Last Updated: April 1,2022
FLARE Group Labor and Social Security Attorney Office ("FLARE Group") provides human capital compliance and advisory services to clients. FLARE Group, recognizing the importance of protecting personal information, complies with the Act on the Protection of Personal Information (“Personal Information Protection Act”) and other laws and regulations, guidelines, and norms applicable to the protection of personal information, and makes efforts to protect personal information pursuant to the Personal Information Protection Policy and Specific Personal Information Protection Policy set forth below.
Personal Information Protection Policy
1. Acquisition of Personal Information
FLARE Group obtains personal information by lawful and appropriate means. Personal information subject to acquisition includes the following.
2. Purposes of Use of Personal Information
FLARE Group uses personal information for the following purposes. Except where permitted in accordance with the Personal Information Protection Act and other laws and regulations, without the consent of a principal, personal information is not used beyond this scope.
3. Provision of Personal Data to Third Parties
FLARE Group may provide third parties with personal data to the extent necessary to attain the purposes of use set forth in “2. Purposes of Use of Personal Information” above. FLARE Group complies with the Personal Information Protection Act and other laws and regulations with respect to provision of personal data to third parties.
4. Personal Information Security Management
In order to appropriately protect and manage personal information, FLARE Group stipulates and complies with basic matters relating to the acquisition, use, retention, provision, and deletion (destruction) of personal information including the following, and makes efforts to maintain personal information as accurate and up-to-date.
FLARE Group may share personal data with other firms belonging to the FLARE network (see “(2) Scope of sharing users” below for details).
(1) Shared personal data
Name, title/position, employer, affiliation, address, date of birth, contact information (phone number/email address), nationality, information set forth in submitted resumes/CVs and other submitted documents, qualification/license information, employee number, face photo, information relating to work management, work duties, taxes, pay, or welfare, Individual Number and specific personal information, and cookie information, etc.
(2) Scope of sharing users
Currently, affiliated members of FLARE Group consist of the following businesses and entities, but their names, scope, and organizational structures are subject to change.
(3) Purpose of use of sharing users
Personal data is used for the same purposes of use set forth in “2. Purposes of Use of Personal Information” above to the extent necessary within the scope set forth in “(2) Scope of sharing users” above.
(4) Persons responsible for management of shared personal data
6. Matters Relating to Retained Personal Data
(1) Names, addresses, and representatives of business operators handling personal information
(2) Purpose of use of retained personal data
The same as the purposes of use set forth in “2. Purposes of Use of Personal Information” above.
(3) Retention period for retained personal data
When the retention period stipulated in laws and regulations etc. ends or its use ceases to be necessary through the attainment of the purposes of use set forth in “(2) Purpose of use of retained personal data” above, retained personal data will be destroyed or deleted without delay.
(4) Procedures for requesting disclosure etc. of retained personal data and where to lodge a complaint etc.
With respect to disclosure, etc. of retained personal data of FLARE Goup (request for notice of purpose of use of retained personal data; disclosure of retained personal data; correction, addition, or deletion of information; suspension of use or erasure; or suspension of provision to third parties) and disclosure etc. of records of provision of personal information to third parties, if the principal makes a request by email to the contact, we will confirm the particulars and contact you regarding how the request will be handled.
For comments, questions, complaints, and other inquiries regarding the protection of personal information by FLARE Goup, please send an email via our website's Inquiry Form.
Specific Personal Information Protection Policy
Regarding the handling of Individual Numbers and specific personal information, FLARE Goup complies with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures and related laws, regulations and guidelines, and operate pursuant to the following purposes of use and policies.
(1) Purposes of use
(2) Matters relating to security management measures
In order to prevent leakage, loss or damage to specific personal information, and otherwise appropriately manage specific personal information, FLARE Goup also establishes and complies with the provisions of the Specific Personal Information Protection Rules and the like.
(3) Contact point for questions and complaints etc.
For comments, questions, complaints, and other inquiries regarding the protection of specific personal information by FLARE Goup, please send an email via our web sites' Inquiry Form.
FLARE Goup is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, FLARE Goup is committed to the appropriate protection and use of personal information that has been collected online.
1. Collection and use of personal information
1.1 What information we collect
We obtain your personal information if you provide us with the information online — for example, if you enter your personal information in a prescribed form for a contact described on our web sites and send it to us, if you make an inquiry about employment opportunities or apply for employment with us through our recruitment web sites, or if you enter your personal information for the purpose of registration to certain services which we provide. In some cases, you will have previously provided your personal information to us (if, for example, you are a former employee). If you choose to register or login to our web sites using a third party single sign-in service that authenticates your identity and connects your social media login information (for example, LinkedIn, Google, or Twitter) with us, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.
