Global Privacy Policy for BIPROGY Group
Formulation: June 2, 2025
BIPROGY Group Companies (meaning the companies set out in the Corporate Information page of our website; the same applies hereinafter; “BIPROGY Group Companies,” “we,” or “our”) process the personal information of each of our customers, other similar trading partners (including our partners), and shareholders (including the officers or employees of that customer, other similar trading partner, or shareholder if it is an entity; in addition, including potential trading partners and persons who have accessed websites of BIPROGY Group Companies; the same applies hereinafter), as well as job applicants for, and former employees of, BIPROGY Group Companies (collectively, “identifiable persons,” unless specified otherwise) as follows.
websites of BIPROGY Group Companies
In addition to this Global Privacy Policy for BIPROGY Group Companies (this “Global Privacy Policy”), the following country-specific exhibit may also apply to an identifiable person depending on the areas in which BIPROGY Group Companies that process the identifiable person’s personal information are located and the area in which the identifiable person resides or is located, so please refer to the country-specific exhibit. If this Global Privacy Policy conflicts with the country-specific exhibit, then the country-specific exhibit will prevail to the extent that such conflict exists.
EEA (European Economic Area) and UK Exhibit
BIPROGY Group Companies may also prescribe individual privacy policies, and in this case, if this Global Privacy Policy conflicts with an individual privacy policy, then the individual privacy policy in question will prevail to the extent that such conflict exists.
1.Categories of personal information subject to processing
BIPROGY Group Companies process the following personal information and other personal information BIPROGY Group Companies have obtained in relation to business activities.
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Personal information of customers and other similar trading partners
BIPROGY Group Companies process the following personal information of customers and other similar trading partners of BIPROGY Group Companies.
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Name; address; name, location, and division of the corporation to which the customer or other similar trading partner belongs; job type; job title; telephone number; e-mail address; fax number, details of inquiries; and telephone recording information
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Other information stated on the business card of a customer or other similar trading partner
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Sales negotiation histories and information regarding details of transactions (including details of products and services to which a customer or other similar trading partner has subscribed, details of sales negotiations, and details of inquiries and estimates)
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Cookies, IP addresses, provider information, terminal information, web browser information, user activities (time of day when the website was visited, session length, frequency, transitions, traffic sources, clicks in the website, and scrolling in the website), and attributes (such as age, gender, interest categories, affinity categories, and in-market segments; for more information about interest categories, affinity categories, and in-market segments, please see here）
About Demographics and Interests – Analytics Help (google.com)
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Entry/exit records for, and video recordings of, visitors to BIPROGY Group Companies’ facilities and other similar information
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Other personal information of customers and other similar trading partners necessary for the purposes set out in “2.” in this Global Privacy Policy
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Personal information of shareholders of BIPROGY Group Companies
Each BIPROGY Group Company processes the following personal information of the shareholders of that group company.
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Name, address, e-mail address, number of shares owned, date of share acquisition, shareholder number, dividend payment history, and account for dividends
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Other personal information of shareholders necessary for the purposes set out in “2.” in this Global Privacy Policy
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Personal information of job applicants for BIPROGY Group Companies
Each BIPROGY Group Company processes the following personal information of the job applicants for that group company.
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Name, address, telephone number, e-mail address, date of birth, gender, facial portrait, name of school, faculty and department, work experience, and other information stated on the documents for application (including in an electromagnetic manner) or provided with those documents as attachments
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Other personal information of job applicants for BIPROGY Group Companies necessary for the purposes set out in “2.” in this Global Privacy Policy
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Personal information of former employees of BIPROGY Group Companies
Each BIPROGY Group Company processes the following personal information of the former employees of that group company.
