1. Objective of Protecting Personal Data

   Although our main business is generating eGift tickets and selling our system, we believe that it is an important responsibility of our company to properly protect all the personal data under our care. In order to process personal data appropriately, we have set the following protection policy and we shall strive to provide personal data protection to the best of our ability.

2. Obtaining Personal Data

   The personal data obtained by the company is limited to the scope required to fulfill the purpose of use. The company adopts legitimate and fair methods for collecting personal data.

3. Use of Personal Data

   The company provides proper management of the collected personal data, and does not process (use, distribute, etc) the personal data beyond the scope required for the intended purpose of use. The company takes precautionary measures to prevent misuse in non-intended purposes.

4. Proper Management of Personal Data

   In order to ensure the accuracy and security for personal data, the company implements Security Policy as a data security measure, that prevents unauthorized access of personal data, leakage of personal data, loss and damage of personal data, etc. In addition, in the event of security breach incidents being reported in the market that give rise to customers’ request for security improvement, we shall promptly take corrective actions and strive to enhance security.

5. Legal Compliance

   The company shall comply to the legal requirements and guidelines set by the country, and other regulations governing personal data. The company shall ensure that our management system is compliant to these legal requirements, guidelines and other regulations at all times.

6. Continuous Improvement

   Through interval audit and review of personal data protection management system, the company shall make effort to implement continuous improvement and maintain the system in the best possible condition at all times.

7. Handling of Complaints and Queries

   The company shall provide an appropriate system to respond to complaints and queries with regards to personal data, in accordance to the manual.

Mutsumi Ota
CEO
giftee, Inc.
Date of establishment: 1 Apr 2016

Usage Purpose of Personal Data

The following are the usage purpose of the personal data processed in the company. ( Applicable to all disclosed personal data.)

1. Recruitment Information

   1. To receive recruitment applications.
   2. To contact applicants (notice of screening results, attachment of recruitment documents,etc).
   3. To conduct recruitment screening.

2. Employee Information

   1. Human resource management (personnel change, appraisal for salary adjustment / promotion, employee education)
   2. Labour management, payroll management (time attendance management, payment of salary/bonus, statutory deduction, year-end adjustment)
   3. Welfare (employment insurance, medical insurance, employees’ pension insurance, enlisting and maintaining participation in property savings)
   4. Health management (conduct periodical medical checkup, store and manage medical checkup records, support in prolonged absence)
   5. Safety management (theft prevention by maintaining access record )
   6. Sales and Public Relations (for promoting sales activities and recruitment)
   7. Submission of personal data for the purpose of income tax reporting and social insurance to income tax department and pension department, etc.

3. Customer Information and others

   1. For the management of membership services (for digital gift ticket service) provided by the company and the operation of the services
   2. For the implementation of campaign, seminar, survey, monitoring, interview, etc
   3. For communication to respond to enquiries and for contacting purposes
   4. To communicate with companies with business relations

4. Entrusted Party of Personal Data

   In the regional digital currency business, a portion of the residents information of the rural local government is stored on the cloud server managed by the company, as an entrusted party, through the assignment of digital currency issuance operation.

5. Assignment of Personal Data

   The company entrusts all or part of the employee information and customer information to third party contractors for processing.

Processing of Disclosed Personal Data

giftee, Inc.
Mutsumi Ota, CEO
Ayumi Utsunomiya, Personal Data Protection Manager

1. Contact Point for Complaints and Enquiries on Personal Data Disclosure

   If you have any complaints or enquiries regarding the handling of personal data disclosure, kindly contact the below Personal Data Protection Manager, or the authorized personal data protection organization.
   ■giftee, Inc.　　Personal Data Protection Manager: Ayumi Utsunomiya
   Tel：03-6303-9318
   Email：info@giftee.co
   
   ■Authorized Personal Data Protection Organization
   (Note that this is not the customer service contact for product and services enquiry.)
   Japan Information Processing and Development Center (JIPDEC)　Personal Data Complaints & Consultation Office
   Address:　Roppongi First Building, 9-9 Roppongi 1-chome, Minato-ku, Tokyo 106-0032
   Tel: 03-5860-7565　0120-700-779

2. Personal Data subject for Disclosure and its Usage Purpose

   Please refer to the above “Usage Purpose of Personal Data”.

3. Provision and Entrusting of Disclosed Personal Data to Third Party Contractors

   The company may provide personal data to third party contractors. Please refer to “Usage Purpose of Personal Data”. In the case where operations are contracted to a third party contractor, all or partial of the personal data shall be forwarded to the contractor limited to the scope deemed necessary to carry out the operation. In this case, the contractor shall bear equal responsibility on the confidentiality obligations as us, and we shall perform the supervision deemed appropriate and necessary to ensure that the security management of personal data is performed.

4. Disclosure Procedure and Method

   Please contact (1) as stated in the above.
   We will perform one of the following procedures for the disclosure of personal information.

   1. Request for disclosure by postal mail
      We will send a “Request Form for Personal Information Disclosure (for individual application)”. Please attach a copy of identity verification document for the individual(※1) and post to us. Upon successful verification, we shall respond to the request accordingly.
      In the case of request made through a representative, please attach the identity verification document for representative (※2) and post to us. (For postal mail, please shade the registered location where applicable.)
   2. Request for disclosure by walk-in
      Please bring along an identity verification document for the individual(※1). Upon successful verification, please fill in the “Request Form for Personal Information Disclosure (for individual application)” and we shall respond to the request accordingly.
      In the case of request made through a representative, please bring along the identity verification document for the representative (※2).
      
      ※1【Identity verification document of the individual】
      Any one of the following documentation, with photo identification, is acceptable.
      ・Driving license
      ・Passport
      ・Health Insurance Card
      ・Others
      
      ※2【Identity verification document for representative】
      1. In the case of legal representative of a minor or guardian
         1. Document that can verify the identity of the representative(※1).
         2. (In the case of a minor) a family register certificate or (in the case of guardian) a registration certificate as stipulated in Article 10 of the Law in relation to Registration of Guardian.
      2. In the case of appointed representative
         1. Document that can verify the identity of the representative(※1).
         2. Original letter of authorization from requestor complete with seal.

   ※Upon the completion of the above request procedure via postal mail or walk-in, the “Request Form for Personal Information Disclosure (for individual application)” shall be disposed.

5. Disclosure Method

   Disclosure is provided in writing.

6. Notification of Information Correction, Addition and Deletion

   The company shall provide notification in writing for any correction, addition and deletion of information through disclosure.

7. Reasons for Rejecting Disclosure Request

   We shall not process the request for disclosure if any of the following 1～7 applies. We shall notify in writing the reason of not being able to process the request.

   1. The name and address stated in the “Request Form for Personal Information Disclosure (for individual application)” do not match with the name and address stated in the identity verification document.
   2. The name and address of the representative stated in the “Request Form for Personal Information Disclosure (for individual application)” do not match with the name and address stated in the identity verification document.
   3. The requested information is not subject to disclosure.
   4. The disclosure or clarification of absence or presence of such personal information may cause harm to the life, physical body or property of the individual or a third party.
   5. The disclosure or clarification of absence or presence of such personal information may risk promoting or inducing unlawful or illegal behaviour.
   6. The disclosure or clarification of absence or presence of such personal information may pose a risk to national security or risk losing the trust in the relationship with other countries or international organizations, or create a disadvantageous position in negotiation.
   7. The disclosure or clarification of absence or presence of such personal information may cause obstruction to crime prevention, public order control or investigation to maintain order and other public safety.

8. No fees shall be charged.