When you register or submit personal information to us, we will use this information in the manner outlined in this Privacy Statement. Your personal information is not used for any other purposes than those specified, unless we obtain your permission, or unless otherwise required or permitted by law. For example, if you register to our web sites and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across our other sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with us, we will use the information that you provide to match you with available our job opportunities. If you provide us with your personal information to join our seminars and events, we may analyze and process the information to contact you regarding the seminars and events, analyze user behavior, improve our services, or advertise, promote, and market our services.
In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).
1.2 The legal grounds we have to use your personal information
We generally collect only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection. When we process your personal information, we will rely on one of the following processing conditions:
Examples of the ”legitimate interests” referred to above are:
We will not collect the personal data including special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), genetic data, biological data, or health data and data about alleged or proven criminal offences except as expressly permitted by law (which means Japanese and foreign laws regarding personal information protection applied).
1.3 Automatic collection of personal information
1.3.1 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate will be recorded for IT security and system diagnostic purposes. This information will also typically be used in aggregate form to conduct web site trend and performance analysis.
Cookies will typically be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features.
Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.
Other third party tools and widgets will be used on our individual web pages from time to time to provide additional functionality. Use of these tools or widgets will typically place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
When you register your personal information on our web site, including but not limited to application forms for our seminars, we may link your browsing history on the web site and your personal information to understand and analyze them for the purpose of improvement of user services, advertisement, sales promotion and activities, and other activities.
BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.
1.3.3 Google Analytics
We use Google Analytics. More information about how Google Analytics is used by us can be found here:https://marketingplatform.google.com/about/analytics/terms/us/
1.3.4 Web beacons
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. We only use web beacons in accordance with applicable laws.
We or our service providers will use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.
In some of our newsletters and other communications, we will monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
1.3.5 Location-based tools
We will collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
1.4 Social media widgets and applications
Our web sites will typically include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications will collect and use information regarding your use of our web sites (see details on ”Social Sharing” cookies above). Any personal information that you provide via such social media applications will often be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, our web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively "Social Media Features"). The purpose of Social Media Features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any of our social media feature will typically be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we often have limited or no control.
2. Sharing and transfer of personal information
2.1 Transfer within the network of KPMG firms
We share information about you with other affiliated members of FLARE Group network as part of our services by establishing appropriate safeguards, such as concluding standard contracts for information protection or applying supplementary rules where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the FLARE Group network are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run FLARE Group’s business.
2.2 Transfers to third parties
We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. We will not transfer the personal information you provide to any third parties for their own direct marketing use.
In general, you are not required to submit any personal information to us, but we will require you to provide certain personal information in order for you to receive additional information about our services and events. We will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
4. Your rights
If we process personal information about you, you have the following rights:
(1) Access: you have the right to know what kind of personal information has been collected about you and how such information has been used.
(2) Correction: you have the right to correct any inaccuracies in the personal information that we hold about you.
(3) Erasure (“Right to be forgotten”): you have the right to withdraw your consent and obtain the erasure of personal information.
(4) Restriction of Processing: you have the right to restrict the processing of personal information.
(5) Data Portability: you have the right to receive your personal information we collect in a machine-readable format and to reuse it for your own purposes.
(6) Object to processing: you have the right to object to us processing your personal information.
(7) Automated Decisions: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
(8) Complaint with a supervisory authority: you have the right to lodge a complaint with a supervisory authority, particularly in the member state of the European Union of your habitual residence, place of work, and/or place of the alleged infringement of an applicable law.
You can make a request or exercise these rights by sending an email via our web sites' Inquiry Form and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
5. Data security and integrity
We have reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual's request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected.
6. Links to other sites
7. Changes to this statement
8. Policy questions and enforcement
9. Additional description on the handling of personal data to which the General Data Protection Regulation (GDPR) is applied
When those of you who reside in the EEA or the UK provide your personal data to us via internet through a certain process, GDPR may be applied. The following as well as the above mentioned are additionally applied if we obtain the personal data under such circumstances.
9.1 Lawfulness of processing personal data
When we process your personal data, we will rely on one of the following processing conditions:
9.2 Description on retention periods for EU personal data
We have data protection officers (DPOs). Their contacts are as follows and may be contacted by email via our web sites' Inquiry Form.
How to contact us
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