws and regulations;
- d) When the business is succeeded due to M&A, organizational division, business transfer and other grounds.
- e) When interests of the Data Subject or a third party including life, body, property or other rights may be harmed and at the same time it is difficult to obtain consent of the Data Subject.
- f) When the information is necessary for cooperating in execution of duties required by laws and regulations, and the execution of duties may be hindered by process of obtaining consent of the Data Subject.
- g) When it is permitted by laws and regulations or with sufficient reason.
7. Inquiry for Personal Information
The Data Subject has the right to request from COMPANY access to and rectification or erasure of Personal Information or restriction of processing concerning the information subject or to object to processing as well as the right to data portability. If the Data Subject exercise such rights , the Data Subject is advised to contact COMPANY as follows:
- a) through [contact us] on its website.
- b) ring to “general affairs & human resource group., personal information section (+81-3-3288-3288)”.
- c) email to “Zipango, S. L.” (infor★zipango.com), COMPANY’s representative. (*Please replace “★” with “＠”.)
After confirming that the inquirer is a person who is entitled to the request, COMPANY shall appropriately deal with the request as far as it could within a reasonable term. Note that the inquiry will not be accepted if the Data Subject directly visits COMPANY for the inquiry.
8. Management of Personal Information
COMPANY shall appropriately and carefully handle Personal Information and settle a position responsible for information management in order to ensure accuracy and safety of Personal Information. The person in charge of information management shall:
- a) implement safety control for Personal Information such as prevention and adjustment of unauthorized access to Personal Information and loss, destruction, falsification and leakage of Personal Information;
- b) determine the minimum period for which Personal Information will be stored in consideration of the business necessities of COMPANY and the nature of the information; and
- c) educate employees on appropriate handling of Personal Information.
9. Application and Modification