ZENSHO AGENCY GROUP PRIVACY POLICY

I​NTRODUCTION

Welcome to Zensho Agency’s (“Zensho”) privacy policy.

We are a recruiting business operator approved by Japan’s Ministry of Health, Labour and Welfare and we use personal information in compliance with Japan’s personal information protection law and other applicable laws.

Zensho respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we collect, use and/or retain your personal data and tell you about your privacy rights and how the law protects you.

1. I​MPORTANT​ ​INFORMATION​ ​AND​ ​WHO​ ​WE​ ​ARE

P​URPOSE​ ​OF​ ​THIS​ ​PRIVACY​ ​POLICY

This privacy policy aims to give you information on how Zensho collects and processes your personal data, including any data you may provide through this website when you visit our website and/or contact us.

Our services and this website are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

C​ONTROLLER

Zensho is made up of different legal entities, which includes Zensho Agency Kabushiki Kaisha (a Japanese company) and Zensho Agency Ltd (a company registered in England). This privacy policy is issued on behalf of the Zensho Agency Group so when we mention “Zensho”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Zensho Group responsible for processing your data. Zensho Agency Kabushiki Kaisha is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

C​ONTACT​ ​DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Zensho Agency Kabushiki Kaisha
Email address: dpo@zensho.co
Postal address: Akasaka 2-9-2-3F, Minato-ku, Tokyo, 107-0052, Japan

If you are based in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (​www.ico.org.uk)​ . If you are based elsewhere in the EU, there are different supervisory authorities in the various different member states. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.

C​HANGES​ ​TO​ ​THE​ ​PRIVACY​ ​POLICY​ ​AND​ ​YOUR​ ​DUTY​ ​TO​ ​INFORM​ ​US​ ​OF​ C​HANGES

We keep our privacy policy under regular review and update it from time to time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

T​HIRD​ – ​PARTY​ ​LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. T​HE​ ​DATA​ ​WE​ ​COLLECT​ ​ABOUT​ ​YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes your name, username or similar identifier, marital status, title, date of birth, gender and educational and occupational backgrounds including your positions.
• Contact Data includes email address, telephone numbers and location.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We will collect, use and share Aggregated Data in accordance with this privacy policy and in consistent with the requirements under the applicable local law.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, social status, political opinions, trade union (labor union) membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences or information that you were a victim of a crime.

I​F​ ​YOU​ ​FAIL​ ​TO​ ​PROVIDE​ ​PERSONAL​ ​DATA

Where we need to collect personal data by law and you fail to provide that data when requested, we may not be able to perform the service you have requested.

3. H​OW​ I​S​ ​YOUR​ ​PERSONAL​ ​DATA​ ​COLLECTED​ ?

We use different methods to collect data from and about you including through:

• Direct interactions​. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you give us feedback or contact us.
• Automated technologies or interactions​. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources​. We will receive personal data about you from various third parties and public sources, such as those set out below:
  • Technical Data from analytics providers
  • Identity and Contact Data from data brokers or aggregators
  • Identity and Contact Data from publicly available sources
  • Identity and Contact Data from social and other networking sites, such as Facebook, Twitter, Instagram and LinkedIn.

4. H​OW​ ​WE​ ​USE​ ​YOUR​ ​PERSONAL​ ​DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Please see the end of this document to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We will also obtain your consent when sharing your personal data you have specifically provided to us (e.g., your resume) with our corporate clients.

P​URPOSES​ ​FOR​ ​WHICH​ ​WE​ ​WILL​ ​USE​ ​YOUR​ ​PERSONAL​ ​DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) dealing with an enquiries made by you	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how people use our website)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Usage (d) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you. This will include, for the purpose of our recruiting business, use of your personal data to provide hiring information to you or to match you with job opportunities or companies, and to provide you with other recruiting related services.	(a) Identity (b) Contact (c) Technical (d) Usage	Necessary for our legitimate interests (to develop our products/services and grow our business)

O​PTING​ ​OUT
You can ask us or third parties to stop sending you messages at any time by contacting us at any time.

Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of your contact with us.

C​HANGE​ ​OF​ ​PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. D​ISCLOSURES​ ​OF​ ​YOUR​ ​PERSONAL​ ​DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out below.
• External Third Parties as set out below.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law, e.g., we require that our third parties have established a personal data protection system that satisfies the standards equivalent to the ones applied in EEA or Japan, as applicable. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In addition, as stated above, we will obtain your consent when sharing your personal data you have specifically provided to us (e.g., your resume) with our corporate clients.

6. I​NTERNATIONAL​ ​TRANSFERS
We share your personal data within the rest of the Zensho Agency Group. This will involve transferring your data outside Japan or the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

Many of our external third parties are based outside Japan or the EEA so their processing of your personal data will involve a transfer of data outside Japan or the EEA.

Whenever we transfer your personal data out of Japan or the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Japanese government or European Commission, or when can rely on another legal ground which allows us to transfer your personal data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Japan or the EEA.

7. D​ATA​ ​SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know to perform their duties or obligations. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. D​ATA​ ​RETENTION

H​OW​ ​LONG​ ​WILL​ ​YOU​ ​USE​ ​MY​ ​PERSONAL​ ​DATA​ ​FOR​ ?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see the section on your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information for a longer period without further notice to you.

9. Y​OUR​ ​LEGAL​ ​RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.

If you wish to exercise any of the rights set out above, please contact us.

N​O​ ​FEE​ ​USUALLY​ ​REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

W​HAT​ ​WE​ ​MAY​ ​NEED​ ​FROM​ ​YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. G​LOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

I​NTERNAL​ T​HIRD​ P​ARTIES

Other companies in the Zensho Agency Group acting as joint controllers or processors and who are based in the UK and Japan and provide IT and system administration services and undertake leadership reporting.

E​XTERNAL​ T​HIRD​ P​ARTIES

• Our service provision partners and consultants acting as processors or jointcontrollers with whom we work to provide our services.
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Our corporate clients.

YOUR LEGAL RIGHTS
You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.