Ayudante, Inc. (the “Company”) hereby establishes this Privacy Policy (this “Policy”) as follows, with regard to the handling of personal data in accordance with the EU and UK General Data Protection Regulation (respectively referred to as the “EU GDPR” or the “UK GDPR” and collectively referred to as the “GDPR”).
If you are a customer who is not subject to the GDPR, please refer to the separate Privacy Statement.
If this Policy conflicts with any other terms and policies on the processing of personal data, this Policy shall prevail over such terms and policies.
1.Types of Personal Data Processed by the Company
The types of personal data the Company collects and processes shall be as follows:
| Data Subjects | Specific Types of Data |
| Business partners | ・Name, phone number, signature, e-mail address, physical address, date of birth, company name and company address, department, job title, gender, nationality, and other contact information; ・Communications with Company personnel; ・Photographs, surveillance images and other image data; ・Information for identity verification which are required by applicable laws, etc., such as driver’s license, passport, national ID number, social security number and proof of residence; and ・Personal data required pursuant to statutory provisions. |
| Officers and employees, etc. | ・Name (including legal and preferred names), phone number, signature, e-mail address, physical address, date of birth, job title, gender, nationality, other contact information, professional qualifications, previous work experience, education level, competencies and skills, current base compensation, personal interests, curriculum vitae; ・Communications with Company personnel; ・Photographs and other image data; ・Information for identity verification which are required by applicable laws, etc. such as driver’s license, passport, national ID number, social security number and proof of residence; and ・Personal data required pursuant to statutory provisions. |
| Job applicants | ・Name (including legal and preferred names), phone number, signature, e-mail address, physical address, date of birth, gender, nationality, other contact information, professional qualifications, previous work experience, education level, competencies and skills, personal interests, curriculum vitae; ・Communications with Company personnel; ・Photographs and other image data; ・Information for identity verification which are required by applicable laws etc. such as driver’s license, passport and proof of residence; and ・Personal data required pursuant to statutory provisions. |
| Stockholders | ・Name, phone number, signature, e-mail address, physical address, date of birth, company name and company address, department, job title, gender, nationality, and other contact information; ・Communications with Company personnel; ・Photographs, surveillance images and other image data; ・Information for identity verification which are required by applicable laws etc. such as driver’s license, passport, national ID number, social security number and proof of residence; and ・Personal data required pursuant to statutory provisions. |
| Website visitors | ・Cookie ID, advertising ID, IP address and other online identifiers; ・Browser type and version, operating system, and device identifiers; ・Information about pages visited, time spent on each page, and navigation paths. |
2.Purposes and Legal Basis for Processing
The purposes of the processing that the Company will perform and the legal basis for the processing shall be as follows:
| Categories of Personal Data | Purposes | Legal Base |
| Business Partners | Providing the Company’s services | ・Necessary for the performance of a contract or to take steps at the request of the data subject prior to entering into a contract ・Necessary for the Company’s legitimate interests (to conduct our business) |
| Planning, researching and developing the Company’s services | ・Necessary for the Company’s legitimate interests (to improve our products and services) | |
| Publicizing, advertising and promoting the sales of the Company’s services and the services of the Company’s business partners (including use for the purpose of information analysis and marketing, as well as sending information about products, services, exhibitions and events by email, direct mail, etc.) | ・Necessary for the Company’s legitimate interests (to perform marketing activities) ・Consent (only if required by law) | |
| Performing services regarding the execution of and support for agreements with clients | ・Necessary for performing contracts or taking steps at the request of the data subject prior to entering into a contract ・Necessary for the Company’s legitimate interests (to conduct our business) | |
| Contacting visitors to the Company’s exhibitions and events | ・Necessary for the Company’s legitimate interests (to conduct our business) | |
| Responding to inquiries and consultations made to the Company | ・Necessary for performing contracts or taking steps at the request of the data subject prior to entering into a contract ・Necessary for the Company’s legitimate interests (to conduct our business) | |
| Managing the history of visitors to the Company | ・Necessary for the Company’s legitimate interests (to conduct our business) | |
| Officers and Employees, etc. | Performing labor and employment management of employees and other procedures required by the Company for itsbusiness | ・Necessary for performing contracts or taking steps at the request of the data subject prior to entering into a contract ・Necessary for the Company’s legitimate interests (to operate labor and employment management) ・Necessary for compliance with a legal obligation |
| Corresponding with, providing information to and sending items for distribution to retired employees | ・Necessary for the Company’s legitimate interests (to operate labor and employment management) | |
| Job applicants | Performing screening for recruitment of and administrative procedures for people who have applied for recruitment or internships | ・Necessary for performing contracts or taking steps at the request of the data subject prior to entering into a contract ・Necessary for the Company’s legitimate interests (to conduct our recruiting activities) ・Necessary for compliance with a legal obligation |
| Stockholders | Performing services regarding the rights and obligations of shareholders and other stakeholders under the Companies Act and other laws and regulations, such as sending notices of convening and managing attendance at shareholder meetings | ・Necessary for performing contracts or taking steps at the request of the data subject prior to entering into a contract ・Necessary for the Company’s legitimate interests (to conduct our business) ・Necessary for compliance with a legal obligation |
| Website visitors | Operating our website properly | ・Necessary for our legitimate interests (to conduct our business) |
| Analysing the behaviours of website visitors and measuring performance of our website | ・Necessary for the Company’s legitimate interests (to improve our services) ・Consent | |
| Enabling the functions of our website by personalising our content to you and remembering your preferences | ・Necessary for the Company’s legitimate interests (to improve our services) ・Consent | |
| Targeting website visitors to make our website and the advertising displayed on it more relevant to your interests | ・Consent |
3.Sources of Personal Data
The Company will collect personal data in the following ways:
A) Information that you provide to the Company: This includes information about you that is provided by you when filling in forms or when you are communicating with the Company, whether face-to-face, by phone, by e-mail or otherwise;
B) Information that the Company collects or generates about you: This includes data from and about you through automated technologies or interactions. As you interact with the Company’s website, the Company will automatically collect technical data about your equipment as well as your browsing actions and patterns. the Company collects this personal data by using cookies and other similar technologies; and
C) Information the Company obtains from other sources: This includes data provided to the Company by the Company’s affiliates and subsidiaries, third-party service providers, agencies or other publicly available sources where applicable.
