AsiaQuest Co., Ltd. (“we,” “our,” or “us”) recognizes the importance of Personal Information and makes company-wide efforts to protect Personal Information. Recognizing that the Personal Information that was obtained through our business activities is our important asset, we establish, inform all of our officers and employees of, implement, and promote this personal information protection policy (this “Policy”).

 

Article 1 Definitions

In this Policy, the following terms have the following meanings.

  1. The term “APPI” means the Act on the Protection of Personal Information (Act No. 57 of 2003).
  2. The term “Laws, Etc.” means laws, cabinet orders, rules, standards, guidelines, and the like.
  3. The term “Personal Information” means the “personal information” under Article 2, paragraph 1 of the APPI.
  4. The term “Identifiable Person” means the “identifiable person” under Article 2, paragraph 4 of the APPI.
  5. The term “Information Related to Personal Information” means the “information related to personal information” under Article 2, paragraph 7 of the APPI.
  6. The term “Personal Data” means the “personal data” under Article 16, paragraph 3 of the APPI.
  7. The term “Retained Personal Data” means the “personal data the business holds” under Article 16, paragraph 4 of the APPI.
  8. The term “Record of Third Party Provision” means the “record of provision to a third party” under Article 33, paragraph 5 of the APPI.
  9. The term “Officers, Employees, Etc.” means our officers, employees, part-timers, contract employees, dispatched employees and all others who are engaged in our business; those who are or were under our employment screening; and those who retired from us.

 

Article 2 Acquisition of Personal Information

When we obtain Personal Information, we will:

(1) obtain it to the extent necessary to achieve the purpose of use;

(2) use lawful and fair means; and 。
(3) make a public announcement or notification (including the public announcement through this Policy) of the purpose of use and if we obtain Personal Information written in an agreement or other document (including an electromagnetic record) directly from an Identifiable Person, we will obtain it after clearly showing him or her the purpose of use and obtaining his or her consent.


Article 3 Purpose of Use of Personal Information

We properly use Personal Information to the extent necessary to achieve the following purpose of use.

When we use Personal Information for a purpose that is not stated below, we will use it after obtaining the consent of the relevant Identifiable Person.

(1) Business partners

  • For negotiations, meetings, and necessary communication
  • For contracting procedures
  • For procedures for entering into and exiting from our facilities
  • For the registration of users to our system
  • For the introduction of our products and services
  • For the activities to improve our products and services
  • For the activities to improve convenience for business partners
  • For customer demand surveys and marketing activities
  • For the delivery of ads and emails and the optimization, effect measurement, and analysis of web page display
  • For other operations necessary to perform the relevant agreement

(2) Inquirers

  • For the responses to inquiries
  • For the introduction of our products and services
  • For the activities to improve our products and services
  • For the activities to improve convenience for users
  • For inquirer demand surveys and marketing activities
  • For the delivery of ads and emails and the optimization, effect measurement, and analysis of web page display

(3) Participants in events and seminars

  • For the operation of events and seminars
  • For the introduction of our products and services
  • For the activities to improve our products and services
  • For customer demand surveys and marketing activities
  • For the provision of information on our employment opportunities, events, seminars, etc.
  • For participant demand surveys and marketing activities
  • For the delivery of ads and emails and the optimization, effect measurement, and analysis of web page display

(4) Job applicants

In addition to the information provided by each Identifiable Person, information provided by third parties in the course of screening (such as the results of a competence examination, health information, a certificate of student registration, a certificate of graduation, and a transcript) are included.

  • For recruitment management operations
  • For the adjustment of schedule with each applicant
  • For screening based on documents and screening based on interviews
  • For the confirmation of history of application
  • For the preparation of statistical data necessary to prepare and improve future recruitment plans
  • For the provision of information on our employment opportunities, events, seminars, etc.
  • For the delivery of ads and emails and the optimization, effect measurement, and analysis of web page display

(5) Shareholders

  • For the exercise and performance of legal rights and obligations of shareholders
  • For us to extend various facilities to the position as a shareholder
  • For the implementation of various measures to smooth the relationship between the shareholders and us
  • For shareholder management including the preparation of shareholder data based on the prescribed standards under various Laws, Etc.
  • For the responses to inquiries, requests, etc. from shareholders
  • For our business management and inner management

(6) Officers, Employees, Etc. and their dependents

  • For the operations related to operational communication and equipment and facility management
  • For the operations related to transfer, evaluation of performance, commendation, disciplinary disposition, and other personnel management
  • For administrative affairs related to personnel administration
  • For the operations related to wage, bonus, retirement allowance, corporate pension, shareholding association, etc.
  • For the operations related to education and training
  • For the operations related to welfare and well-being, etc.
  • For the operations for safety, hygiene, health management, etc.
  • For the operations related to employment insurance and social insurance
  • For the operations based on Laws, Etc. such as taxes, social security, and the like
  • For the discovery, deployment, and development of human resources by taking statistics about, analyzing, and using personnel information
  • For the operations related to or ancillary to any of the above items

Article 4 Compliance with Relevant Laws, Regulations, Guidelines, Etc.

We comply with the APPI and other relevant Laws, Etc. in handling Personal Data.

 

Article 5 Safety Management Measures

We take safety management measures that are necessary and appropriate to manage Personal Data including the prevention of leakage of, loss of, or damage to the data. We also provide necessary and appropriate supervision over the persons and entrustees (including sub-entrustees) who handle Personal Data.

The main contents of the safety management measures for Personal Data are as follows.