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Name, address, date of birth, telephone number, e-mail address, gender, facial portrait, term of office, salary and remuneration, amount of retirement allowance and retirement bonus, and account number
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Other personal information of former employees of BIPROGY Group Companies necessary for the purposes set out in “2.” in this Global Privacy Policy
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2.Purposes of processing
BIPROGY Group Companies process personal information for the following purposes and other similar purposes permitted by applicable laws and regulations. In addition, BIPROGY Group Companies may de-identify or aggregate personal information.
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Personal information of customers and other similar trading partners
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To conduct offers, sale, or provision in relation to products, services, or support
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To send announcements regarding products, services, or events (including seminars or exhibits) handled by BIPROGY Group Companies (including announcements depending on the interests, concerns, and needs of the customer or other similar trading partner based on the product and service purchase history and other similar information of the customer or other similar trading partner)
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To conduct registration for use of services provided by BIPROGY Group Companies
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To deliver various publications
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To conduct communications, negotiations, and discussions with, and to perform contracts with, customers and trading partners (including performance of contracts with contractors for contracted services, such as system development, consulting, system support, education, and training)
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To respond to inquiries or requests from customers and trading partners (including the use of telephone recording information to ensure the accuracy of the details of conversations and appropriate responses)
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To manage the operation of training programs
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To conduct various surveys
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To upgrade and improve existing products, services, and sales activities and to develop new products and services (including upgrading, improvement, and development based on questionnaire surveys, market research, analysis of customer trends, and other such necessary analysis (including analysis of the interests, concerns, and needs of a customer or other similar trading partner based on the product and service purchase history and other similar information of the customer or other similar trading partner))
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To ensure security, such as crime prevention or disaster prevention, and for entry/exit control of buildings that BIPROGY Group Companies are responsible for managing
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To use information of a customer or other similar trading partner for the smooth operation and improvement of the services provided in our websites, such as by analyzing information of a customer or other similar trading partner that we obtain when a customer or other similar trading partner accesses our websites
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To perform other necessary duties for BIPROGY Group Companies in relation to customers and other similar trading partners
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To exercise and defend legal claims
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For procedures and cooperation in reporting and notifying government agencies and public organizations
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For audits, operation of internal report system, and to otherwise prevent and deal with unjust acts
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To perform obligations and exercise rights under applicable laws
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Personal information of shareholders of BIPROGY Group Companies
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To take necessary procedures or measures in relation to shareholders
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To communicate matters with shareholders
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For procedures and cooperation in reporting and notifying government agencies and public organizations
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For audits, operation of internal report system, and to otherwise prevent and deal with unjust acts
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To perform obligations and exercise rights under applicable laws, including the Companies Act
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Personal information of job applicants for BIPROGY Group Companies
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For recruitment procedures
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To provide information to, contact, and notify job applicants
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For procedures and cooperation in reporting and notifying government agencies and public organizations
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For audits, operation of internal report system, and to otherwise prevent and deal with unjust acts
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To perform obligations and exercise rights under applicable laws
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Personal information of former employees of BIPROGY Group Companies
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To provide personnel and labor services (including benefits) for former employees as required by law
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To provide former employees with company information, to contact former employees as necessary for social gatherings, etc., and for other former employee management purposes
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For procedures and cooperation in reporting and notifying government agencies and public organizations
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For audits, operation of internal report system, and to otherwise prevent and deal with unjust acts
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To perform obligations and exercise rights under applicable laws
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3.Legal basis, etc. for processing
BIPROGY Group Companies process personal information in accordance with the legal bases under the applicable personal information protection regulations (such as the data principal’s consent, performance of contractual obligations, legitimate interests, and compliance with laws and regulations). Please refer to the country-specific exhibit for details regarding our legal basis for processing in the country in question.
The provision of personal information may be mandatory for various reasons, such as being a statutory or contractual requirement or being a necessary condition for entering into a contract. Specific details are as follows.
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Personal information of customers and other similar trading partners
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The provision of the following is a necessary condition for entering into a contract with BIPROGY Group Companies: name; address; name, location, and division of the corporation to which the customer or other similar trading partner belongs; job type; job title; telephone number; e-mail address; and fax number. If the customer or other similar trading partner does not provide us with such personal information, the customer or other similar trading partner might not be able to use products or services of BIPROGY Group Companies.