4.Sharing and Disclosure of Personal Data
The Company shares and discloses personal data to the following third parties in accordance with the GDPR for the purposes of processing described in “2. Purposes and Legal Basis for Processing” above:
- Any of our group companies, including our affiliates and subsidiaries;
- Service providers, including IT infrastructure service providers and security service providers;
- Business partners, including ad serving and analytics service companies;
- Police and competent government authorities when it is necessary to comply with legal obligations, including where an obligation arises as a result of a voluntary act; and
- Third parties when it is necessary for some other justifiable reasons that are permitted by applicable laws and regulations.
5.International Transfer
The Company will transfer personal data in some cases to third countries and regions outside the EEA and the UK. These countries and regions include, without limitation, Japan, the United States, Canada, and Singapore. If these countries and regions are deemed by the EU and/or the UK to provide an adequate level of data protection, then the Company will transfer personal data based on the adequacy decision under Article 45(1) of the GDPR. If these countries and regions are not recognised as countries and regions that provide an adequate level of data protection, then the Company will implement appropriate safeguards by executing one or more of the following with the transferee: (i) the European Commission’s Standard Contractual Clauses (EU SCC) for the EU under Article 46(2)(c) of the EU GDPR; or (ii) the International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum to the EU SCC (Addendum) for the UK under Article 46(2)(d) of the UK GDPR. If you wish to receive documentation related to these safeguards, please inquire via the contact information provided in “10. Contact”.
6.Data Security
The Company has put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, or altered or disclosed. In addition, the Company limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know the same. These parties will only process your personal data based on the Company’s instructions and they are subject to a duty of confidentiality. Moreover, the Company has put procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach in cases where the Company is legally required to do so.
7.Data Retention
The Company will only retain your personal data for as long as reasonably necessary to fulfil the purposes of processing described in “2. Purposes and Legal Basis for Processing” above. However, the Company may retain your personal data for a longer period if the Company needs to do so in order to comply with any legal, regulatory, tax, accounting or reporting requirements, or if the Company reasonably believes there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, the Company considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which the Company processes your personal data and whether the Company can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.
8.Your Legal Rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Right to object to the processing: You have the right to object to the processing of your personal data in certain situations;
- Right to information: You have the right to be informed about whether and to what extent the Company processes your data;
- Right of access: Subject to certain exceptions, you have the right to obtain confirmation as to whether or not the Company processes your personal data, and if so, the right to request access to your data;
- Right of rectification: If the personal data that the Company processes is incomplete or incorrect, you have the right to request the completion or correction thereof at any time;
- Right to deletion: Subject to certain exceptions, if you consider that the Company should stop processing some or all of your personal data, you have the right to request its deletion. However, there may well be reasons why immediate deletion may not be possible (such as where retention is required in order to meet legal or regulatory obligations);
- Right to restrict the processing: You have the right to request that the Company restricts the processing of your personal data;
- Right to data portability: Where the processing takes place on the basis of your consent or contract, and is carried out by automated means, you have the right to request that the Company provide your personal data to you in a machine-readable format;
- Rights in relation to automated decision making and profiling: You have the right to object to decisions based exclusively on the automated processing of your personal data; and
- Right to withdraw your consent: If your personal data is processed on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
Personal data that must mandatorily be provided is indicated in the relevant forms that you complete. In cases where the provision of personal data is mandatory, the Company is not able to provide our products and/or services to you if the relevant information is not provided.
9.Cookies and Similar Technologies
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10.Contact
For any questions or inquiries regarding this Policy, such as in relation to security control measures, please contact the Company’s Inquiry Counter or the Company’s representative in the EU and UK to which you provided personal data. The contact details of the Company and the Company’s representative are as follows.
A) Data Controller
Ayudante, Inc.
Kojimachi Central Building 6F, 2-2-4, Kojimachi, Chiyoda-ku, Tokyo (102-0083)
Telephone: 03 – 3239 – 8441
E-mail: info8441@ayudante.jp
(Hours of Operation: 11:00 a.m. to 5:00 p.m., excluding weekends and holidays)
B) Representative
Address: Kojimachi Central Building 6F, 2-2-4, Kojimachi, Chiyoda-ku, Tokyo (102-0083) Ayudante, Inc.
Telephone: +81-3 – 3239 – 8441
E-mail: info8441 (at) ayudante.jp
Established on 12,February 2025