Privacy Policy

Privacy Policy

RevisionDate of enactment: 8th September 2014

RevisionDate : 1st April 2022

Goodcom Asset Co., Ltd.
President and Chief Executive Officer (Preseident and CEO) Yoshikazu, Nagashima

Our company understand the importance of personal information, thus we will obey the law and strive our best to protect personal information. In addition, we will follow the following policy to maintain and update our IT system. We will constantly improve our system to provide a safe environment for our customer.

1. 1. We only collect necessary personal information that is needed for our business, for employment, or for HR management. We do not use your Personal Information that exceed this range. In addition, we will take measures to prevent unintended use
2. We obey laws that regulate personal information.
3. 3. Our hosting services maintains its systems in accordance with reasonable industry standards to reasonably secure the information of its customers. Moreover, we provide immediate support to deal with any security problem.　　In addition, if it is determined that there is a problem with the protection of personal information, we will promptly take corrective measures.
4. If there is any complain toward our security system, we will not hesitate to respond to it.
5. We will update our personal information maintain system constantly in order to provide a secure environment.

Contact information

This policy is followed by entire employee from our company. From our Homepage, you can easily access to our brochure.

Personal information handle

１． Purpose
（1） We will send you a document before we receive personal information from you (including homepage or email)

（2） Other purposes

About Holding personal data

Regarding the retained personal data or records provided by third parties held by the Company, notification, disclosure, correction, addition or deletion, suspension of use, erasure and third party of the purpose of use from the person or his / her agent We will respond to requests for suspension of provision to (hereinafter referred to as “requests for disclosure, etc.”) as follows.

1. Company name
   Good Com Asset Co.,Ltd
   17F, Nishi-Shinjuku Building, Sumitomo Real Estate, 7-20-1, Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023
   President and CEO Yoshikazu Nagashima
2. Personal information manager
   Title of manager: personal information manager Managing Director
   Division: Administration Division
   Phone number: 03-5338-0170
3. Holding personal data
   

   Category	Purpose
   Customer information (user, etc.)	Response toward inquiry
   Guidance of our products and service (Our supplier, etc.)	Guidance of our products and service
   Our employee information	Employee’s HR management, business management, health management, security management.
   Our recruitment information	To contact our candidates and for recruiting business
   Shareholder information	information disclosure, distribution, contact.
   Phone inquiry	For our employee’s educational purpose Confirmation of phone content
   Specific personal information	For the purpose of use stipulated in the Number Usage Law

4. Consignment of personal information handle
   In order to run business, we may consign external for handling personal information for above purpose. We will choose high quality contractor to make proper use of personal information with high security.
5. Where to make complaints regarding the handling of retained personal data
   17F, Nishi-Shinjuku Building, Sumitomo Real Estate, 7-20-1, Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023
   Good Com Asset Co., Ltd. Personal information inquiry window
   TEL: 03-5338-0170 (Reception hours 10: 00-18: 00 *)
   * Saturdays, Sundays, national holidays, year-end and New Year holidays, and Golden Week will be handled on the next business day or later.
6. Personal Information Protect Organization
   Our company is a member of the following Personal Information Protect Organization.
   If you have any complaint toward our company’s privacy policy, please contact following organization.
   JIPDEC Privacy Policy Complaint
   <Address> Roppongifua-suto Bld.12F, Roppongi , Minato-ku, Tokyo, 106-0032, Japan

   <Phone> 03-5860-7565　0120-700-779

7. Procedures for responding to requests for disclosure of retained personal data or records provided by third parties
   Request for personal information disclosure
   1. Apply for disclosure
      Please make an inquiry from above Personal information inquiry
      * If you wish to disclose by electromagnetic procedure, please let us know.
      As a rule, we will process according to your request
   2. Procedure for disclosure
      1. After we receive your application, we will send you an invoice.
         • Notification of purpose: Purpose of personal information usage invoice
         • Disclosure: disclosure invoice
         • Revise, reinforce, delete, and stop providing personal information to third party: personal information revise and termination invoice.
      2. Please send your invoice, power of attorney (if needed), and postal money order (for purpose of usage Retained personal data disclosure, such as invoices) to above Personal Information Inquiry.
      3. After we receive your invoice, we will confirm your personal information with you (ex: ask you your phone number or birthday).
      4. We will send you the document by mail.
   3. Documentation to prove of delegation
      If you need an attorney, there is something must be check with your attorney.
      An attorney must provide documentation to prove that he or she is delegated by the principal. Please send attorney’s identification as well.　Also, please send each document not including personal number, or treat all digits with black.
   4. <Disclosure request>
      • Power of attorney from the principal.