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The provision of details of inquiries, sales negotiation histories, and information regarding details of transactions (including details of products and services to which a customer or trading partner has subscribed, details of sales negotiations, and details of inquiries and estimates) is a necessary condition for inquiries or making requests for estimates. If the customer or other similar trading partner does not provide us with such personal information, BIPROGY Group Companies might not be able to respond to inquiries or provide estimates.
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The provision of the following is a necessary condition for using our websites: cookies that are strictly necessary for the use of BIPROGY Group Companies’ websites and information regarding user activities and the like obtained by those cookies; IP addresses; and types of browser. If the customer or other similar trading partner does not provide us with this information, the customer or other similar trading partner might not be permitted to use our websites.
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The provision of entry/exit records for, and video recordings of, visitors to our facilities and other similar information is a requirement for ensuring security, such as crime prevention or disaster prevention, and entry/exit control of buildings that BIPROGY Group Companies are responsible for managing. If the visitor does not provide us with such personal information, BIPROGY Group Companies might reject the visitor’s entry to the building in question.
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In any other case where the customer or other similar trading partner does not provide us with personal information despite the fact that the provision of that personal information is a necessary condition, BIPROGY Group Companies might not be able to provide the customer or other similar trading partner with products, services, or the like of BIPROGY Group Companies (including our websites).
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Personal information of shareholders of BIPROGY Group Companies
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The provision of the name, address, e-mail address, number of shares owned, date of share acquisition, shareholder number, dividend payment history, and account for dividends of the shareholder is mandatory as a legal or contractual requirement. If the shareholder does not provide us with this information, the shareholder might not be able to exercise rights or perform obligations under the Companies Act or other laws or regulations.
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Personal information of job applicants of BIPROGY Group Companies
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The provision of name, address, telephone number, e-mail address, date of birth, gender, facial portrait, name of school, faculty and department, work experience, and other information stated on the documents for application (including in an electromagnetic manner) or provided with those documents as attachments might be a necessary condition to apply for recruitment. If the job applicant does not provide us with this information, the job applicant might not be permitted to participate in the recruitment activities of, or be considered for any hiring or screening conducted by, BIPROGY Group Companies.
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Personal information of former employees of BIPROGY Group Companies
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The provision of name, address, date of birth, telephone number, e-mail address, gender, facial portrait, term of office, salary and remuneration, amount of retirement allowance and retirement bonus, and account number might be a necessary condition for various inquiries. If the former employee does not provide us with this information, BIPROGY Group Companies might not be able to respond to various inquiries.
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4.Retention period for personal information
In order to decide the appropriate retention period for personal information, BIPROGY Group Companies consider the following: the volume, nature, and confidentiality of the personal information; the potential risk of damage caused by unjust use or disclosure of the personal information; the purposes for which BIPROGY Group Companies process the personal information, and whether BIPROGY Group Companies can achieve those purposes by other means; and applicable legal requirements. If the personal information of an identifiable person collected by BIPROGY Group Companies becomes no longer necessary, BIPROGY Group Companies delete or anonymize the personal information, or if such measures are impracticable (for example, if the personal information has been stored in back-up archives), we retain the personal information of the identifiable person safely until its deletion becomes practicable and ensure that any new processing is not conducted with respect to the personal information.
5.Sources of personal information
BIPROGY Group Companies obtain the personal information of an identifiable person directly from that person (including in cases where personal information is obtained automatically). However, we may obtain the personal information of an identifiable person indirectly from a third party other than the identifiable person in the following cases.