(Formulation of written personal information protection policy)
  • This Policy is formulated with respect to the “compliance with relevant laws, regulations, guidelines, etc.,” “inquiries about the handling of Retained Personal Data,” and the like in order to ensure proper handling of Personal Data.
(Establishment of Rules on Handling of Personal Data)
  • Rules on the handling of Personal Data are established with respect to the method of handling, responsible person, persons in charge, their duties, etc. at each stage of acquisition, use, storage, provision, deletion, disposal, etc.
(Organizational Safety Management Measures)
  • Having established a person responsible for handling Personal Data and having clarified the persons engaged in handling Personal Data and the scope of Personal Data handled by them, we have a system to report and communicate to the responsible person any fact or indication of a breach of a law or handling rule.
  • We regularly check by ourselves the status of handling of Personal Data and receive audit by another department and an outsider.
(Human Safety Management Measures)
  • We regularly provide training to engaged persons on matters to note in handling Personal Data.
  • Matters regarding the confidentiality of Personal Data are specified in the Work Rules.
  • (Physical Safety Management Measures)
  • We implement measures to manage engaged persons’ entry into and exit from the area in which Personal Data is handled and to prevent unauthorized persons from browsing Personal Data.
  • We implement measures to prevent the theft, loss, or the like of the devices, electronic media, documents, or the like in which Personal Data is handled.
(Technical Safety Management Measures)
  • We control access to limit the scope of the persons in charge and the database, etc. in which Personal Information is handled.
  • We have introduced a mechanism to protect the information system in which Personal Data is handled from unauthorized external access or malware.
(Understanding of External Environment)
  • We implement safety management measures, understanding the system to protect Personal Information in a foreign country in which Personal Data is stored. Please contact us for the specific name of the country.




Article 6 Entrustment and Provision of Personal Data, Etc.

(1) Supervision over entrustees

When we entrust a third party with all or part of handling of Personal Data to the extent necessary to achieve the purpose of use, we will provide necessary and appropriate supervision so that the Personal Information is safely managed at the entrustee.

 

(2) Entrustment and provision to third parties of Information Related to Personal Information for marketing activities

We may provide Information Related to Personal Information to the following partners (including those in a foreign country) after obtaining consent from each Identifiable Person for the optimization of and the relevant effect measurement and analysis of ad delivery, email delivery, web page display, etc. in order to effectively provide services and useful information.

 

Receiving partners:

  • Meta Platforms, Inc. (California, USA)
  • Google LLC (California, USA)
  • Twitter, Inc. (California, USA)
  • HubSpot, Inc. (Massachusetts, USA)
  • Cloud CIRCUS, Inc. (Tokyo, Japan)

Information Related to Personal Information to be provided:

  • Hashed (*1) email addresses
  • 1st party cookie (*2) information

*1 Hashing means converting original data into an irregular string based on a specific calculation formula. This is used to prevent unauthorized use as the restoration to the original data is extremely difficult.
*2 1st party cookies mean digital files that are used as identifiers left on the browser of a viewer as a record of access to a website administered by us.

(3) Joint use of Personal Data with group companies

We may use Personal Data obtained with the relevant customer’s consent jointly with our group companies.

Items of Personal Data to be jointly used:

  • Name, affiliation, contact details, etc. of each customer, inquirer, and seminar participant
  • Name, affiliation, contact details, personal history, etc. of each job applicant

Scope of joint users:

  • PT. AQ Business Consulting Indonesia
    (Jakarta, Republic of Indonesia: our Indonesian subsidiary)
  • AsiaQuest Internet Malaysia SDN. BHD.
    (Kuala Lumpur, Malaysia: our Malaysian subsidiary)

Users’ purpose of use:

As stated in Article 3.

 

Name of the person responsible for the management of the Personal Data:

AsiaQuest Co., Ltd.

 

(4) Other than the above, we do not provide obtained Personal Data to any third party unless:

  • the consent of the relevant Identifiable Person is obtained;
  • it is based on a Law, Etc.; or
  • it is necessary to protect the life, body, or property of a person but it is difficult to obtain the consent of the relevant Identifiable Person.

Article 7 Inquiries on Handling of Retained Personal Data

We are responsible for responding to complaints, consultations, and other inquiries regarding the handling of Personal Information.

We will respond to each 1) request for disclosure, 2) request for notification of the purpose of use, 3) request for correction, 4) request for addition or deletion, 5) request for erasure, or 6) request for suspension of use, suspension of provision to third parties, or the like with respect to certain Retained Personal Data or a Record of Third Party Provision (if the Retained Personal Data or the Record of Third Party Provision does not exist, we will notify to that effect) after confirming the requesting person is the relevant Identifiable Person by an appropriate means.

Please make inquiries to the following contact point.

 

[Contact point for inquiries]

  • Contact point Personal Information Contact Person in Administration Department of AsiaQuest Co., Ltd.
  • Address 6F, Iidabashi i-MARK ANNEX, 3-11-13, Iidabashi, Chiyoda-ku, Tokyo, 102-0072
  • Telephone +81-3-6261-2701
  • Contact form https://www.asia-quest.jp/privacy_contact/
     
Article 8 Continuous Improvement

We properly manage, continue to improve, and always keep the best conditions of Personal Data.



Article 9 Amendment of this Policy

This Policy may be amended.

In principle, the amended Policy shall be effective from the time that it is posted on our website.

 

Established on January 1, 2015
Revised on October 1, 2023
AsiaQuest Co., Ltd.
Jun Momoi, President and Representative Director