      <If attorney is a minor> please provide one of the following documents

      • Certificate of family register
      • Resident’s card (with relationship recorded)
      • Proof of the Authority of Statutory Representation

      <If attorney is an adult ward’s legal representative> please provide one of the following documents

      • Guardianship Registration’s certification of registered matters.
      • Proof of the Authority of Statutory Representation
   5. Identification of attorney
      • • Driver’s license
      • • Passport
      • • 3. Health insurance(Please submit all digits of the insured person’s symbol, number, etc. in black)
      • • Resident’s card
      • • Basic resident register card
8. Request for notification of purpose or disclosure fee
   One request is 1,000 yen (tax excluded)
   (If you make a paper request, please enclose the postal exchange with the invoice you send. If you request by other methods, we will consult with you at the time of request.)

• Details of the personal information handling system and measures taken
  (1) Formulation of basic policy
  As a privacy mark certified business operator, we have formulated a “personal information protection policy”. In order to ensure the proper handling of personal data, we have formulated personal information protection rules based on relevant laws and guidelines, and are operating PMS (Personal Information Protection Management System).
  (2) Development of discipline regarding the handling of personal data
  The handling method, responsible person / person in charge, and their duties are stipulated in the Personal Information Protection Regulations at each stage of acquisition, use, storage, provision, deletion, disposal, etc.
  (3) Organizational safety management measures
  1.Based on the personal information protection regulations, appoint a department manager regarding the handling of personal data, centering on the personal information protection manager, and clarify the employees who handle personal data and the range of personal data handled by the employees, We have established a reporting and communication system to the personal information protection manager when we grasp the facts or signs that violate the law or handling regulations.
  2. In addition to conducting regular self-inspections regarding the handling status of personal data, we also carry out audits (including renewal examinations) by other departments and outsiders.
  (4) Human safety management measures
  1.We provide regular training to employees regarding points to note regarding the handling of personal data. In addition, we are calling attention to new threats such as Zero Day attacks as appropriate.
  2.Matters concerning confidentiality of personal data are described in the work regulations.
  (5) Physical safety management measures
  1.In the office that handles personal data, we control the entry and exit of employees and restrict the equipment they bring in, and take measures to prevent unauthorized persons from viewing personal data. Outsiders accept visits in a reception space without personal data, and if it is unavoidable to allow entry to the office, record it on the entrance / exit reception slip so that the respondent does not always accompany personal data. We are doing it.
  2.Take measures to prevent theft or loss of equipment, electronic media, documents, etc. that handle personal data, and when carrying the equipment, electronic media, etc., including movement within the office, personal data can be easily found. We are taking measures to prevent it.
  (6) Technical safety management measures
  1.We control access to servers and business systems to limit the range of personal information databases handled by the person in charge.
  2. We have introduced a mechanism to protect information systems that handle personal data from unauthorized access or software from the outside.[Privacy policy and purpose of personal information protection]
  * The purpose of personal information protection is set company-wide or departmentally as a goal or goal to achieve the personal information protection policy (from the privacy mark construction and operation guidelines).
  * At our company, proper handling of personal information is included in daily business procedures, and as a result, we believe that the purpose of personal information protection is to suppress the manifestation of personal information protection risk. As an initiative for that purpose, we are operating and continuously improving based on the PMS annual plan.
  * Specifically, in order to verify every year whether or not the personal information protection policy has been achieved through all PMS activities, the purpose of our personal information protection is shown in the table below. We confirm the degree of achievement of that purpose through activities based on the PMS annual plan. At the same time, we guarantee that personal information is handled properly by undergoing a third-party evaluation through a renewal examination once every two years.Main PMS (Personal Information Protection Management System) Operation Details

  Implementation content	manager	Responsible person	Implementation period	Ex-post evaluation
  Review of personal information	Personal information department manager	Personal information protection manager	October	Approval record
  Risk assessment / countermeasures	Personal information protection manager	Top management	November	Approval record
  Review of laws and regulations	Personal information department manager	Personal information protection manager	May	Approval record
  Reassessment of contractors	Personal information department manager	Personal information protection manager	October	Approval record
  Regular PMS education	Personal information department manager	Personal information protection manager	November	Implementation record
  Periodic operation confirmation	Personal information department manager	Personal information protection manager	quarter	Implementation record
  Periodic internal audit	Each auditor	Personal information protection audit manager	October	Implementation record
  Management Review	Personal information protection manager	Top management	January	Implementation record

Governing Law

Goodcom Asset Co. Ltd makes no representation that this Privacy Policy and such practices comply with the laws of
any other country. Visitors who use the Site and reside outside Japan do so on their own initiative and are responsible
for compliance with local laws, if and to the extent local laws are applicable.
If you reside outside of Japan, by using our Site, you consent to the transfer and use of your information outside
your country.