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Personal information of customers and other similar trading partners
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When obtaining personal information from other BIPROGY Group Companies
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When a customer or any other similar trading partner is an entity, and BIPROGY Group Companies obtain the personal information of such entity’s officers and employees from such entity
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When obtaining personal information from website traffic analysis service providers (which provide Cookies, IP addresses, provider information, terminal information, web browser information, user activities, or attributes), such as Google LLC
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Any other cases where personal information is lawfully obtained from a third party (including public information stated in the Official Gazette (Kanpo), websites, or commercially available books, etc.)
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Personal information of shareholders of BIPROGY Group Companies
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When obtaining personal information from a stock transfer agent service provider of Sumitomo Mitsui Trust Bank
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When a shareholder is an entity, and BIPROGY Group Companies obtain the personal information of such entity’s officers and employees from such entity
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Any other cases where personal information is lawfully obtained from a third party (including public information stated in the Official Gazette (Kanpo), websites, commercially available books, etc.)
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Personal information of job applicants for BIPROGY Group Companies
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When obtaining personal information from employment agencies, job search websites, or the like
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Any other cases where personal information is lawfully obtained from a third party (including public information stated in the Official Gazette (Kanpo), websites, commercially available books, etc.)
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Personal information of former employees of BIPROGY Group Companies
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Where personal information is lawfully obtained from a third party (including public information stated in the Official Gazette (Kanpo), websites, commercially available books, etc.)
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6.Sharing and disclosure of personal information
BIPROGY Group Companies share or disclose personal information set out in “1. Categories of personal information subject to processing” above with third parties in the following cases:
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sharing of personal information with other BIPROGY Group Companies to fulfil the purpose stated in “2. Purpose of processing” above;
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sharing of personal information with processors (meaning service providers that provide services necessary for the business activities of BIPROGY Group Companies; including service providers that provide cyber security services, employment agencies and job search websites, Google LLC and other website traffic analysis service providers, attorneys, accountants, financial advisors, and the like) to fulfil the purpose stated in “2. Purpose of processing” above;
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sharing of personal information associated with the corporate sale, merger, acquisition, or other transfer of all or part of our assets;
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sharing of personal information that is required by laws or orders of governmental agencies and the like;
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sharing of personal information with a third party that is (i) necessary for the protection of the life, body, or property in relation to BIPROGY Group Companies, a data subject, or a third party, and (ii) permitted by applicable data protection regulations;
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sharing of personal information with the data subject’s consent; and
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sharing of personal information that is otherwise permitted under applicable data protection regulations.
7.Cross-border transfer of personal information
Personal information may, as a result of instances of sharing or disclosure stated in “6. Sharing and disclosure of personal information” above, be transferred to the following countries and regions and other countries and regions to which the transfer of personal information is required to fulfil the purpose stated in “2. Purpose of processing” above.
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United States
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Germany
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Japan
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China
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Singapore
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Thailand
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Philippines
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Indonesia
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Vietnam
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Malaysia
Upon transferring personal information to any of the countries listed above, BIPROGY Group Companies take appropriate protection measures required by the personal information protection regulations of each country. Please refer to the exhibit for each country for the protection measures in each country.
8.Safety management measures
BIPROGY Group Companies take necessary and appropriate measures, such as countermeasures against unauthorized access and countermeasures against computer viruses, to prevent loss, destruction, falsification, leaking, and the like of personal information.
In addition, BIPROGY Group Companies exercise necessary and appropriate supervision over employees of BIPROGY Group Companies, contractors, etc. to ensure the protection of personal information.
9.Regarding cookies and web beacons, and access logs
BIPROGY Group Companies use cookies, web beacons, and the like on some web pages or records access logs. BIPROGY Group Companies use these functions for the following purposes:
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to ascertain the activity of a site user or measure the effectiveness of advertising; or
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to solve any problem that occurs in any website of a BIPROGY Group Company.
“Cookies” function to save the time needed to re-enter data and enable the display of optimal content for a user by retaining user information in a browser. Through browser settings, users can refuse the receipt of cookies or display a warning when receiving cookies. However, in such cases, restrictions might arise, such as the inability to use all or a part of the services on the web page in question.
