Link Technology Co., Ltd.
Atsushi Kawai, President
Link Technology Co., Ltd. will observe laws and regulations regarding the protection of personal information, and considering the importance of out clients personal information, we will handle out clients personal information that we collect and manage, according to the following policies to protect personal information.
Effective as of August 1, 2011
Link Technology recognizes the importance of protecting personal information in an advanced information and communication society and believes that safely and properly handling the personal information of all those with whom we interact, from our customers and the representatives of our business partners to our employees, is an important social responsibility.
The job title and contact information for the manager in charge of protecting personal information are provided below. This person bears full responsibility for promoting, maintaining, implementing and improving the internal personal information protection system.
Personal Information Protection Manager
The personal information we handle can be broken down into the main categories below.
We only collect personal information using fair and legal means. Moreover, in accordance with our management system for the protection of personal information, we obtain the consent of the individual prior to collecting the information.
When working with indirectly collected personal information entrusted to us by clients, we confirm with our clients that they have obtained the consent of the individual.
However, we may forgo this in the event that we determine that notifying or disclosing information to the individual or obtaining their consent would put their life/property or that of a third party at risk or violate the law. Such decisions will not be made arbitrarily but objectively based on logical reasoning and common sense.
When we collect personal information from an individual directly in writing, we explain the voluntariness as well as the impact on the individual if we are unable to obtain the information on a case by case basis. In many cases, if we are unable to obtain certain personal information, we likely will not be able to provide the individual with services involving said information, but depending on the item, there are also many pieces of information for which provision is voluntary, so in addition to individual points of contact, we also have a point of contact for complaints and inquiries provided below.
We use personal information only within the scope of the purpose to which the individual has given their consent.
The purpose of use of personal information we handle within our business is as follows:
Within the scope of the purpose of use to which the individual has given their consent, we may share or disclose the personal information we have collected with third parties.
We share/disclose personal information primarily in the following work/formats:
When we take on information processing/software development work, we may entrust a third party with the handling of personal information with the consent of the client in order to serve the purpose. When entrusting a third party with the handling of personal information, we select a business partner that meets a certain level of requirements regarding the proper protection of such information in accordance with our management system for the protection of personal information, and we conclude a confidentiality agreement with them, checking and monitoring the handling of the information after the work is assigned and managing/overseeing the information until it is returned or destroyed after the work is complete.
We may provide the personal information of employees to a third party when subcontracting the preparation of company PR materials (such as brochures and websites) or labor/social insurance operations. In such cases, we handle selection of the company and conclusion of agreements in the same way as subcontracting of software development.
We retain the personal information we collect for a certain period of time based on internal document control rules according to the format, type, etc. of the information. In particular, with regards to the information of job applicants, policy holders, shareholders and employees for which we have responsibility corresponding to the individual's rights as presented in the following paragraph, there are some items we retain even after the individual is no longer affiliated with us (due to cancellation, leaving the company, etc.) in order to respond to legal requirements and resolve subsequent problems.
We implement reasonable and appropriate safety measures with respect to risk pertaining to personal information based on the rules of our management system for the protection of personal information as we go about managing the personal information we collect (from collection to return or disposal).
In the event that we receive a request from the individual to which the personal information we retain or manage belongs to exercise the rights described below, we will take action (including deciding whether the request is appropriate or not) and notify the individual of the result (including the reason we were unable to comply with the request if we were unable to do so) without delay.
The points of contact for the respective services will respond to inquiries regarding the procedures for such requests and will explain the contents of disclosure, format, external proof (means to confirm identity) required of the individual or his/her proxy, etc. In the event that the point of contact is unknown, the point of contact for complaints and inquiries below will handle the request or direct you to the appropriate point of contact.
By periodically educating about and familiarizing employees with our management system for protecting personal information, we will maintain its proper operation, and by regularly auditing the system and reviewing it under the direction of the company president, we will engage in ongoing improvements to as well as promotion and maintenance of the system.
We have established a point of contact for complaints and inquiries which takes complaints and inquiries regarding all the personal information in our care from the individual in question. This point of contact will also respond to requests for disclosure or discontinuation of use of personal information on behalf of the division in charge of collecting or using the information.
Link Technology Co., Ltd.
Omori-Honda, 2F, 3-35-14 Minami-Ooi, Shinagawa-ku, Tokyo 140-0013, Japan