“Web beacon” is a technology that enables ascertainment of access status from a user’s computer and collects statistics on use rate, etc. of a specific web page (it may also known as a “clear GIF”).
“Access logs” use cookies or web beacons to record URLs, IP addresses, domain names, and other similar items that a user accesses. BIPROGY Group Companies may use access logs to confirm user activity history resulting from clicking URLs, etc. stated in an information e-mail or to refer to such history in relation to an identifiable person’s personal information that the Company holds. Information obtained from such confirmation, etc. is used in accordance with the purposes of use specified in advance.
Regarding the use of Google Analytics
BIPROGY Group Companies may use Google Analytics for ascertaining the use status of websites. However, Google Analytics collects only information that cannot identify individuals and does not obtain information that can identify individuals without the consent of the identifiable person in question.
Please refer to the following link for Google Analytics Terms of Service
Google Analytics Terms of Service
Google Analytics uses cookies, etc. to collect the personal information of identifiable persons. Please refer to the following link for details regarding how Google Analytics collects and uses information when an identifiable person uses a website of a BIPROGY Group Company
https://policies.google.com/technologies/partner-sites
Information of identifiable persons collected by Google Analytics is managed in accordance with the Privacy Policy of Google, Inc. Please refer the following link for the Privacy Policy of Google, Inc.
Privacy Policy of Google, Inc.
Persons who wish to suspend the use of Google Analytics are requested to access the following link
10.Links, etc. to third-party websites or the like
Websites of BIPROGY Group Companies may provide identifiable persons with links to websites or applications of third parties other than BIPROGY Group Companies. BIPROGY Group Companies do not manage how those websites or applications handle personal information, and those websites and applications are not covered by this Global Privacy Policy. The identifiable person in question must confirm the privacy policies of other websites or applications that the person uses to ascertain how those websites or applications handle personal information.
11.Rights of identifiable persons
BIPROGY Group Companies respect the rights identifiable persons hold under the applicable personal information protection regulations of each country. For example, to the extent granted under the applicable personal information protection regulations of each country, a data subject may hold the following rights, among others: right to access; right to rectification; right to erasure; right to restriction of processing; right to objection to processing; right to withdraw consent (which may be granted if the data subject has given consent regarding certain types of processing activities; however, the data subject’s withdrawal of consent does not affect the lawfulness of processing conducted based on consent of the data subject before the withdrawal); right to data portability; and right not to be subject to automated decision-making.
When an identifiable person exercises rights granted under the personal information protection regulations of the country in question, he or she may contact us using the contact details stated in “12. Contact details” below.
12.Contact details
For questions and inquiries regarding this Global Privacy Policy, please contact us using the contact details below:
BIPROGY Inc.
Secretariat for the Committee for Promotion of Personal Information Protection
Address: 1-1-1 Toyosu, Koto-ku, Tokyo 135-8560
Tel: +81-3-5546-4111 (Corporate Headquarters)
Office hours: 9:00–17:30 (Excluding weekends and holidays)
Please refer to the Corporate Profile for the address of BIPROGY Inc. and the name of its representative.
13.Amendment to this Global Privacy Policy
If BIPROGY Group Companies intend to amend this Global Privacy Policy (including the exhibit for each country), we may amend all or part of, or make an addition to, this Global Privacy Policy by publishing that amendment or addition on our websites, sending an e-mail to that effect to identifiable persons, or giving notice by any other method that BIPROGY Group Companies deem appropriate (subject to applicable laws and regulations, if any). In such a case, the post-amendment version of this Global Privacy Policy will be applied from the earlier of the date on which an identifiable person uses a product or service of BIPROGY Group Companies or accesses our websites for the first time after receiving such notice, or the date stated in such notice. If there are other necessary procedures concerning the applicable personal information protection regulations, BIPROGY Group Companies will take such procedures.